This Privacy Notice is based on the EU’s General Data Protection Regulation (2016/679, “GDPR”), namely the obligation to inform the data subjects (GDPR Articles 12–14), the data controller’s obligation to maintain a record of processing activities under its responsibility (GDPR Article 30), as well as the obligations set out in the Finnish Data Protection Act (1050/2018) supplementing the GDPR.
Additionally, this Privacy Notice has been prepared with the aim of making it accessible in accordance with the requirements of the EU’s Web Accessibility Directive (Directive (EU) 2016/2102 of the European Parliament and of the Council on the accessibility of the websites and mobile applications of public sector bodies) and the Finnish Act on the Provision of Digital Services (306/2019) supplementing it.
Metropolia’s Recruitment Register
Name
Metropolia University of Applied Sciences Ltd
Contact information
Metropolia University of Applied Sciences Ltd (Business ID: 2094551-1)
Postal address: P.O. Box 4000, FI-00079 Metropolia
Visiting address: Myllypurontie 1, 00920 Helsinki, Finland
Telephone (switchboard): +358 9 7424 5000
Person responsible for the register at the data controller
Name: Riitta Konkola
Position: President, CEO of Metropolia University of Applied Sciences
Person responsible for the content of the register:
Name: Mikko Jäkälä
Position: Director, People and Culture / Human Resources Services
Address: Metropolia University of Applied Sciences Ltd, PO Box 4000, FI-00079 METROPOLIA
Email: mikko.jakala [at] metropolia.fi (mikko[dot]jakala[at]metropolia[dot]fi)
Contact details of the contact person for the register:
Name: Mikko Jäkälä
Position: Director, People and Culture / Human Resources Services
Address: Metropolia University of Applied Sciences Ltd, PO Box 4000, FI-00079 METROPOLIA
Email: mikko.jakala [at] metropolia.fi (mikko[dot]jakala[at]metropolia[dot]fi)
Suvi Väänänen, Metropolia’s Data Protection Officer
Email: tietosuojavastaava [at] metropolia.fi (tietosuojavastaava[at]metropolia[dot]fi) phone: .+358 40 844 0690
Purpose of the processing of personal data:
The purpose of the processing of Metropolia’s Recruitment Register and the personal data it contains is to conduct the recruitment process for persons applying to Metropolia University of Applied Sciences Ltd. Personal data are processed for the purpose of, for example, processing job applications, informing applicants of the progress of the recruitment process, arranging interviews, testing professional or personal suitability and preparing employment contracts. The recruitment process is conducted by Metropolia’s Human Resources Management (Human Resources Services).
This Privacy Notice for Metropolia’s Recruitment Register is supplemented by the Privacy Notice for the Register of Metropolia’s Human Resources Management, which can be viewed on Metropolia’s public website under the “Privacy Notices” section.
Lawful basis for the processing of personal data:
The lawful bases for the processing of the personal data are the following, in accordance with the EU’s General Data Protection Regulation:
The processing of the personal data contained in Metropolia’s Recruitment Register is necessary for the performance of a contract to which the data subject (applicant) is party or in order to take steps at the request of the data subject prior to entering into a contract (EU’s General Data Protection Regulation, “GDPR”, Article 6(1)(b)).
The processing of the personal data contained in Metropolia’s Recruitment Register is necessary for the purposes of the legitimate interests pursued by the controller or by a third party (GDPR, Article 6(1)(f)). A legitimate interest arises if there is a relevant relationship between the data subject and the controller, such as the data subject being employed by the controller.
The processing of the personal data contained in Metropolia’s Recruitment Register is also based on the consent of the data subject to the processing of their personal data for one or more specific purposes (GDPR, Article 6(1)(a)).
In addition, the processing is based on explicit consent given by the data subject to the processing of sensitive personal data belonging to special categories of personal data, such as biometric personal data (facial photo for identification purposes) (GDPR, Article 9(2)(a)).
A legitimate interest may arise if there is a relevant relationship between the data subject and the controller. An example of a legitimate interest is when the data subject is employed by the controller.
The data subjects of Metropolia’s Recruitment Register are the persons submitting an application in the recruitment processes of Metropolia University of Applied Sciences. In addition, the data subjects also include employees and other contact persons of Metropolia’s Human Resources Management who are responsible for recruitment.
The following personal data are stored in Metropolia’s Recruitment Register by personal data category:
DATA FOR THE RECRUITMENT PROCESS
Basic information:
- forename, surname, date of birth/personal identity code, address;
- email address, telephone/mobile phone number;
- eligibility information: applicable degree, work experience, other merits and pedagogic studies;
- curriculum vitae;
- job applications.
Information about education:
- degree or degrees that are relevant for the position;
- educational institution;
- graduation date(s);
- language skills.
Information about work experience:
- Current/former employer;
- job title;
- main job duties;
- start and end date of the employment relationship;
- information about competence;
- possible references.
Contact details of the member of Metropolia staff who is responsible for the recruitment:
- forename and surname;
- position;
- email address and/or telephone number.
The personal data have mostly been collected from the data subjects themselves. In addition, public databases may be used as regular sources of personal data.
Access to the personal data contained in Metropolia’s Recruitment Register will be given, where necessary, in the systems listed below. (For the purpose of repairing a technical fault, for example, access will be given with administrator rights to the system provider or to the maintenance personnel of a measurement device.) All system/equipment/software providers used (the companies behind them) can be deemed to be recipients of personal data and recipients of regular disclosures from the register.
With respect to the systems used by Metropolia’s Recruitment Register, personal data processing agreements in accordance with Article 28 of the GDPR have been or will be concluded with the following cooperation partners:
ARC Technology Oy; HR system
The HR system is used to conduct Metropolia’s recruitment process. The applicant (data subject) fills in the information on the application and delivers the necessary attachments using the electronic form provided by the HR system. The HR system is operated on a Metropolia server.
Microsoft Corporation; Metropolia’s email system
Information about Metropolia’s recruitment process and activities as well as invitations to surveys are sent by email through Metropolia’s Microsoft Outlook Exchange email system. Although Metropolia has procured the email system as part of the Microsoft O365 service package, the system is operated on Metropolia’s own server.
Leijonaverkot Oy (part of the Erillisverkot Group, formerly Deltagon Group Oy) and secure mail (Deltagon’s sec@gw secure mail solution)
The email encryption solution procured by Metropolia, namely the Deltagon sec@gw secure mail solution, may be used for the transmission of sensitive personal data and confidential documents to email addresses outside Metropolia (when email is sent to and from an email address that does not have the “@metropolia.fi” domain).
Eduix Oy; E-lomake (E-form) software
The E-lomake software may be used to conduct feedback surveys related to the recruitment process and to collect personal data for an employment contract when recruiting part-time lecturers.
As a general rule, the personal data contained in Metropolia’s Recruitment Register are not transferred outside the EU or EEA or to international organisations.
The personal data contained in the register may be transferred outside the EU or EEA for the provision of IT services that are necessary for working or completing studies, based on a case-by-case consideration. The state to which personal data are transferred is the United States. It is also possible that personal data may be transferred to, for example, India, a country where global ICT service providers frequently base their help desk operations or ICT user support functions.
The international transfer of personal data from a personal data register of Metropolia University of Applied Sciences to the United States and/or elsewhere outside the EU or EEA is secured primarily with measures, i.e. Standard Contractual Clauses, provided for in Chapter V, Article 46 of the EU’s General Data Protection Regulation (GDPR). The Standard Contractual Clauses are included in agreements with ICT service providers concerning the processing of personal data.
Only the necessary data are transferred and the transfer is carried out in accordance with data protection legislation and within the restrictions placed by it. A separate agreement is always concluded on data security during the transfer.
The personal data are retained only for as long as is necessary for the purposes specified in this Privacy Notice. The personal data are stored for the duration of the recruitment process.
Some necessary parts of personal data may be retained after the recruitment process has been concluded to the extent permitted or required by applicable laws. As a general rule, personal data are retained for two years after the recruitment process has been concluded. If the applicant is selected for the job position, the personal data will be retained in accordance with the regulations applicable to employment relationships. A persons who is not selected has the right to lodge a complaint about the selection with the Ombudsman for Equality and further to the district court. For the purpose of supervision, the Ombudsman for Equality and the district court have the right to receive the necessary data from various authorities free of charge and regardless of whether the law requires the data to be kept secret.
The personal data will be erased once it is no longer necessary to store them under the law or for fulfilling the rights or obligations of either party.
The data subjects have the right to receive confirmation from the data controller of whether their personal data are being processed. Furthermore, the data subjects have the right of access to their personal data and the right to inspect their personal data stored in the register and to receive copies of them. Under the GDPR, the data controller must respond to requests by the data subjects to exercise their rights within one month of receiving such a request.
A. Right of access to personal data
The data subjects have the right to check whether their personal data are stored in the personal data register. A data subject may submit a request for information by delivering the data subjects’ information request form, which can be found on Metropolia’s public website and/or Metropolia’s intranet, to one of the three offices of Metropolia’s Student and Admission Services. The form must be filled in carefully, printed and signed personally by the data subject. If the data subject is a member of staff, they can deliver the request form to Metropolia’s Human Resources Management unit. When submitting the request, the data subject must prove their identity in a reliable manner (for example by presenting an official personal identity document or driving licence to the Metropolia employee receiving the request).
The visiting addresses of the offices of Metropolia’s Student and Admission Services are:
Metropolia’s Myllypuro campus
Myllypurontie 1, 00920 Helsinki, Finland
Metropolia’s Arabia campus
Hämeentie 135 D, 00560 Helsinki, Finland
Metropolia’s Myyrmäki campus
Leiritie 1, 01600 Vantaa, Finland
The visiting address of Metropolia’s Human Resources Management unit is:
Metropolia’s Myllypuro campus (Buildings C and D, 5th floor)
Myllypurontie 1, 00920 Helsinki, Finland
All information requests will be forwarded from the offices of Metropolia’s Student and Admission Services and/or the Human Resources Management unit to Metropolia’s Data Protection Officer (email: tuulia.aarnio [at] metropolia.fi (tuulia[dot]aarnio[at]metropolia[dot]fi), tietosuojavastaava [at] metropolia.fi (tietosuojavastaava[at]metropolia[dot]fi)).
Metropolia’s Data Protection Officer will respond to information requests submitted by the data subjects. If necessary, the Data Protection Officer can be requested to provide additional information on progress in the processing of the request or on the content of the response.
B. Right to rectify personal data and to restrict processing
The data subjects have the right to request the data controller to restrict the processing of their personal data in the following cases:
- the data subject disputes that their personal data are correct (right to rectify personal data), in which case processing will be restricted until the data controller can ascertain that the data are correct;
- processing is unlawful and the data subject objects to the erasure of their personal data, instead requesting that the processing of the data be restricted;
- the data controller no longer needs the personal data for the purposes of the processing, but the data subject needs them in order to establish, exercise or defend a legal claim.
Such a request for rectifying personal data in a Metropolia personal data register or for restricting processing can be submitted in person to one of the above-mentioned offices of Metropolia’s Student and Admission Services or Metropolia’s Human Resources Management unit (staff only), where the data subject must prove their identity in a reliable manner when submitting the request.
C. Right to erase personal data
The data subject has the right to obtain from the controller the erasure of their personal data from a Metropolia register without undue delay if any of the following conditions are met:
- the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- the data subject withdraws consent on which processing is based and there is no other lawful basis for processing;
- the personal data have been unlawfully processed; or
- the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
Such a request for the erasure of personal data in a Metropolia personal data register can be submitted in person to one of the three above-mentioned offices of Metropolia’s Student and Admission Services or Metropolia’s Human Resources Management unit (staff only), where the data subject must prove their identity in a reliable manner when submitting the request.
D. Right to data portability (transfer of data from one system to another)
Partially applicable. Article 20 of the General Data Protection Regulation introduces a new right of the data subject: the right to receive their personal data in a “structured, commonly used and machine-readable format” and the right to transmit those data to another controller. The purpose of this right is to increase the opportunities available to data subjects to influence their personal data because this facilitates the transfer or copying of personal data from one data system environment to another (to their own systems, the opportunity to save the data for their personal use or to begin storing their personal data in systems controlled by reliable third parties). In this respect, the right to data portability from one system to another complements the right of access to one’s personal data.
The right to data portability from one system to another under Article 20 of the General Data Protection Regulation also means that the data subjects have the right to receive their personal data in a structured, commonly used and machine-readable format so that they can easily transfer those data from one system to another system with another controller. The data may be transferred at the data subject’s request directly from one data controller to another if this is technically feasible (section 2 of Article 20). Data controllers are encouraged to develop compatible formats that enable the transfer of data from one system to another, although data controllers are not obliged to accept or maintain data processing systems that are technically compatible.
It should be noted with respect to Article 20 of the General Data Protection Regulation that the right to data portability only applies to personal data processing activities that are based on:
- consent of the data subject (in accordance with Article 6(1)(a) or Article 9(2)(a) if the processing concerns special categories of personal data), or
- a contract to which the data subject is a party (in accordance with Article 6(1)(b)).
In other words, Article 20 of the General Data Protection Regulation must be complied with if the lawful basis for the processing of personal data is the consent of the data subject or the execution of a contract. The right only applies to personal data provided by the data subject to the data controller.
A request based on Article 20 of the General Data Protection Regulation can be submitted in person to one of the three above-mentioned offices of Metropolia’s Student and Admission Services or Metropolia’s Human Resources Management unit (staff only), where the data subject must prove their identity in a reliable manner when submitting the request.
E. Right to not be subjected to a personal data breach
The data subject has the right to not be subjected to a personal data breach, as referred to in Article 33 of the EU’s General Data Protection Regulation, due to the data controller’s negligence in data protection and/or data security matters or due to negligence on the part of a data processor used by the controller in data protection and/or data security matters. The data subject has the right to be informed without undue delay if a personal data breach is likely to pose a high risk to the rights and freedoms of natural persons.
According to Article 21 of the EU’s General Data Protection Regulation, the data subjects have the right to object, on grounds relating to their particular situation, at any time to processing of personal data concerning them which is based on point (e) of Article 6(1) (processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller), such as profiling based on these provisions. The data controller may no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
The request to stop processing of collected personal data can be submitted to one of the three above-mentioned offices of Metropolia’s Student and Admission Services or Metropolia’s Human Resources Management unit (staff only), where the data subject must prove their identity when submitting the request.
If the processing of personal data is based on the data subject’s consent, the data subject has the right to withdraw their consent for processing at any time without the withdrawal of consent affecting the lawfulness of processing based on consent before its withdrawal.
The withdrawal of consent for the processing of personal data collected by Metropolia (withdrawal request) can be submitted to one of the three above-mentioned offices of Metropolia’s Student and Admission Services (or in the case of a member of staff, to the Human Resources Management unit), where the data subject must prove their identity when submitting the request.
Every data subject has the right to lodge a complaint with a supervisory authority if the data subject considers that the processing of their personal data infringes the applicable data protection regulations.
The national supervisory authority in Finland is the Office of the Data Protection Ombudsman. Contact details:
Office of the Data Protection Ombudsman
Street address: Lintulahdenkuja 4, 00530 Helsinki, Finland
Postal address: PO Box 800, 00531 Helsinki, Finland
Telephone (switchboard): +358 29 56 66700
Registry Office: +358 29 566 6768
Email: tietosuoja [at] om.fi (tietosuoja[at]om[dot]fi)
General description of the technical and organisational security measures aiming at protecting the personal data of the data subjects and the personal data registers:
- The protection of the register has been agreed upon with the system providers. If necessary, the responsibilities have been described in adequate detail in the appropriate agreements.
- The employees and other personnel have undertaken to comply with the obligation of secrecy and to keep confidential the information they receive in connection with the personal data processing.
- The system providers (personal data processors) undertake to maintain the register and the personal data relating to it in accordance with good data processing practices and comply with the obligation to absolute secrecy and confidentiality.
- The data security of the personal data register of the data controllers and the confidentiality of the data contained therein are ensured with appropriate technical and administrative means in accordance with good data processing practices.
- The data controllers have restricted user rights and authorisations to data systems, tools and other storage platforms in such a way that they can only be accessed and processed by the persons who are necessary for such processing due to their job duties or position.
- The system containing personal data may only be used by employees who are entitled to process personal data due to their job duties and/or position. Such employees will be given the appropriate training for their duties.
- Every user of a tool/system must identify themselves with their personal codes, which are issued when the right to access the tool/system is granted. The right of access will expire once the employee resigns or is transferred from the duties for which they were granted the right at Metropolia.
- The data are collected in databases that are protected logically and physically.
The databases and their back-up copies are located in locked premises, and the data can only be accessed by certain pre-appointed persons.
Information on whether the provision of personal data for processing in Metropolia’s Recruitment Register is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether the data subject is obliged to provide the personal data and of the possible consequences of failure to provide such data. An account has been given for each register regarding how the personal data were obtained.
Metropolia’s Recruitment Register is a personal data register based on voluntary participation that is used for managing Metropolia’s recruitment processes.
No one is obliged to join Metropolia’s Recruitment Register. The provision of data is based on the recruitment process. If an applicant does not provide the necessary data in the recruitment process, this may affect their selection.
The personal data stored in the register have mostly been collected from the data subjects themselves. In addition, public databases may be used as regular sources of personal data.
Metropolia’s Recruitment Register and the personal data it contains are not used for automated decision-making or profiling.