Metropolia’s Security Register

This Privacy Notice is based on the EU’s General Data Protection Regulation (2016/679, “GDPR”), namely on the obligation to inform the data subjects (GDPR Articles 12–14) and the data controller’s obligation to maintain a record of processing activities under its responsibility (GDPR Article 30), as well as on 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.

Purpose of the processing of personal data:

The purpose of processing the Security Register of Metropolia University of Applied Sciences and the personal data it contains is to ensure the personal safety of staff and students working or studying on Metropolia’s premises and other persons visiting the premises, as well as to promote a comfortable learning and working environment. In addition, Metropolia’s Security Services protect property and data from situations that pose a hazard to them.

The purpose of Metropolia’s Security Services is also to safeguard the continuity of vital operations by identifying operational risks and threats and their impacts, and planning risk assessments, damage control measures and potential recovery measures in advance. Occupational safety and health duties are also covered by the Security Register.

To fulfil these purposes, the Security Services at Metropolia use various devices and systems when carrying out their duties (e.g. access control and video surveillance). The purpose of these devices and systems that promote security is to guarantee the legal protection and safety of staff, students, service providers, customers and other visitors of Metropolia University of Applied Sciences. In addition, Metropolia’s Security Services aim to protect property and to prevent crime and situations that endanger property or safety, as well as to investigate them, using the devices and systems available to Metropolia. The data contained in Metropolia’s Security Register are used, for example, for investigating and identifying the access events of persons moving within premises.

The management of the security and risk management operations at Metropolia is the responsibility of the Director of Human Resources, who is assisted by the security leadership and a security team composed of security representatives. The security leadership of Metropolia University of Applied Sciences is responsible for making preparations, drafting readiness plans and leading risk management operations during disturbances in normal conditions as well as in exceptional circumstances.

This Privacy Notice for Metropolia’s Security Register is supplemented by the Privacy Notice for the User Register of Metropolia’s Requeste Service Request System, the Privacy Notice for the Personal Data Register of Metropolia’s Facilities Management Services and the Privacy Notice for Metropolia’s Visitor Register. All of the Privacy Notices for Metropolia’s personal data registers are available on the public website of Metropolia University of Applied Sciences in the Privacy Notices section.

Lawful basis for the processing of personal data:

The processing of the personal data contained in Metropolia’s Security Register is based on compliance with a legal obligation and the performance of a task carried out in the public interest (EU’s General Data Protection Regulation, Article 6(1)(c) and (e)).

The operations of Metropolia University of Applied Sciences are subject to the Universities of Applied Sciences Act (932/2014), which states that the core operations of a UAS include the implementation of a teaching and learning process. Functions supporting the operations of the UAS include security and risk management services, which are responsible for the safety of all groups of people doing business at Metropolia, thus also promoting the uninterrupted implementation of the teaching and learning process that makes up a part of the core operations of the UAS.

Similarly, the Universities of Applied Sciences Act (section 66) and the Emergency Powers Act (1552/2011, section 12) require UASs to have a readiness plan that includes plans and actions to be taken in exceptional circumstances as well as other measures to ensure that core duties can be handled with as little disruption as possible in exceptional circumstances, disturbances and special situations. Metropolia’s Security Services perform a legal obligation in accordance with the Universities of Applied Sciences Act with the readiness plan used at Metropolia. Metropolia’s Security Services also process personal data while performing tasks carried out in the public interest because the objective of the readiness measures of Metropolia University of Applied Sciences is to achieve a level of operational readiness in day-to-day disturbances as well as in exceptional circumstances that allows operations to be continued in existing premises or to be resumed as quickly as possible elsewhere, or to be provided as distance teaching. The President and CEO, with the assistance of the security management, is responsible for launching the measures.

The data subjects of Metropolia’s Security Register are Metropolia’s staff, students, service providers and customers as well as external persons visiting Metropolia.

The following personal data are stored in Metropolia’s Security Register, by personal data category:

ACCESS CONTROL SYSTEM

Metropolia’s access control system consists of the use of an access ID at Metropolia’s campuses. Electric locks (see section “Lock Management”) are part of the access control system.

The following personal data are recorded for the persons registered at the campuses (staff/students/service providers) in the Abloy OS access control system used there:

accepted and rejected access events
date and time
forename
surname
personal ID
national personal identity code (date of birth without the real final four digits in the code)
job title
organisation: Metropolia, e.g. Financial and Administrative Services
role: staff/student/partner for whom access rights have been determined in advance
ID/ID number
access code
areas the person may access

The following personal data are recorded on the data subjects (staff/students/service providers) in the access control system used at the campuses:

forename
surname
personal ID
department
validity of the access ID (e.g. in the case of a student, the start date and the presumed end date)
access rights (corresponds to the role in Abloy OS)
position

The data in the access control system is only accessible to separately appointed persons under protected user rights.

KEY MANAGEMENT

Metropolia University of Applied Sciences uses hard key management, iLOQ electronic key management, loan key management and Abloy Oy’s key management. The personal data stored on the data subjects are found in section 6 “Description of personal data categories of the data subjects” in the Privacy Notice for the Personal Data Register of Metropolia’s Facilities Management Services.

RECORDING VIDEO SURVEILLANCE

The campuses of Metropolia University of Applied Sciences have recording camera surveillance consisting of digital video recordings of the persons moving in the areas monitored by cameras. The areas with video surveillance are Metropolia’s general indoor areas (lobbies and corridors) and outdoor areas. The filmed persons (data subjects) are informed of video surveillance at Metropolia properties with stickers displaying the text “Recording video surveillance is used at this property”. These are attached at the entrances to each property. This complies with the obligation to provide transparent information in accordance with the EU’s General Data Protection Regulation. Only Metropolia’s Security Services have the right to view the recordings. Access to real-time video footage, but not recordings, is also given to the lobby services (Securitas Oy).

The following personal data are recorded on the data subjects (staff/students/service providers/customers/outsiders visiting Metropolia):

movement of the person and their image on a video recording
date and time

No speech is recorded.

BURGLAR ALARM SYSTEM

A burglar alarm system is in use at Metropolia campuses, and potential alarm incidents are recorded on the data subjects.

PERSONAL ACCESS CONTROL CARD WITH A PHOTO

Metropolia’s staff (lecturers/employees) use a personal access control card with a photo as a means of access identification at their campuses. The personal access control cards of Metropolia’s staff are linked to their Metropolia IDs.

The students use a personal card with RFID (radio frequency identification) that can be an HSL card, a Metropolia library card or a photocopying card linked to a Metropolia ID and obtained from a Metropolia library. This personal card is integrated into the access control system through a self-registration point. To use the means of access identification, it must be registered at one of the self-registration points, which are computers dedicated for this purpose at Metropolia campuses.

SECURITY NOTIFICATION

The staff, students and service providers can report situations threatening health and safety in a security notification sent through the Requeste service request system. The following data are recorded in the security notification:

incident and where it took place
person called to the scene
level of severity
location (school)
damage caused
time of the incident
telephone number of the data subject (student or employee/lecturer who is a member of staff)
subject and description of the matter which the service request concerns
attachment file for the matter which the service request concerns

SECURITAS OY’S INCIDENT REPORT

The Private Security Services Act (1085/2015, section 8) contains provisions on the obligation of a security guard to prepare a written statement (incident report) on events leading to an apprehension or the use of force while on guard duty. A security guard may also prepare an incident report concerning other events that led to measures. The following data are recorded on the data subject in an incident report:

the guard’s observations and measures related to the incident in question
the surname, forenames, personal identity code and address information of the person(s) subjected to the measures

RISKI ARVI SYSTEM

Duties related to occupational safety are managed at Metropolia University of Applied Sciences using a system called Riski Arvi.

Access to the personal data contained in Metropolia’s Security 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 and the subcontractors they possibly use) 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 Security Register, personal data processing agreements in accordance with Article 28 of the GDPR have been or will be concluded with the following cooperation partners:

Caverion Suomi Oy; systems and devices supplied by it

Caverion Suomi Oy provides Metropolia University of Applied Sciences with the access control, working hours monitoring, video surveillance and burglar alarm systems used by the UAS. Caverion Suomi Oy provides installation, servicing and fault diagnostics as well as support and maintenance services for these systems. If necessary, Caverion Suomi Oy will be given access to these systems through a VP connection for installation, maintenance and fault repair.

As the system provider, Caverion Suomi Oy has the right to use subcontractors (Mirasys Oy, Devnet Oy, Abloy Oy and Oy Hedengren Ab) in its operations for the provision of these systems. Caverion Suomi Oy is responsible for the operations conducted by its subcontractors (e.g. processing of personal data) as for its own operations.

Amme user management system and access pass system (in-house production)

Metropolia’s Amme user management system is used for creating the students’ and employees’ online IDs and email passwords as well as for managing Metropolia’s access pass system. Amme is Metropolia’s user management system that includes the user IDs of staff, students, partner organisations and external users. The partner organisations include educational institutions operating in the same premises as Metropolia (Helsinki Conservatory of Music, Helsinki Pop & Jazz Conservatory, Heltech) and the procured staff working on Metropolia’s properties. External users include other users such as consultants and external partners in projects.

Abloy Oy; Abloy OS access control system

The Abloy OS access control system is used for managing access control for those doing business in Metropolia’s premises (staff/students/partners). Certain personal data of the data subjects are transferred to the Abloy OS access control system from Amme (see section 6 of this Privacy Notice). These personal data of the data subjects are also transferred from Amme to a server maintained by Valtti Kumppanit Oy (SaaS), which is used by Abloy Oy. Valtti Kumppanit Oy provides IT service management systems. In addition, the supplier of this system (Caverion Suomi Oy) has access, if necessary, to the Abloy OS access control system for performing installation and maintenance work.

Stanley Security Oy; Timecon GMS access control system

The access control system (Timecon GMS) is used at Metropolia campuses. Movement in premises with access control takes place using an access pass and within the limits of the access rights granted to each person.

Access passes are issued free of charge for the duration of the employment relationship or active studies. The caretakers at the campuses are responsible for handing over and receiving access passes.The user rights in the access control system are managed by Metropolia’s Security Services.

Stanley Security Oy; Reg@Web working hours management system

Metropolia’s staff can add and correct timestamps in the Reg@Web working hours management system. The employee and their supervisor can review the timestamp history in the service.

DevNet Oy; Promid working hours management system

Metropolia’s staff can add and correct timestamps in the Promid working hours management system. The employee and their supervisor can review the timestamp history in the service.

Mirasys Oy; DVMS (Digital Video Management System)

Surveillance of the general indoor areas (lobbies, corridors) and the outdoor areas at Metropolia’s campuses is conducted using DVMS (Digital Video Management System). As the administrator, Metropolia’s Security Services have access to the system and the recordings it contains. In addition, the caretakers in the lobby and security guard services (Securitas Oy) have access to real-time footage from the cameras but not to recordings. If necessary, the system supplier Caverion Suomi Oy will be given access to this systems through a VP connection for installation, maintenance and fault repair.

Securitas Oy; Lobby and security guard services and Securitas’s incident reports

Securitas Oy provides the lobby and security guard services at Metropolia’s campuses. The lobby services handle the opening and closing of Metropolia’s campuses, provide guidance concerning the premises and services, load paper and ink cartridges into multi-function printers, manage access cards and passes, manage parking permits, distribute and receive loaned devices and handle the mail.

In addition, Securitas Oy’s employees who work in Metropolia’s lobby services record incident reports into Securitas Oy’s system.

Oy Hedengren Ab; HHL burglar alarm system

The purpose of the burglar alarm system of Oy Hedengren Ab used at Metropolia’s campuses is to monitor and detect potential criminal activity directed at the premises, people and property. The burglar alarm system sends information on alarm incidents occurring in the monitored areas to the security company (Securitas Oy). If necessary, the system supplier Caverion Suomi Oy will be given access to this systems through a VP connection for maintenance and fault repair.

Sysart Oy; Requeste service request system (security notifications)

Security notifications and reports on close calls are sent to Metropolia’s Security Services through the Requeste service request system. Requeste is a service request and work management system developed by Sysart Oy and intended for use by work groups. Requeste is a browser-based customer interface through which users can send service requests to the different service teams at Metropolia. The Requeste service request system includes auditing software that creates an inventory of devices that is used to fetch data on the devices.

Data may also be disclosed to the police or other relevant authorities in cases specifically stated in the law, such as criminal investigations. The disclosure is always based on a specific request submitted by the authorities.

Nomis Oy; Riski Arvi software/browser-based application

Nomis Group’s Riski Arvi software is used to process matters related to occupational safety at Metropolia. The results of risk assessments are documented in the Riski Arvi software/browser-based application.

Risk assessment is a statutory obligation of an employer so as to protect employees from work-related hazards. Risk assessment is a continuous activity based on the identification of hazards occurring at work. Metropolia uses a browser-based application called Riski Arvi intended for organisations to self-assess occupational health and safety risks. Riski Arvi is used to assess occupational health and safety risks at the workplace and to prepare summary reports of the results of assessments and of the measures proposed based on the assessments.

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), dpo [at] metropolia.fi (dpo[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 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 performance 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.

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.

Privacy notice: Metropolia’s Security Register