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.
Personal data register of ICI Project in Metropolia
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: Niina Huovinen
Position: Head of International Relations
Address: Metropolia Ammattikorkeakoulu Oy, PO Box 4000, FI-00079 METROPOLIA
E-mail: niina.huovinen [at] metropolia.fi (niina[dot]huovinen[at]metropolia[dot]fi)
Contact details of the contact person for the register:
Name: Tiina Piipponen
Position: Project manager / International Relations Adviser
Address: Metropolia University of Applied Sciences, PO Box 4000, FI-00079 METROPOLIA
E-mail: tiina.piipponen [at] metropolia.fi (tiina[dot]piipponen[at]metropolia[dot]fi)
Contact details in questions concerning the purpose of the register: tiina.piipponen [at] metropolia.fi (tiina[dot]piipponen[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:
International Erasmus Cooperation Partnership (KA2) funded project Inclusive Comprehensive Internationalisation - ICI aims to provide intercultural and global learning opportunities for all students, regardless of their background or orientation and support them in their development of globally responsible professionals and citizens. The ICI project works to enhance the quality of international learning experiences by developing an inclusive comprehensive approach to internationalisation which includes virtual and blended international learning opportunities. To reach these important goals ICI project partners aim to develop training for different HEI staff groups to improve their competencies to facilitate and create international learning opportunities for their students and raise awareness inclusiveness of the international learning opportunities.
Following project results are to be developed through the ICI project:
- PR1: Framework for Inclusive Comprehensive Internationalisation
- PR2: Guideline for Self-Assessment of Inclusive International Learning Opportunities
- PR3: Training for Inclusive Comprehensive Internationalisation
- PR4: Manual to the ICI Training
- PR5: Roadmaps towards Inclusive Comprehensive Internationalisation
The main coordinator of ICI Erasmus+ Cooperation Partnership project is the UNIVERSITAT ROVIRA I VIRGILI, Spain, other partners are HOGESCHOOL VAN AMSTERDAM, the Netherlands, UNIWERSYTET IM. ADAMA MICKIEWICZA W POZNANIU, Poland, UNIVERSITA DEGLI STUDI DI NAPOLI FEDERICO II, Italy, Gregersen-Hermans Consultancy, Netherlands and Metropolia UAS, Finland. (https://iciproject.org/)
At each partner university, we will establish an ICI Core Team, who will act as changemakers in their own institution. ICI Core Team members will join forces and be the main change agents for implementing a comprehensive and inclusive internationalisation strategy. ICI Core Team consist of seven members:
- an internationalisation leader
- a teaching coordinator (academic staff)
- an educational developer
- an administrative staff member
- an ICT/Blended learning expert
- two students
The personal data included in the personal data register of Metropolia’s ICI project will carry out e.g. the following processing operations:
- communicating and informing the project activities
- organizing events and development workshops
- taking photos and videos in the events and development workshops of the project
The current privacy policy of Metropolia's ICI project personal data register is supplemented by the following registers with their privacy policy:
- Privacy policy of personal data register of ICI Project Research Material in Metropolia
- The project is funded by European Commission’s Erasmus+ programme and the results of ICI project are public.
- Legal basis for the processing of personal data:
The legal basis for processing the personal data in the personal data register of Metropolia’s ICI project is:
consent given by the data subject
The legal basis for the processing of personal data contained in the personal data register of Metropolia University of Applied Sciences is not “legitimate interests”. Therefore this section does not apply.
The following personal data are stored according to the personal data groups into the personal data register of the ICI project at Metropolia:
Staff at Metropolia
- basic information on the staff: first name; surname; e-mail
- Information on action aimed at data subjects: consent to receive newsletters; consent to receive direct marketing by e-mail and/or information on other forms of cooperation
- Photographs and videos: photographs and video recordings taken at the events and development workshops of the project. Photos and videos are used on the project website as well as in other communication.
Metropolia students:
- Basic information on the students of Metropolia: first name; surname; e-mail address
- Study and degree information: the degree; the degree program; the stage of studies; type of studies (internship, theoretical studies, innovation studies, final thesis, elective studies)
- Information on the procedures targeted at the data subjects: consent on receiving newsletters; consent on direct marketing by e-mail and /or information on other co-operation.
- Photos and videos: photos and video recordings taken at the development workshops and events of the project. Photos and videos are used on the project web pages and in other forms of communication.
The professionals in the project:
- The basic data concerning the professionals in the project: first name, surname, the e-mail address, organisation they are representing
- Information on the procedures aimed at the data subjects: consent to receive newsletters; consent to direct marketing via the e-mail or/and information on other forms of co-operation
- Photographs and video recordings: photographs and video recordings taken in the events and development workshops of the project. The photos and video recordings are used on the web sites of the project as well as other forms of communication.
The interest groups in the project:
- Photos and video recordings: photographs and video recordings taken in the events and development workshops of the project. The photos and video recordings are used on the web sites of the project as well as other forms of communication. The persons of these groups can be seen in the pictures and in the video recordings.
The personal data are obtained from the data subjects themselves.
Access to the personal data contained in the personal data register of the ICI project of Metropolia 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 the ICI Project of Metropolia, personal data processing agreements in accordance with Article 28 of the GDPR have been concluded with the following cooperation partners:
Service provider CSC Oy and Zoom web conferencing tool
Zoom is a web conferencing tool (Funet Miitti / NORDUnet, service provider CSC Oy - The Center for Science Information Technology - IT Center for Science). Zoom web conferencing tool is used to communicate and transmit information within the ICI Project . CSC's Funet Miitti (Zoom) service has been implemented jointly in co-operation with NORDUnet and is therefore not part of the publicly available Zoom service. In addition, the Zoom service provided by NORDUnet operates entirely in the EU, in server environments reserved for NORDUnet's own use. These servers are located in Denmark and Sweden. The services have also been agreed with NORDUnet and Zoom, taking into account the requirements of European data protection regulations (GDPR).
Microsoft Corporation and Microsoft Teams web conferencing tool
Microsoft Teams web conferencing tool is also used to communicate and transmit information within the ICI Project.
Leijonaverkot Oy (part of Erillisverkot Group, former Deltagon Group Oy) and Deltagon’s sec@gw -security mail solution
Deltagon's sec@gw security e-mail solution can be used to forward sensitive personal data and confidential documents to e-mail addresses outside Metropolia (when e-mail is sent to a non-“@ metropolia.fi” e-mail address, or back to Metropolia), if needed.
Microsoft Corporation ja Microsoft O365 -alustapalvelut (Forms ja OneDrive)
The Microsoft Forms survey tool can be used in the project to, for example, conduct feedback surveys. Microsoft OneDrive tool can be used to share project documents, such as meeting documents, with a network of partners.
E-form software
The events and development workshops of Metropolia’s ICI project are signed up to with an e-form, from which the data are transferred into Excel to manage the participant data.
As a general rule, personal data contained in the personal data register of Metropolia will not be transferred outside the EU or EEA or to international organisations.
However, personal data contained in the personal data register may be transferred outside the EU or the EEA in order to provide IT services necessary for work or study, on a case-by-case basis. The destination country to which the personal data is transferred then, is mainly the United States. It is also possible that India is the destination country as global ICT service providers use often India as a host country for the international helpdesk service / ICT technical user support.
The ICT service provider of Metropolia UAS may not transfer or grant access to personal data or process personal data of Metropolia UAS outside the EU or the EEA without prior consultation and prior written consent received from Metropolia UAS.
In the case of written consent has been received from the data controller (Metropolia UAS) for the personal data transfer outside the EU or the EEA, a documented TIA (Data Transfer Impact Assessment) must be conducted and approved by the data controller. Before personal data can be transferred outside the EU or the EEA, the data exporter (Metropolia UAS) of personal data must ensure that an adequate level of data protection is guaranteed for the personal data to be transferred. If the basis for the transfer does not guarantee adequate protection in itself, it can be supplemented in certain cases with different kinds of technical, organisational or agreement-based additional safeguards.
The controllers and processors of personal data that are transferring the data must check on a case-by-case basis if the legislation of the third country guarantees a level of protection for the personal data to be transferred that is essentially equivalent to that of the EU and of the EEA. The assessment must take account of the case-by-case conditions of the transfer, the legislation of the third country in question and the applicable basis for the transfer. The data exporter (Metropolia UAS) is responsible for drawing up a concrete assessment. The assessment must also be documented carefully.
In the case of written consent received from the data controller /data exporter (Metropolia UAS) for the personal data transfer outside the EU or the EEA, the contract bounding the data transfer must include Standard Contractual Clauses (SCC) adopted by the EU Commission. In addition, the data controller /data exporter (Metropolia UAS) must assess and follow-up on a regular basis the level of data protection in the destination country. The data controller /data exporter (Metropolia UAS) may negotiate with the
ICT service provider whether some additional safeguards - like technical, organizational or agreement-based additional safeguards - might be used when transferring data from the EU or the EEA outside the EU or the EEA. The data transfer might be conducted also by using an other data controller’s written approved mechanism.
The SCC (Standard Contractual Clauses) clauses will be included as part of the personal data processing agreement to be drawn up with the ICT service provider. Only the necessary data will be transferred and the transfer will be made in accordance with and within the limits set by data protection law. The security and data protection of the transfer are always agreed separately.
The personal data collected in the personal register of the Metropolia ICI project will be saved permanently in an electronic form in the National Archives of Finland in accordance with the regulation for the permanent storage period concerning the Universities of Applied Sciences.
Such personal data collected in the project are exceptions where the processing and the saving period are included in the following separate personal data registers, which have their unique specified saving periods, e.g. due to the requirement from the sponsor:
the personal data register of the Metropolia.fi website
the project management register
the permanent storage period stated by the National Archives of Finland concerning the UAS regulates saving other information within the project.
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
Metropolia’s Karamalmi campus
Karaportti 2, 02610 Espoo, 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: tietosuojavastaava [at] metropolia.fi (tietosuojavastaava[at]metropolia[dot]fi)).
Metropolia’s Data Protection Officer will respond to information request 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 the correctness of their personal data (right to rectify personal data), in which case processing will be restricted until the data controller can ascertain that the data is correct;
- processing violates the law 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 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)
Partly applicable. Article 20 of the General Data Protection Regulation (GDPR) introduces a new right of data portability of a data subject. This right allows for data subjects to receive the personal data that they have provided to a data controller, in a structured, commonly used and machine-readable format, and to transmit those data to another data controller without hindrance. The new right to data portability aims to empower data subjects regarding their own personal data, as it facilitates their ability to move, copy or transmit personal data easily from one IT environment to another (whether to their own systems, the systems of trusted third parties or those of new data controllers).
In accordance with Article 20(1)(a) of the GDPR, in order to fall under the scope of data portability, processing operations must be based:
- either on the data subject’s consent (pursuant to Article 6(1)(a), or pursuant to Article 9(2)(a) when it comes to special categories of personal data);
- or, on a contract to which the data subject is a party pursuant to Article 6(1)(b).
The GDPR does not establish a general right to data portability for cases where the processing of personal data is not based on consent or contract.
Such a request pursuant to Article 20 of the GDPR 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
FI-00531 Helsinki
Telephone (switchboard): + 358 29 56 66700
Fax: + 358 9 56 66735
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 the personal data register of Metropolia University of Applied Sciences 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 was obtained.
The personal data register of Metropolia’s ICI project is a personal register based on voluntary access, with which the project's activities, communications and current information of the project are managed.
It is not compulsory to be registered in the personal data register of Metropolia ICI project
The personal data saved in the register has, in principle, been obtained from the registered person himself/herself
The personal data within the personal data register of Metropolia’s ICI project are not used in the automatic decision making nor profiling.