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 Research Material 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)
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
- Inclusive Comprehensive Internationalisation
As part of the ICI project each project partner university carries out self-assessment of inclusive international learning opportunities in their own institution. The current privacy policy of Metropolia's ICI Project Research Material data register describes collecting and processing the personal data; the categories of personal data; the legal basis for processing the personal data; and the retention period of the personal data for this self-assessment at Metropolia.
The data content of the research register will be collected during the year 2023.
The material is collected by interviewing Metropolia staff and students that are invited to take part in the self-assessment research. Perspectives, lived experiences, thoughts and ideas from diverse groups of students are playing an important role in building up project results and hence achieving the objectives of the project.
Participating in the research for ICI self-assessment of Metropolia organised as a part if ICI project is entirely voluntary and is based on the voluntary consent given by the research subject. Data collected for ICI self-assessment of Metropolia will be analysed according to guidelines. Results
of the analysis help to develop outlined project results. Analysis of the collected data is done during the year 2023.
The total duration of the project will take place between 1 February 2021 and 31 January 2025. Thus, the data content of the research register will be saved for the duration of the study until the end of January of the year 2025, after which the research data will be permanently deleted. The present study does not create a permanent personal data register.
During the research for self-assessment, personal data is produced when applying for and when inviting to join the participants for interviews, as well as when saving discussions, interviews and questionnaire materials. The purpose of processing the personal data is to advance reaching the outputs and results of the project.
The research material is saved in Metropolia’s secure workstations that can only be accessed by the ICI research group. The direct identification of the data subject (name) is removed before analysing the research material, and only the research group has access to pseudonymised material.
The current privacy policy of Metropolia's ICI project research material personal data register is supplemented by the following registers with their privacy policy:
- Privacy policy of personal data register of ICI Project in Metropolia
The use of the register is based on an appropriate project plan and the register of research subjects is only used for the project. Research permits are collected from Metropolia.
Legal basis for the processing of personal data:
Processing data in the personal register of the research material in the ICI Project project at Metropolia is based on consent (consent of the subject).
and
Consent of the subject is also legal basis for processing of special categories of personal data.
The legal basis for the processing of personal data contained in the personal data register of Metropolia ICI project research material is not “legitimate interests”. Therefore this section does not apply.
The following personal data are stored in the personal data register of Metropolia’s ICI project research material:
Metropolia staff and students taking part in the interviews and focus group interviews linked to Metropolia’s ICI self-assessment
- Basic information: the first name; the surname, e-mail (when searching for the subjects)
- If consent of subject, also information about specific groups subject him-/herself self-identifies with (e.g. age, gender, sexual orientation, nationality, ethnic background, socio-economic status, first to university religion, disability, learning difficulty, carer/provider, etc.). Interviewee is informed that sharing or not sharing this information is not a condition for participating in the research. Interviewee can also inform whether this information can be stored in the research data for the duration of the research or not.
- Interview data from the research subjects: audio recordings (when interviewing the subjects and analysing the material)
- Questionnaire replies of the research subjects: written replies (when answering the inquiry and analysing the material)
All material is anonymised before the analysing phase.
Consent for and information on certain actions
- Information on consent given for actions targeted at the data subjects in the personal data register of ICI project research material of Metropolia: consent for participating in the research
- Information on the actions targeted at the data subjects: information on reaseacrh for data subject
The personal data have been received from the data subject him or herself
The personal data of Metropolia’s ICI project research material can be accessed only by the Metropolia ICI project research group.
Access to the personal data contained in the personal data register of the ICI project research material 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 research material 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).
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.
E-form software
Surveys of Metropolia’s ICI project research material are conducted 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 ICI Project research material 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 data of the Metropolia ICI project research material data register will be collected during year 2023. The analysis of the collected research data will be conducted by the end of year 2023. Results of the analysis will be used to help to develop project results. The total duration of the ICI project will take place between 1 February, 2022 and 31 January 2025. Hence, the data content of the research register will be saved during the research project until the end of January of the year 2025, after which the research data will be permanently deleted. A permanent register of persons is not created from the study.
The direct identification (name) of the (data subject) is removed (pseudonymisation) before analysing the research material and only the Metropolia ICI project research group has the access to the pseudonymised data.
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.
Processing the personal data within Metropolia’s data register in relation to whether the act of submitting the data is legal, based on a contract or whether it is a contractual requirement and whether the registered person has to submit the personal data and the consequences of not submitting the personal data. On the register-to-register basis, it has been found out where the personal data has been acquired.
The personal data register of Metropolia’s ICI project research material is a register based on voluntary participation aiming to advance the goals of the project.
No one is forced to become a member of the personal data register concerning the research data. The participation in the research is totally voluntary. The participants might refuse to take part in the study or stop participating at any stage without the need from the data subject (the research subject) to voice his or her reason for this.
The personal data saved in the register has been obtained from the data subject himself or herself.
Participating in the study causes no harm for the data subject (research subject). The identity of the participants (research subjects) will be protected.
The personal data register of Metropolia ICI project research material and the data contained in it will not be used in automated decision-making or profiling.