See Privacy Notice for Personal Data Register of the Urban SOS-Project’s research material.
The Personal Data Register of Metropolia's Urban SOS Project’s Research Material
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: Annakaisa Oksava
Position: Head of School, School of Wellbeing
Address: Metropolia Ammattikorkeakoulu Oy, PO Box 4000, FI-00079 METROPOLIA
E-mail: annakaisa.oksava [at] metropolia.fi (annakaisa[dot]oksava[at]metropolia[dot]fi)
Contact details of the contact person for the register:
Name: Tiina Lehto-Lundén
Position: Project Manager, School of Wellbeing
Address: Metropolia University of Applied Sciences, PO Box 4000, FI-00079 METROPOLIA
E-mail: tiina.lehto-lunden [at] metropolia.fi (tiina[dot]lehto-lunden[at]metropolia[dot]fi)
Contact details in questions concerning the purpose of the register:
E-mail: tiina.lehto-lunden [at] metropolia.fi (tiina[dot]lehto-lunden[at]metropolia[dot]fi)
Sanna Saarnia, Metropolia’s Data Protection Officer
Email: tietosuojavastaava [at] metropolia.fi (tietosuojavastaava[at]metropolia[dot]fi)
The purpose of processing personal data
The aim of the international Erasmus+ funded Urban SOS project is to develop educational activities focusing on the current growing need in the field of social services to take part in both the international and multiprofessional dialogue.
We want to activate a discussion regarding what affects the well-being of the residents in an urban environment. We invite both the residents and educators in the field of social services together with the agents acting in the field and the local authorities implementing the urban policy.
The Urban SOS project aims to analyse the social work of the city and the structures of the social support and communities to help create sustainable solutions for the residents and the cities.
During the project, we will develop the following four “products”:
- Creating an approach based on common practices that are research based, analytical and methodological.
- Training material for the teaching staff
- E-learning material for the professionals in the social field
- Creating an online learning community. We use gamification methods to increase the student engagement, motivation and knowledge.
The personal data included in the personal data register of Metropolia’s Urban SOS -project will carry out e.g., the following processing operations.
- communicating and informing of the project activities
- organizing events, development workshops and happenings
- taking photographs and videos in the events and development workshops related to the project.
The current privacy policy of Metropolia's Urban SOS research 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.
The data content of the research register will be collected during the years 2020-2022. The material is collected by interviewing and reviewing documents from both the Kalliola settlement and Miitti ltd, and possibly from other project partners. Participating in the study is entirely voluntary and is based on the voluntary consent of the research subject.
On the basis of i.e., these interviews and the information analysed based on them, outputs are developed according to the project goals. In order to meet these goals, co-development workshops and surveys are needed, all of which involve processing the personal data.
The analysis of the collected research data and the use of the data as part of the project's work packages will take place by the end of 2022. The total duration of the project will take place between 31 August 2019 and 31 December 2022. Thus, the data content of the research register will be saved for the duration of the study until the end of 2022, after which the research data will be permanently deleted. The present study does not create a permanent personal data register.
During the study, personal data is produced when applying for and when inviting to join the participants for interviews and co -development workshops, 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 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 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 all the required organisations.
The legal basis for processing the personal data:
Processing data in the personal register of the research material in the Urban SOS project at Metropolia is based on consent (consent of the subject).
Processing data in the personal register in the Urban SOS project at Metropolia
is based on performing the task owing to public interest: conducting scientific research.
The legal basis for the processing of the personal data in the Metropolia's Urban SOS project is not a "legitimate interest". That's why this part is not applicable.
The following personal data are stored in the personal data register of Metropolia’s Urban SOS project assorted by personal data groups
All material is anonymised before the analysing phase.
Persons taking part in the activities of the project partner
- Basic information: the first name; the surname (when searching for the subjects)
- 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)
The personal data have been received from the data subject him or herself.
The project acts according to the privacy policy explained on the Metropolia.fi web site or the project and privacy policy of the project management register.
When broadly interpreting the EU General Data Protection Regulation Article 4.9 what is listed next is the processors/ recipients of the personal data, to whom the register keeper “transfers” or “transfers for processing” the personal data (e.g. with a technical interface when performing maintenance tasks)
The personal data of Metropolia’s Urban SOS can be accessed only by the research group and the students supervised by the research group working on their final theses, who have an understanding of the principals of research ethics.
As a general rule, personal data contained in the personal data register of the xx activities / project 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. International transfers of personal data from the Metropolia University of Applied Sciences' personal register to the United States and / or elsewhere outside the EU / EEA are primarily secured then by the safeguard provided for in Article 46 of Chapter V of the EU General Data Protection Regulation (GDPR), standard contractual clauses. 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.
(-> If you use IT systems, softwares etc. provided by IT service provider registered in United States /outside the EU/EAA, it might be possible that the IT service provider uses servers for the data storage located in United States /outside the EU/EEA -> This might mean that personal data will be transferred to United States/ outside the EU/EEA as the storing of personal data is considered as processing of personal data according to the GDPR, and as storing personal data into the data storage servers located outside the EU/EEA, is considered as transferring personal data outside the EU/EEA according to the GDPR).
If that is the case, you need to specify to which third countries outside the EU or EEA you are transferring personal data (list of countries/mapping of countries).
When mapping transfers, do not forget to also take into account onward transfers, for instance whether your processors outside the EEA transfer the personal data you entrusted to them to a sub-processor in another third country or in the same third country. In other words, you must know where the personal data you exported may be located or processed by the importers (map of destinations).
Keep in mind that remote access from a third country (for example in support situations) and/or storage in a cloud situated outside the EEA, is also considered to be a transfer. More specifically, if you are using an international cloud infrastructure you must assess if your data will be transferred to third countries and where, unless the cloud provider clearly states in its contract that the data will not be processed at all in third countries.
As a next step, you must identify the transfer tools (safeguards) you are relying on amongst those described in the Chapter V of the GDPR (Articles 45 - 49).
Article 46 of the Chapter V of the GDPR lists standard contractual clauses (SCCs) as a transfer tool containing “appropriate safeguards” for the data transfer.
Whatever GDPR transfer tool you choose, you must ensure that, overall, the transferred personal data will have the benefit of an essentially equivalent level of protection. “An essentially equivalent level of protection” means that the transferred personal data is afforded a level of protection in the third country that is essentially equivalent to that are guaranteed in the EEA where strict data protection legislation prevails.
It might be useful to contact Data Protection Officer of Metropolia UAS (dpo [at] metropolia.fi (dpo[at]metropolia[dot]fi); tietosuojavastaava [at] metropolia.fi (tietosuojavastaava[at]metropolia[dot]fi)) in a case considering international personal data transfers outside the EU or EEA.
The data of the research register will be collected during 2019-2022. The analysis of the collected research data and using the data as a part of the project’s work packages will take place by the end of 2022. The total duration of the project will take place between 31 August and 31 December 2022. Hence, the data content of the research register will be saved during the research project until the end of 2022, 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 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 the personal data is based on the consent of the data subject, the data subject has the right to cancel the given consent at any point without it affecting the lawfulness of processing carried out prior to this.
Withdrawing the consent regarding the processing of the personal data collected at Metropolia (request for withdrawal) can be made by submitting the request to one of the three aforementioned Metropolia’s student and applicant service offices, where the registered person must prove his or her identity at the time of 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 Urban SOS project 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 included in the personal data register of Metropolia Urban SOS project’s research material is not automatically used for decision making or profiling.