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.
Name of the register
Personal data register of Metropolia’s Helsinki XR Center activities
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: Tiina Vuorio
Position: Project manager, RDI-services
Address: Metropolia University of Applied Sciences, PO Box 4000, FI-00079 METROPOLIA
E-mail: [email protected]
Contact details of the contact person for the register:
Name: Mira Simsiö
Position: Coordinator, RDI-services
Address: Metropolia University of Applied Sciences, PO Box 4000, FI-00079 METROPOLIA
E-mail: [email protected]
Data Protection Officer
Tuulia Aarnio, Metropolia’s Data Protection Officer
Contact details of the Data Protection Officer:
Purpose and legal basis of the processing of personal dataPurpose of the processing of personal data:
The purpose of the personal data register of the Metropolia’s project “Metropolia RDI Profi – to profile Metropolia as an internationally recognized actor in applied XR technology and education” is to manage Helsinki XR Center’s (HXRC) communication and economic reporting in Metropolia together with cooperation partners, stakeholders and operators. The register includes data about the Helsinki XR Center project, general activities and project management staff with their contact information, cooperation partners (organisations and contact persons), and funding information related to HXRC.
The processing of the personal data contained in the personal data register of Helsinki XR Center includes following activities:
• management of the financier’s contact information
• management of the contact information of partners outside Metropolia
• data management affiliated to communication activities
• dealing with HXRC funding reporting
• management of contact information of cooperation partners
• management of start up activities and contact information
• management of communication with cooperation partners
• communication of events and activities
• organizing events and workshops
• collection of research data and feedback
Reportronic project management system is used to track Metropolia’s project workers’ working hours and work plan implementation. Thus, Metropolia’s project data register and its privacy notice complement the privacy notice of the data register of the Helsinki XR Center of Metropolia.
Legal basis for the processing of personal data:
The processing of the personal data contained in the personal data register of the Helsinki XR Center of Metropolia University of Applied Sciences is based on public interest.
Information collected via registration to Helsinki XR Center events is based on consent obtained from the registered person.
The management purpose of personal data, legal basis and other information of Metropolia’s project data register that complement Helsinki XR Center’s personal data register are mentioned in its own privacy notice.
Legitimate interests of the data controller or a third party
The legal basis for the processing of personal data contained in the personal data register of the Helsinki XR Center of Metropolia University of Applied Sciences is not “legitimate interests”. Therefore, this section does not apply.
Description of the groups of data subjects and personal data groups
The following personal data are stored in the personal data register of the Helsinki XR Center of Metropolia University of Applied Sciences:• Basic information and contact details: forename(s); surname; birthday; birth month; birth year; address; postal code; city; telephone number; email address
• Information of activities targeted to registered persons: consent for receiving newsletters
• Photos and videos: photos and videos taken in the Helsinki XR Center related events and workshops
Stakeholders involved in Helsinki XR Center activities:
• Basic information and contact details: name of the stakeholder; name of the contact person; email address; possible organisation/enterprise and title
Regular sources of personal data
The personal data are obtained from the registered persons themselves.
Information systems used in the processing of personal data
The various IT systems, applications and software used by Helsinki XR Center include:
E-lomake system and Eventbrite
Registration for Helsinki XR Center events and workshops is done by Eventbrite event management system or E-lomake system. The collected data are transferred to Excel in Helsinki XR Center’s Google Drive cloud. The email addresses collected during the registration are transferred to Postiviidakko newsletter system operated by LianaTech.
G Suite for Education
Information for the data register of Helsinki XR Center is collected and managed with Google corporation’s education directed application package G Suite for Education. Personal data specially is managed with Google Drive cloud service. Parts of the data register that are related to documenting, like images, videos, contact information, data tables, feedback, and research inquiries, are mainly processed with Metropolia’s acquired Google bound tools.
Microsoft Office 365 Education
Helsinki XR Center project workers use Metropolia’s email system. The email system is based on Microsoft Office 365, but the email server is Metropolia’s own. In addition, sending newsletters and communication with cooperation partners, financier and other possible operators happen with the email.
Helsinki XR Center project workers use Microsoft TEAMS service for internal communication. Microsoft TEAMS communication tools is acquired to Metropolia as a part of bigger 0365 Microsoft package.
In addition, project workers use cloud service tools approved by Metropolia.
Dynasty case and contract management system
Project contracts are managed with Dynasty case and contract management system.
Halli and Reportronic project management systems
The system includes information about all operators working in the project.
WordPress content management system and Zoner.fi web hotel
The public web page of Helsinki XR Center is below domestic web hotel Zoner.fi and they are constructed with WordPress content management system. WordPress uses Metropolia’s own servers (no service provider from outside). Contact information of the project workers are in the web page.
Postiviidakko newsletter tool
(communications about services and e.g. sending of invitations to events) Information about the activities of Helsinki XR Center, for example, invitations to events (if the registered person has given their express consent for it in writing) are sent by email through the Postiviidakko newsletter tool.
Microsoft AltspaceVR event platform
Helsinki XR Center uses AltspaceVR platform, owned by Microsoft, for events and meetings. Usernames and emails are saved to AltspaceVR. Helsinki XR Center can see usernames and emails used by the persons registered to Helsinki XR Center’s events. Helsinki XR Center does not collect usernames or emails saved to AltspaceVR for further use.
Meetup event management system
Helsinki XR Center uses Meetup application for arranging and advertising events. Usernames and emails are saved to Meetup application’s own system, which the user is responsible for. Helsinki XR Center does not collect usernames or emails saved to Meetup for further use.
Data recipients or recipient groups and regular disclosures
Access to the personal data contained in the personal data register of the Helsinki XR Center 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 Helsinki XR Center of Metropolia, personal data processing agreements in accordance with Article 28 of the GDPR will be concluded by Helsinki XR Center with the following cooperation partners:
• Eduix Oy and e-form system used in Metropolia
• Google LCC and Google bound cloud services (Google bound cloud services found in cloud services under Tools section in Oma-intranet)
• Microsoft Corporation and Microsoft bound cloud services approved by Metropolia (Microsoft bound cloud services found in cloud services under Tools section in Oma-intranet)
• Sebitti Oy and Reportronic project management system
• Innofactor Oyj and Dynasty case and contract management system
• Liana Technologies Oy and Postiviidakko newsletter tool
Data processing agreements in accordance with Article 28 of the GDPR will be concluded with the following system vendors / system service provider (NB Helsinki XR Center project manager is responsible for making a personal information processing agreement with these cooperation partners as these are tools for the project only and not tools for Metropolia) :
• ”Eventbrite Oy” and Eventbrite event management system
• ”Zoner Oy” ja Zoner.fi web hotel
• Meetup event management system
Transfer of information outside the EU or EEA or to international organisations
The personal data register of Helsinki XR Center is managed with cloud services where personal data can be transferred outside the EU or EEA or to international organisations.The transfer of personal data outside the EU or EEA is done by data protection regulation when Google and Microsoft bound cloud service tools are used.
Valid processing agreement of personal data between Metropolia and Google LLC is based on general agreement of cloud service tools, since all Google bound services (like Google Drive) have been introduced to use in Metropolia as a part of G Suite cloud service set.
In this agreement, international personal data transfer outside GDPR-area (outside EU and EEA) is accepted. Google LLC informs its European partners that they use standard contractual clauses accepted by EU commission as a special safeguard measure when transferring international personal data.
It is noted in the valid processing agreement of personal data between Metropolia and Google LLC that the current information about the physical location (Google’s data centers/servers) of client’s personal data can be found from the link:
• “Data Center Information. Information about the locations of Google data centers is available at https://www.google.com/about/datacenters/inside/locations/hamina/”
Microsoft Corporation informs its European partners who use Microsoft Office 365 Education system that they use standard contractual clauses accepted by EU commission as a special safeguard measure when transferring international personal data:
The agreement concerning Microsoft cloud services can be examined here https://www.microsoft.com/en-us/trustcenter.
Personal data retention times
The personal data collected for and processed within the personal data register of Helsinki XR Center are stored in the register for a period of 10 years.
Rights of the data subject
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: [email protected], [email protected]).
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 must 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)
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.
Right to object
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, where the data subject must prove their identity when submitting the request.
Right to withdraw consent
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.
Right to lodge a complaint with a supervisory authority
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: Ratapihantie 9, 6th floor
00520 Helsinki, Finland
Postal address: PO Box 800
Telephone (switchboard): + 358 29 56 66700
Fax: + 358 9 56 66735
Email: [email protected]
Principles of data protection in the register
General description of the technical and organisational security measures aiming at protecting the personal data of the data subjects and the personal data registers at Metropolia:• The data controller (Metropolia) and the system providers have agreed on the protection of the register. If necessary, the responsibilities have been described in adequate detail in the appropriate agreements.
• The employees and other personnel of the data controller (Metropolia) 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 that act on behalf of the data controller, Metropolia) 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 controller (Metropolia) 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 controller (Metropolia) has 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 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 (information on the source of the personal data)
Information on whether the provision of personal data for processing in the personal data register of the Helsinki XR Center 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 Helsinki XR Center of Metropolia University of Applied Sciences is based on voluntary registration and it is used to manage the activities and services of Helsinki XR Center.
• It is not compulsory to be registered in the personal data register of the Helsinki XR Center of Metropolia University of Applied Sciences.
• The personal data stored in the register have mostly been collected from the data subjects themselves.
Automated individual decision-making, including profiling
The personal data register of the Helsinki XR Center of Metropolia University of Applied Sciences and the data contained in it will not be used in automated decision-making or profiling.
See also description of: