Privacy notice of U!REKA European University
Helsinki, 21 January 2025
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.
1 Name of the register
Personal data register of the U!REKA SHIFT project
2 Data controller
Name and Contact Information:
Metropolia Ammattikorkeakoulu Oy (Metropolia University of Applied Sciences Ltd.), Business ID / Registration nr: 20945511; address: Myllypurontie 1, 00920 Helsinki, Finland. Telephone (switchboard): + 358 9 7424 5000
Frankfurt University of Applied Sciences, Business ID / Registration nr: DE 114110370; address: Nibelungenplatz 1, Frankfurt am Main, 60318, Germany. Telephone +49 69 1533-0
HOGESCHOOL GENT (HOGESCHOOL GENT University of Applied Sciences and Arts), Business ID / Registration nr: BE0255.647.755; address: GERAARD DE DUIVELSTRAAT 5, GENT 9000, Belgium. Telephone: +32 9 243 33 33. e-mail:
INSTITUTO POLITECNICO DE LISBOA, Business ID / Registration nr: 508 519 713; address: ESTRADA DE BENFICA 529, LISBOA 1549 003, Portugal. Phone:(+351) 217 101 200
STICHTING HOGESCHOOL VAN AMSTERDAM, Business ID / Registration nr: NL8152.91.152 B01; address: WIBAUTSTRAAT 3 B, AMSTERDAM 1091 GH, Netherlands. Telephone: +31 020 595 4955
VSB – TECHNICAL UNIVERSITY OF OSTRAVA, Business ID / Registration nr: 61989100; address: 17 LISTOPADU 2172/15, OSTRAVA PORUBA 708 00, Czechia. Telephone: +420 596 991 111
3 Purpose and legal basis of the processing of personal data
Purpose of the processing of personal data:
The goal of the Erasmus+ funded U!REKA SHIFT project is to support the development of the U!REKA European University alliance. During the project, the U!REKA partners will co-develop:
- Joint governance bodies and principles of good governance, joint vision and values
- Joint frameworks for student, staff and external stakeholder engagement
- Inclusive and connected inter-university campus
- Three joint Centres of Expertise
- Joint incubator program
- Joint hackathons
- Joint Education framework
- Joint courses and study programs including course materials
- Training materials for university staff
- Joint internship program for students
The purpose of processing personal data in this register is to promote the above stated goals of the U!REKA SHIFT project and the personal data is collected for the following processing operations:
- Communicating and marketing project activities, events, studies or trainings
- Enrollment and participation in project activities, events, studies or trainings
- Planning and developing contents for project activities and outputs
Legal basis for the processing of personal data:
The processing of personal data in the personal data register of U!REKA SHIFT project is based on the legitimate interest, contract or consent obtained from the data subject.
4 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 is legitimate interests in the context of communicating and marketing project activities, events, studies or trainings. Communicating and marketing is essential for creating and strengthening the U!REKA brand, keeping students, staff and stakeholders informed and engaged with the project and for the future growth and prospective of U!REKA European University. |
5 Description of the groups of data subjects and personal data groups
The data subjects in the personal data register are
- Students and staff members of U!REKA partners as well as external stakeholders who get involved in the U!REKA SHIFT project activities.
The following personal data are stored in the personal data register of U!REKA SHIFT.
BASIC INFORMATION AND CONTACT DETAILS
- Basic information on the staff members and students of U!REKA partners e.g. first name; surname; female/male/non-binary, street address; postal address; city; telephone number; e-mail address.
- Basic information on other involved stakeholders e.g. first name; surname; female/male/non-binary, street address; postal address; city; telephone number; e-mail address.
INFORMATION RELATED TO THE PROJECT, COOPERATION AND COMMUNICATION
- Information on the procedures aimed at the data subjects: consent, if required, to receive newsletters; feedback surveys; audivisual recordings of events, for example with Zoom and Teams; or/and information on other forms of cooperation.
- Photos and video recordings: photographs and video recordings taken in the events of the project. The photos and video recordings are used on the websites 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.
CONSENT FORM AND INFORMATION ON CERTAIN ACTIONS
Registration forms: The registration forms ask for the basic and contact information described above and for consent to use the contact information for activities and communication of the project.
Consent forms: with the consent form, the participant gives his or her consent to voluntary participation and the collection of personal data in the development activities of the U!REKA SHIFT project, such as planning and developing contents for project activities and outputs. The consent states that he or she has read the relevant information sheet
6 Regular sources of personal data
The personal data are obtained from the data subjects themselves or with their permission from the institution they study or work at.
7 Data recipients or recipient groups and regular disclosures
Access to the personal data contained in the personal data register of the U!REKA SHIFT project will be given, where necessary, to the following categories of recipients: public authorities, IT providers and IT support. IT 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.
8 Transfer of information outside the EU or EEA or to international organisations
As a rule, personal data contained in the personal data register 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 IT service providers of U!REKA may not transfer or grant access to personal data or process personal data of U!REKA outside the EU or the EEA without prior consultation and prior written consent received from U!REKA. In the case of written consent has been received from the data controller (U!REKA) 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 (U!REKA) 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, 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 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 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 must assess and follow up on a regular basis the level of data protection in the destination country. The data controller /data exporter 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 another 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.
9 Personal data retention times
The personal data collected for and processed within the personal data register are, as a rule, stored in the register for a period of five years after the project has ended.
The following regulations have been observed when determining the retention times:
- EU General Data Protection Regulation (“GDPR”, 2016/679)
- Data Protection Act (1050/2018)
- Directive 95/46 / EC
- Finland: Universities of Applied Sciences Act (932/2014)
- Netherlands:The principle of the Higher Education and Research Act (Wet op het Hoger Onderwijs en Wetenschappelijk Onderzoek) and the Archiefwet (Archive Law) and its selection lists (Selectielijst Hogescholen).
10 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. The data subject may make requests by contacting the points of contact described in Section 3. When making a request, the data subject must verify their identity in a reliable manner. 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.
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.
C. Right to erase personal data
The data subject has the right to the erasure of their personal data 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.
D. Right to data portability (transfer of data from one system to another)
The data subject has the right to receive the personal data that they have provided to a controller, in a structured, commonly used, and machine-readable format, and to transmit that data to another controller if it is technically feasible.
The right applies to the automated processing of personal data, when the personal data concerns the data subject and have been provided by them, and when the basis for processing is:
- the consent of the data subject; or
- a contract to which the data subject is a party.
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.
11 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 any of the data controllers (see page 1 for contact information), where the data subject must prove their identity when submitting the request.
12 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 U!REKA (withdrawal request) can be submitted to any of the data controllers (see page 1 for contact information), where the data subject must prove their identity when submitting the request. |
13 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 authorities and their contact information are as follows:
Finland:
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
Registry: +358 29 566 6768
Email:
Germany
Der Hessische Beauftragte für Datenschutz und Informationsfreiheit
Postfach 31 63
65021 Wiesbaden
Germany
Telefon: +49 611 140 80
E-Mail: poststelle(at)datenschutz.hessen.de
Website: www.datenschutz.hessen.de
Netherlands:
Autoriteit Persoonsgegevens (AP)
Postbus 93374
2509 AJ Den Haag, the Netherlands
Tel: +31 070 888 85 00
Fax: +31 088 – 071 21 40
Website: Autoriteit Persoonsgegevens
Contact details website: Contact met de Autoriteit Persoonsgegevens
Belgium:
Gegevensbeschermingsautoriteit
Drukpersstraat 35, 1000 Brussel
Tel: +32 (0)2 274 48 00
Email:
Czechia:
Office for Personal Data Protection
Address: Pplk. Sochora 27, 170 00 Praha 7
Website: www.uoou.cz.
Portugal:
Comissão Nacional de Proteção de Dados
v. D. Carlos I, 134, 1º – 1200-651 Lisboa
Tel: 351 213 928 400
Email:
Website: https://www.cnpd.pt
14 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:
- The data controllers 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 controllers 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) 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 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 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.
- The data are collected in databases that are protected technically and physically.
- The databases and their back-up copies are in locked premises, and the data can only be accessed by certain pre-appointed persons.
15 Information on whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter 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 is a statutory or contractual requirement, or a requirement necessary to enter 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.
16 Automated individual decision-making, including profiling
The personal data register and the data contained in it will not be used in automated decision-making or profiling. |
