1. Entity and person in charge of processing personal data
Student Services, Sanna Kotajärvi-Söderholm, Senior Head of Academic Affairs
E-mail: firstname.lastname@example.org, telephone: +358 (0)40 860 9524
2. Contact person(s) for processing personal data
Study psychologist Outi Rämö
E-mail: email@example.com, telephone: +358 (0)50 477 8425
Study psychologist Katri Ruth / Sibelius Academy, Kuopio campus
E-mail: firstname.lastname@example.org, telephone: +358 (0)50 341 0656
3. Register name and brief description
This privacy notice describes how the study psychology activities of the University of the Arts Helsinki (in Finnish, English and Swedish) process the personal data of individual guidance counselling clients. Study psychologists at the University of the Arts Helsinki and the service provider responsible for the Swedish-language study psychology service are authorised health care professionals who are bound by the Act on Health Care Professionals (559/1994), the Act on the Status and Rights of Patients (785/1992) and the Ministry of Social Affairs and Health Decree on Patient Documents (298/2009).
4. Purpose and legal basis for processing personal data
The University’s operations are steered by obligations arising from the Universities Act (558/2009) and other legislation. In accordance with legislation governing university operations, the university does not act as a health care unit, and the university does not have a statutory obligation under the Universities Act or another Act to provide a study psychologist service.
The legal basis for processing the information ofguidance counselling clients is related to the performance of a statutory, public teaching task as defined in the Universities Act (Supporting the completion of the teaching task, with particular regard to guidance and accessible study). The processing of personal data is therefore based on carrying out a task in the public interest (Article 6, paragraph 1e of the General Data Protection Regulation).
The purpose of processing personal data is to:
- plan and implement study psychological guidance forguidance counselling clients
- promote and plan the study capacity of guidance counselling clients
- keep statistics on and plan the controller’s own activities for the quality control and development of study psychologist activities at the University of the Arts Helsinki.
Automated decision-making or profiling referred to in the GDPR is not utilised in the processing of personal data.
5. What data do we process?
The following data on guidance counselling clients is processed in study psychology activities:
Information given to the study psychologist for a callback in connection with the contact request (text message, telephone number).
Information recorded as a guidance counselling client:
- Basic information such as first name, last name, date of birth and personal identity code, mother tongue, educational institution and major subject, year of starting studies and number of credits, student number, degree programme, nationality and service language
- Contact details such as e-mail address, phone number, address information
- Appointment information (date, duration, first visit, follow-up visit, meeting)
- Information on the termination of the guidance counselling relationship (date)
Sensitive personal data:
Due to the nature of study psychology activities, the guidance counselling relationship often also involves the processing of information concerning the health of the guidance counselling client. Health-related information may include:
- Grounds for seeking guidance
- Visit entries
- Summary of guidance and possible summaries of guidance generated in the guidance client relationship, certificates, recommendations, statements, questionnaire information and research documents
- Information provided by the guidance client on his/her health (e.g. grounds for seeking guidance, literacy certificate, etc.)
6. Where do we get information?
Information is obtained from the StudyInfo system of the University of the Arts Helsinki (information on the right to study and the stage of studies) and from the guidance counselling client. The information compiled by the study psychologist on the guidance counselling client relationship is obtained from the study psychologist.
7. To whom do we disclose and transfer data, and do we transfer data outside the EU or EEA?
Client data concerning the guidance counselling relationship is confidential. Client data may only be disclosed (Section 13 of the Act on the Status and Rights of Patients (785/92)) with the consent of the client or under an explicit legal provision.
Data is only processed within the EU or EEA.
8. How do we protect data and for how long do we store it?
The data processed in study psychology activities is confidential. Personal data may only be processed by those employees of the University of the Arts Helsinki whose work tasks require it (study psychologist, study psychologist intern and Chief Information Security Officer / Data Protection Officer (where the latter is concerned, only limited access to the system in case of support related to the processing of an incident) and by the Swedish-language service provider (study psychologist) commissioned by and serving on behalf of the University of the Arts Helsinki. All persons processing personal data are bound by a confidentiality obligation.
The data consists of manual (paper) and electronic material.
Study psychology guidance counselling client data is mainly processed in a secure electronic client data system, which is suitable for processing patient data and offers proven data security. Log data is used to monitor the use of data in the electronic client system.
As Controller, the University of the Arts Helsinki has taken the necessary technical and organisational measures and also requires the service providers it uses to do so.
We store personal register data related to the guidance counselling relationship for 12 years after the end of the relationship, after which the data is deleted from the register.
We assess the need for data storage on a regular basis, taking into account any applicable legislation. In addition, we take reasonable steps to ensure that the data subject’s personal data being stored in the register is not outdated, erroneous or incompatible with the purpose of processing. We immediately correct or erase such data.
9. What are your rights as a data subject?
You have the right to take the following measures regarding your personal data:
- The right to request access to personal data relating to you and the right to request the rectification or erasure of such data
- The right to request restriction of the processing of personal data or to object to its processing
- Right to request the transfer of personal data from one system to another
Please note that the suitability and scope of your aforementioned rights will be determined on a case-by-case basis in accordance with the EU’s General Data Protection Regulation and that you do not have the aforementioned rights in all cases.
10. Exercising your rights
In order to exercise the aforementioned rights, you may contact a study psychologist, after which your request will be processed in accordance with University procedures.
Please provide your name, contact details (e.g. email address or phone number) and how you wish to exercise the aforementioned rights.
Under the General Data Protection Regulation, the time limit for responding to your request is one month. If necessary, the period may be extended by a maximum of two months, taking into account the complexity and number of requests.
11. Other rights
Right to lodge a complaint with the supervisory authority
In addition to the aforementioned rights, you have the right to file a complaint concerning the processing of personal data with the Office of the Data Protection Ombudsman acting as the supervisory authority. The telephone advice number and opening hours of the Office of the Data Protection Ombudsman can be found on the website of the Office of the Data Protection Ombudsman.
- Postal address: Office of the Data Protection Ombudsman, P.O. Box 800, 00521 Helsinki
- E-mail: email@example.com
Right to be notified of a breach of your personal data
We are obligated to personally notify data subjects whose data the breach concerns. The right will enter into effect if the breach most likely poses a high risk to the rights and freedoms of the individual, for example, in the form of identity theft, payment fraud or other criminal activity
12. Who can you contact?
Questions concerning the guidance counselling relationship:
You may ask a study psychologist to tell you about any saved entries made concerning you in guidance counselling. You may order the saved entries, summaries, statements, certificates and recommendations to be sent to you in writing by post by sending a request to: Order request for study psychologist documents / Study psychologists, P.O. Box 36, 00097 University of the Arts Helsinki. The request will be directed to the study psychologists who have provided guidance counselling to the client.
If you have any questions regarding this privacy statement, please contact us at firstname.lastname@example.org.