Data policy

THE FUTURE PATH PROJECT DATA POLICY FOR ASYLUM SEEKERS  (SECTIONS 1-10)

This document is the privacy statement in accordance with the General Data Protection Regulation of the European Union (decree 2016/679).

The privacy statement informs you on how we process your personal data when it has been registered into our system. It also gives you information on your rights based on the EU data protection regulation.

1 Register administrator

Laurea University of Applied Sciences
Ratatie 22
01300 Vantaa
Business ID: 1046216-1

2 Contact person in matters concerning the register

Pauli Turunen
Project manager
pauli.turunen[at]laurea.fi

3 Name of the register

Data privacy statement for the asylum seekers participating in the Future Path project.

4 Purpose and legal bases of the processing of personal data

Future path is a  pilot project funded by the European Union Home Affair Funds during 1.8.2019 – 31.7.2020. The purpose of the project is to develop and implement a training & recruitment program  which highlights the features of the society and market environment in Iraq and strengthens the asylum seekers’ skills in entrepreneurship. The purpose of collecting and processing personal data is to discover the competences and education of the asylum seekers to be utilized upon returning to Iraq in cooperation with the business operations of Finnish enterprises. The aim of personalisation of the training and support functions is to get to know the person of whom the data is being collected and processed.

The legal bases  for data handling is the consent of the data subject.

5 Data contents of the register

The data of the registered persons is related to the specific uses of the information. This data is partly depending on the information that the registered person wishes and consents to share.

The register administrator will collect the following obligatory information:  name, country of origin, place of residence, ethnic background, age, gender, education, work experience, email, phone number, language skills, family relations (dependants) and willingness to cooperate with Finnish enterprises in Iraq. Other collected data may include any kind of voluntary information given by the registered person.

6 Regular sources of personal data

The data is collected from the registered persons directly using questionnaires and interviews.

7 Regular transfers of personal data

Register administrator uses specified contract partners in data handling and processing. Personal data is transferred to these contract partners in compliant with data protection rules and written partnership agreement. The contract partners participate in collecting the personal data. Data is assigned to the following partners:

  1. Comprendum
  2. Haaga-Helia University of Applied Sciences

Comprendum  prepares a research for Haaga-Helia, including the interests and opportunities of  Finnish small and medium-sized enterprises and their business plans to match the market demand in Iraq.  In addition, Comprendum will contact and recruit suitable Finnish companies, map their needs and preoccupations and participate in designing a cooperative operational model for the asylum seekers and the recruited Finnish companies. Comprendum also supports Haaga-Helia in producing an orientation material package and helps in designing the on-boarding training program for individual asylum seekers and matching companies.

Haaga-Helia will handle the data of the Finnish corporations collected by Comprendum as part of the project operations.

8 Principles of register protection

The handling of data is done carefully and the register administrator has ensured that appropriate technical and organisational measures have been taken to protect the personal data and the register’s servers. Employees have been given training on data protection and instructions on how to process the personal information confidentially and with safety.  The employees are committed to follow professional secrecy regulations and will not share any personal data to others.

Questionnaires will be stored in the locked premises of the RDI unit staff. The premises are equipped with electronic access control. In addition, the material is kept in Laurea Leppävaara campus in a locker for which only the register administrator can access.

The data of the questionnaires is saved into an Excel file which is kept in ePouta system managed by the register administrator. The access to the file is limited and requires ID and password. Haaga-Helia’s project manager and the teacher responsible for entrepreneurship tutoring and councelling will be granted access to the ePouta system  by sharing the workspace via encrypted email from Laurea project manager. The access is granted for a limited period until 31.7.2020. The Excel file may not be copied or downloaded from the server and the information must not be saved outside the ePouta system.

9 Retention period for collected data

Personal data will be stored during the following retention period:

  1. The paper forms are destroyed on 31.7.2020 at the latest.
  2. The Excel file is retained at most three (3) years, in order to be able to support the persons returning to Iraq during a possibly subsequent project or follow-up cooperation of Future Path.  If the continuation for the project will not be applied or any other form of cooperation  does not begin by 31.7.2020, the Excel file will be destroyed.

10 Rights of the data subject

The data subject will have the following rights:

  • Right to have a confirmation from the register administrator concerning the status of one’s own personal data (is the data being handled or not and if yes; right to have access to the personal data)
  • Right to request the correction or supplement of false or inaccurate personal information without delay. The correction is done by the register administrator.
  • Right to demand the register administration to delete all personal data without unnecessary delay, if the applicable data protection regulation conditions are met;
  • Right to request the handling of personal data be limited be the register administrator, if the applicable data protection regulation conditions are met;
  • Right to get all the information given by the registered person, in a comprehensive and digitally readable and generally available format; right to transfer own personal information to any other register administrator  without interference of the current register administrator, if the applicable data protection regulation conditions are met.

All requests concerning the rights of the data subject should be sent to: Future path, Pauli Turunen, Vanha maantie 9, 02650 Espoo, Finland.

The register administrator may ask the requester to present a valid ID if needed. The register administrator will reply the requester  within the time period set in the General Data Protection Regulation of EU.

The registered person has the right to make a complaint to a monitoring authority if she/he believes that the handling of personal data  is done against the applicable data protection regulation. The national monitoring authority in Finland is Office of the Data Protection Ombudsman.

 

THE FUTURE PATH PROJECT DATA POLICY FOR ASYLUM SEEKERS  (SECTIONS 11-20)

This document is the privacy statement in accordance with the General Data Protection Regulation of the European Union (decree 2016/679).

The privacy statement informs you on how we process your personal data when it has been registered into our system. It also gives you information on your rights based on the EU data protection regulation.

11 Register administrator

Laurea University of Applied Sciences
Ratatie 22
01300 Vantaa
Business ID: 1046216-1

12 Contact person in matters concerning the register

Pauli Turunen
Project manager
pauli.turunen[at]laurea.fi

13 Name of the register

Data privacy statement for the enterprises participating in the Future Path project.

14 Purpose and legal bases of the processing of personal data

Future path is a  pilot project funded by the European Union Home Affair Funds during 1.8.2019 – 31.7.2020. The purpose of the project is to develop and implement a training & recruitment program  which highlights the features of the society and market environment in Iraq and strengthens the asylum seekers’ skills in entrepreneurship.

The purpose of data processing is communication with the enterprises which have expressed their interest towards the project actions.

The legal bases for data handling is the consent of the data subject.

15 Data contents of the register

The data of the registered person is related to the specific uses of the information. This data is partly depending on the information that the registered person wishes and consents to share.

The register administrator will collect the following obligatory information:  name,  email, phone number, organisation and line of business. Other collected data may include any kind of voluntary information given by the registered person.

16 Regular sources of personal data

The data is collected from the registered persons directly using questionnaires.

17 Regular transfers of personal data

Register administrator uses specified contract partners in data handling and processing. Personal data is transferred to these contract partners in compliant with data protection rules and written partnership agreement. The contract partners participate in collecting the personal data. Data is assigned to the following partners:

  1. Comprendum
  2. Haaga-Helia University of Applied Sciences

Comprendum  prepares a research for Haaga-Helia, including the interests and opportunities of  Finnish small and medium-sized enterprises and their business plans to match the market demand in Iraq.  In addition, Comprendum will contact and recruit suitable Finnish companies, map their needs and preoccupations and participate in designing a cooperative operational model for the asylum seekers and the recruited Finnish companies. Comprendum also supports Haaga-Helia in producing an orientation material package and helps in designing the on-boarding training program for individual asylum seekers and matching companies.

Haaga-Helia will handle the data of the Finnish corporations collected by Comprendum as part of the project operations.

18 Principles of register protection

The handling of data is done carefully and the register administrator has ensured that appropriate technical and organisational measures have been taken to protect the personal data and the register’s servers. Employees have been given training on data protection and instructions on how to process the personal information confidentially and with safety.  The employees are committed to follow professional secrecy regulations and will not share any personal data to others.

Questionnaires will be stored in the locked premises of the RDI unit staff. The premises are equipped with electronic access control. In addition, the material is kept in Laurea Leppävaara campus in a locker for which only the register administrator can access.

The data of the questionnaires is saved into an Excel file which is kept in ePouta system managed by the register administrator. The access to the file is limited and requires ID and password. Haaga-Helia’s project manager and the teacher responsible for entrepreneurship tutoring and councelling will be granted access to the ePouta system  by sharing the workspace via encrypted email from Laurea project manager. The access is granted for a limited period until 31.7.2020. The Excel-file may not be copied or downloaded from the server and the information must not be saved outside the ePouta system.

19 Retention period for collected data

Personal data will be stored during the following retention period:

  1. The paper forms are destroyed on 31.7.2020 at the latest.
  2. The Excel file is retained at most three (3) years, in order to be able to support the persons returning to Iraq during a possibly subsequent project or follow-up cooperation of Future Path.  If the continuation for the project will not be applied or any other form of cooperation  does not begin by 31.7.2020, the Excel file will be destroyed.

20 Rights of the data subject

The data subject will have the following rights:

  • Right to have a confirmation from the register administrator concerning the status of one’s own personal data (is the data being handled or not and if yes; right to have access to the personal data)
  • Right to request the correction or supplement of false or inaccurate personal information without delay. The correction is done by the register administrator.
  • Right to demand the register administration to delete all personal data without unnecessary delay, if the applicable data protection regulation conditions are met;
  • Right to request the handling of personal data be limited be the register administrator, if the applicable data protection regulation conditions are met;
  • Right to get all the information given by the registered person, in a comprehensive and digitally readable and generally available format; right to transfer own personal information to any other register administrator  without interference of the current register administrator, if the applicable data protection regulation conditions are met.

All requests concerning the rights of the data subject should be sent to: Future path, Pauli Turunen, Vanha maantie 9, 02650 Espoo, Finland.

The register administrator may ask the requester to present a valid ID if needed. The register administrator will reply the requester  within the time period set in the General Data Protection Regulation of EU.

The registered person has the right to make a complaint to a monitoring authority if she/he believes that the handling of personal data  is done against the applicable data protection regulation. The national monitoring authority in Finland is Office of the Data Protection Ombudsman.