Privacy notice for study psychologist activities
Articles 13 and 14 of the EU Data Protection Regulation concerning informing of the data subject. Drawn up on 23 April 2020. Updated on 10 April 2024.
1. Controller
Uniarts Helsinki
Postal address: P.O. Box 1, 00097 Uniarts
Phone number: +358 294 472 000 (exchange)
2. Unit and person in charge of processing personal data
Study Services, Senior Head of Academic Affairs Milla Vaisto-Oinonen
Email: firstname.lastname@uniarts.fi
Phone number: +358 294 472 000 (exchange)
3. Contact person for the processing of personal data
Shared Study Services, Study Psychologist Sanna Vuorinen
Email: firstname.lastname@uniarts.fi
Phone number: +358 50 477 8425
4. Data protection officer
Uniarts Helsinki’s data protection officer is Legal Counsel Minna Eskola.
Email: tietosuoja@uniarts.fi
Phone number: +358 294 473 490
Postal address: P.O. Box 1, 00097 Uniarts
5. Name of register and brief description
Uniarts Helsinki’s client register for study psychologist activities
This privacy notice describes how the personal data of clients receiving individual counselling are processed in the study psychologist activities of Uniarts Helsinki (activities in Finnish, English and Swedish). Uniarts Helsinki’s study psychologists 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 (94/2022).
6. Purpose and legal basis for the processing of 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.
Uniarts Helsinki’s right to process personal data is based on:
- Performance of a task carried out in the public interest
- Compliance with a legal obligation
The legal basis for processing the information of counselling clients is related to the performance of a statutory, so-called public teaching task as defined in the Universities Act (Supporting the completion of the teaching task, with particular regard to counselling and accessible studying).
The purpose of processing personal data is to:
- plan and implement study psychological guidance for counselling clients
- promote the counselling client’s ability to study and to prepare related plans
- keep statistics on and plan the controller’s own activities for the quality control and development of study psychologist activities at Uniarts Helsinki.
Automated decision-making or profiling referred to in the GDPR is not utilised in the processing of personal data.
7. What data do we process?
The following information concerning counselling clients may be processed in study psychologist activities:
- Information given to the study psychologist for a callback in connection with a contact request (text message, phone number).
Information recorded concerning counselling clients:
- Basic information (such as first name, last name, date of birth and personal identity code, first language, academy and major subject, year of starting studies and number of credits, study right number, degree programme, nationality, and service language)
- Contact details (such as email address, phone number, address information)
- Information concerning appointments (date, duration, first visit, follow-up visit, meeting)
- Information on the termination of the counselling relationship (date)
Sensitive personal data:
Due to the nature of study psychologist activities, the counselling relationship often also involves the processing of information concerning the health of the counselling client. Health-related information may be included in the following data:
- Grounds for seeking counselling
- Visit entries
- Summary of counselling and possible summaries of counselling generated in the counselling relationship, certificates, recommendations, statements, questionnaire information and assesment documents
- Information provided by the counselling client on their health (e.g. grounds for seeking counselling, dyslexia-related certificate, etc.)
8. Where do we get data?
Information is obtained from Uniarts Helsinki’s student information system (information on the right to study and the stage of studies) and directly from the counselling client. The information compiled by the study psychologist on the counselling client relationship is obtained from the study psychologist.
9. To which parties do we disclose and transfer data, and do we transfer data outside the EU or the EEA?
Client data concerning the counselling relationship is confidential. Client data may only be disclosed (Section 13 of the Act on the Status and Rights of Patients (785/1992)) with the consent of the client or under an explicit legal provision.
No data from the client registers of Uniarts Helsinki’s study psychologists will be transferred outside the EU or the EEA.
10. How do we protect data and for how long do we store it?
As the controller, Uniarts Helsinki has taken the necessary technical and organisational measures and also requires the same from the service providers it uses.
The data that is processed as part of study psychologist activities is confidential. Personal data can only be processed by the Uniarts Helsinki employees whose job duties (study psychologist, study psychologist trainee and data security officer / data protection officer, the last mentioned only have restricted access to the system when providing support for handling a problem situation). All persons processing personal data are bound by a confidentiality obligation.
The data consists of manual (paper) and electronic material.
The data of clients receiving face-to-face or remote counselling as part of study psychologist activities is mainly processed in a secure electronic client data system that 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.
We store personal register data related to the 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 retention of the data on a regular basis, taking into account any applicable legislation. In addition to this, we take reasonable steps to ensure that the data subject’s personal data being retained in the register is not outdated, erroneous or incompatible with the purpose of processing. We immediately rectify or erase such data.
11. What are your rights as a data subject?
Data subjects have the following rights:
- Right to request access to their data
- Right to receive information on the processing of their personal data
- Right to have erroneous or inaccurate personal data rectified
- Right to have data erased
- Not applicable if the basis for processing is a statutory duty or a duty in the public interest
- Right to request the restriction of the processing of data
- Right to object to processing i.e. to ask that data is not processed
- Right to have data transferred from one system to another
- Applicable when the processing is based on an agreement or consent
- Right to withdraw their consent
- Applicable when the processing is based exclusively on consent
- The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
- Right to receive information on a personal data breach that results in a high risk
- Right not to be subject to a decision based on automated processing
Data subjects have the right to lodge a complaint especially to the supervisory authority of their permanent place of residence or work if they find that the processing of personal data violates the EU’s General Data Protection Regulation 2016/679. Data subjects also have the right to employ administrative appeals and other legal remedies. You can make a notification to the data protection ombudsman here.
In order to exercise the aforementioned rights, you may contact the study psychologist, after which your request will be processed in accordance with the university’s procedures.
In the request, please provide your name, contact details (e.g. email address or phone number) and how you wish to exercise the aforementioned rights. If you are sending your request by email, use an encrypted email connection (encrypted email).
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.
12. Who can you contact?
Questions concerning the counselling relationship:
You may ask the study psychologist to tell you about any saved entries made concerning you in counselling sessions. You may order to receive any saved entries, summaries, statements, certificates and recommendations concerning you in writing by sending a request by post to the address: Opintopsykologien asiakirjatilauspyyntö / Opintopsykologit (=Order request for study psychologist documents / Study psychologists), P.O. Box 36, 00097 Uniarts. The request will be directed to the study psychologists who have provided counselling to the client in question. In principle, the study psychologist will present the entries requested in the aforementioned manner to the client who requested them only in person after the person’s identity has been verified.
Privacy notice:
If you have any questions regarding this privacy notice, please contact us by writing an email to tietosuoja@uniarts.fi.