Privacy notice: Photograph, video and other audiovisual material register for communication
Privacy notice: Photograph, video and other audiovisual material register for communication: joint informative document for data subjects (Articles 13 and 14 of the General Data Protection Regulation [2016/679]).
Purposes of processing personal data
Photos, videos and other audiovisual material related to teaching, marketing and communications are used for marketing and internal and external communication purposes of Häme University of Applied Sciences Ltd and Häme Vocational Institute Ltd.
Material is retained in digital form at Häme University of Applied Sciences Ltd and shared in electronic channels for the use of the personnel and students. Material is shared to services provided by third parties, such as social media, or to collaboration partners which use the material for the marketing and communication purposes of Häme University of Applied Sciences Ltd or Häme Vocational Institute Ltd in their own channels.
The personal data file formed by the photo release forms is retained in paper form by the person in charge in a location with restricted access. Scanned copies of the photo release forms are retained in digital form in the material archive of the photoshoot with restricted access.
Legal basis for processing
The purposes and the legal basis for processing personal data:
- Consent – persons have given their consent to Häme University of Applied Sciences Ltd or Häme Vocational Institute Ltd for using and publishing photos, videos or other audiovisual material of them.
Personal data content and retention periods of the register
|Data category name
|Marketing photos, videos and other material
|Permissions of the persons in the materialName, signature, education as well as the situation, place and time of the photo
Persons who appear in Häme University of Applied Sciences Ltd’s or Häme Vocational Institute’s marketing photos, videos or other audiovisual material aimed at marketing or communication purposes and who have given their consent to the use of this material. The consent has been granted in a written form by signing a HAMK photo release form.
Regular sources of data
Subjects (individuals) of marketing photos, videos or other material who have given their written (or otherwise verifiable) consent to the use of this material.
Regular disclosures of data
Marketing photos, videos and other material may be disclosed to third parties for HAMK marketing and communication purposes in a channel or service provided by a third party. Photos, videos and other material can also be disclosed outside the EU or EEA.
However, photo release forms granted to HAMK are not disclosed to third parties or outside the EU or EEA.
Principles of data protection of the register
A Manual material
Persons who appear in HAMK’s or HAMI’s photos, videos and other material give their consent to the use of this material by signing a photo release form. These release forms will be stored in paper form and retained in a locked space located in the unit of the person in charge of the photoshoot.
B Data processed through automated data processing
The paper release forms of the persons who appear in photos, videos and other material are scanned and stored in digital form in the same location as the original photos, videos or other material are kept. The processing of digital photo release forms is restricted, and access is granted only to those persons who are entitled to access and use the data in the system in order to perform their duties.
Photo and video material is shared using secure electronic channels selected by Häme University of Applied Sciences Ltd for the use of its personnel and students.
No automated decision-making is performed on the recorded data.
Transfer of data outside the EU or EEA
Photos, videos and other material used for marketing purposes can be transferred outside the EU or EEA.
However, photo release forms granted to HAMK are not transferred outside the EU or EEA.
Rights of the data subject
The EU General Data Protection Regulation (2016/679) provides the data subject with the following rights:
The data subject shall have the right to withdraw his or her consent at any time. (Article 7)
The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed. The data subject shall have the right to access to the personal data concerning him or her. Where requests are manifestly unfounded or excessive, in particular because of their repetitive character, the data controller may charge a fee or refuse to act on the request. (Article 12 and Article 15)
The data subject shall have the right to obtain from the data controller the rectification of inaccurate personal data concerning him or her contained in the register (Article 16). A request for rectification shall be submitted in writing. Persons in an employment relationship (with HAMK or HAMI) are able to do rectification suggestions concerning their recorded working hours, which are then approved by their supervisor or salary administration personnel.
The data subject shall have the right to request the erasure of personal data concerning him or her where one of the following grounds applies (Article 17):
- the personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
- the data subject withdraws consent on which the processing is based and there is no other legal ground for the processing;
- the data subject objects to the processing, and there are no overriding legitimate grounds for the processing (Article 21);
- the personal data have been unlawfully processed;
- 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.
The data subject shall have the right to obtain restriction of processing where one of the following applies (Article 18):
- the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
- the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
- the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;
- the data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the controller override those of the data subject.
Where the processing is based on consent and carried out by automated means, the data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a data controller, in a machine-readable format. (Article 20)
Requests to exercise these rights are to be submitted:
Häme University of Applied Sciences Ltd
Data protection officer
P.O. Box 230 (Visamäentie 35A)
FI-13101 Hämeenlinna, Finland
The data subject shall have the right to lodge a complaint with the Office of the Data Protection Ombudsman.
Häme University of Applied Sciences Ltd and Häme Vocational Institute Ltd
P.O. Box 230 (Visamäentie 35A), FI-13101 Hämeenlinna
Telephone: +358 3 6461, e-mail address: email@example.com