Privacy state­ment: Draft Program

PRIVACY STATEMENT  4th May 2018, updated on 28th Novem­ber 2023

Regu­la­tion (EU) 679/2016 on General Data Protec­tion as of 25th May 2018

Karelia Univer­sity of Applied Sciences / Draft Program®

(see desc­rip­tion at

1. Regis­ter Controller

Karelia Ammat­ti­kor­kea­koulu Oy / Karelia Univer­sity of Applied Sciences Ltd.

Address: Tikka­rinne 9, FI-80200 Joensuu

Tel. +358 13 260 600

Email: [email protected]

2. Person in Charge of the Register

CEO / Presi­dent of Karelia UAS

3. Person in Charge of the Draft Program®

Research and Deve­lop­ment Direc­tor Anne Ilvonen, tel. +358 50 311 6314, email: [email protected], Tikka­rinne 9, FI-80200 Joensuu

4. Contact Person of the Draft Program®

Princi­pal Lectu­rer of Entrepre­neurs­hip Heikki Immonen, tel. +358 50 310 9657, email: [email protected], Karja­lan­katu 3, FI-80200 Joensuu

5. Person in Charge of Data Protection

Karelia Ammat­ti­kor­kea­koulu Oy, Tieto­suo­ja­vas­taava, Tikka­rinne 9, FI-80200 Joensuu

Tel. +358 50 525 0623, email: [email protected]

6. Purpose of proces­sing perso­nal data

Accor­ding to the Univer­si­ties of Applied Sciences Act, the mission of univer­si­ties of applied sciences is to provide higher educa­tion for profes­sio­nal expert jobs based on the requi­re­ments of working life and its deve­lop­ment and on the premi­ses of acade­mic research and acade­mic and artis­tic educa­tion and to support the profes­sio­nal growth of students. They shall also carry out applied research, deve­lop­ment and inno­va­tion acti­vi­ties and artis­tic acti­vi­ties that serve educa­tion in univer­si­ties of applied sciences, promote industry, busi­ness and regio­nal deve­lop­ment and rege­ne­rate the industrial struc­ture of the region. In carrying out their mission, univer­si­ties of applied sciences shall promote life­long lear­ning. These are statu­tory tasks.

The Draft Program® ( is a program at Karelia Univer­sity of Applied Sciences that promo­tes the emer­gence of entrepre­neurs­hip in higher educa­tion insti­tu­tions. The program provi­des support for teams selec­ted for the program by provi­ding infor­ma­tion, orga­ni­sing trai­ning works­hops, and provi­ding funding for purc­ha­ses needed when commercia­li­sing the partici­pants’ busi­ness ideas and expe­ri­men­ting them. Perso­nal data is collec­ted within the Draft Program® for conduc­ting the applica­tion process and for infor­ming the selec­ted teams about new applica­tions and trai­ning works­hops. In order to monitor the deve­lop­ment budget alloca­ted to the teams partici­pa­ting the program, purc­ha­ses made within the program are stored toget­her with the name of the contact person of the team. In addi­tion, anony­mi­sed perso­nal infor­ma­tion is gathe­red in acti­vity reports that are submit­ted to program part­ners as well as in the deve­lop­ment of program acti­vi­ties. The anony­mi­sed data collec­ted within the program can be used, for example, in research acti­vi­ties in the field of entrepre­neurs­hip and inno­va­tion, but a sepa­rate research permit from Karelia UAS will be reques­ted for this purpose.

7. Content of the Register

Data on the following groups of people has been collec­ted for the Draft Program®: team leaders who can be students, alumni or repre­sen­ta­ti­ves of the staff of Karelia UAS or partner insti­tu­tions of the Draft Program®, and other team members. The cate­go­ries of perso­nal data proces­sed in the system are as follows: name, email, telep­hone number, emplo­yer, field of study, and the person’s role or duty. Furt­her­more, infor­ma­tion on the team’s busi­ness idea, applica­tion points recei­ved during the applica­tion process as well as the judges’ comments, and purc­ha­sed made during the team’s deve­lop­ment project.

8. Legal basis for proces­sing perso­nal data

The Draft Program® is a volun­tary program. When applying for the program, the applicant accepts the proces­sing of his/her perso­nal data by giving his/her consent to the proces­sing of data.

9. Grounds for provi­ding perso­nal data

The infor­ma­tion requi­red for the applicants of the Draft Program® is needed for imple­men­ting the program applica­tion and program services (purc­ha­ses, trai­ning workshops).

10. Legi­ti­mate advan­ta­ges of the regis­ter controller

Imple­men­ta­tion and deve­lop­ment of the Draft Program®.

11. Secu­rity of proces­sing perso­nal data

Infor­ma­tion on the applicants who have applied for the program and have been selec­ted to the program is stored in elect­ro­nic form in a sepa­rate DRAFT folder on the server of Karelia UAS. Only those Karelia UAS emplo­yees have access to the folder that need this infor­ma­tion for imple­men­ting program acti­vi­ties. The desc­rip­tions of busi­ness ideas in paper format, inclu­ding perso­nal infor­ma­tion of the applicants, as well as judges’ comment forms are stored in a locked closet in the office of the Princi­pal Lectu­rer of Entrepre­neurs­hip. Exter­nal judges, who have signed a confi­den­tia­lity agree­ment, will have access to the infor­ma­tion about the applicants on the applica­tion day (i.e. judge’s comment form). The forms will be collec­ted from the judges at the end of the applica­tion day.

12. Reci­pients or reci­pient groups of perso­nal data

As part of the applica­tion process, applicants’ infor­ma­tion is displayed on a sepa­rate screen in a closed confe­rence room for the repre­sen­ta­ti­ves of Draft Program® part­ners. The part­ners are the Univer­sity of Eastern Finland and Riveria. The purpose of displaying the infor­ma­tion is to pre-select the applicants and to form the final scores.

13. Trans­fer of perso­nal data outside the Euro­pean Union or the Euro­pean Econo­mic Area

Perso­nal data will not be trans­fer­red outside the EU or EEA.

14. Reten­tion of perso­nal data

For indi­vi­duals whose team is selec­ted for the Draft program, their infor­ma­tion will be retai­ned for 6 years following the end of the last fiscal year during which their team recei­ved compen­sa­tion from the Draft program, in accor­dance with the Accoun­ting Act. Perso­nal data of indi­vi­duals who are not selec­ted for the Draft program will be deleted at the end of the selec­tion process.

15. Rights of the regis­te­red person

The rights of the regis­te­red person are deter­mi­ned accor­ding to the purpose of proces­sing perso­nal data. The regis­te­red person has the right to inspect the data concer­ning him/herself stored in the regis­ter. The request for the inspec­tion has to be made to the cont­rol­ler of the regis­ter. The regis­te­red person has the right to request correc­tion or removal of data, set limi­ta­tions for the hand­ling of his/her perso­nal data, object the hand­ling of the data, and s/he has the right to trans­fer data from one system to another. The regis­te­red person has the right to with­draw his/her consent to the hand­ling of his/her perso­nal data at any time. In addi­tion, the regis­te­red person has the right to file a complaint with the super­vi­sory autho­rity. The contact person concer­ning the rights of the regis­te­red person is the person in charge of data protec­tion, whose contact details are in section 5 of this statement.

16. Auto­ma­tic deci­sion-making and profiling

Not in use.