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 50 477 7983, 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.