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Privacy Policy

Data Privacy Notice - Digital Skills and Jobs Platform

Processing operation: Processing of personal data on the Digital Skills and Jobs Platform (https://digital-skills-jobs.europa.eu/en) including IP addresses from visitors of its publicly available portal and personal data from registered users of its closed community area.

Data Controller: European Health and Digital Executive Agency (“HaDEA”), Place Charles Rogier 16, 1210 Saint-Josse-ten-Noode, Belgium.

Data Processors: 

The consortium (“DSJP Contractors”) consisting of: 

  • EUN Partnership aisbl (“European Schoolnet”), Rue de Trèves, 61, 3rd floor, 1040 Brussels, Belgium. 
  • Tremend by Publicis Sapient, Splaiul Unirii, 165, 4th Floor, Building offices TN Office 2, District 3, Bucharest 030134, Romania. 
  • DIGITALEUROPE aisbl, Rue de la Science 14, 1040 Brussels, Belgium. 
  • LIKTA, Dzirnavu street 91-3, Riga, LV-1011, Latvia. 
  • European DIGITAL SME Alliance aisbl, Rue Marie Thérèse 21, bte. 5, 1000 Brussels, Belgium. 
  • Public Libraries 2030 aisbl, Rue Maximilien 16, 1050 Brussels, Belgium. 

 

Other: 

The European Commission:

  • The European Commission’s Directorate-General for Informatics (“DIGIT”) provides the IT hosting service for the platform.
  • The European Commission’s Directorate-General for Communications Networks, Content and Technology (CNECT), Unit G.2: Interactive Technologies, Digital for Culture and Education (“Unit G.2”) collaborates on the implementation of the project. 

 

  1. Introduction 

This data privacy notice concerns the Digital Skills and Jobs Platform (“DSJP”) 

including the personal data we may collect and process from its visitors and from the registered users of the DSJP community tool.  

The Digital Skills and Jobs Platform, including the DSJP community tool, is developed, maintained and administered by the DSJP Contractor (Data Processors) on behalf of HaDEA, the European Health and Digital Executive Agency (Data Controller). The DSJP project is implemented in collaboration with the European Commission. 

The European institutions and agencies are committed to protecting and respecting your privacy. As this service collects and further processes personal data, specific data protection rules apply. This specific DSJP data privacy notice explains the reason for any data collection and processing, the way we collect, handle and ensure protection of all personal data gathered, how that information is used and what rights you may exercise in relation to your data.  

  1. Short description of the processing

The Digital Skills and Jobs Platform is composed of a publicly available portal area and a closed community area accessible via registration only (DSJP community tool). 

The portal area will contain information and resources for a variety of stakeholders. The DSJP community tool is primarily used to manage, animate, and expand the Digital Skills and Jobs community, facilitating the exchange of knowledge, content, and good practices between different stakeholders and enabling networking and discussions. It also provides a private networking space for the Digital Skills and Jobs National Coalitions. 

The community tool is being continuously improved. Its current functionalities include the below:  

  • A member dashboard. 
  • A member directory / profile.  
  • An organisations directory / profile. 
  • A pledging organisations directory. 
  • Discussions and content sharing functionalities for events, blogs, news with additional features such as liking, commenting and tagging. 
  • An advanced search system. 
  • Collaborative groups. 
  • Email notifications. 
  • Direct messaging. 

 

Based on the data we process, we are able to provide different types of user experiences for DSJP users. To get basic access to the DSJP community tool, all users need to give consent to a minimum set of data processing activities (see section 5). 

In addition, registered users are given the option to opt-in or op-out of various sets of data processing activities to benefit (or not) from a range of smart features and more personalised user experiences including content recommendations. Registered users have the option to give additional consent and provide their behaviour data (e.g., actions through the platform) as per the below options: 

  • give consent only to the basic data processing activities.
  • give consent to receiving recommendations based on platform behaviour tracking.
  • give consent to receiving recommendations based on their answers to the content preferences questions.
  1. Why do we process your data? 

We collect and process your personal information in the platform to:

  • Administer the Digital Skills and Jobs Platform, in particular the DSJP community tool and to manage various community tool functionalities.
  • Better understand what type of user you are and which needs you may have so that we can recommend to you the most relevant content or services. 
  • Enable and improve the user experience within this and similar future projects developed by the European Commission. 
  • Establish your membership within the Digital Skills and Jobs community, create your DSJP account, which allows you to participate in the DSJP community. 
  • Contact you about a range of online and offline networking, capacity building and communication activities relating to the community and to ensure your participation therein. 
  • Provide aggregated statistics related to user activity on the platform, such as number of and geographical spread of registered users, number of each type of activity created (e.g. number of blog articles, number of partnership requests, number of comments etc.), number of users engaged and time spent by registered users for the purpose of evaluating usage patterns and user preferences/requirements. This will allow us to collect relevant information on performance vs KPIs and in general to the degree of appreciation of the community tool features. 
  • Evaluate and support the security and correct operation of the platform, and the lawfulness of its use. 
  1. Legal Basis of the Processing

The processing operations on personal data for the organisation and management of the Digital Skills and Jobs Platform are lawful under Article 5-1 (a) and (d) of Regulation 2018/1725:

  • (a) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Union institution or body.  
  • (d) the data subject has given consent to the processing of his or her personal data for one or more specific purposes. 

 

  1. Which data do we collect and process?  

Personal data collected when you visit the DSJP website:

  • IP address (only for logged in users). 

Mandatory fields to be filled by you when contacting the DSJP contractors for general enquiries via the contact form: 

  • Name.
  • Email address.

Mandatory fields to be filled by you when suggesting new platform content via the content suggestion form: 

  • Name.
  • Email address. 

Mandatory fields to be filled in when you create a DSJP user account:    

  • First name and last name of the user (via EU Login). 
  • Email address of the user (via EU Login). 
  • Country (users with editorial/community manager roles only). 

 

These data become part of your DSJP user account. To create an account, you need to submit personal data via the EU Login authentication service. Personal data entered in EU Login for authentication (first name, last name, and email address) are then automatically transferred to the Digital Skills and Jobs Platform. The EU Login service is subject to its own record (see DPR-EC-03187 Identity & Access Management Service - IAMS) and privacy statement. 

Optional fields that may be added by you in your DSJP user profile: 

  • Organisation name.  
  • Organisation’s and/or user Bio URL (e.g. linkedin profile, company website).
  • City. 
  • Job title. 
  • Profile picture (e.g. user’s photo, company logo). 
  • Student and job seeker status. 
  • Language preference. 
  • Geographical sphere.

Mandatory fields to be filled in when you create an organisation account:  

  • Organisation name. 
  • Organisation description. 
  • Contact person for the organisation.
  • Contact email address for the organisation. 

Optional fields that may be added by you in your organisation account:  

  • Contact person for pledges.
  • Contact email address for pledges. 

Additionally, you may spontaneously provide other, non-mandatory personal data in free text fields or as part of more general information requested. 

Other information may be collected when you choose to join a specific community group. For instance, you may be asked to provide information about your motivation to join and your professional background and experience which are relevant for a particular community.

Users of the platform can in any case voluntarily contribute with content, some of which may contain personal data:                                                          

  • Articles, blogs and news (i.e. author’s name is visible, data in the text itself).  
  • Comments. 
  • Pictures, text files. 
  • Links (e.g. to videos). 


As previously indicated, we may also collect and analyse data related to user activity on the platform, via tracking usage frequency, search behaviours, preferences and settings. For users opting in to the smart features providing more personalised user experiences, we will collect and process additional user behaviour data.  

The tracked user behaviour consists of user interactions and parameters linked to a limited number of content types (event, training offer, news, funding opportunity and good practice), then used to build a content profile for the user so relevant content can be recommended/suggested to the user. Such interactions and parameters are:

  • Like/unlike content and comments.
  • Indications about being interested in content.
  • Keywords used when searching content.
  • Page metadata of visited pages.
  • Page reading time.
  • Posting of comments.
  • Rating of content.
  • Subscribe to/unsubscribe from content. 

The user behaviour data collected can be linked to an individual registered user via the User profile (account). 

Europa Analytics is used as general web analytics service to evaluate the effectiveness and efficiency of the platform. The service uses cookies to function. When opening a page where Europa Analytics is enabled, the browsing experience is registered by the service. Simultaneously a dedicated banner may appear, asking the visitor to accept or refuse cookies. If cookies are refused, the Europa Analytics service will also stop registering the browsing experience. More information on Europa Analytics.

Please note that HaDEA, as Data Controller, does not request nor expect that participants to the Digital Skills and Jobs Platform include (i) special categories of data under Article 10(1) of Regulation 2018/1725 (that is “personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation”) or (ii) personal data related to criminal convictions and offences as provided for in Article 11 of Regulation 2018/1725, related to themselves or to third persons in their contributions to the Digital Skills and Jobs Platform. Any inclusion of these types of personal data is the responsibility of the participant. The moderator might decide to delete such personal data on the basis of a case-by-case assessment. 

  1. How long do we keep your data? 

HaDEA, the European Commission and the DSJP Contractors keep your data for as long as follow-up actions to the Digital Skills and Jobs Platform are necessary, namely as long as needed for the operation of the platform (in particular the platform’s community tool) and its related management.  

However, in case you are no longer interacting with the platform as a registered user, your personal data will be kept during 5 years after your last interaction with the platform. Then, your personal data will be deleted, unless you renew your interest in being a registered user of the platform. Your name as ‘author’ of content such as articles will be replaced by the wording “anonymous”. 

Your personal data will be deleted from the platform before the end of the 5-year retention period upon your explicit request (see contact information in Section 11. below).

  1. How do we protect your data? 

All data in electronic format (e-mails, documents, uploaded batches of data, etc.) are stored either on the servers of the European Commission, HaDEA (Data Controller) or their contractors (Data Processors) as specified in this notice. 

In order to protect your personal data, European institutions and agencies have put in place a number of technical and organisational measures. Technical measures include appropriate actions to address online security, risk of data loss, alteration of data or unauthorised access, taking into consideration the risk presented by the processing and the nature of the personal data being processed. Organisational measures include restricting access to the personal data solely to authorised persons with a legitimate need to know for the purposes of this processing operation.

Selected contractors are bound by a specific contractual clause to ensure that confidentiality obligations and data processing operations of your data are aligned with standards and rules imposed by the contracting authority in accordance with Regulation 2018/1725. 

  1. Who has access to your data and to whom is it disclosed? 

All personal data provided by you can be accessed by the websites’ administrators and staff involved in this processing operation, meaning relevant European Commission and HaDEA staff, and the DSJP Contractors on a “need to know” basis. The DSJP Contractors are EUN Partnership aisbl (“European Schoolnet”), DIGITALEUROPE aisbl, European DIGITAL SME Alliance aisbl, Public Libraries 2030 aisbl, all located in Belgium; Tremend Software Consulting srl based in Romania and LIKTA based in Latvia.   

 

Furthermore, access to a subset of your personal data can be provided to other external sub-contractors working punctually on behalf of and under contractual agreement with HaDEA, the European Commission or DSJP contractors and engaged in the creation, maintenance, management, and archiving of websites (e.g. SEO expert, accessibility expert) according to the “need to know” principle. Such staff abide by statutory, and when required, additional confidentiality agreements.

Apart from data collected and processed to administer the DSJP community tool, a wider range of editorial processes and mechanisms have been put in place on the platform to give visibility to the full range of relevant stakeholders or to give these stakeholders a more active role in the platform’s content management cycle.  

Content and text (e.g. articles) published through the DSJP community tool may appear on the public side of the platform. Content and text published on the platform may also appear on the National Coalition websites connected to this platform, as they may republish this content in their national official languages. Equally, content and text published on the National Coalition websites may be republished on the platform.  

As a registered user, information you provide may be accessible to other platform users in the following ways:  

  • DSJP user account data: mandatory information (i.e. first name, last name, email, country) will be visible within the DSJP community only to other registered users. 
  • DSJP user profiles data: optional information you may have filled in (e.g. bio, job title, profile picture, city, etc.), except your student or job seeker status, will be visible within the DSJP community to other registered users. 
  • Organisation account data: 
    • mandatory information (e.g. contact person for the organisation, etc.) will be published on the DSJP platform and available to all visitors. 
    • optional information you may have filled in (i.e. contact name and email for pledges) will be published on the DSJP platform and available to all visitors.
  • If you post content including blogs, articles or news items your first and last name as ‘author’ will be visible to the groups having access to the content. 
  • Content you contribute to:
    • within public community groups is accessible by other registered users.  
    • within private community groups is accessible by other registered users who have been given access to this private group by the platform administrators. 
    • within the open discussion space will be accessible by all visitors. 

Comments you submit in response to public articles will be accessible to all visitors. You can configure the privacy settings of your account in your DSJP Dashboard.  

International data transfers:        

Your information/personal data is not intended to be transferred to destinations outside of the EU/EEA, although subsets of it may be accessible to parties outside of the EU/EEA if published on the public areas of the platform (e.g. your first and last name as ‘author’ of platform content on the public area of the platform) or be visible by registered users located abroad (in line with community area visibility rules listed above). 

  1. What are your rights and how can you exercise them? 

As a registered user of the Digital Skills and Jobs Platform, you have a number of rights as articulated in Regulation 2018/1725, such as:  

  • Article 17 - Right of access by the data subject. 
  • Article 18 - Right to rectification. 
  • Article 19 - Right to erasure (right to be forgotten). 
  • Article 20 - Right to restriction of processing.  
  • Article 21 - Notification obligation regarding rectification or erasure of personal data or restriction of processing. 
  • Article 22 - Right to data portability. 
  • Article 23 - Right to object. 
  • Article 24 - Rights related to automated individual decision making, including profiling. 

You can modify your personal data in the DSJP user profile section of your DSJP Dashboard. You can also modify or delete your posted content. You may also ask the platform team to remove your profile and accompanying personal data by contacting them at https://digital-skills-jobs.europa.eu/en/contact. If you do as such, your created content on the platform will be anonymised. As a registered user, you can also opt out at any time of previously opted-in advanced user experiences and smart features requiring the provision of additional user data by unticking the relevant boxes in your DSJP user profile. 

More generally, you can withdraw consent for services at any time by notifying the Data Controller (and DSJP Contractors) using the contact details in Section 11. 

You can also exercise your rights by contacting the Data Protection Officer. If necessary, you can also address the European Data Protection Supervisor. Their contact information is given in Section 11 below.

  1. Other related privacy statements

Furthermore, other data processing activities (e.g. Digital Skills and Jobs Digest subscriptions) subject to specific privacy statements can be accessed via the Digital Skills and Jobs Platform. 

EU Login is used to manage access to the community area of the platform, please refer to the dedicated privacy statement and record: DPR-EC-03187 Identity & Access Management Service – IAMS.

  1. Contact information 

The Data Processors: 

If you have questions or concerns related to this privacy notice or the platform , please do not hesitate to notify the DSJP Contractors at https://digital-skills-jobs.europa.eu/en/contact. Your query will be transferred to the Data Controller if applicable. You can also contact the Data Controller directly. 

The Data Controller: 

If you have comments, questions or concerns, or would like to exercise your rights, or submit a complaint regarding the collection and use of your personal data, please feel free to contact the Data Controller, HaDEA using the following contact information: hadea-cef-ict@ec.europa.eu

The Data Protection Officer (DPO) of HaDEA:

The HaDEA DPO may also be contacted with regard to issues related to the processing of your personal data using: HADEA-DPO@ec.europa.eu  

The European Data Protection Supervisor (EDPS):

In case of conflict, official complaints can be addressed to the European Data Protection Supervisor (EDPS) by using the following contact information: edps@edps.europa.eu.