Specific Privacy Statement - Digital Skills and Jobs Platform
This data protection notice concerns the Digital Skills and Jobs Platform (DSJP) including the personal data we may collect and process from registered users on the DSJP community tool.
The Digital Skills and Jobs Platform, including the DSJP community tool, is developed, maintained and administered by the DSJP contractor (the Data Processors) on behalf of HaDEA, the European Health and Digital Executive Agency (the Data Controller)
The European institutions 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 protection 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.
Why do we process your data?
We may collect and use your personal information to administer the Digital Skills and Jobs Platform, in particular the DSJP community tool.
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.
Based on the data we process, we are able to provide two different types of user experience 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. In addition, users may opt into a range of smart features which will provide a more personalised user experience. For this, you will have to give additional consent to a wider range of data processing activities.
The community tool is being developed progressively. Its current functionalities are 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.
Collecting and using your data enables us to establish your membership within the Digital Skills and Jobs community, to 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, and to have an overview of the various types of members of the communities.
Within this context, we may also collect and analyse data 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 in order to have aggregated data regarding the DSJP community tool use. 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.
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 such (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.
The processing operations on personal data for the organisation and management of the Digital Skills and Jobs Platform are lawful under Article 5(d) of Regulation 2018/1725, as the user provides consent before becoming a member or before personal data is published.
Which data do we collect and process?
We collect and process personal data necessary for the creation of your account on the Digital Skills and Jobs Platform website, which allows you to participate in the DSJP community and for the organisation and management of the various community tool functionalities.
Personal data collected when you visit the DSJP website:
- IP address (unless it is masked).
Mandatory fields to be filled in when you create a DSJP user account:
- First name and last name of the user.
- Email address of the user.
These data become part of your DSJP user account.
Optional fields you can fill in when creating a DSJP user profile include:
- Organisation name.
- Organisation’s and/or user Bio.URL (e.g. linkedin profile, company website).
- Job title.
- Profile picture (e.g. user’s photo, company logo).
- Student and job seeker status.
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 to be filled in when you create an organisation account:
- Contact person for Pledges.
- Contact email address for Pledges.
Mandatory or optional fields to be provided when you join discussion groups in the community:
Other personal data may be collected when you 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.
Registered users of the platform can in any case 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).
- 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, such as the 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 users opting in to the smart features providing a more personalised user experience, we will collect and process additional user behaviour data. A more exhaustive overview of how you interact with content and other users on the platform will help us to better understand what type of user you are and which needs you may have.
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.
- How long do we keep your data?
HaDEA and the Digital Skills and Jobs Platform contractors may keep your data for as long as follow-up actions to the DSJP are necessary, namely the operation of the Platform (in particular the Platform’s community tool) and its related management. Your personal data may 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 can be deleted from the Platform before the end of the five-year retention period upon your explicit request (see Contact Information in Section 8. below)
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, or of its contractors in line with its decision C(2006)3602 of 16 August 2006 concerning the security of information systems used by the European Commission. Any contractor is bound by a specific contractual clause for any processing operations of your data on behalf of HaDEA.
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, meaning relevant Commission and HaDEA staff, and the Digital Skills and Jobs Platform (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 your personal data can be provided to other external contractors working punctually on behalf of and under contractual agreement with DSJP contractors and engaged in the creation, maintenance, management, and archiving of websites according to the “need to know” principle. Such staff abide by statutory, and when required, additional confidentiality agreements.
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, would 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 platform visitors, including those who have not registered.
Comments you submit in response to public articles will be accessible to all platform visitors, including those who have not registered. You can configure the privacy settings of your account in your DSJP Dashboard.
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 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.
If you feel your privacy rights have been infringed in any way, please do not hesitate to notify the platform support team at https://digital-skills-jobs.europa.eu/en/contact.
If you have further comments or questions, any concerns or 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: firstname.lastname@example.org
The HaDEA DPO may also be contacted using: HADEA-DPO@ec.europa.eu
In case of conflict, complaints can be addressed to the European Data Protection Supervisor (EDPS) by using the following contact information: email@example.com.