INTERSKILLAR  privacy  policy

Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons regarding the processing of personal data and on the free movement of such data, otherwise known as the General Data Protection Regulation (hereinafter referred to as “GDPR”) lays down the legal framework applicable to the processing of personal data.

As part of its business activity, InterSkillar processes personal data by collecting information concerning its customers, candidates and prospects.

For the correct understanding of this privacy policy, it is specified that:

• Customers, also referred to as recruiters, can be described as any physical persons or legal entities who wish to recruit staff and/or assess the skills of their Candidates, but also for employment professionals, who can be described as any physical persons or legal entities whose business activity is in the field of recruitment, especially recruitment agencies, temporary employment agencies, companies in the temporary work sector, or consultancy firms for interim management or human resources, and for coaches and program managers, who can be described as any physical persons or legal entities who support young talents development and provide guidance, having subscribed to InterSkillar;
• Candidates can be described as any physical persons using the services of the InterSkillar website i) to get to know themselves better and receive a career manual, ii) as part of a coaching program, iii) with a view to being hired by a recruiter 
• Prospects can be described as any potential customer of InterSkillar whose contact details were received during events, from business cards, online promotion, etc;
• Users are understood to be any natural person using the InterSkillar service, i.e. Candidates, Customers and Prospects during a demonstration phase of the tool.

The purpose of this policy is to fulfil InterSkillar's obligation to provide information and thus formalise the rights and obligations of its customers, candidates and prospects with regard to the processing of their personal data.

This privacy policy applies to the processing of personal data of InterSkillar's customers, candidates and prospects.

This privacy policy relates to the processing operations for which InterSkillar is the controller in the meaning of the GDPR.

The processing of personal data may be handled directly by InterSkillar or through a processor that InterSkillar specifically designates.

This policy is independent of any other document that may apply within the contractual relationship between InterSkillar and its customers, candidates and prospects.

This policy is accepted when customers and candidates register, at the same time as they accept the general terms and conditions of use.

This data protection policy applies to prospects when they use InterSkillar services.

InterSkillar does not process any data concerning its customers, candidates or prospects that does not relate to personal data collected by or for its services, or processed in connection with its services, or if such processing does not meet the requirements of the general principles of the GDPR.

Any new processing, modification or deletion of any existing processing will be brought to the attention of customers and contacts through the modification of this policy.

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1- candidate data

1.1. TYPES OF DATA COLLECTED

a) Collected data necessary for the provision of the service:

• Identity and contact data (first name, last name, e-mail);
• Professional data (professional skills and experience);
• Identification data (IP address in particular);
• Connection data (logs, token in particular);
• Acceptance data (clicks);

b) Non-mandatory collected data:

• Contact data (phone number, localisation);
• Personal data (gender, age, sexual orientation, ethnicity, disability, marital and family status, level and type of education, postal code);
• Profile picture

InterSkillar offers psychometric tests designed to determine the cognitive abilities, motivations and personality traits of students and young people starting their career. The questionnaires offered by InterSkillar allow for the automated processing of personal data in order to evaluate certain personal aspects of Candidates, which corresponds to profiling within the meaning of the GDPR.

InterSkillar deals with sensitive data given explicit consent within the meaning of Article 9 of the GDPR.

1.2. SOURCE OF DATA

InterSkillar collects data from its candidates through:

• Registration to our online services by the candidates;
• Electronic forms filled out by candidates;
• Information collected through the customers.

1.3. DATA CONFIDENTIALITY

Candidates data is currently only accessible by candidates themselves if they have signed up to the platform independently. If candidates are joining the platform through an invitation sent by their coaches, their profile will be shared with their coaches.

1.4. PURPOSES

As appropriate, InterSkillar processes the data of its candidates for the following purposes:

• Managing the registration and candidate’s account, including managing its confidentiality; 
• Providing our services to candidates, including:

• Sending synthesis of the questionnaires to the candidates;
• Access to the profile and transmission of the results of the questionnaires to the

coach(es) as part of the candidate coaching;

• Targeted recommendations for the professional development of candidates;

• Managing the rights of the data subjects;
• Collecting diversity data on the Belgian workforce
• Support (by phone or online); 
• Fulfilling our administrative obligations;
• Sending complementary information or surveys related to the services; 

We only use anonymised data as defined by the DPA for the improvement of our services and for statistical purposes.

1.5. DURATION OF STORAGE

Candidates' data storage duration is defined by InterSkillar in view of its legal and contractual constraints and failing this, according to its needs, and in particular according to the following principles:

After the set storage periods, the data is either erased or preserved after being anonymized, especially for statistical purposes. It also may be preserved in cases of pre-litigation or litigation.

Candidates are reminded that erasure and anonymization are irreversible operations and that InterSkillar is no longer able to restore such data afterwards.

1.6. LEGAL BASIS

The data processing purposes listed have the following legal basis:

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2. CUSTOMER DATA (RECRUITERS; PROGRAM MANAGERS; COACHES) 

2.1. TYPES OF DATA COLLECTED 

a) Collected data necessary for the provision of the service:

• Identity and contact data (gender, first name, last name, e-mail, phone number);
• Professional data (company, job position);
• Connection data (logs, token in particular);
• Acceptance data (clicks)
• Identification data (IP address in particular); 

b) Non-mandatory collected data:

- Professional data (sector of activity); 

- Profile picture.

InterSkillar does not deal with sensitive data within the meaning of Article 9 of the GDPR.

2.2. SOURCE OF DATA

InterSkillar collects data from its customers through:

• Data provided by the customer (forms, order form, contract, business card);
• Data entered online (website, social networks, ...);
• Access by the customer to our online services;
• Registration for events organised by InterSkillar; Data may also be collected indirectly via InterSkillar's partners or suppliers.

2.3. PURPOSES

As appropriate, InterSkillar processes the data of its customers for the following purposes:

• Managing the customer relationship (including contract execution and account management);
• Providing our services;
• Support (by phone or online);
• Conducting surveys;
• Sending commercial and marketing information about the services and managing events organised by

InterSkillar;

• Fulfilling our administrative obligations.

We only use anonymised data as defined by the DPA for the improvement of our services and for statistical purposes.

2.4. DURATION OF STORAGE

Customers' data storage duration is defined by InterSkillar in view of its legal and contractual constraints and failing this, according to its needs, and in particular according to the following principles:

It is up to the Customer to define its own retention policy for Candidate data in accordance with the recommendations of the DPA.

After the set storage periods, the data is either erased or preserved after being anonymized, especially for statistical purposes. It also may be preserved in cases of pre-litigation or litigation.

Customers are reminded that erasure and anonymization are irreversible operations and that InterSkillar is no longer able to restore such data afterwards.

2.5. LEGAL BASIS

The data processing purposes listed have the following legal basis:

3.    Prospect Data

3.1. TYPESOFDATACOLLECTED

a) Collected data necessary for the provision of the service:

• Identity and contact data (gender, first name, last name, e-mail, phone number);
• Professional data (company, diploma, job position);
• Identification data (IP address in particular); 
• Connection data (logs, token in particular); 
• Acceptance data (clicks). 
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b) Non-mandatory collected data:

• Professional data (sector of activity);
• Profile picture.
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InterSkillar does not deal with sensitive data within the meaning of Article 9 of the GDPR.

3.2. SOURCE OF DATA

InterSkillar collects data from its prospects through:

• Data provided by the prospects (forms, order form, contract, business card);
• Registration or subscription to our online services (website, social networks, ...);
• Registration for events organised by InterSkillar;
• List provided by the organisers of events or conferences in which we participate.

Data may also be collected indirectly via InterSkillar's partners or suppliers.

3.3. PURPOSES

As appropriate, InterSkillar processes the data of its prospects for the following purposes:

• Managing the prospect relationship;
• Support (by phone or online);
• Conducting surveys;
• Accessing to InterSkillar services during a trial phase;
• Sending commercial and marketing information about the services and managing events organised by InterSkillar.

3.4. DURATION OF STORAGE

Prospects' data storage duration is defined by InterSkillar in view of its legal and contractual constraints and failing this, according to its needs, and in particular according to the following principles:

After the set storage periods, the data is either erased or preserved after being anonymized, especially for statistical purposes. It also may be preserved in cases of pre-litigation or litigation.

Prospects are reminded that erasure and anonymization are irreversible operations and that InterSkillar is no longer able to restore such data afterwards.

3.5. LEGAL BASIS

The data processing purposes listed have the following legal basis:

4. RECIPIENTS OF DATA

InterSkillar ensures that the data is accessible only to authorised internal or external recipients.

The recipients of customers', candidates' and prospects' personal data within InterSkillar are subject to a non-disclosure obligation.

Furthermore, personal data may be transferred to any authority legally entitled to have access to it. In this case, InterSkillar is not responsible for the conditions under which the personnel of these authorities have access to and use the data.

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4.1. CONCERNING CANDIDATES

4.2. CONCERNING CUSTOMERS

4.3. CONCERNING PROSPECTS

5. DATA SUBJECTS RIGHTS MANAGEMENT

5.1. RIGHT OF ACCESS

Customers, candidates and prospects usually have a right to ask InterSkillar for confirmation whether their data is being processed.

Customers, candidates and prospects also have a right of access, subject to compliance with the following rules:

• The request must come from the persons themselves and must be capable to justify their identity ;
• The request must be made in writing to the following address: Silversquare North, Bd Albert II 4, 1000 Bruxelles - Belgium or to the e-mail address privacy@interskillar.com.

If necessary, InterSkillar may request a copy of a proof of identity in case of reasonable doubt as to the identity of the person making the request.

Customers, candidates and prospects have the right to request a copy of personal data concerning them that is processed by InterSkillar. However, in the event of a request for additional copies, InterSkillar may require payment of any pertaining costs by the customers, candidates or prospects.

If a customer, candidate or prospect submits their request for a copy of the data electronically, the requested information will be provided in a commonly used electronic form, unless requested otherwise.

Customers, candidates and prospects are informed that this right of access does not concern confidential information or data of which the law does not authorise the transfer.

This right of access must not be exercised in an abusive manner, that is to say carried out irregularly for the sole purpose of disrupting InterSkillar.

5.2. MODIFICATION - UPDATES AND CORRECTIONS

InterSkillar will update personal data:

- Automatically, for online changes to fields that technically and legally can be updated; - Upon written request of the person themselves, who must prove their identity.

5.3. RIGHT TO ERASURE

Customers', candidates' and prospects' may ask for their right to the erasure of their personal data in the following cases only:

• The personal data is no longer necessary for the purposes for which it was collected or otherwise processed;
• The data subject withdraws the consent on which the processing is based and there is no other legal basis for the processing;
• The data subject objects to processing that is necessary for the legitimate interests pursued by InterSkillar and that there is no compelling legitimate reason for the processing;
• The data subject objects to the processing of their personal data for purposes of prospecting, including profiling;
• The personal data has been subject to unlawful processing.

In accordance with privacy legislation, customers, candidates and prospects are informed that this is an individual right which can only be exercised by the data subject with regard to their own information.

Customers, candidates and prospects can either exercise their right to erasure:

• Either directly on their InterSkillar personal account;
• Or in writing to the following address: Silversquare North, Bd Albert II 4, 1000 Bruxelles - Belgium or to the e-mail address privacy@interskillar.com.

If necessary, InterSkillar may ask for a copy of a proof of identity in the event of reasonable doubt as to the identity of the person making the request.

5.4. RIGHT TO RESTRICTION

InterSkillar shall be entitled to restrict processing in the specific case where the accuracy of the personal data is disputed by the client, candidate or prospect. This limitation will be effective for as long as InterSkillar is verifying the accuracy of the personal data.

5.5. RIGHT TO OBJECT

Data subjects may object to the processing when it concerns commercial prospecting.

5.6. RIGHT TO PORTABILITY

InterSkillar enables the portability of data in the specific case of data provided by the customers, candidates or prospects themselves, through the online services offered by InterSkillar and solely for purposes requiring the consent of the individuals or the execution of a contract.

Customers, candidates and prospects can either exercise their right to portability:

• Either directly on their InterSkillar personal account;
• Or in writing to the following address: Silversquare North, Bd Albert II 4, 1000 Bruxelles - Belgium or to the e-mail address privacy@interskillar.com.

In this case, the data will be transmitted in a structured, commonly used and machine-readable format.

5.7. POST-MORTEM DATA PRIVACY

Customers, candidates and prospects are informed that they have the right to provide guidelines regarding the storage, deletion and transmission of their personal data post mortem. Specific post-mortem directives can be sent and such rights can be exercised by e-mail at the address privacy@interskillar.com or by the postal service to the following address InterSkillar, Silversquare North, Bd Albert II 4, 1000 Bruxelles - Belgium accompanied by a copy of a signed identity document.

5.8. AUTOMATED INDIVIDUAL DECISION-MAKING

InterSkillar does not use automated individual decision-making processes as specified at the Article 22 of the GDPR.

As part of an algorithm in operation on its site, InterSkillar offers a decision support tool to best target the most relevant candidates.

However, any decision to hire is the sole responsibility of the Customer. The tools proposed on InterSkillar's website are only help tools for decisions intended for customers and may only be considered as such. There is no automatic sorting or exclusion of candidates.

6. ADDITIONAL ARRANGEMENTS

6.1. OPTIONAL OR COMPULSORY RESPONSES

Customers, candidates and prospects are informed, on each form that collects personal data, of the compulsory or optional nature of the responses by way of an asterisk.

In cases where responses are compulsory, InterSkillar explains to customers, candidates and prospects the consequences of not responding.

6.2. COOKIES AND TRACKERS

Cookies or trackers may be installed on the terminal of the InterSkillar website’s visitor.

All of the elements relating to the management of these cookies and trackers can be accessed at any time on the InterSkillar website by clicking on "Manage cookies" at the bottom of the page.

7. CONTACTS

7.1. DATA PROTECTION OFFICER

InterSkillar has designated a data protection officer.

The contact details are as follows:
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Name: Leïla MAIDANE

E-mail address: privacy@interskillar.com

Phone number : +32 486 21 78 73 

7.2. RIGHT TO LODGE A COMPLAINT WITH THE DPA

Customers and contacts concerned by the processing of their personal data are informed of their right to lodge a complaint with a supervisory authority, namely the DPA in Belgium, if they consider that the processing of their personal data does not comply with European data protection regulations, at the following address:
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DPA – Service des plaintes (complaints service)

35 Rue de la Presse, 1000 Bruxelles - Belgium

Phone number: +32 2 274 48 00

8. DATA LOCALISATION

The data stored by InterSkillar is hosted in Netherlands in a Datacenter operated by Azure that meets Tier III and ISO 27001 standards. A backup server is operated by Azure in Ireland.

9. POLICY UPDATES

This policy may be modified or adapted at any time in the event of legal developments, changes in jurisprudence, decisions or recommendations made by the DPA or common practices.

Any new version of this policy will be brought to the attention of customers and contacts by any means chosen by InterSkillar, including by electronic means (e.g. sent by email or posted online).

10. FOR MORE INFORMATION 

For further information, please contact our data protection officer at the following email address: privacy@interskillar.com.

For more general information on data privacy, please consult the website of the DPA https://www.dataprotectionauthority.be.

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