SkillsTrust Privacy Policy

We at SkillsTrust take your privacy very seriously. This Privacy Policy applies to all visitors, users, and others who access the Skillstrust Platform or whose personal data is processed by SkillsTrust. 

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the EU General Data Protection Regulation 2016/679 (EU GDPR) in relation to products and services we offer to individuals and our wider operations in the European Economic Area (EEA). 

Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

1. Key Terms

   
   

It would be helpful to start by explaining some key terms used in this policy:

We, us, our, the Company
Refers to Skills Economy Insight Limited trading as SkillsTrust, a company incorporated in Ireland with registration number 704253 and headquartered at 77 Camden Street Lower, Dublin, D02 XE80, Ireland.

Personal data
Any information relating to an identified or identifiable individual, as defined under GDPR.

Special category personal data
This includes:

• Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, or trade union membership

• Genetic and biometric data (when processed to uniquely identify an individual)

• Data concerning health, sex life, or sexual orientation, as defined under GDPR

  
  

Data subject
The individual to whom the personal data relates, as defined under GDPR.

2. Personal Data We Collect About You

We may collect and use the following personal data about you:

1. your name and contact information, including email address and telephone number;

2. your gender, if you choose to give this to us;

3. location data, if you choose to give this to us;

4. Information about how you use our website, IT, communication and other systems;

5. your responses to surveys, competitions and promotions; and

6. Anonymised Pay Data: An anonymised compensation report for employees of our clients, including for each employee:

• Job title

• Employee ID Number

• Contract type

• Hours worked (if not full time)

• Gender

• Base compensation amount

• Bonus participation and structure

• Variable compensation amount

• Amount of benefits in kind received

We may collect and use this personal data to provide services to you. If you do not provide personal data we ask for, it may delay or prevent us from providing our services to you. In some cases, you may provide personal data to us about other people (such as employees). You must ensure that you have given those individuals appropriate notice that you are providing their information to us.

3. How Your Personal Data Is Collected

We collect most of this personal data directly from you or your employer either in person, by email, and via our Platform, website or related applications. 

However, we may also collect information from other sources such as: 

1. from publicly accessible sources such as recruitment websites and professional networking websites;

2. from cookies on our website—for more information on our use of cookies, please see our cookie policy at the footer of our website;

3. via our IT systems e.g. through automated monitoring of our websites and other technical systems, such as our computer networks and connections, communications systems, email and instant messaging systems;

4. How and Why We Use Your Personal Data

Under data protection law, we can only use your personal data if we have a proper reason, e.g.:

1. where you have given consent;

2. to comply with our legal and regulatory obligations;

3. for the performance of a contract with you or to take steps at your request before entering into a contract; or

4. for our legitimate interests or those of a third party.

A legitimate interest is when we or our clients have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.

The list below explains what we may use your personal data for and why.

• Providing products and services to you or your employer
  Reason: To perform our contract with you or your employer, or to take steps at your request before entering into a contract.
• Preventing and detecting fraud against you or us
  Reason: For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for you and/or us.
• Conducting checks to identify our customers and verify their identity, along with other activities necessary to comply with professional, legal, and regulatory obligations
  Reason: To comply with our legal and regulatory obligations.
• Gathering and providing information required by or relating to audits, enquiries, or investigations by regulatory bodies
  Reason: To comply with our legal and regulatory obligations.
• Ensuring business policies are adhered to (e.g. policies covering security and internet use)
  Reason: For our legitimate interests or those of a third party, i.e. to make sure we are following our internal procedures so we can deliver the best service to you.
• Operational reasons, such as improving efficiency, training, and quality control
  Reason: For our legitimate interests or those of a third party, i.e. to be as efficient as possible so we can deliver the best service to you at the best price.
• Statistical analysis to help us provide our services and manage our business (e.g. relating to financial performance, customer base, product range, or other efficiency measures)
  Reason: For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price.
• Preventing unauthorised access and modifications to systems
  Reason: For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for you and/or us.
  Also: To comply with our legal and regulatory obligations.
• Updating and enhancing customer records
  Reason: To perform our contract with you or your employer, or to take steps at your request before entering into a contract.
  Also: To comply with our legal and regulatory obligations.
  Additionally: For our legitimate interests or those of a third party, e.g. ensuring we can stay in touch with our customers about existing orders and new products.
• Marketing our services and those of selected third parties
  To:
  — Existing and former customers
  — Third parties who have previously expressed an interest in our services
  Reason: For our legitimate interests or those of a third party, i.e. to promote our business, and where appropriate, based on your consent.
• External audits and quality checks (e.g. for ISO or equivalent accreditation, and the audit of our accounts)
  Reason: For our legitimate interests or those of a third party, i.e. to maintain our accreditations and demonstrate we operate at the highest standards.
  Also: To comply with our legal and regulatory obligations.

Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws, for example:

1. we have your explicit consent;

2. the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or

3. the processing is necessary to establish, exercise or defend legal claims.

5. Marketing

We may use your personal data to send you updates (through our application or by email, text message, telephone or post) about our products and services, including exclusive offers, promotions or new products and services.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by contacting us or using the unsubscribe link in emails.

We may ask you to confirm or update your marketing preferences if you ask us to provide further products and services in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and never share it with other organisations outside of our group for marketing purposes.

6. Who We Share Your Personal Data With
   
   

We routinely share personal data with:

1. companies within our group;

2. our customers where they are using our services and we are analysing their jobs data and pay data;

3. third parties we use to help deliver our products and services to you, e.g. payment service providers and cloud service providers;

4. other third parties we use to help us run our business, e.g. marketing agencies or website hosts;

5. our professional advisors;

6. our banks;

7. contractors who deliver the services.

We only allow our service providers to handle your personal data to the extent necessary in connection with the above, and if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you. 

We may also need to:

1. share personal data with external auditors, e.g. in relation to ISO accreditation and the audit of our accounts;

2. disclose and exchange information with judicial and / or regulatory bodies to comply with our legal and regulatory obligations;

3. share some personal data with other parties, such as a potential buyer of some or all of our business or during a restructuring—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations.

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

7. Where Your Personal Data is Held

Personal data may be held at our offices and those of our group companies, third party agencies, service providers, our clients, and representatives as described above (see above: ‘Who we share your personal data with’).

Some of these third parties may be based outside the EEA. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the EEA’. 

8. How Long Your Personal Data Will Be Kept

We will keep your personal data while we are providing products and services to you or your employer. 

Thereafter, we will keep your personal data for as long as is necessary:

1. to respond to any questions, complaints or claims made by you or on your behalf;

2. to show that we treated you fairly;

3. to keep records required by law.

We will not keep your personal data for longer than necessary. Different retention periods apply for different types of personal data. When it is no longer necessary to keep your personal data, we will delete or anonymise it.

9. Transferring Your Personal Data out of the EEA and/or UK

To deliver services to you, it is sometimes necessary for us to share your personal data outside the EEA, e.g.:

1. with other companies within our group that are now or may be in the future located outside the EEA;

2. with your and our service providers located outside the EEA;

3. if you are based outside the EEA;

4. where there is an international dimension to the services we are providing to you.
   
   

Under data protection law, we can only transfer your personal data to a country or international organisation outside the EEA where:

1. the European Commission has decided the particular country or international organisation ensures an adequate level of protection of personal data (known as an ‘adequacy decision’); 

2. there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or

3. a specific exception applies under data protection law
   
   

These are explained below.

10. Your Rights

You have the following rights, which you can exercise free of charge:

• At any time, to your personal data being processed for direct marketing purposes (including profiling);
• In certain other situations, to our continued processing of your personal data — for example, where processing is carried out for the purposes of our legitimate interests.

For further information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below).

If you would like to exercise any of those rights, please:

1. email or write to us—see below: ‘How to contact us’; and

2. provide enough information to identify yourself (e.g. your full name, address and customer or matter reference number) and any additional identity information we may reasonably request from you;

3. let us know what right you want to exercise and the information to which your request relates.

11. Keeping your personal data secure

    
    

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. 

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

12. How to complain

Please contact us if you have any query or concern about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Data Protection Commissioner and they may be contacted at https://www.dataprotection.ie/en/individuals.

13. Changes to this privacy policy

This policy was published on December 11th 2024 and last updated on 7 April 2025. We may change this privacy notice from time to time—when we do we will inform you via our website.

14. How to contact us

You can contact us by email at support@skillstrust.org.