Privacy Notice

ICDL PRIVACY NOTICE

INTRODUCTION

ICDL Foundation, incorporated and registered in Ireland with company number 259212 (“ICDL”, "we", “our” or “us”) is responsible for the ICDL learning and certification programmes (our “ICDL Programmes”), contact details in section 12 below. ICDL is the digital skills standard and you can find out more about the ICDL Programmes at www.icdl.org.

ICDL operates the ICDL Programmes directly in Ireland and regionally from wholly owned subsidiaries; ICDL Africa (based in Rwanda), ICDL Asia (based in Singapore) and ICDL Europe (based in Brussels), details of which are in section 12 below.

ICDL also works with a number of national operators in various regions, all driving towards our social mission to raise digital competence standards in the workforce, education and society. ICDL Programmes are delivered via a network of over 20,000 test centres (“ATC”) worldwide.

Each subsidiary, national operator and/or ATC, in the course of performing their obligations to ICDL, is an independent Data Controller under applicable data protection legislation. A “Data Controller” determines the purposes for which, and the means by which, Personal Data (as defined below) is processed.

ICDL Foundation is the Data Controller of Personal Data in Ireland and is a Data Processor of Personal Data on behalf of each subsidiary, national operator and/or ATC, for personnel administering and Candidates undertaking the ICDL Programmes outside Ireland. See section 12 below for further information about the Data Controller relevant to your region.

ICDL Connect is an online platform used by ICDL to deliver ICDL learning support, documentation and supporting materials or guidance, as tailored specifically for each type of user. This Privacy Notice applies to all users of ICDL Connect (“our platform”) save for Section 2 which is a supplement and applicable for users in Ireland only. When this Notice refers to “you” or “your” we mean you as a registered user of ICDL Connect as identified in your online profile for this platform.

In this Notice, “Personal Data” means information relating to a living individual who is or can be identified either from that data or from that data in conjunction with other information that is in, or is likely to come into, our possession, and includes Personal Data as described in Data Protection Laws (as defined below). Any Personal Data that is collected about you for the purpose of operating, administering or delivering an ICDL service referred to as “Your Personal Data” in this Notice.

We are committed to respecting your privacy and protecting Your Personal Data. The collection, storage, sharing and use of Your Personal Data is governed by laws, such as the General Data Protection Regulation (EU) 2016/679 (the “GDPR”) and any other applicable law or regulation relating to the processing of Personal Data and the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011, all of which combined are referred to as the “Data Protection Laws” in this Notice.

INFORMATION WE GATHER ABOUT USERS IN IRELAND

Your access and use of this platform is administered by ICDL Foundation who is also the Data Controller of Personal Data for users, including Candidates, registered with ICDL Ireland.

Reference to the “Data Protection Laws” in this Notice also includes the Irish Data Protection Acts 1988 to 2018.

Your Personal Data is collected via your online account or directly from you via your use of and interaction on our Platform and also when you contact us in person, by telephone, text or email. Check our Cookie Policy for further information.

In order to set up your online account, information (per section 3 below) is collected and input to the platform by your test centre and, where required, with consent to upload Your Personal Data obtained from your parent or guardian (see section 4 below if you are aged under 16).

We do not collect special categories of personal data (these include information about your health, genetic and biometric data, your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, or trade union membership). We also do not collect any information about criminal convictions and offences. We do however process information necessary to provide ‘reasonable accommodation’ to any Candidate, if requested, in accordance with any relevant legislation (such as the Irish Equality Acts).

INFORMATION PROCESSED ABOUT ICDL CANDIDATES

In order to set up your account for our platform, information is collected and input to the platform by your test centre and, where required, with consent to upload Your Personal Data obtained from your parent or guardian (see section 4 below if you are aged under 16).

In accordance with Data Protection Laws, we process Your Personal Data as follows:

Basic Information: such as your first and last name (including prefix or title);
Contact Information: such as your email address and any other contact information you choose to provide to us e.g. a phone number or postal address;
Candidate Profile Information: includes your Candidate Registration Number, username and password, purchases or orders made by you or on your behalf, course progress, interactions, preferences you choose and your feedback;
Technical Information: such as information from your visits to our platform (including internet protocol (IP) address and login data, browser or client application information, time zone setting and location, language preference, operating system and application version, device type and ID, and device model and manufacturer, and other technology on the devices you use to access our platform) or in relation to materials and communications we send to you electronically; and
Any Other Information: relating to you which you may provide to us

Your Personal Data is collected via your online account or directly from you via your use of and interaction on our platform and also when you contact us in person, by telephone, text or email. Check our Cookie Policy for further information.

We do not process special categories of personal data (these include information about your health, genetic and biometric data, your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, or trade union membership). We also do not process any information about criminal convictions and offences. We may however process information necessary to provide ‘reasonable accommodation’ to any Candidate, if requested, in accordance with any relevant equality legislation in your region.

We may share Your Personal Data regarding your learning activities, where necessary, with relevant third parties, regulatory authorities, training and/or test centres. For more information on who we share Your Personal Data with, please see section 9 below.

For more information on how long we retain Your Personal Data, please see section 10 below.

CANDIDATES AGED UNDER 16 YEARS

Where you are under the age of 16 years, your test centre must obtain consent from your parent or guardian to provide your Personal Data to us and to set up your account with us on our platform in order for you to use and benefit from the platform and its learning environment.

Please speak to your parent, guardian or another trusted adult if you do not understand anything in this Notice or if you have questions.

You may continue lifelong learning with the ICDL Programmes and maintain your Candidate profile and online account into adulthood.

INFORMATION WE PROCESS ON USERS OF OUR PLATFORM WHO ARE EMPLOYED OR CONTRACTED BY A THIRD PARTY

If you have the right to access our platform based on employment or contractual obligations (for example: an ICDL test centre, a national operator or another third party) you should note that ICDL processes information necessary for the organisational functioning of ICDL.

This includes, but is not limited to, data related to your knowledge of ICDL, this platform, any training and development and security.

In order to provide access to the platform, and in accordance with Data Protection Laws, we process Your Personal Data from or about you as listed here:

Basic Information: such as your first and last name (including prefix or title);
Contact Information: such as your email address and any other contact information you choose to provide to us e.g. a phone number or postal address;
Candidate Profile Information: includes your Candidate Registration Number, username and password, purchases or orders made by you or on your behalf, course progress, interactions, preferences you choose and your feedback;
Technical Information: such as information from your visits to our platform (including internet protocol (IP) address and login data, browser or client application information, time zone setting and location, language preference, operating system and application version, device type and ID, and device model and manufacturer, and other technology on the devices you use to access our platform) or in relation to materials and communications we send to you electronically; and
Any Other Information: relating to you which you may provide to us

Your Personal Data is input for access to your online account or directly from you via your use of and interaction on the platform and also when you contact us in person, by telephone, text or email. This includes, but is not limited to, data related to your knowledge of ICDL Programmes, any training and development and security. Check our Cookie Policy for further information.

In order to set up your account on our platform, information is input to the platform as requested by your organisation.

We do not process any other categories of personal data.

THE LEGAL BASIS FOR USING YOUR PERSONAL DATA

We will use Your Personal Data, and share that data, for any one or more of the following legal bases (reasons):

if we have a good reason to use Your Personal Data, and this is not overridden by your own rights and interests (this is also known as our “legitimate interests”), this could include activities related to learning, training, monitoring as well as everyday business operations, administrative tasks, such as troubleshooting, data analysis, and data security. In this case, we will carefully consider and balance any potential impact (either positive or negative) on your rights before we process Your Personal Data for our legitimate interests. We do not use Your Personal Data for activities where our interests are overridden by the impact on you;
where we have an agreement with you or on your behalf to do so, to provide you with access to our platform and to deliver ICDL related material and options, to manage our relationship with you while we do so;
in limited circumstances, where you have given your express consent or your parent or guardian has done so where you are under the age of 16; and/or
to comply with a legal obligation to which we are subject.

We may process Your Personal Data for more than one of the legal bases above, depending on the specific purpose for which we are using Your Personal Data.

HOW WE USE YOUR PERSONAL DATA

We will only use Your Personal Data for the purposes for which we collect it, unless we believe that we need to use Your Personal Data for another reason that is compatible with the original purpose. If we intend to process Your Personal Data for an unrelated purpose, prior to that processing we will notify you and explain the legal basis that we propose to rely on to do so.

The detail below describes all the ways we use Your Personal Data, and which of the legal bases (described in section 6) we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

Purposes of information we collect and the legal basis for processing and, where necessary, the basis of legitimate interests

To respond to an enquiry from you, provide customer support or to otherwise manage our relationship with you, we may use your: Basic Information; Contact or Profile Information; and any other Information you provide. This is necessary for our legitimate interests to manage and/or maintain our relationship with you, and provide you with provide you with important updates regarding the ICDL Programme(s). It is also necessary to take steps at your request to provide services to you.
To provide you with ICDL activities related to guidelines, supporting material, learning and, training as well as everyday business operations, administrative tasks, such as troubleshooting, data analysis, and data security. We may use your: Basic Information; Contact Information; Profile Information and/or Technical Information. This is necessary for our legitimate interests in administering, maintaining and delivering the ICDL Programmes and to take steps at your request to provide the correct support for you for ICDL Programmes and/or to perform a contract with you.
To register you as a Candidate for eLearning and create a Candidate Account for you. We may use your: Basic Information; Contact Information and Profile Information. This is necessary for our legitimate interests of ensuring the effective operation and management of the ICDL Programmes and managing your education preferences and needs for an ICDL Programme.
To meet a specific legal, regulatory or compliance obligation, including in relation to recording and monitoring communications, so as to investigate security incidents and prevent crime. This could include: Basic Information; Contact Information; Profile Information, Technical Information and any other Information required. This will only be necessary to comply with a legal obligation and/or for a security or criminal investigation.
To provide you with information about other ICDL Programme(s) that may be of interest to you (if you either have requested such information from us or used our platform and you have not opted out of receiving such communication). We use Basic Information and Contact Information which is necessary for our legitimate interests (to develop ICDL Programmes and grow our business). Consent or consent of your parent or guardian will be sought where you are aged under 16 years

Please contact us if you would like further information on how we process Your Personal Data where more than one ground has been set out above. See ‘How to Contact Us’ below.

WHO WE SHARE YOUR PERSONAL DATA WITH

We will not disclose your Personal Data to third parties unless required by law to do so, or as otherwise set out in this Notice.

We may share Candidate Personal Data regarding learning activities, where necessary, with relevant third parties, regulatory authorities, training and test centres.

We may share Your Personal Data with another company within our corporate group, to undertake consolidated group corporate services, reporting services and functions, or to provide us with administration and ancillary services. All companies within the ICDL corporate group are subject to the same standards and obligations with regard to Your Personal Data.

We may also share information with our third party service providers who provide services to us. Categories of service providers include learning content providers, customer support service providers, data analytics providers, data hosting providers, records-storage companies and other IT professional service providers.

INTERNATIONAL DATA TRANSFERS

Your Personal Data may be transferred to, stored at, or accessed from a destination outside the European Economic Area (“EEA”) for the purpose of us providing platform access and services to you, depending on your location. Countries outside the EEA have different laws for protection of Personal Data. Data Protection Laws require us to ensure that any transfers of Your Personal Data are made according to additional protections set out in Chapter V of the GDPR and we comply with these requirements where we do such transfers.

If Your Personal Data is transferred to, stored at, or accessed from a third country, we will ensure a suitable level of protection is afforded to it by ensuring at least one of the following safeguards under Chapter V of the GDPR is implemented:

We will only transfer your Personal Data to countries outside the EEA that the European Commission has deemed to provide an adequate level of protection for Personal Data (known as an “adequacy decision”); or
In the case of countries outside the EEA that do not have an adequacy decision, we have or will put in place appropriate contracts with third parties incorporating standard contractual clauses approved by the European Commission and carry out a risk assessment on the transfer and adopt any supplementary security measures to ensure compliance with Data Protection Laws.

In relation to any communications by email (including our newsletter), Your Personal Data (the minimum amount required for this particular communication is an email address) is processed by our electronic communications service provider, located outside the EU. We have signed a Data Protection Addendum with this service provider to incoporate the standard contractual clauses approved by the European Commission. You can opt-out of receiving our newsletters at any stage (Please see ‘Your Legal Rights regarding Your Personal Data’ below for further information).

Please contact us if you require further information on the specific safeguard used by us when transferring Your Personal Data.

HOW LONG WE HOLD (RETAIN) YOUR PERSONAL DATA

We will only retain Your Personal Data for as long as reasonably necessary to fulfil the purposes it was collected for, and satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain Your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of further communications or interaction with you.

If you are a Candidate, we will retain Your Personal Data for the purposes of maintaining your ICDL profile for future learning.

To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of Your Personal Data, the purposes for which we process Your Personal Data, whether we can achieve those purposes through other means, and the applicable legal, regulatory or other retention requirements.

You have the right to request deletion of your Personal Data. Please see ‘Your Legal Rights regarding Your Personal Data’ below for further information.

Your Legal Rights regarding Your Personal Data

You have the following rights under Data Protection Laws and we, as controller of Your Personal Data in the activities set out in this Notice, will comply with those rights which are explained in more detail in the table below.

For security reasons, we may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is to ensure that Your Personal Data is not disclosed to any person who does not have a right to receive it.

Right to be provided with a copy of Your Personal Data

You have the right to request a copy of Your Personal Data. Requests for Your Personal Data must be made to us (see ‘How to Contact Us’ below) specifying what Personal Data you need access to, and a copy of such request may be kept by us for our legitimate purposes and a copy of such request may be kept by us for our legitimate purposes in managing the platform and where relevant, your account details. To help us find Your Personal Data easily, please give us as much information as possible about the type of information you would like to see.
If, to comply with your request, we would have to disclose Personal Data relating to or identifying another individual, we may need to withhold that Personal Data or edit the information to remove the identity of that individual.

Right to require us to correct any errors in Your Personal Data (also known as the 'right to rectification')

You have the right to request that we amend any inaccurate or incomplete Personal Data that we have about you. If you would like to do this, please (i) email or write to us (see ‘How to Contact Us’ below); (ii) let us have enough information to identify you (e.g. name, email address); and (iii) let us know the information that is incorrect and what it should be replaced with.
If we are required to update Your Personal Data, we will inform recipients to whom that Personal Data has been disclosed (if any), unless this proves impossible or has a disproportionate effort.
It is your responsibility (or that of your parent/guardian where you are under 16) that all of the Personal Data provided to us is accurate and complete. If any information you have given us changes, please update these details in your online account or let us know as soon as possible (see ‘How to Contact Us’ below).

Right to object to our use of Your Personal Data:

You have the right to ask us to stop using Your Personal Data where we do so for our legitimate interests (see ‘How We Use Your Personal Data’ above), and we will comply unless there is a compelling legitimate ground for us to continue using it, which we will explain to you.
You also have the right to ask us to stop contacting you for direct marketing purposes. If you would like to do this, please (i) click on ‘unsubscribe’ on an email; or (ii) send an email via ‘How to Contact Us’ below.
We will provide you with information on action taken on a request to stop direct marketing, this may be in the form of a response email confirming that you have ‘opted out / unsubscribed’. Unsubscribing from direct marketing does not unsubscribe you from essential electronic communications in respect of the administration of your online account and use of the platform.

>Right to require us to delete your information in certain situations (also known as a ‘right of erasure’ or ‘right to be forgotten’)

You can ask us to erase Your Personal Data where or if: (i) we do not need Your Personal Data in order to process it for the purposes set out in this Notice; (ii) you had previously given us consent to process Your Personal Data, and you now withdraw that consent and we cannot otherwise legally process Your Personal Data; (iii) you object to our processing and we do not have any legal basis for continuing to process Your Personal Data; (iv) Your Personal Data has been processed unlawfully or has not been erased when it should have been; or (v) the Personal Data must be erased to comply with a legal requirement.
We may continue to process Your Personal Data in certain circumstances in accordance with Data Protection Laws.
Where you have requested the erasure of Your Personal Data, we will inform recipients to whom that Personal Data has been disclosed, unless this proves impossible or involves disproportionate effort. We will also inform you about those recipients if you request it.

Right to restrict use of Your Personal Data (also known as ‘right of restriction’)

You may request that we stop processing Your Personal Data temporarily if: (i) you do not think that Your Personal Data is accurate (but we may start processing again once we have checked and confirmed that it is accurate); (ii) the processing is unlawful but you do not want us to erase Your Personal Data; (iii) we no longer need the Personal Data for our processing; or (iv) you have objected to processing because you believe that your interests should override the basis upon which we process Your Personal Data.
If you exercise your right to restrict us from processing Your Personal Data, we will continue to process the Personal Data if: (i) you consent to such processing; (ii) the processing is necessary for the exercise or defence of legal claims; (iii) the processing is necessary for the protection of the rights of other individuals or legal persons; or (iv) the processing is necessary for public interest reasons.

Right to data portability

You may ask for an electronic copy of Your Personal Data that you have provided to us and which we hold electronically, or for us to provide this directly to another party (such as a provider or operator of ICDL Programmes or modules outside the ICDL group of companies). This right only applies to Personal Data that you have provided to us – it does not extend to data generated by us. In addition, the right to data portability also only applies where: (i) the processing is based on your consent or for the performance of a contract; and (ii) the processing is carried out by automated means.

Right to withdraw your consent

Where processing is based on your consent, you have the right to withdraw your consent at any time with future effect by contacting us. However, if you do withdraw your consent we may not be able to continue to deliver updates, communications or verify your profile.

Rights in relation to automated decision making

You have the right not to be subject to a decision made solely by automated means without human involvement that has legal or significant effects on you. This right does not apply where the decision is (i) authorised or required by law (e.g. to prevent fraud or tax), (ii) necessary for the performance of a contract between you and us, or (iii) based on your explicit consent.
We do not make any such automated decisions based on Your Personal Data.

Right to complain to the Data Protection Commission

If you do not think that we have processed Your Personal Data in accordance with this Notice, please contact us in the first instance (see ‘How to Contact Us’ below).
If you are not satisfied, and you are based in Ireland and/or Europe you can lodge a complaint to the Data Protection Commission or exercise any of your other rights pursuant to Data Protection Laws. Information about how to do this is available on the Data Protection Commission website at https://www.dataprotection.ie.
If you are not satisfied and are based outside Europe, you should lodge a complaint with the relevant Supervisory Authority which is responsible for the supervision of privacy issues and/or the processing of Your Personal Data in your jurisdiction. Such Supervisory Authority may be any court, regulatory agency or authority which has been appointed by applicable laws and/or regulations (including Data Protection Legislation).

We will respond to any rights that you exercise without undue delay and in any event within one month of receiving your request, unless the request is particularly complex, in which case we will respond within three months (we will inform you within the first month if it will take longer than one month for us to respond).

If you have any comments, concerns or complaints about our use of Your Personal Data, please contact us (see ‘How to Contact Us’ below).

You will not generally have to pay a fee to exercise any of your rights below, however, we may charge a reasonable fee where deemed necessary and we may refuse your request where:

such request is manifestly unfounded or excessive, especially if it is repetitive in nature (in this case, if we decide to provide you with the Personal Data requested, we may charge you a reasonable fee to account for administrative costs of doing so); or
we are entitled to do so pursuant to Data Protection Laws.

How to Contact Us

If you have any questions about this Notice or our data protection practices please contact us at:

ICDL Ireland
Level 1, The Chase
Arkle Road
Dublin 18
Ireland
info@icdl.ie
https://icdl.org/country/ireland
Telephone: +353 1 2377797

ICDL Africa Limited
Career Center Building
KG 541 ST
9th Floor, PO Box 3974
Kigali
Rwanda
https://icdl.org/icdl-africa/
Telephone: +250 788 380102

ICDL Asia PTE Ltd
50 Raffles Place
Level 19 Singapore Land Tower
Singapore 04862
https://icdl.org/icdl-asia/
Telephone: +65 66312809

ICDL Europe SRL
Rue des Colonies 11
1000 Brussels
Belgium
https://icdl.org/icdl-europe/

ICDL Foundation (for National Operators)
Level 1, The Chase
Arkle Road
Dublin 18
Ireland
info@icdl.org
www.icdl.org
Telephone: +353 1 6306000

To find out more about ICDL in your region and/or to know whom your national operator (Data Controller) is, you may visit https://icdl.org/icdl/

UPDATES TO PRIVACY NOTICE

We may change or update our Notice from time to time and at our sole discretion which will be prominently advised to you on the platform. The date of the most recent revisions will appear on the top of this Notice. If you do not agree to such changes, please do not continue to use the platform. If you continue to use the platform you are deemed to understand and accept a revised Notice.

COOKIES

You should be aware that each time you visit a website, general information about your visit is retained. Statistical and other analytical information is collected on an aggregate and non-individual specific basis of all browsers who visit the site. This statistical and analytical information provides us with general and not individually specific information about the number of people who visit this website; the number of people who return to this site; the pages that they visit; where they were before they came to this site and the page and site at which they exited.

This information helps us monitor traffic on our website, so that we can manage the website's capacity and efficiency. It also helps us to understand which parts of this website are most popular, and generally to assess user behaviour and characteristics in order to measure interest in and use of the various areas of the website. This type of non-personal information and data can be collected through the standard operation of our Internet servers and logs as well as "cookies".

A cookie is a small file or string of text on the site user's computer that is used to aid Web navigation. One simple way to prevent the use of cookies is to activate the facility which is available in most web browsers that enables you to deny or accept cookies. However, you should realise that cookies may be necessary in order to provide you with certain features such as the customised delivery of certain information.

We use the following different types of cookies to monitor web activity:

Web Beacons
A web beacon operates as a tag that records visitors to a particular web page on our website after clicking through from an ICDL related advertisement on another website or email. Web beacons provide an ability to produce specific profiles of user behaviour by collecting limited non personally identifiable information. For example, beacons are used to count the number of users who visit our website. It is not possible to refuse the use of web beacons as they are used in conjunction with cookies. However, because they are used in conjunction with cookies, they can be effectively disabled in the browser by changing the settings to restrict or block cookies.
Strictly Necessary Cookies
Strictly Necessary (or Mandatory) cookies enhance your browsing experience and are also required for the effective functioning of our website.
Functionality Based Cookies
Functionality based cookies allow our website to remember choices and preferences that you make and provide more personalised features during browsing. These cookies can also be used to remember customisable changes made by you. This information is usually anonymised and cannot track your browsing activity on other websites.
Performance Based cookies
Performance based cookies collect information about how visitors use our website. Cookies of this nature typically do not collect personally identifiable information. All information these cookies collect are by default aggregated, anonymous and used to improve the way our website(s), services and applications work.

The following cookies are used on our website: