OnSkil Privacy Policy

This privacy policy applies only to this website. The website is operated by TWRG Holdings Ltd (company number: 6381352) of The Old Free School, George Street, Watford WD18 0BX and is the provider of the ‘OnSkil' platform, which is a software as a service (SaaS) offering.

TWRG endeavours to ensure that the information that you submit to us remains private, and that it is used only for the purposes described below. We aim to provide a safe and secure experience for all of our users. We make every effort to comply with our obligations under the EU General Data Protection Regulation (GDPR). Additionally, we understand the importance of maintaining the confidentiality of your CV and other information stored about you while using the site.

Manage Your Privacy

To provide the best experiences, we and our partners use technologies like cookies to store and/or access device information. Consenting to these technologies will allow us and our partners to process personal data such as browsing behaviour or unique IDs on this site. Not consenting or withdrawing consent, may adversely affect certain features and functions.

You may withdraw your consent, review or update your privacy settings here.

Information we collect

Due to the nature and functionality of this software (e.g. job finding services), it goes without saying, we can’t help you develop professional connections without some information about you, such as basic profile details from both Candidates and Clients.  We also collect information generated as you use our services, for example access logs, as well as information from third parties, like when you access our services through a social media account. 

We do not however collect any personal data from users for our own use.  We are the Data Processor and you are the Data Controllers.

If you want additional info, we go into more detail below.

Candidate Account and CV information

When you register your details onto the OnSkil platform, you will be asked to upload an anonymised CV to protect your identity during your job searching process.  We promote employment based on your skills and experience to this end we feel that personal information should be kept secure until such time you wish for it to be exposed.  Your CV data will only be viewable once you have applied by selecting ‘make an offer’ for a job that you have received a match for.  If you do not apply for any jobs your data will not be shared.  OnSkil attempts to verify the identity and the nature of the business of such organisations however does not make any warranties as to their authenticity.

Candidate personal information

When you register with us as a candidate, we will process your personal data on the basis set out in this policy, as it is in our legitimate interests to do so following your registration. 

We will collect personal information from you, such as your name, contact details, details of the kind of work you are looking for, your skill set, the location where you want to work and your anonymised CV.We ask candidates not to include any information on their CV that is considered sensitive personal data, for example your name, address, contact telephone numbers, social and personal URL’s, racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, your health, sex life or sexual orientation.  OnSkil will prompt you to remove these details, however we are unable to take responsibility to do this on behalf of candidates.

We will use your personal data to manage your account and to email you about our services which includes job alerts and emails about projects that are relevant to your fields of interest. We may contact you regarding site changes or changes to the OnSkil products or services that you use.

Disclosure of personal information

When you register, we store some information about you in your account, but it is protected by your password and may only be accessed by you. 

You can delete your account at any time. 

Your CV until such time you choose the option to ‘make an offer’, will be hidden and inaccessible to all OnSkil clients.  

All clients of OnSkil will be unable to view or access your CV until such time you approved access during the recruitment process.  Approval will be submitted when you choose to ‘make an offer'.  By submitting an offer, you are effectively authorising for your CV and contact details to be shared with a prospective client for employment services. Your anonymised CV’s will then be viewable and downloadable to the said end client only associated with the vacancy you have submitted interest to.  Should a Client request to interview you, only then will your personal contact details will be disclosed.  OnSkil will keep you updated on your progress with all vacancies.  OnSkil is not liable or takes no responsibility for CV data that may be downloaded by clients during this process as this will be deemed out of our control.

Please do not submit your personal information to us if you do not want us to collect it. 

If you choose to create a profile and upload a CV to our platform, we rely on you to ensure that your details are kept up to date. You should update your CV at least every six months, particularly if your contact details have changed.

Please note that OnSkil reserves the right to remove from our database, CVs which include any content that we consider to be illegal or offensive.

We may record and share aggregated information with our clients. Additionally, if you input your information on a separate client registration page or job application page outside of the OnSkil platform, for the same client, then the information that you give to the client is not the responsibility of TWRG.

TWRG will also use the aggregate data to identify employment trends across different industries, such as salary averages. This information will not be capable of being linked to any personally identifying information about users.

Please be aware that some of our customers may be located in countries outside the European Economic Area.

PLEASE NOTE: Your current employer may be a customer of TWRG, or a client of one of our customers. TWRG makes every effort to ensure transparency of vacancies that are uploaded to our platform and candidates stay in control of their applications, however TWRG cannot restrict the clients who access profiles on our database and cannot be held responsible for any eventuality.

Client Accounts and User information

We do not collect any personal data from your users for our own use. We are the Data Processor and you are the Data Controller in respect of the personal data which relates to your users and any other data you input into the OnSkil platform.  It is entirely up to you what data you wish to put in our system, and what permissions you assign to your account users which may give them access to the personal data of Data Subjects. You are responsible for providing your data subjects with your own privacy policy or notice in respect of the personal data you control.

We collect personal data from our contacts as our Clients so that we can develop a relationship with you and provide the best customer service to you. We also want to be able to provide you with expert support and have the ability to let you know about updates to our services as well as providing you with marketing materials and promotional offers we think might be of interest to you. Where our customers are individuals and sole traders, the legal basis on which we rely for processing your personal data is that it is necessary for the performance of a contract or in order to take steps at your request prior to entering into a contract (for example if you request a free trial).

Where our clients are corporate entities, we process the personal data of our contacts at the company on the basis that we have a legitimate interest for this processing. Our legitimate interest is in ensuring that we maintain an appropriate relationship with our clients and so that we are able to provide the clients with excellent customer services.

You are under no statutory obligation to provide us with personal data, however for business continuity purposes, we require clients to provide us with contact information for the individual at their business who is responsible for its use of the OnSkil platform in order for us to enter into a contract with the business. This is because this individual will be our main point of contact should we need to provide any notice or important information relating to our services.

OnSkil will support and implementation team may access your account.  This is a requirement in order for them to fulfil their role to ensure they can provide support to our Clients.  This access is logged.  It is essential as typically they provide a crucial role in helping refine your use the platform and enhance your results from the platform.

Data Storage

All data contained within the OnSkil platform application including data which is entered through the user interface, CV uploads, client import files, API and any other areas in which the data becomes available through the interface. This data may be entered by administrators or data controllers themselves, or through any automated system processes that you may have in place to import data into our system.

For reasons of redundancy and scalability, we host our data on services provided by Amazon Web Services.

OnSkil may need to handle data provided to us directly from clients during implementation and if our client requests us to assist with any data inputting or other ad-hoc support tasks which require us to process we may receive files from clients which contain personal data. We may store copies of such personal data on our local machines in the office whilst we undertake the task. Following completion of the task, we will ask our customer whether the personal data should be returned or destroyed. Our policy is to not store any personal data on any of our disks which are not encrypted, and staff are aware which disks are safe to store personal data on.

We maintain restricted access to servers and our platform.  Access is limited to key senior member of the technical team, and access to servers are audited.  We also maintain a log of all people who have access to servers.  Any persons that no longer require access , their credentials are promptly revoked.

Information collection and use

IP Logging

Like many websites, we routinely capture your IP address information to determine your general location.

This is anonymous in nature and is never linked to your Candidate Account or CV Information.

Capturing your IP address information helps us work out whether you are visiting the site from within the UK, EU or rest of the world, and means we can show you content that's specific to your location and ask the right questions about your eligibility to work in the UK or EU should you wish to apply for a job on OnSkil. OnSkil automatically receives and records information on our web server logs from your bser including your IP address. OnSkil records IP addresses for anonymous statistical purposes, administration of our website and servers, and to improve our services.

An IP address, or 'internet protocol address', is a unique identifying number given to every device connected to the internet. Like a car license plate, an IP address is a special serial number used for identification.

Cookies

Information may be gathered from your registration form and your use of our website through "cookies". The information gathered may be used by OnSkil internally, for purposes relating to your use of the website and for marketing activities, and may be passed to carefully selected third parties to use for marketing activities. If you do not wish to receive marketing material from OnSkil or from carefully selected third parties you should tick the appropriate box on the submission form. If you subsequently decide you no longer wish to receive direct marketing/information from OnSkil or no longer wish us to pass your information to third parties you should notify us using the Contact page of our website.

OnSkil may set and access cookies on your computer. You can choose whether or not to accept cookies, however, if you do not accept OnSkil cookies, some of our services may not be available to you. More information about OnSkil cookies can be found in our Cookie Policy. This policy does not apply to companies that OnSkil does not own or control, or to people that OnSkil does not employ.

When you log into our website, we may share information that we collect from you, such as your email, IP address, or information about your browser or operating systems that uses this information to create an online identification code for the purpose of recognising you on your device. This code does not contain any of your identifiable personal data and cannot be used to re-identify you. We place this code in our cookie and allow it to be used for online and cross-channel advertising. It may be shared with our advertising partners and other third party advertising companies globally for the purpose of enabling interest-based content or targeted advertising throughout your online experience (e.g. web, email, connected devices, and in-app, etc). These third parties may in turn use this code to link demographic or interest-based information you have provided in your interactions with them. You have the right to express a choice regarding our sharing of this data with any for the above purposes, of the creation of this code, or of our sharing of the code with our advertising partners.

Third Party Cookies

OnSkil currently uses Google Ads as a service to serve personalised adverts when visiting other Google Ad network sites. Google Ads are authorised by OnSkil to place and read cookies on our websites (including network websites and emails).

When you use our website, we share information that we may collect from you, such as your email, IP address or information about your browser or operating systems, with our partner, TWRG Holdings Ltd and its group companies (‘TWRG’).  TWRG may drop a cookie on your browser or directly in our emails and match your shared information to their on- and offline marketing databases and those of its advertising partners to create a link between your browser and information in those other databases. Similarly, when you use our mobile apps, we may also share hashed and de-identified email addresses, mobile device ID, location data, and advertising identifiers with TWRG, which uses that information to create a link between your mobile device and its databases. This link may be shared by our partners globally for the purpose of enabling interest-based content or advertising throughout your online experience (e.g. cross device, web, email and in app etc.) by third parties unaffiliated with our website. These third parties may in turn link further demographic or interest-based information to your browser. You have the right to exercise your rights under GDPR including opting out of TWRG Cookie or Mobile Identifiers and can easily do so by clicking on this link.

Other choice options for display: Users can also express their choices, through the following platforms: IAB opt-out platform, Network Advertising Initiative opt-out platform, Digital Advertising Alliance platform that provide options to express their choices for all companies that are registered in this platform.

OnSkil uses a specific cookie in order to facilitate the use of Google Universal Analytics for logged in Candidates or Client (“Logged-In User”). If you are a Logged-In User, OnSkil may use your Candidate or Client user ID in combination with Google Universal Analytics and Google Analytics to track and analyse the pages of OnSkil that you visit. We do this to better understand how you use OnSkil, with the aim of improving OnSkil for all users. We do not pass any Logged-In User personal identification information to Google Analytics.

Learn more about privacy at Google or opt-out of this feature by installing the Google Analytics Opt-out Bser Add-on.

Tracking Pixels in Emails

Like around 40% of emails sent worldwide, OnSkil uses tracking pixels in some of the emails which we may send you. A tracking pixel is a small, invisible image inserted into OnSkil emails which we use to measure the performance and effectiveness of our emails.

We collect this information anonymously for statistical reporting and do not use it to tailor our marketing or sales activity towards any individual.

We use a pixel provided by Google Analytics to determine the effectiveness of our messages in attracting traffic to our website.

We use a pixel provided by Return Path to assess the time spent reading our messages to enable us to improve what we send you. The Return Path pixel also identifies the platform on which you open your email (e.g. your email client or device type) and we use this information to ensure we are designing emails effectively for how our users choose to view our emails.

Both pixels also anonymously provide details of the country you are in when you open your email, as well as the time you open it. We may use this information to ensure our services are effectively used and to measure how quickly our messages are reviewed by their recipients.

Emails from OnSkil

If you choose to join OnSkil, you will receive email communications from us. You will receive essential communications, but on registering will also be given the option to receive 'Job Alerts' and 'Updates'.

Essential Communications

We will send you messages that we consider necessary to meet our legal obligations and your expectations of us, including about your account, application confirmations and documentation relating to employment opportunities or additional premium products.

In accordance with our Terms & Conditions, if you do not wish to receive emails of this nature, you should not use OnSkil (see Closing your OnSkil account below).

Job Alerts

Job Alerts are bespoke notifications of the latest jobs available on our site which match your search criteria. They could include:

  • Job Alerts
    These will be sent to you when a job matches your criteria, unless no new jobs matching your criteria have been posted since your last Alert. 
  • Interview Alerts
    If a client wishes to interview you, you will receive an alert to notify you that your personal contact details have been shared.  These will vary in frequency depending on your applications made and your profile being selected.
  • Company Alerts
    If you choose to set-up a Vacancy, you will be alerted when candidates match to your vacancy to prompt you to log into the platform to review your applications that are matching your search criteria. These will also vary in frequency depending on your search criteria and the volume of candidates the Company receives.

You can change which Alerts you receive at any time via your matches within from your portal dashboard. You can also Snooze Job Alerts for a set period if you decide to pause your job search, or can stop receiving Job Alerts altogether if you so choose - this can also be done via your settings, or you can click the unsubscribe link in any Job Alert email.

Updates

Updates are emails from OnSkil which help you to progress in your job search, provide tips, motivational advice and additional suggestions. They could include:

  • Reminders
    Application summaries and notifications of any requests from companies. We'll also give you a nudge if you’ve not checked-in for a while to keep you active in your search.
  • Company Promoted Opportunities
    Some recruiters or employers ask us to reach out to candidates they think would be a good match. You'll only receive one if factors such as salary and location are aligned.
  • Improve Your Prospects
    We'll let you know about improving your profile, if your data is incomplete to enhance your job matches.
  • OnSkil Family
    Help us make OnSkil better!  We may ask your thoughts on work or the job market, or ask you to review new or existing services.  Essentially like you, we want to keep our skills on point!

Statistical information

OnSkil gathers general information about users, for example, what services users access the most and which areas of the OnSkil site are most frequently visited, the number of CVs on the database, or the number of visitors to the site and for other lawful purposes. Such data is used in the aggregate to help us to understand how the OnSkil site is used. We gather this information so that we can continue to improve and develop our services to benefit our users. We may make this aggregated information available to users of the OnSkil site, to our clients, advertisers, suppliers and other reputable third parties. These statistics are anonymous and contain no personal information and cannot be used to gather such information.

Security

The site is protected against unauthorised access using the latest security devices and 'firewalls'.

Other brands and websites within our network

The TWRG Holdings Ltd Group incorporates this website, as well as www.twrg.co.uk.

Other ways of ensuring your privacy & your data protection rights:

These options are available when you log in to our website.

You may access and amend your personal details at any time.

Stop receiving OnSkil Emails

You may unsubscribe from any employment or promotional information that we may send to you by in any of the following ways:

  • Using the unsubscribe function at the bottom of the email
  • Amending your account details by logging in to our website
  • Contacting us on the Contact page of our website.

You will continue to receive essential communications. In accordance with our Terms & Conditions, if you do not wish to receive emails of this nature, you should not use the OnSkil platform (see Close your OnSkil account below).

Close your OnSkil account

You can remove the information that OnSkil stores about you, at any time, by logging in to your account and choosing to delete your account.

Contact us or make a complaint

If you have any questions about this policy or our use of your Personal Information, please raise your query via our contact form. If you do not think we are handling your Personal Information adequately, you have the right to make a complaint to the Information Commissioner's Office. Further information, including contact details, are available at https://ico.org.uk