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Please read the following important terms carefully.
Check that you agree with them before signing up with UpSkill Me:
If there is anything in these terms that you do not understand or are unsure about, you should ask a trusted adult for help.
If you have any questions, get in touch with us at firstname.lastname@example.org
If you do not agree to these terms, do not sign up to UpskillMe.
About us and our service
Who we are
We are Upskill Global Limited, a company incorporated and registered in England and Wales with company number 11967077. Our registered office is at 19 Beaulieu Avenue, London, England, SE26 6PN.
About Upskill Me
Our service, Upskill Me, delivered through our website upskillme.io, is aimed at school children in Years 7 to 13. Upskill Me is an online platform assisting students in developing, recording and showcasing their employability skills. It enables students to record, track and reflect on their achievements and skill growth. It gives them access to information about work experience, career events, learning opportunities and resources.
How to contact us
If you have any questions, comments or complaints in regard to this statement or our processing of students’ personal data, please contact us at email@example.com or the above address.
Purpose of this statement
This document serves as our public statement on data protection. It sets out how we process the personal information of Upskill Me’s registered student users, the parents or guardians of such students and non-student users of Upskill Me. It is aimed at schools whose students use Upskill Me, the parents or guardians of such students, and any non-student registered users of Upskill Me (teachers of students who use Upskill Me, and employees of third party organisations that offer opportunities to students through Upskill Me).
If you are a parent/guardian of a student using Upskill Me or a non-student registered user of Upskill Me and want to learn how we use your personal data, read section 6 (Privacy Notice) of this statement.
If you are a student user of Upskill Me, you may prefer to read our Privacy Notice for Students. If that notice is too basic for you, you are welcome to read this statement to learn more.
Data Protection Legislation
Our use of students’ personal data is subject to data protection laws applicable in the United Kingdom. On the date of the publication of this statement, these laws include the EU General Data Protection Regulation, the UK Data Protection Act 2018, and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (together Data Protection Legislation).
Even though the United Kingdom has left the European Union, the EU General Data Protection Regulation continues to apply in the United Kingdom during the transition period, until the end of 2020.
Data protection roles
For the purposes of the Data Protection Legislation we are the controller of registered users’ (data subjects’) personal data processed in connection with their use of Upskill Me. This means that we are responsible for determining the purposes and means of the processing of their personal data.
Whilst we will take into consideration all reasonable requests from schools concerning the personal data of their students, we do not act as processors on behalf of schools, or joint controllers with schools. Neither do we act as processors on behalf of or joint controllers with schools or third party organisations in respect of the personal data of their staff registered to use Upskill Me.
Age appropriate design standards
We aim to comply with the standards set out in the Information Commissioner’s Office Age Appropriate Design Code of Practice for Online Services.
Best interests of the child
Upskill Me has been designed and developed with the best interests of students and respect of their rights in mind, including:
- online safety;
- access to information and development opportunities;
- freedom of expression;
- encouraging self-development;
- building confidence in their skills and abilities;
- assisting them in developing and showcasing their professional personality;
- providing them with tools to showcase their skills to potential employers;
- equal opportunities and freedom from discrimination; and
- freedom from economic exploitation.
Data protection impact assessment
Under the Data Protection Legislation, offering online services directly to children mandates the use of data protection impact assessments.
We have undertaken a data protection impact assessment in order to assess and minimise risks to the rights and freedom of students, which may arise from our data processing. Our findings have been reflected in the development of Upskill Me.
Age appropriate application
We recognise that needs and capacities of children in Years 7 to 13 differ depending on their age. Therefore, we have designed Upskill Me to reflect that.
We verify the age of children through our sign up process. Most children will sign up to Upskill Me through an invitation sent to them by their school. Other children will sign up by selecting their school on our sign up page and using their school email.
We offer different service options to children in differing age groups:
- Level 1, Limited (Years 7 - 8, Ages 11 - 12)
- Level 2, Basic (Years 9 - 11, Ages 13 - 16)
- Level 3, Advanced (Years 12 - 13, Ages 16+)
We make only such features of Upskill Me available to students as we believe to be appropriate to their age group:
- We enable students in all age groups to: record their achievements, qualifications and interests; monitor their skills progression, points and levels; earn progress badges; add and manage their goals; view work experience, events, career advice and e-learning opportunities; and receive direct messages from us about third party opportunities.
- Students in Years 9-11, will additionally have the option to join the employer talent pool available within Upskill Me.
- Students in Years 12-13, will have the extra option to create their own public employment profile and be able to use it to apply for job opportunities and receive direct messages from potential employers. Their information, sourced from their profiles and applications, may appear in dashboards used by employers to manage information about targeted candidates for the purpose of their recruitment campaigns.
We screen content served to children within Upskill Me to ensure it is appropriate to their age.
We provide age appropriate privacy information (see section 5.4, Transparency, below).
We provide high privacy settings for all children by default (see section 5.7, Default settings, below).
We recognise that children aged 11-15 are particularly susceptible to peer pressure, and that their self-esteem may be adversely affected as they compare themselves with other children. As such, we do not make their profiles visible to other students.
We provide age appropriate privacy information to children. This includes:
- our Privacy Notice for Students; and
- concise, just in time explanations provided within Upskill Me at the points at which use of that data is collected or activated (for example, on our sign up forms, within our privacy settings dashboard, and at the point of the publication of the student’s public profile).
Our Privacy Notice for Students adopts a layered approach. The first layer presents only limited, easy to understand information. However, students have the option to view more detailed information by selecting options provided within the document.
We prompt students within Upskill Me to speak to an adult before activating any new use of their data if they are below 13 years of age or uncertain on whether they should proceed.
Detrimental use of data
We observe the rules concerning marketing communications featuring or addressing children set out in the UK Code of Non-broadcast Advertising and Direct & Promotional Marketing (CAP Code).
We provide our users with information about work experience, career events and learning opportunities offered by employers and other third party providers within the Upskill Me platform and by email and text. Except for direct messaging by employers to students aged 16+ who have published their public profiles, in order to protect their privacy, we do not allow third parties to send marketing communication directly to children. We screen the content of all third party marketing communications before it is approved for publication within Upskill Me.
Policies and community standards
We operate our service and use personal data of children in compliance with our published terms and policies:
- this Data Protection Statement and Privacy Notice;
- our Privacy Notice for Students; and
Where we rely on consent to process personal data of students, we use privacy settings and the privacy dashboard to give students the choice over how their personal data is used and made accessible to other users and third parties.
We enable students to choose which optional elements of the service they wish to activate, and how much information to share in their public profiles.
We collect and retain only the minimum amount of data required to provide our service and for the other purposes set out in section 6.3 (How and why we use personal data) of this statement.
The use of all non-essential cookies (including those that collect geolocation data) is switched off by default and only activated if the user accepts such other cookies.
Where we rely on consent to process students’ personal data, we seek parental authorisation for children under 13 years of age. See section 6.3(a) (How and why we use personal data. Consent) of this statement.
We allow parents/guardians of children in Years 7 and 8 to monitor their use of Upskill Me. We inform children in that age group that their use of Upskill Me can be monitored by them.
Certain in-service content can be of interest to students sharing certain characteristics (e.g. e-Learning content about empowering women to succeed professionally may be of interest to female users, or e-learning content concerning GSCEs may be of interest to pre-GSCE students). We may use automated processing to filter users by certain characteristics and offer targeted content to them within Upskill Me.
Similarly, employers may wish to offer specific opportunities to students who share certain characteristics (e.g. if they live in the geographical area where the opportunity is available, are in a specific age group, or have particular interests or skills). We do not allow employers to market their opportunities to students directly but we may use automated processing to filter our users by the required characteristics and direct selected third party offers to such students.
The characteristic by which we may filter students for the purpose of targeted marketing may include their ethnicity, gender and free school meal allowance. This is to ensure that third parties can meet and monitor their compliance with non-discrimination legislation and offer equal opportunities to students of all backgrounds. This may include targeting specific opportunities to students with certain protected characteristics. Students can choose whether or not to provide such information and we will seek their (or, where appropriate, their parent/guardians’) consent to such use.
Targeted content and opportunities are optional and students (or their parents/guardians) must opt-in before their use is activated.
We do not use any other forms of profiling.
We do not encourage children to provide unnecessary personal data or weaken their privacy settings.
We provide tools within the service to enable children to easily:
- exercise their data protection rights (e.g. to download their data or ask that we delete their data, stop using their data or correct their data).