Data Protection Policy

Digital tracking of VET graduates via auto-analytics
to enhance the quality and sustainability
of vocational and educational training programmes

Data Protection Policy

IO2 DITOGA MOBILE APP | IO3 DITOGA ANALYTICS SOFTWARE

1 Introduction

The DITOGA Mobile App (IO.2) is a tool that collects data about the well-being and professional achievements of VET graduates. This data is then processed in the DITOGA Analytics Software (IO.3) and allows VET providers to draw conclusions about potential skill gaps and adapt their VET training offers accordingly.

As the main purpose of the DITOGA mobile app is to collect data from VET graduates, data and privacy protection are essential components of a GDPR compliant implementation of the project. The project team considers the privacy of users a priority. The data is anonymised to ensure protection of personal data. All data that is visible in the data analytics software is anonymised and no correlations with real persons will be visible.

Educational institutions involved in DITOGA application/software development are committed to complying with data protection act and GDPR (General Data Protection Regulation), which can be found:

GDPR (EU) 2016/679: https://eur-lex.europa.eu/eli/reg/2016/679/oj

Later in this document The DITOGA Mobile App (IO.2) and DITOGA Analytics Software (IO.3) are called “service”.

 

2 How privacy is taken into account in the application/software development?

 2.1. What is personal information

All data related to an identified or identifiable person is personal data. Information such as names, telephone numbers, location data is personal data.

The data protection principles must always be observed when processing personal data.

The data-protection principles state that personal data must be

  • processed lawfully, fairly and in a transparent manner in relation to the data subject
  • collected and processed for a specific and lawful purpose
  • collected only to the amount necessary with regard to the purpose of the processing
  • updated when required ‒ inaccurate personal data must be erased or rectified without delay
  • kept in a form which only permits the identification of data subjects for as long as is necessary for the purposes of processing the personal data; and
  • processed confidentially and securely.

These principles have been taken into account when developing DITOGA application and analytics software.

 

2.2. Controller and data processor

There are two kinds of roles in processing personal data. A controller is an individual or organisation that determines the purposes and means of the processing of personal data. A company, authority or corporation that collects your personal data is called a controller. A processor is person/ organisation with access to the personal data collected by the controller.

In DITOGA mobile app and Analytics Software the controller is Jugend am Werk Steiermark GmbH in Austria. VET centers registered to the service can be seen as processors.

Data will not be shared with third parties.

 

 

3   Rights of the data subject according to the GDPR

According to the General Data Protection Regulation (GDPR), data subjects have several rights. In the following paragraph is explained how the rights are taken into consideration.

 

Right to obtain information on the processing of their personal data

Data subjects have the right to be informed of the collection and processing of their personal data. The processing of personal data shall be done in a transparent manner. The information on processing must be provided in a concise, transparent, intelligible and accessible from and be presented in clear and plain language.

The data subject can give his or her consent to processing the data subject's personal data. Such consent must be a freely given, specific, informed and unambiguous indication of the data subject's agreement to the processing of personal data relating to him or her. The data subject can give a written or oral statement of his or her consent or express it by some other clear, affirmative act, such as ticking a box on a website. It must be as easy to withdraw consent as to give it.

When registering the DITOGA app or software, the users have to confirm that they agree with the data regulations and terms and conditions. In the end of this document, the information provided to the users of the service is included.

Screenshot of the app. Agreeing the data regulations and terms and conditions.

 

Right of access to their data

Data subjects have the right to receive confirmation from the controller on whether or not the controller is processing personal data that concerns them.  In DITOGA service the user can see his/her own personal data via his own login pages and she/he can make sure what kind of data is processed.

 

Right to rectification of their data

Data subjects have the right to demand the rectification of inaccurate personal data concerning them and to have incomplete personal data completed.

If the user wants to have his/her data rectified, the user can contact us and make a request directly to info@ditoga.eu

 

Right to the erasure of their data and to be forgotten

The user has the right to erase her/his personal data.

If the user wants to erase his/her personal data, the user can contact us and make a request directly to info@ditoga.eu

 

Right to restrict the processing of their data

The user can request processing of his/her personal data to be restricted. In certain cases, user can request the controller to restrict the processing of his/her personal data.

If the user restricts processing, the user can contact us and make a request directly to info@ditoga.eu

 

Right to data portability

The user has the right to receive the personal data concerning himself/herself from the controller in a commonly used format in order to deliver them to another service provider. Transferring user’s personal data does not necessarily mean that it will be erased from the original controller's systems. However, the user does have the right to request the controller to erase your personal data from its file.

If the user wants to receive his/her personal data in a commonly used format, the user can contact us and make a request directly to info@ditoga.eu

 

Right to object to the processing of their data

The user can object to the processing of his/her data. In certain situations, the user can also object to the processing of his/her own personal data, i.e. request that it not be processed at all. Objecting is possible if the controller is processing user data on the basis of public interest or the exercise of official power or on the basis of legitimate interest. An example of processing based on legitimate interest would be using the user personal data for direct marketing. (DITOGA service do not use the user’s personal data for direct marketing.)

If you don’t want your data processed, contact us and make a request directly to info@ditoga.eu

 

Right not to be subject to a decision based solely on automated processing

The user has the right to demand human involvement in decisions concerning user. The DITOGA service does not automatically profile the user or make automated decisions

 

 

4 Collecting data in DITOGA application and analytics software

4.1. Collecting data in DITOGA application

In this service the data is collected direct from the person who has registered to the service. Upon registration, the app will collect personal data about:

  • E-mail address of user (for registration and identification only, not visible for anyone apart from the user themselves)
  • Age range of users
  • Country of residence
  • VET centre of graduation
  • VET sector of graduation
  • Year of VET graduation
  • Employment situation

Picture: Screenshot of the app. Registration phase.

When using the app regularly, the app collects data about:

  • Automatically generated nickname (no individual changes possible)
  • Mood, productivity, stress level, motivation
  • Successfully earned badges
  • Reward points and rank list slot
  • Goals reached
  • Dates and time frame when the data was inserted into the app

Picture: Screenshot of the app. Dashboard.

Picture: Screenshot of the app. Earned badges.

 

What kind of data do users see from each other?

  • In the rank list: Automatically generated nicknames and amount of reward points
  • In the newsfeed: Automatically generated nicknames, successful earned badges, reached goals
  • In the user profile & dashboard notifications: Automatically generated nickname

Picture: Screenshot of the app. Rank list.

Picture: Screenshot of the app. Newsfeed.

 

4.2. Collecting data in DITOGA software

In the analytics software the data is collected direct from the registered person who is representing VET Center. Upon registration of a VET Center, the software will collect following data:

  • Name of the representative of VET center
  • country
  • name of the VET center
  • address of VET center website of VET center
  • e-mail of contact person or legal representative

 

 

 

5 Processing data in DITOGA application and analytics software

The DITOGA Analytic Software(IO.3), which will be implemented through a webserver, will access the data collected with the DITOGA Mobile App and stored in Jugend am Werk Steiermark GmbH in Austria database. It will calculate correlations between co-dependencies and then allow the users (VET providers or VET professionals) to log in, access, and further utilise the results from their web browser. They will interpret the data and draw conclusions about potential skill gaps that could be addressed in their VET offers.

Data correlation strategies are described in terms of how the data of VET graduates will be accessed, processed, and set into correlation by the software. For instance, showing VET professionals only data relevant to their individual VET centre they will be able to create a VET provider profile and are then able to sort data automatically according to peculiar key words (e.g. VET centre of graduation, sector of work, etc.). The software will also produce diagrams and statistics based on the quantitative data and at the same time word clouds and/or ranked lists for qualitative comments (like the success moments). In this way, VET providers and VET professionals will have the DITOGA analytics software at their disposal allowing them to process, analyse, visualise, and interpret the data digitally acquired from their VET graduates in order to draw deductions for their individual potential areas of improvement.

 

6 Data Protection Steering Committee

To ensure safety and sustainable data protection, the DITOGA partnership has assembled a Data Protection Steering Committee. From each VET center registered in the DITOGA software (IO3), one person is responsible to oversee the data protection actions implemented in their VET center when working with the app user data later on. In the beginning, this Steering Committee consists of project partners (at least 6 persons). Nevertheless, the final responsible party is the coordinator of the DITOGA project: Jugend am Werk Steiermark GmbH. They can also be reached using the e-mail address provided in the info section of the app and their imprint is also noted in the privacy statement of the DITOGA website.  If you have any questions about the privacy policy or the data we hold on you, please do not hesitate to contact us via info@ditoga.eu.  For more information https://www.ditoga.eu/en/

 

7 The information provided for the users of the app and software

This following information is provided for the users, when they are registering to the service: They are asked to agree with it before continuing with the service.

 

Data Protection Policy (Data regulations)

DITOGA Analytics application

The DITOGA Data Protection Policy assures that the data processing and storage is compliant to the European Data Protection Regulation GDPR (EU) 2016/679: https://eur-lex.europa.eu/eli/reg/2016/679/oj

 

Introduction

  • The DITOGA mobile app is used by VET learners and graduates and it supports to monitor their professional achievements and motivates them to excel themselves. The DITOGA software will be used by VET professionals and providers in order to obtain and interpret meaningful data concerning the career paths of their graduates.

 

What data is collected

Users of the app (“VET graduates”):

  • Personal identification information (E-mail address, age range, country, your VET center, VET sector, year of graduation, employment)

How data is collected

  • Data is collected directly from the registered person. In the registration process the user enters their own data to the application register.

 

How data is used:

  • To manage your account
  • To monitor oneself and professional achievements
  • To motivate and cheer other users with Ranking list and Reward Points
  • To analyze pseudonymized data in DITOGA software used by VET centers in order to obtain and interpret data concerning the careers paths of graduates.
  • The user’s personal data will be used only as written in this document. Data will not be shared with third parties for example marketing purposes.
  • Data inserted in the App can’t identify individual persons.

 

How data is stored:

DITOGA analytics software/application securely stores your data at the server of Jugend am Werk Steiermark (AT).

The DITOGA products will stay freely accessible for 2 years after the project end. Active data is stored for 6 months after the project ends, unless the user want to delete his/her account earlier. See you rights below.

 

Security description of the service (Technical (IT) measures):

Appropriate and proper technical and organisational security measures are taken to ensure that there is no unauthorised access to the personal data that is hold and that it is not used, destroyed, modified, made public or misused in any other way.

All API endpoints, which provide access to sensitive private data, are only accessible with a valid login. Fetching detailed information is always limited to the users own data. Public data like the newsfeed or ranklist include only users that have not opted out of these features.

Any communication between app or browser and the backend is always encrypted based on current industry standards. Passwords are only stored hashed using recommended hashing algorithms like bcrypt or argon2.

Data protection rights of the users:

  • The right to be informed

The user is informed about the Data Protection policy and Terms and Conditions when she/he is signing in to the app.  She/he confirms that she/he has read and accepted it.

  • The right of access

The user can see his/her own personal data via his own login pages.

  • The right to rectification

If the user wants to have his/her data rectified, the user can contact us and make a request directly to info@ditoga.eu

 

 

  • The right to erasure

If the user wants to erase his/her personal data, the user can contact us and make a request directly to info@ditoga.eu

  • The right to restrict processing

If the user restricts processing, the user can contact us and make a request directly to info@ditoga.fi

  • The right to data portability

If the user wants to receive his/her personal data in a commonly used format, the user can contact us and make a request directly to info@ditoga.eu

  • The right to object

If the user doesn’t  want his/her data processed, the user contact us and make a request directly to info@ditoga.eu

  • Rights related to automated decision making and profiling

The application does not automatically profile the user or make automated decisions.

 

What are cookies?

Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our software, we may collect information from you automatically through cookies or similar technology.

For further information, visit allaboutcookies.org.

 

 

How does the DITOGA analytics application use cookies?

The application uses cookies only for sessions to keep the user logged in while using the application.

How to manage cookies

The analytics application requires a valid login and cannot be used without cookies.

 Privacy policies of other websites

This privacy policy applies only to this mobile application, so if you click on a link to another website, you should read their privacy policy.

 

Changes to the privacy policy

The DITOGA project keeps its privacy policy under regular review and places any updates on this document. This privacy policy was last updated on 2nd April 2020.

 

How to contact us

If you have any questions about the privacy policy or  the data we hold on you, please do not hesitate to contact us via info@ditoga.eu.

For more information https://www.ditoga.eu/en/

The users of the analytics software are provided with the following information:

 

Data Protection Policy (Data Regulations)

DITOGA Analytics software

 

The DITOGA Data Protection Policy assures that the data processing and storage is compliant to the European Data Protection Regulation GDPR (EU) 2016/679: https://eur-lex.europa.eu/eli/reg/2016/679/oj

 

Introduction

  • The DITOGA mobile app is used by VET learners and graduates and it supports to monitor their professional achievements and motivates them to excel themselves. The DITOGA software will be used by VET professionals and providers in order to obtain and interpret meaningful data concerning the career paths of their graduates.

 

What data is collected

Users of the DITOGA software (“VET centers”):

  • Personal identification information (Name, e-mail, country, name of the VET center, address of VET center, website of VET center, e-mail of contact person or legal representative)

How data is collected

  • Data is collected direct from the registered person who is representing VET center. The user manages her/his own data. DITOGA Analytics Software uses the information collected from VET graduates in the DITOGA App to obtain and interpret data concerning the career paths of the graduates. The data from VET graduates is collected direct from the registered users via DITOGA app.

 

How data is used:

  • To manage VET center’s account [thereinafter ’Users’]
  • The VET center’s account data will be used only as written in this document. Data will not be shared with third parties.
  • Data inserted in the Software can’t identify individual persons

The VET centers can analyse pseudonymised data in order to obtain and interpret data concerning the careers paths of graduates of their own VET center via their VET center account. The graduates are using only DITOGA Analytics Mobile app, not the software.

 

How data is stored:

DITOGA analytics software securely stores data at the server of Jugend am Werk Steiermark (AT).

Users manage storing time of their own data. Users can delete their account via her/his own login page.

The DITOGA products will stay freely accessible for 2 years after the project end. Active data is stored for 6 months after the project ends.

If someone deletes VET center’s account, all data will be deleted for that user

 

Security description of the service (Technical (IT) measures):

Appropriate and proper technical and organisational security measures are taken to ensure that there is no unauthorised access to the personal data that is hold and that it is not used, destroyed, modified, made public or misused in any other way.

All API endpoints, which provide access to sensitive private data, are only accessible with a valid login.

Access to students data and analytics is forced to the users VET center and verified on server side.

Any communication between app or browser and the backend is always encrypted based on current industry standards. Passwords are only stored hashed using recommended hashing algorithms like bcrypt or argon2.

Data protection rights of the users:

  • The right to be informed: The user is informed about  the Data Protection policy and Terms and Conditions when she/he is signing in to the software.  She/he confirms that she/he has read and accepted it.
  • The right of access: The user can see his/her own personal data via his own login pages.
  • The right to rectification: The user can edit his/her own personal data via his own login pages.
  • The right to erasure: The user has the right to erase her/his personal data. The user can delete his/her account via his/her own login page. When a user deletes his/her data it will be completely deleted and won’t appear in the software anymore.
  • The right to restrict processing: If The user restricts processing, The user can delete his/her account and data via his/her own login page.
  • The right to data portability: Software is not collecting downloadable data from VET centers users.
  • The right to object: If The user object to app activities, the user can delete his/her account and data via his/her own login page.
  • Rights related to automated decision making and profiling: The software does not automatically profile the user or make automated decisions.

Marketing

The data is not used for marketing purposes.

What are cookies?

Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our software, we may collect information from you automatically through cookies or similar technology.

For further information, visit allaboutcookies.org.

How DITOGA analytics software uses cookies?

The application uses cookies only for sessions to keep the user logged in while using the application.

How to manage cookies

The analytics application requires a valid login and cannot be used without cookies.

Privacy policies of other websites

This privacy policy applies only to this software, so if you click on a link to another website, you should read their privacy policy.

Changes to the privacy policy

The DITOGA project keeps its privacy policy under regular review and places any updates on this document. This privacy policy was last updated on 2nd April 2020.

How to contact us

If you have any questions about the privacy policy or  the data we hold on you, please do not hesitate to contact us via info@ditoga.eu.

For more information https://www.ditoga.eu/en/ 

 

 

DITOGA mobile application 

Generic Terms and Conditions Template

The DITOGA mobile app is used by VET learners and graduates and it supports to monitor their professional achievements and motivates them to excel themselves. The DITOGA software will be used by VET professionals and providers in order to obtain and interpret meaningful data concerning the career paths of their graduates.

Please read these terms and conditions ("terms", "terms and conditions") carefully before using DITOGA Analytics application (the "service") operated by DITOGA project: https://www.ditoga.eu/en ("us", 'we", "our").

Conditions of Use

We will provide their services to you, which are subject to the conditions stated below in this document. Every time you download DITOGA Analytics application, use it or its services, you accept the following conditions. This is why we urge you to read them carefully.

Privacy Policy

Before you continue using DITOGA Analytics application we advise you to read our privacy policy regarding our user data protection. It will help you better understand our practices.

Intellectual property right

The entire compilation of the content (digital downloads, images, texts, graphics, logos)   found on DITOGA Analytics application is freely accessible for non-commercial usage, provided that no substantial changes are made and that full reference should be made to the source of the material (project title, grant agreement number) and that the project has been funded under the Erasmus+  programme.

Age of the user

The service is provided to users over age 15. When you create an account, you confirm that you are over 15 years old.

User Account

You must ensure that no unauthorized access to the DITOGA application is obtained through your username and password and take all necessary steps to keep them confidential. You shall inform the DITOGA partnership at  info@ditoga.eu immediately if you have any reason to believe that your password has become known to or been used by any other person.

The DITOGA administrator reserves the right, in its sole discretion, to restrict, suspend or terminate your access to all or any part of the DITOGA application without prior notice and without liability, in case of any violation of any of the terms and conditions.

Communications

The entire communication with us is electronic with email, info@ditoga.eu

Applicable Law

By using this application, you agree that the laws of the Austria without regard to principles of conflict laws, will govern these terms and conditions, or any dispute of any sort that might come between DITOGA project and you.

Disputes

DITOGA analytics application disputes shall be arbitrated by Austria you consent to exclusive jurisdiction and venue of such courts.

 

 

DITOGA Analytics software

Generic Terms and Conditions Template

The DITOGA software will be used by VET professionals and providers in order to obtain and interpret meaningful data concerning the career paths of their graduates.  The DITOGA mobile app is used by VET learners and graduates and it supports to monitor their professional achievements and motivates them to excel themselves.

Please read these terms and conditions ("terms", "terms and conditions") carefully before using DITOGA Analytics software (the "service") operated by DITOGA project: https://www.ditoga.eu/en/ ("us", 'we", "our").

Conditions of Use

We will provide their services to you, which are subject to the conditions stated below in this document. Every time you download DITOGA Analytics software, use it or its services, you accept the following conditions. This is why we urge you to read them carefully.

Privacy Policy

Before you continue using DITOGA Analytics software we advise you to read our privacy policy regarding our user data protection. It will help you better understand our practices.

Intellectual property right

The entire compilation of the content (digital downloads, images, texts, graphics, logos)   found on DITOGA Analytics software is freely accessible for non-commercial usage, provided that no substantial changes are made and that full reference should be made to the source of the material (project title, grant agreement number) and that the project has been funded under the Erasmus+  programme.

Age of the user

The service is provided to users over age 15. When you create an account, you confirm that you are over 15 years old.

User Account

You must ensure that no unauthorized access to the DITOGA software is obtained through your username and password and take all necessary steps to keep them confidential. You shall inform the DITOGA partnership immediately if you have any reason to believe that your password has become known to or been used by any other person.

The DITOGA administrator reserves the right, in its sole discretion, to restrict, suspend or terminate your access to all or any part of the DITOGA software without prior notice and without liability, in case of any violation of any of the terms and conditions.

Communications

The entire communication with us is electronic with email, info@ditoga.eu

Applicable Law

By using this software, you agree that the laws of the Austria without regard to principles of conflict laws, will govern these terms and conditions, or any dispute of any sort that might come between DITOGA project and you.

Disputes

DITOGA analytics software disputes shall be arbitrated by Austria you consent to exclusive jurisdiction and venue of such courts.

 

References:

GDPR (EU) 2016/679: https://eur-lex.europa.eu/eli/reg/2016/679/oj. Electronical reference 2.4.2020.

Data protection. https://tietosuoja.fi/en/home. Electronical reference 2.4.2020.

Exclusion of liability / Disclaimer for mobile application

1. Content of the Online Offer

The author reserves the right not to be responsible for the topicality, correctness and completeness of the information provided in our mobile application. Liability claims against the author, which refer to material or non-material damage caused by the use or non-use of the information provided or by the use of incorrect or incomplete information, are excluded in principle, unless there is evidence of wilful intent or gross negligence on the part of the author. All offers are subject to change and non-binding. The author expressly reserves the right to change, supplement or delete parts of the mobile application or the entire offer without separate announcement or to discontinue the publication temporarily or permanently.

 

2. Copyright and Trademark Law

The author endeavours to observe the copyrights of the images, graphics and texts used in all publications, to use images, graphics and texts created by himself or to use licence-free graphics and texts. All brand names and trademarks mentioned within the offer and, if applicable, protected by third parties are subject without restriction to the provisions of the respective valid trademark law and the ownership rights of the respective registered owners. The mere mention of a trademark does not imply that it is not protected by the rights of third parties! The copyright for published objects created by the author himself remains solely with the author of the mobile application. Any reproduction or use of such graphics and texts in other electronic or printed publications is not permitted without the express consent of the author.

 

3. Data Protection

If the opportunity for the input of personal data (email addresses) is given, the input of these data takes place voluntarily. For further information, please also refer to our data protection declaration.

 

4. Legal Effectiveness of this Disclaimer

This exclusion of liability/disclaimer is to be considered part of the Internet offer from which reference was made to this page. If sections or individual terms of this statement are not legal or correct, the content or validity of the other parts remain uninfluenced by this fact.

Since the mobile application and the associated information, software and documentation are provided free of charge, any liability for material defects and defects of title of the App, information, software and documentation, in particular for their correctness, freedom from errors, freedom from third-party property rights and copyrights, completeness and/or usability - except in the case of intent or fraudulent intent - is excluded.

Otherwise, Jugend am Werk Steiermark GmbH shall only pay compensation for damages caused by intent or gross negligence. Liability for slight negligence is excluded. The limitation of liability does not apply to personal injury. Jugend am Werk Steiermark GmbH does not guarantee the uninterrupted availability of the App.