Privacy Policy

EASEC·EU
Privacy Policy Last updated: August 2026 · Applies globally across all EASEC services and platforms

1. Introduction

EASEC — European Accreditation of Soft Skills & Employability Competencies — is an independent international certification authority dedicated to evaluating, certifying, and credentialling transversal competencies and employability skills under internationally recognised standards including ESCO, EQF, Tuning, the World Economic Forum Future of Jobs Framework, UNESCO, and O*NET.

This Privacy Policy explains how personal data is collected, processed, stored, shared, and protected when individuals, institutions, or organisations interact with any EASEC service, platform, or digital environment.

EASEC operates across three verticals — EASEC for Schools, EASEC for Higher Education, and EASEC for Work — structured commercially through four service lines: Programme Accreditation; Diagnostic and Certification Assessments (Certification Centre); Professional Profile Certifications; and the Talent Intelligence Platform. This Policy applies uniformly across all verticals and service lines, with specific provisions noted where applicable.

EASEC also offers ten professional competency certification programmes and operates the Skills-First Employer Network (skillsfirst.easec.eu) and the EASEC International Cooperation Programme, all of which are covered by this Policy.

By accessing or using any EASEC service, you acknowledge that you have read and understood this Privacy Policy. Where services are accessed through an institution, employer, or Authorised Partner, you should also refer to that organisation's own privacy notices.


2. Legal Entities Operating Under This Policy

Primary Entity — Europe & International
INNZPIRA ANALYTICS S.L.

C. de la Travesía, Poblados Marítimos, 46024 València, Valencia, Spain

CIF: B19336213

Operating under the registered European trade mark EASEC — European Accreditation of Soft Skills & Employability Competencies. Operates all EASEC for Schools, EASEC for Higher Education, EASEC for Work, professional certification, Skills-First Employer Network, and International Cooperation Programme services billed in EUR.

Contact: info@easec.eu

Secondary Entity — United States
Innzpira LLC

5900 Balcones Drive, Ste 4000, Austin, Texas 78731, USA

Operates EASEC for Work billing in USD for clients accessing services through work.easec.eu with card payment in US dollars.

Contact: info@easec.eu

Both entities operate under a unified privacy governance framework. References to "EASEC" throughout the remainder of this Policy apply to both entities where relevant to the context.


3. Regulatory Framework and Standards Alignment

EASEC operates in compliance with the following regulatory frameworks:

  • Regulation (EU) 2016/679 (GDPR) — General Data Protection Regulation
  • Spanish Organic Law 3/2018 (LOPDGDD) — on Personal Data Protection and Guarantee of Digital Rights
  • Regulation (EU) 2024/1689 (EU AI Act) — Artificial Intelligence Act, applicable to EASEC's deployment of AI systems in assessment processes, including the transparency obligations under Article 50, and where applicable, the risk classification and conformity requirements relevant to AI systems used in educational and employment contexts
  • Regulation (EU) 910/2014 (eIDAS) — on electronic identification and trust services, applicable to digital credential issuance and verification
  • Europass Digital Credentials Infrastructure (EDCI) — interoperability principles for digital credential formats
  • Texas Data Privacy and Security Act (TDPSA) and applicable US federal privacy law, where Innzpira LLC is the processing entity
  • Open Badge 3.0 Standard (1EdTech) — governing digital badge issuance and portability
  • 1EdTech CASE (Competency and Academic Standards Exchange) — metadata framework applied to issued credentials

EASEC holds certifications under ISO 9001 (Quality Management) and ISO 27001 (Information Security Management), and maintains a formal appeals and complaints procedure aligned with ISO/IEC 17024 (Conformity Assessment — General Requirements for Bodies Operating Certification of Persons).

ISO 20000 Alignment Note EASEC currently aligns its IT service management practices with ISO 20000 principles. Formal certification to this standard is included in EASEC's strategic roadmap. This alignment governs internal service delivery processes irrespective of formal certification status.

4. Data Protection Officer and Contact

EASEC has designated a Data Protection Officer (DPO) responsible for overseeing compliance with data protection obligations and serving as the primary contact for data subjects and supervisory authorities.

Data Protection Officer
Moisés Fernández — Head of IT

Email: mfernandez@easec.eu

General privacy enquiries: info@easec.eu

C. de la Travesía, Poblados Marítimos, 46024 València, Valencia, Spain

All data subject requests, privacy complaints, or enquiries regarding this Policy should be directed to the DPO. EASEC commits to responding to verified data subject requests within thirty (30) calendar days.


5. Role of EASEC as Certification Authority

Irrespective of how an individual accesses EASEC services — directly, through an institution, through an employer, through an Authorised Partner, or through the International Cooperation Programme — EASEC acts as the independent legal issuer of all competency certifications and digital credentials. Specifically, EASEC:

  • Determines and applies all certification methodologies, scoring rules, and competency frameworks
  • Is the sole authority responsible for deciding whether a competency certification is issued, maintained, or revoked
  • Maintains all certification records, audit trails, and verification systems
  • Is responsible for the authenticity, integrity, and permanent availability of issued credentials
  • Operates as a trust infrastructure enabling credential traceability and public verification
  • Maintains the Assessment Integrity Framework (AIF) governing the integrity of all assessment processes

Co-branded credentials include an institution's or employer's logo but this does not alter EASEC's role as sole legal issuing authority, nor does it transfer to institutions any ownership of, or responsibility for, certification data held by EASEC.


6. Platforms and Domains Covered by This Policy

DomainPurposePrimary Users
www.easec.euMain institutional website, information, service access, and B2C direct purchase of certificationsAll visitors, institutions, individuals, consumer purchasers
cert.easec.euInstitutional administration panel, personal EASEC Wallet for assessed individuals — assessment dispatch, licence management, analytics, credential access, and report accessInstitutional administrators, assessed individuals
work.easec.euEASEC for Work talent intelligence platform — talent assessment, project management, and professional reportingCorporate clients, HR and talent teams, consultancies
awards.easec.euEASEC annual awards programme — nominations, applications, and resultsInstitutions, individuals
skillsfirst.easec.euSkills-First Employer Network — employer commitment to skills-based hiring and talent development (subject to its own specific terms and conditions; this Privacy Policy applies to all personal data processed through the platform)Employers, HR leaders
Domain
www.easec.eu
Purpose
Main institutional website, information, service access, and B2C direct purchase of certifications
Primary Users
All visitors, institutions, individuals, consumer purchasers
Domain
cert.easec.eu
Purpose
Institutional administration panel, personal EASEC Wallet — assessment dispatch, licence management, analytics, credential access, and report access
Primary Users
Institutional administrators, assessed individuals
Domain
work.easec.eu
Purpose
EASEC for Work talent intelligence platform — talent assessment, project management, and professional reporting
Primary Users
Corporate clients, HR and talent teams, consultancies
Domain
awards.easec.eu
Purpose
EASEC annual awards programme — nominations, applications, and results
Primary Users
Institutions, individuals
Domain
skillsfirst.easec.eu
Purpose
Skills-First Employer Network — employer commitment to skills-based hiring and talent development
Primary Users
Employers, HR leaders

7. Relationship with Institutions, Employers, Partners, and Direct Consumers

Institutions and Certification Centres

Where universities, schools, or educational groups operate as EASEC Certification Centres, the institution acts as an independent Data Controller for participant data it collects and introduces into the EASEC platform. EASEC acts as an independent Data Controller for certification records, credential issuance, and verification data. For the limited purpose of administering assessments and generating cohort analytics, EASEC may act as Data Processor following institutional instructions.

Employers and EASEC for Work Clients

Where employers or consultancies access EASEC for Work services, the employer or consultancy is the Data Controller for employee or candidate data introduced into the platform. EASEC acts as Data Processor for assessment administration and report generation, and as independent Data Controller for credential issuance and individual EASEC Wallet accounts.

Individual Direct Consumers (B2C)

Where individuals purchase assessment or certification services directly through www.easec.eu, EASEC acts as the sole Data Controller for all data collected in connection with that purchase and the resulting assessment and credential issuance. No institutional intermediary is involved in B2C transactions. The same certification standards and credential validity terms apply as in institutional B2B arrangements.

Authorised Partners

EASEC operates an Authorised Partner Network comprising three categories of partner: Authorised Representatives, Authorised Resellers, and Authorised Referral Partners. Authorised Partners may introduce clients to EASEC services and, in some cases, facilitate onboarding and administration. Partners do not access personal data of assessed individuals unless explicitly authorised under the applicable EASEC Partner Agreement. The rights, obligations, and data processing terms applicable to each partner category are governed by the applicable Partner Agreement.

International Cooperation Programme Participants

Institutions accessing EASEC services through the EASEC International Cooperation Programme are subject to this Privacy Policy and to the data protection terms set out in the applicable cooperation agreement or memorandum of understanding. EASEC acts as independent Data Controller for all certification records and credential issuance arising from services delivered under the Programme.


8. Categories of Personal Data Processed

Identity and Contact Data

  • Full name and surname
  • Email address (institutional or personal)
  • Country or region
  • Institutional or employer affiliation

Assessment and Certification Data

  • Psychometric assessment responses (self-report instrument items)
  • Scoring outputs and competency level results
  • Certification outcomes and proficiency levels attained (Emerging, Foundational, Intermediate, Advanced, or Mastery)
  • Credential identifiers, metadata, CASE-standard skills data, and framework alignment metadata (ESCO, EQF, Tuning, WEF, UNESCO, O*NET)
  • Timestamped issuance and verification records

AI-Assisted Situational Assessment Data

The following data categories are generated and processed in connection with the EASEC AI Engine situational assessment dimension, which is integrated as a complementary qualitative layer within EASEC's diagnostic and certification instruments:

  • Open-text situational response: the free-text written by the participant in response to an AI-generated situational scenario. This constitutes a behavioural and potentially psychological data point and is treated with heightened care.
  • AI-generated interpretive analysis: the structured qualitative output (identified strengths, development opportunities, suggested performance contexts, and recommended next steps) produced by the EASEC AI Engine from the participant's open-text response. This analysis is accessible exclusively to the individual participant through their EASEC Wallet.
  • Response time data: the elapsed time between display of the situational scenario and submission of the participant's response, recorded as a behavioural contextual metric.
  • Internal competency indicator: an internal classification derived by the AI Engine on a numeric scale of 1 to 5, used solely for instrument calibration and quality assurance. This indicator is not displayed to the participant, is not communicated to any institution or employer, and does not form part of the certified assessment score.
Important — AI Engine Data Access Restriction Open-text situational assessment responses, AI-generated interpretive analyses, and internal competency indicators are NEVER shared with institutional clients, employer clients, Authorised Partners, or any third party. They are accessible exclusively to the individual participant through their personal EASEC Wallet account.

Professional Certification Assessment Data

For participants completing EASEC professional certification programmes (including the ten professional certifications across the For Schools, For Higher Education, and For Work domains), the same categories of psychometric assessment data and AI-assisted situational assessment data as described above are processed, together with:

  • Professional role and domain context data where provided during registration
  • Competency framework alignment data specific to the professional certification assessed

Programme Accreditation Data

  • Programme documentation submitted by institutions
  • Participant lists (name and institutional email) provided for quality surveys
  • Quality and satisfaction survey responses
  • Programme alignment evaluation records (ESCO, EQF, Tuning, and WEF Future of Jobs framework alignment data)

Assessment Integrity Monitoring Data

In connection with the EASEC Assessment Integrity Framework (AIF), EASEC may process the following data categories for the purpose of detecting and preventing assessment fraud:

  • Response pattern analysis data (anomaly detection in timing, consistency, and behavioural indicators)
  • AI-generated content detection signals
  • Session metadata (device, browser, IP address, timing patterns)

This processing is based on EASEC's legitimate interest in maintaining the integrity and credibility of its certification standard. Data processed for integrity monitoring purposes is retained only for the duration necessary to complete the integrity review and, where a breach is confirmed, for the duration necessary to support enforcement and appeals.

Platform and Technical Data

  • IP address and approximate geolocation
  • Device type, browser, and operating system
  • Session activity logs and navigation data
  • Security events and access logs

Communications Data

  • Support requests and correspondence
  • Feedback and survey responses
  • Newsletter and communications preferences

Billing and Commercial Data

  • Legal entity name, billing address, and tax identification (B2B) or individual billing name and address (B2C)
  • Payment transaction references (processed by Stripe — EASEC does not store card data)
  • Invoice and contract records
  • Credit activation dates and credit validity periods

9. Purposes of Processing and Legal Bases

PurposeLegal Basis (GDPR)
Administering psychometric assessments and issuing competency certificationsPerformance of contract / Legitimate interests
Operating the EASEC AI Engine situational assessment dimension (generating situational scenarios and producing interpretive analysis of participant responses)Performance of contract / Legitimate interests
Processing open-text situational responses via AI sub-processors (OpenAI, Anthropic) for qualitative analysis generationPerformance of contract / Legitimate interests (subject to DPA with sub-processors prohibiting training use)
Issuing and managing digital credentials (diploma, Open Badge, Europass EDC, blockchain-anchored credential where activated) with embedded framework alignment metadata (ESCO, EQF, Tuning, WEF, UNESCO, O*NET)Performance of contract / Legitimate interests
Maintaining certification records, audit trails, and verification systemsLegitimate interests / Legal obligation / Public interest
Conducting Programme Accreditation reviews (ESCO, EQF, Tuning, WEF framework alignment)Performance of contract
Generating institutional cohort analytics and reporting dashboardsPerformance of contract / Legitimate interests
Enabling public credential verificationLegitimate interests / Public interest in credential integrity
Administering B2C direct assessment and certification purchasesPerformance of contract
Assessment integrity monitoring under the Assessment Integrity Framework (AIF)Legitimate interests (integrity and credibility of the certification standard)
Preventing fraud and protecting certification integrityLegitimate interests / Legal obligation
Processing payments and managing commercial relationshipsPerformance of contract / Legal obligation
Providing technical supportPerformance of contract / Legitimate interests
Platform security, monitoring, and incident responseLegitimate interests / Legal obligation
Processing data in connection with the Skills-First Employer NetworkPerformance of contract / Legitimate interests
Processing data in connection with the International Cooperation ProgrammePerformance of contract / Legitimate interests
Research, benchmarking, and methodology improvement (aggregated/pseudonymised data only)Legitimate interests
Sending marketing communications where opted inConsent
Compliance with legal and regulatory obligationsLegal obligation
Purpose
Administering psychometric assessments and issuing competency certifications
Legal Basis (GDPR)
Performance of contract / Legitimate interests
Purpose
Operating the EASEC AI Engine situational assessment dimension
Legal Basis (GDPR)
Performance of contract / Legitimate interests
Purpose
Processing open-text situational responses via AI sub-processors (OpenAI, Anthropic) for qualitative analysis generation
Legal Basis (GDPR)
Performance of contract / Legitimate interests (subject to DPA with sub-processors prohibiting training use)
Purpose
Issuing and managing digital credentials (diploma, Open Badge, Europass EDC, blockchain-anchored credential where activated)
Legal Basis (GDPR)
Performance of contract / Legitimate interests
Purpose
Maintaining certification records, audit trails, and verification systems
Legal Basis (GDPR)
Legitimate interests / Legal obligation / Public interest
Purpose
Conducting Programme Accreditation reviews (ESCO, EQF, Tuning, WEF framework alignment)
Legal Basis (GDPR)
Performance of contract
Purpose
Generating institutional cohort analytics and reporting dashboards
Legal Basis (GDPR)
Performance of contract / Legitimate interests
Purpose
Enabling public credential verification
Legal Basis (GDPR)
Legitimate interests / Public interest in credential integrity
Purpose
Administering B2C direct assessment and certification purchases
Legal Basis (GDPR)
Performance of contract
Purpose
Assessment integrity monitoring under the Assessment Integrity Framework (AIF)
Legal Basis (GDPR)
Legitimate interests (integrity and credibility of the certification standard)
Purpose
Preventing fraud and protecting certification integrity
Legal Basis (GDPR)
Legitimate interests / Legal obligation
Purpose
Processing payments and managing commercial relationships
Legal Basis (GDPR)
Performance of contract / Legal obligation
Purpose
Providing technical support
Legal Basis (GDPR)
Performance of contract / Legitimate interests
Purpose
Platform security, monitoring, and incident response
Legal Basis (GDPR)
Legitimate interests / Legal obligation
Purpose
Processing data in connection with the Skills-First Employer Network
Legal Basis (GDPR)
Performance of contract / Legitimate interests
Purpose
Processing data in connection with the International Cooperation Programme
Legal Basis (GDPR)
Performance of contract / Legitimate interests
Purpose
Research, benchmarking, and methodology improvement (aggregated/pseudonymised data only)
Legal Basis (GDPR)
Legitimate interests
Purpose
Sending marketing communications where opted in
Legal Basis (GDPR)
Consent
Purpose
Compliance with legal and regulatory obligations
Legal Basis (GDPR)
Legal obligation

10. Automated Decision-Making and Certification Outcomes

EASEC's competency certification process involves automated scoring that may produce a legally or similarly significant effect — namely, whether a competency credential is issued or not.

The automated certification process:

  • Applies validated psychometric models and predefined scoring rules aligned with internationally recognised competency frameworks (ESCO, EQF, Tuning, WEF, UNESCO, O*NET)
  • Is designed to ensure consistency, objectivity, and comparability across all assessments
  • Does not involve subjective human judgement in the scoring calculation itself
  • Produces a proficiency level result (Emerging, Foundational, Intermediate, Advanced, or Mastery) and determines whether the minimum threshold for certification is met
Your Rights Regarding Automated Certification Decisions In accordance with Article 22 GDPR, you have the right to: (a) obtain human review of any automated certification decision; (b) express your point of view regarding the outcome; and (c) contest a decision you believe is incorrect. In addition to these GDPR rights, EASEC maintains a formal appeals and complaints procedure aligned with ISO/IEC 17024 (Policy P-APR-01). Appeals shall be submitted in writing to info@easec.eu. EASEC will acknowledge receipt within five (5) working days and issue a reasoned decision within thirty (30) working days of receipt of a complete submission.

Where EASEC for Work platform analytics or reports are generated automatically based on assessment data, these constitute informational outputs to support employer decision-making and do not themselves constitute automated decisions with legal effect for individuals.


10A. EASEC AI Engine — Situational Assessment Dimension

EU AI Act 2024/1689 — Article 50 Transparency Notice This section documents EASEC's compliance with Regulation (EU) 2024/1689 (EU AI Act), including the transparency obligations set out in Article 50 and, where applicable, the risk classification and conformity requirements relevant to AI systems used in educational and employment contexts. EASEC monitors regulatory developments under the EU AI Act and will update its compliance measures as implementing provisions and standards are adopted.

10A.1 Nature and Purpose

The EASEC AI Engine is a qualitative assessment component integrated into EASEC's diagnostic and certification assessment instruments across all three verticals. It presents the participant with a contextualised situational scenario generated by an AI language model, calibrated to the participant's assessed competency, segment, approximate age range, and cultural context. The participant's free-text response is analysed by the AI Engine to produce an interpretive reading.

This dimension is interpretive and developmental in nature. It does not constitute, influence, or modify the participant's certified competency score, which is determined exclusively by the validated psychometric instrument and automated scoring model described in Section 10. The AI Engine output is not shared with any institution, employer, partner, or third party — it is accessible exclusively to the individual participant through their personal EASEC Wallet account.

10A.2 Transparency Disclosure at Point of Interaction

Before initiating the AI Engine dimension, participants are informed within the assessment interface of all of the following:

  • (a) that the situational scenario has been generated by an artificial intelligence system (the EASEC AI Engine), calibrated to their profile;
  • (b) that their open-text response will be processed by an AI system to produce an interpretive qualitative analysis;
  • (c) that this analysis is interpretive, developmental, and does not form part of their certified assessment score;
  • (d) that the AI dimension operates with full methodological independence from the psychometric score;
  • (e) that they may request review of the interpretive analysis by a qualified EASEC evaluator at any time, and that a formal appeals and complaints procedure aligned with ISO/IEC 17024 is available;
  • (f) the applicable regulatory references: EU AI Act 2024/1689, Article 50; GDPR Article 22.

The participant's explicit action to continue (clicking the initiation button) constitutes informed acknowledgement of these disclosures. The participant may choose not to complete the AI Engine dimension without affecting their access to the psychometric assessment or certification.

10A.3 AI Sub-Processors

ProviderRoleData ProcessedLocationTransfer Mechanism
OpenAI, LLCLanguage model processing: situational scenario generation and open-text response analysisOpen-text responses and scenario parameters (transient API call — not retained for model training under DPA)USAEU Standard Contractual Clauses
Anthropic PBCLanguage model processing: internal workflow automation and quality assurance functionsInternal workflow data (not participant personal data for assessment purposes)USAEU Standard Contractual Clauses
Provider
OpenAI, LLC
Location
USA
Role
Language model processing: situational scenario generation and open-text response analysis
Data Processed
Open-text responses and scenario parameters (transient API call — not retained for model training under DPA)
Transfer Mechanism
EU Standard Contractual Clauses
Provider
Anthropic PBC
Location
USA
Role
Language model processing: internal workflow automation and quality assurance functions
Data Processed
Internal workflow data (not participant personal data for assessment purposes)
Transfer Mechanism
EU Standard Contractual Clauses

Both providers are engaged under data processing agreements (DPAs) that: (a) expressly prohibit use of EASEC participant data for AI model training, fine-tuning, or product improvement; (b) ensure that data transmitted via API is not retained by the provider beyond the duration necessary to generate the API response; (c) require compliance with applicable EU data protection law through Standard Contractual Clauses.

10A.4 Data Storage and Infrastructure

All AI Engine data — including open-text responses, AI-generated analyses, response time data, and internal competency indicators — is stored exclusively within EASEC's cloud infrastructure located within the European Economic Area: Google Cloud Platform (EU region) and DigitalOcean (EU region). No AI Engine data is permanently stored outside the EEA.

10A.5 What Institutions and Employers Do and Do Not See

Institutional Certification Centres and employer clients with access to EASEC's platform receive:

  • Psychometric certification results (proficiency level and whether the certification threshold was met)
  • The issued digital credential (diploma, Open Badge, Europass EDC) associated with the individual
  • Cohort analytics derived from certified assessment data (aggregated or per-individual, as agreed under the institutional agreement)

Institutional Certification Centres and employer clients do NOT receive, and EASEC does not share with them:

  • The participant's open-text situational response written during the AI Engine dimension
  • The AI-generated interpretive analysis (strengths, opportunities, performance contexts, next steps)
  • The internal competency indicator generated by the AI Engine
Data Access Restriction — Absolute These three data elements (open-text response, AI analysis, internal indicator) are permanently restricted to individual participant access only. This restriction is a deliberate design choice and cannot be overridden by any institutional, employer, partner, or cooperation programme instruction.

10A.6 Human Review Protocol

Participants have the right to request review of their AI Engine interpretive analysis by a qualified EASEC evaluator. This right is presented to participants within the assessment interface at the conclusion of the AI Engine dimension. Review requests may also be submitted at any time to info@easec.eu. EASEC commits to acknowledging review requests within five (5) working days.

10A.7 Rights in Relation to AI Processing

The AI Engine's interpretive analysis constitutes automated processing of personal data to produce an output describing the individual's characteristics. In accordance with Article 22 GDPR, participants have the right to: (a) obtain human review of the AI Engine analysis; (b) express their point of view; (c) contest the analysis where they believe it does not accurately represent them. In addition, participants may submit a formal appeal through EASEC's ISO/IEC 17024-aligned appeals and complaints procedure (Policy P-APR-01). To exercise these rights, contact info@easec.eu or mfernandez@easec.eu.


11. Participation of Minors

EASEC for Schools services are specifically designed for secondary and baccalaureate students aged 15 to 18 years. EASEC for Higher Education and EASEC for Work services are intended for individuals aged 18 or over. B2C direct purchases are available only to individuals aged 18 or over.

Institutional Responsibility for Minors Where minors participate in EASEC assessments through an educational institution — including institutions participating in the EASEC International Cooperation Programme — the institution is solely and exclusively responsible for: (a) obtaining all required parental or guardian consents under applicable national law, including for the AI Engine situational assessment dimension; (b) providing age-appropriate privacy information to students and their families before enrolment; (c) maintaining records of consents obtained; and (d) ensuring that the administration of assessments complies with all legislation protecting minors in its jurisdiction.

Where applicable national law sets the age of digital consent higher than 15 — for example, 16 in Spain and most EU Member States under Article 8 GDPR — institutions must ensure that parental or guardian authorisation is obtained for any participant below that national threshold.

Institutions must not enrol students under the age of 15 in any EASEC service.


12. Personal EASEC Wallet Accounts

Upon completing their first EASEC competency assessment — whether through an educational institution, an employer, an Authorised Partner, the International Cooperation Programme, or through a direct B2C purchase — each individual is automatically assigned a personal EASEC Wallet account. This account:

  • Belongs to the individual and is independent of any institutional, employer, or partner contractual relationship with EASEC
  • Persists indefinitely, for as long as the individual chooses to maintain it
  • Stores all EASEC competency certifications and professional certifications issued to that individual, permanently and without expiry of the record itself
  • Stores the AI Engine interpretive analyses generated for that individual, accessible exclusively to the individual
  • Enables the individual to download, share, and manage their credentials at any time, including sharing to LinkedIn and other professional platforms
  • Cannot be closed or restricted by any institution, employer, partner, or cooperation programme
  • Allows the individual to configure their own data processing preferences and permission settings directly within the platform

Individuals may request closure of their Wallet account at any time by contacting info@easec.eu. Closure of a Wallet account does not delete certification issuance records maintained by EASEC for verification and audit purposes.


12A. Individual Data Control and Permission Management

Each individual with a personal EASEC Wallet account has full control over the data access permissions granted to institutions and employers that have administered EASEC assessments to them. Through their Wallet account settings, individuals may:

  • (a) View which institutions and employers currently have access to their assessment results, credential records, and profile data;
  • (b) Revoke access permissions granted to any specific institution or employer at any time, with immediate effect;
  • (c) Configure whether EASEC may use their individual data (beyond what is required for certification integrity) for internal research and improvement purposes;
  • (d) Exercise all applicable GDPR data subject rights directly through the platform interface.

Effect of Revoking Institutional Access

  • The institution or employer immediately loses all visibility of the individual's identifying data, including name, surname, email address, assessment results, credential records, and historical performance data.
  • The individual's data is anonymised from the institution's perspective. Aggregate and benchmarking data may remain available to the institution in fully non-identifiable form only.
  • EASEC continues to retain the individual's certification records and personal Wallet data in accordance with this Policy.
  • EASEC's obligations as certification issuer are independent of any institutional relationship.
  • Issued credentials remain permanently verifiable through EASEC's public verification infrastructure, as the integrity of the certification registry is a core function of EASEC's role as an independent certification authority and cannot be affected by institutional access revocation.

Effect of Revoking or Restricting EASEC's Own Processing

  • Certification issuance records and credential metadata cannot be deleted from EASEC's certification registry, as their retention is necessary to preserve the integrity of the verification system on which relying parties (employers, institutions, regulatory bodies worldwide) depend.
  • AI Engine data (open-text response, interpretive analysis, internal indicator) may be deleted upon a valid erasure request, subject to the 24-month retention period set out in Section 18, where no overriding legitimate interest applies.
  • All other personal data categories are subject to deletion or restriction rights as set out in Section 20.

13. Digital Credentials and Public Verification

  • Co-branded digital diploma — PDF bearing both the EASEC and institutional or employer logos, with a unique verification code and QR
  • Verifiable digital credential — shareable directly to LinkedIn and other professional platforms
  • Open Badge 3.0 — compatible with any standards-compliant digital wallet or badge platform
  • Europass Digital Credential (EDC) — compatible with the Europass infrastructure and portfolio
  • Blockchain-anchored credential — EASEC is developing an additional blockchain anchoring layer based on Polygon Soulbound Tokens (SBT), which will anchor the credential hash to a public blockchain for additional immutability and third-party verifiability. Where this feature is activated, full terms will be published separately. Blockchain anchoring does not alter the legal standing of the EASEC-issued credential.

Credential metadata includes framework alignment data mapped to ESCO, EQF, Tuning, WEF Future of Jobs, UNESCO, and O*NET as applicable.

Each credential carries a stated validity of three (3) years from issuance. The credential record is never deleted from EASEC's certification registry. Credentials are publicly verifiable at https://cert.easec.eu/certificates/verify. The verification service does not expose assessment response data or AI Engine outputs.


14. Co-Branding and Institutional Profiles

Credentials issued under an institutional agreement include the co-branding of both EASEC and the participating institution or employer. This co-branding does not transfer any data controller responsibility to the institution in respect of EASEC's certification records, nor does it alter EASEC's status as the sole legal issuing authority.

Where an institution operates as an EASEC Certification Centre or holds Programme Accreditation status, EASEC publishes and maintains an institutional profile on the EASEC website for the duration of the agreement. Programme Accreditation status is granted where an institution's programme demonstrates at least 80 % alignment with the applicable international competency frameworks (ESCO, EQF, Tuning, and WEF Future of Jobs). This profile may include the institution's name, logo, contact details, number of certified individuals, competency areas of strength, and accreditation status. Institutions may configure their profile through their administrative account on cert.easec.eu.


15. Third-Party Services and Technology Providers

ProviderPurposeData ProcessedLocation
OpenAI, LLCAI language model: situational scenario generation and response analysis (EASEC AI Engine)Open-text responses (transient API processing, not retained for training under DPA)USA (SCCs)
Anthropic PBCAI language model: internal workflow automation and quality assuranceInternal workflow data — not participant personal data for assessment purposesUSA (SCCs)
Google AnalyticsWebsite traffic analysis and performance measurementAnonymised usage data, session data, device/browser informationUSA (SCCs)
HubSpotCRM, marketing automation, and institutional communicationsContact details, communication history, interaction dataUSA (SCCs)
StripePayment processingPayment transaction references — card data processed directly by Stripe, not accessible to EASECUSA/EU (SCCs)
MetricoolSocial media scheduling and analyticsAggregated social engagement data — no personal data from EASEC usersSpain (EU)
Meta AdsPaid advertising and audience targeting on Facebook/InstagramAnonymised audience data, pixel events on websiteUSA (SCCs)
Google AdsPaid advertising and campaign measurementAnonymised conversion data, advertising identifiersUSA (SCCs)
CookieYesCookie consent managementCookie consent preferences and timestampsEU
Google Cloud PlatformCloud infrastructure and data storageAll personal data categories (stored within EEA region only)EU (EEA)
DigitalOceanCloud infrastructure and data storageAll personal data categories (stored within EEA region only)EU (EEA)
Provider
OpenAI, LLC
Location
USA (SCCs)
Purpose
AI language model: situational scenario generation and response analysis (EASEC AI Engine)
Data Processed
Open-text responses (transient API processing, not retained for training under DPA)
Provider
Anthropic PBC
Location
USA (SCCs)
Purpose
AI language model: internal workflow automation and quality assurance
Data Processed
Internal workflow data — not participant personal data for assessment purposes
Provider
Google Analytics
Location
USA (SCCs)
Purpose
Website traffic analysis and performance measurement
Data Processed
Anonymised usage data, session data, device/browser information
Provider
HubSpot
Location
USA (SCCs)
Purpose
CRM, marketing automation, and institutional communications
Data Processed
Contact details, communication history, interaction data
Provider
Stripe
Location
USA/EU (SCCs)
Purpose
Payment processing
Data Processed
Payment transaction references — card data processed directly by Stripe, not accessible to EASEC
Provider
Metricool
Location
Spain (EU)
Purpose
Social media scheduling and analytics
Data Processed
Aggregated social engagement data — no personal data from EASEC users
Provider
Meta Ads
Location
USA (SCCs)
Purpose
Paid advertising and audience targeting on Facebook/Instagram
Data Processed
Anonymised audience data, pixel events on website
Provider
Google Ads
Location
USA (SCCs)
Purpose
Paid advertising and campaign measurement
Data Processed
Anonymised conversion data, advertising identifiers
Provider
CookieYes
Location
EU
Purpose
Cookie consent management
Data Processed
Cookie consent preferences and timestamps
Provider
Google Cloud Platform
Location
EU (EEA)
Purpose
Cloud infrastructure and data storage
Data Processed
All personal data categories (stored within EEA region only)
Provider
DigitalOcean
Location
EU (EEA)
Purpose
Cloud infrastructure and data storage
Data Processed
All personal data categories (stored within EEA region only)

"SCCs" refers to EU Standard Contractual Clauses pursuant to Article 46 GDPR.

EASEC does not sell personal data to any third party and does not use personal data for behavioural advertising targeting individual users based on their assessment content or certification outcomes.


16. Data Sharing

  • Participating institutions and employers — for cohort analytics, quality reporting, and programme management, in accordance with institutional agreements and the individual's permission settings in their EASEC Wallet
  • Authorised Partners — only where explicitly authorised under the applicable Partner Agreement and limited to the data necessary for the partner's authorised function
  • Technology and infrastructure providers — listed in Section 15, for the operation and maintenance of EASEC platforms
  • Credential verification systems and infrastructures — including Europass and LinkedIn integrations, where individuals choose to share their credentials through those channels
  • Blockchain infrastructure providers — where the individual's credential is blockchain-anchored and the individual has consented to this feature
  • Competent authorities and supervisory bodies — where required by applicable law, court order, or regulatory investigation
  • Innzpira LLC — where billing and service delivery for USD-denominated EASEC for Work services requires data exchange between the two group entities, governed by an intra-group data transfer agreement incorporating appropriate safeguards
AI Engine Data — Absolute Non-Sharing Rule For the avoidance of doubt: open-text situational assessment responses, AI Engine interpretive analyses, and internal competency indicators are never shared with institutional Certification Centres, employers, Authorised Partners, cooperation programme participants, or any other third party. This restriction applies regardless of any institutional agreement, employer instruction, partner arrangement, or cooperation agreement. These data elements are accessible exclusively to the individual participant through their personal EASEC Wallet.

17. International Data Transfers

  • EU Standard Contractual Clauses (SCCs) — applied to transfers to providers in the USA and other non-adequate countries, pursuant to Article 46(2)(c) GDPR
  • Adequacy decisions — relied upon where the European Commission has determined that a recipient country provides an adequate level of protection
  • Intra-group agreement — governing data flows between INNZPIRA ANALYTICS S.L. and Innzpira LLC, incorporating SCCs

17A. Global Regulatory Compliance

EASEC operates in 64+ countries and is committed to meeting applicable data protection standards in each jurisdiction where its services are accessed. The following summarises EASEC's approach to key international regulatory frameworks in addition to EU GDPR.

India — Digital Personal Data Protection Act 2023 (DPDP Act)

For assessments involving participants located in India, EASEC acts as a Data Fiduciary within the meaning of the DPDP Act. EASEC processes personal data on the basis of consent obtained through the assessment consent mechanism. Participants in India have the right to access, correct, and erase their personal data, and to grievance redressal through EASEC's DPO. Cross-border transfers of Indian personal data to EASEC's EEA infrastructure are conducted under applicable lawful transfer mechanisms under the DPDP Act and its implementing rules.

Brazil — Lei Geral de Proteção de Dados (LGPD)

For Brazilian participants, EASEC processes personal data on the legal bases of contract performance and legitimate interest as provided under the LGPD. In accordance with Article 20 LGPD, participants have the right to request review of automated decisions. This right is operationalised through the Human Review Protocol described in Sections 10 and 10A.6, and through the ISO/IEC 17024-aligned appeals procedure.

Colombia — Ley 1581 de 2012

For Colombian participants, EASEC obtains express authorisation for the processing of sensitive data categories (including psychometric and situational assessment responses, which may relate to psychological characteristics) in accordance with the requirements of Ley 1581. The assessment consent mechanism constitutes the required express authorisation.

Chile — Ley 21.096 and Ley 19.628

For Chilean participants, EASEC applies the principles of purpose limitation, proportionality, and habeas data rights in accordance with applicable Chilean data protection law. Participants may exercise rights of access, rectification, cancellation, and opposition through the DPO.

Singapore — Personal Data Protection Act 2012 (PDPA)

For Singaporean participants and institutional clients, EASEC complies with PDPA obligations including purpose limitation, data accuracy, protection, and retention limitation. Cross-border transfers are conducted under the contractual arrangements required by the PDPA.

Japan — Act on the Protection of Personal Information (APPI)

For Japanese participants, EASEC processes personal data in accordance with APPI requirements regarding purpose specification, use limitation, and third-party disclosure restrictions. Cross-border data transfers comply with APPI rules.

Argentina — Ley 25.326 de Protección de Datos Personales

For Argentine participants, EASEC processes personal data in compliance with Ley 25.326, applying the principles of quality, purpose, consent, and security. Sensitive data (including psychometric data) is processed only with the express consent of the data subject.

Mexico — Ley Federal de Protección de Datos Personales en Posesión de los Particulares

For Mexican participants, EASEC acts as a Responsable del tratamiento and complies with the LFPDPPP, including the obligation to make an Aviso de Privacidad available and to honour ARCO rights (Acceso, Rectificación, Cancelación, Oposición).

Other Jurisdictions

For participants and clients in jurisdictions not specifically listed above, EASEC's GDPR-compliant processing framework provides a level of protection that meets or exceeds the requirements of most applicable national data protection laws. Individuals in any jurisdiction may exercise their rights through the DPO contact details set out in Section 4.


18. Data Retention

Data CategoryRetention PeriodJustification
Certification issuance records and credential metadataIndefinitelyPermanent verification and trust integrity of the certification registry
Assessment response data (psychometric instrument)Duration of certification + 5 yearsAudit trail and integrity assurance
AI Engine — open-text situational assessment responses24 months from assessment completionQuality assurance, instrument calibration, and dispute resolution
AI Engine — AI-generated interpretive analysis outputs24 months from assessment completionIndividual Wallet access and quality assurance
AI Engine — internal competency indicatorDuration of associated certification recordInstrument calibration and audit trail integrity
Assessment integrity monitoring dataDuration of integrity review + 24 months (or duration of enforcement/appeals where a breach is confirmed)AIF enforcement, appeals, and audit
Personal EASEC Wallet account dataUntil account closure by the individualContinued credential access by the individual
Institutional cohort analytics dataDuration of agreement + 24 monthsPost-contract quality review and dispute resolution
Programme Accreditation recordsDuration of accreditation + 5 yearsAudit, compliance, and re-accreditation reference
Quality and satisfaction survey responsesDuration of accreditation or agreementQuality monitoring purpose fulfilled at expiry
Billing and contract records (B2B and B2C)10 yearsLegal and tax retention obligations (Spain / applicable jurisdiction)
Support and communications data3 years from last interactionLegitimate interest in handling subsequent enquiries
Website technical and session data26 monthsPerformance analysis (Google Analytics default)
Cookie consent records12 monthsCompliance evidence
Credit activation recordsDuration of credit validity (24 months from activation) + 3 yearsCommercial record and dispute resolution
Data Category
Certification issuance records and credential metadata
Retention Period
Indefinitely
Justification
Permanent verification and trust integrity of the certification registry
Data Category
Assessment response data (psychometric instrument)
Retention Period
Duration of certification + 5 years
Justification
Audit trail and integrity assurance
Data Category
AI Engine — open-text situational assessment responses
Retention Period
24 months from assessment completion
Justification
Quality assurance, instrument calibration, and dispute resolution
Data Category
AI Engine — AI-generated interpretive analysis outputs
Retention Period
24 months from assessment completion
Justification
Individual Wallet access and quality assurance
Data Category
AI Engine — internal competency indicator
Retention Period
Duration of associated certification record
Justification
Instrument calibration and audit trail integrity
Data Category
Assessment integrity monitoring data
Retention Period
Duration of integrity review + 24 months (or duration of enforcement/appeals where a breach is confirmed)
Justification
AIF enforcement, appeals, and audit
Data Category
Personal EASEC Wallet account data
Retention Period
Until account closure by the individual
Justification
Continued credential access by the individual
Data Category
Institutional cohort analytics data
Retention Period
Duration of agreement + 24 months
Justification
Post-contract quality review and dispute resolution
Data Category
Programme Accreditation records
Retention Period
Duration of accreditation + 5 years
Justification
Audit, compliance, and re-accreditation reference
Data Category
Quality and satisfaction survey responses
Retention Period
Duration of accreditation or agreement
Justification
Quality monitoring purpose fulfilled at expiry
Data Category
Billing and contract records (B2B and B2C)
Retention Period
10 years
Justification
Legal and tax retention obligations (Spain / applicable jurisdiction)
Data Category
Support and communications data
Retention Period
3 years from last interaction
Justification
Legitimate interest in handling subsequent enquiries
Data Category
Website technical and session data
Retention Period
26 months
Justification
Performance analysis (Google Analytics default)
Data Category
Cookie consent records
Retention Period
12 months
Justification
Compliance evidence
Data Category
Credit activation records
Retention Period
Duration of credit validity (24 months from activation) + 3 years
Justification
Commercial record and dispute resolution

19. Security Measures

EASEC implements technical and organisational security measures in accordance with its ISO 27001 certification, including:

  • Encryption of data in transit (TLS/HTTPS) and at rest
  • Role-based access controls limiting data access to authorised personnel only
  • Continuous monitoring, intrusion detection, and security event logging
  • Secure cloud hosting environments (Google Cloud Platform, DigitalOcean) with geographic redundancy within the EEA
  • Regular automated backups and tested recovery procedures
  • Periodic security reviews and vulnerability assessments
  • Incident response procedures aligned with GDPR 72-hour breach notification requirements
  • Supplier security assessment for all third-party providers with access to personal data, including AI sub-processors
  • Internal data protection training for all EASEC personnel
  • Assessment integrity monitoring measures under the AIF, designed and operated in accordance with data minimisation and purpose limitation principles

In the event of a personal data breach likely to result in a high risk to the rights and freedoms of individuals, EASEC will notify affected individuals without undue delay and will notify the Agencia Española de Protección de Datos (AEPD) within 72 hours.


20. Data Subject Rights

RightDescription
AccessObtain confirmation of whether your data is processed and receive a copy of it
RectificationRequest correction of inaccurate or incomplete personal data
ErasureRequest deletion of personal data where legally permissible. Note: certification issuance records are retained indefinitely for verification integrity and may not be erased. AI Engine data may be deleted subject to the 24-month retention period.
RestrictionRequest that processing is restricted pending resolution of a dispute or objection
ObjectionObject to processing based on legitimate interests, including for direct marketing purposes
PortabilityReceive your data in a structured, commonly used, machine-readable format where technically feasible
Human review — certificationRequest human review of any automated certification decision pursuant to Article 22 GDPR
Human review — AI EngineRequest review of the AI Engine interpretive analysis by a qualified EASEC evaluator, pursuant to Article 22 GDPR and EU AI Act Article 50
AI analysis contestContest the AI Engine interpretive analysis if you believe it does not accurately represent you
Formal appealSubmit a formal appeal regarding any certification or enforcement decision through EASEC's ISO/IEC 17024-aligned appeals and complaints procedure (Policy P-APR-01)
Withdraw consentWithdraw previously given consent at any time without affecting the lawfulness of prior processing
Permission managementManage institutional and employer data access permissions directly through your EASEC Wallet account settings
Lodge a complaintLodge a complaint with the Agencia Española de Protección de Datos (AEPD) at www.aepd.es, or with your national supervisory authority
Right
Access
Description
Obtain confirmation of whether your data is processed and receive a copy of it
Right
Rectification
Description
Request correction of inaccurate or incomplete personal data
Right
Erasure
Description
Request deletion of personal data where legally permissible. Certification issuance records are retained indefinitely for verification integrity and may not be erased. AI Engine data may be deleted subject to the 24-month retention period.
Right
Restriction
Description
Request that processing is restricted pending resolution of a dispute or objection
Right
Objection
Description
Object to processing based on legitimate interests, including for direct marketing purposes
Right
Portability
Description
Receive your data in a structured, commonly used, machine-readable format where technically feasible
Right
Human review — certification
Description
Request human review of any automated certification decision pursuant to Article 22 GDPR
Right
Human review — AI Engine
Description
Request review of the AI Engine interpretive analysis by a qualified EASEC evaluator, pursuant to Article 22 GDPR and EU AI Act Article 50
Right
AI analysis contest
Description
Contest the AI Engine interpretive analysis if you believe it does not accurately represent you
Right
Formal appeal
Description
Submit a formal appeal regarding any certification or enforcement decision through EASEC's ISO/IEC 17024-aligned appeals and complaints procedure (Policy P-APR-01)
Right
Withdraw consent
Description
Withdraw previously given consent at any time without affecting the lawfulness of prior processing
Right
Permission management
Description
Manage institutional and employer data access permissions directly through your EASEC Wallet account settings
Right
Lodge a complaint
Description
Lodge a complaint with the Agencia Española de Protección de Datos (AEPD) at www.aepd.es, or with your national supervisory authority

Requests may be submitted to info@easec.eu or directly to the DPO at mfernandez@easec.eu. EASEC will verify the identity of the requestor before processing and will respond within thirty (30) calendar days.


21. Cookies

EASEC uses cookies and similar tracking technologies on www.easec.eu. Cookie consent is managed through CookieYes, a GDPR-compliant Consent Management Platform.

You can manage your preferences at any time through the cookie settings panel available in the website footer.

Only strictly necessary cookies are activated without your consent. All other cookie categories — Analytics, Marketing, and Functional — require your explicit consent before being activated. For full details, refer to EASEC's Cookie Policy.

CategoryCookie / ProviderPurposeDuration
NecessaryCookieYes consent tokenStores the user's cookie consent preferences12 months
NecessarySession cookieMaintains authenticated session state on cert.easec.euSession
AnalyticsGoogle Analytics (_ga, _gid)Measures website traffic, page views, and user behaviour in anonymised formUp to 26 months
MarketingMeta PixelTracks website events to measure the effectiveness of Facebook/Instagram advertising campaigns90 days
MarketingGoogle Ads (gclid)Measures conversions from Google Ads campaigns90 days
FunctionalHubSpot chat widgetEnables live chat support functionality and remembers user preferences13 months
Category
Necessary
Duration
12 months
Cookie / Provider
CookieYes consent token
Purpose
Stores the user's cookie consent preferences
Category
Necessary
Duration
Session
Cookie / Provider
Session cookie
Purpose
Maintains authenticated session state on cert.easec.eu
Category
Analytics
Duration
Up to 26 months
Cookie / Provider
Google Analytics (_ga, _gid)
Purpose
Measures website traffic, page views, and user behaviour in anonymised form
Category
Marketing
Duration
90 days
Cookie / Provider
Meta Pixel
Purpose
Tracks website events to measure the effectiveness of Facebook/Instagram advertising campaigns
Category
Marketing
Duration
90 days
Cookie / Provider
Google Ads (gclid)
Purpose
Measures conversions from Google Ads campaigns
Category
Functional
Duration
13 months
Cookie / Provider
HubSpot chat widget
Purpose
Enables live chat support functionality and remembers user preferences

22. Research, Benchmarking, and Standard Development

  • Improving and validating psychometric assessment instruments and the EASEC AI Engine
  • Developing international skills benchmarks and competency profiles aligned with ESCO, EQF, Tuning, WEF, UNESCO, and O*NET frameworks
  • Producing anonymised sector or regional reports on competency trends
  • Advancing research on employability competencies in collaboration with academic or institutional partners
  • Supporting the evolution of the EASEC certification standard
  • Academic publications, conference contributions, and collaborative research projects

EASEC does not sell personal data. EASEC does not use personal data for behavioural advertising. Research outputs do not include any individually identifiable information. Individuals may configure their research processing preference through their EASEC Wallet account settings.


23. Changes to This Policy

EASEC may update this Privacy Policy to reflect changes in applicable law, operational practices, or the services offered. Material changes will be communicated by updating the "Last updated" date at the top of this Policy and, where appropriate, by direct notification to registered users, Authorised Partners, or institutions.

Continued use of EASEC services following publication of an updated Policy constitutes acceptance of the revised terms. Prior versions may be obtained by contacting info@easec.eu.


24. Contact

Data Protection Officer
Moisés Fernández — Head of IT

mfernandez@easec.eu

General Privacy Enquiries
EASEC — European Accreditation of Soft Skills & Employability Competencies

C. de la Travesía, Poblados Marítimos, 46024 València, Valencia, Spain

info@easec.eu  ·  support@easec.eu  ·  partners@easec.eu

Supervisory Authority — Spain
Agencia Española de Protección de Datos (AEPD)

www.aepd.es

You have the right to lodge a complaint with the AEPD or with your national data protection supervisory authority if you believe your rights under GDPR or any other applicable data protection law have been violated.