ClickTrain Recruitment & Skills Testing Policy
1. Purpose and Scope
Last updated: 14 February 2026
This policy explains how ClickTrain Marketing Platform Ltd ("ClickTrain", "we", "us", "our") collects and processes personal information in connection with our recruitment, talent matching and skills-testing services for specialists (talent) who use our Platform at www.clicktrain.com ("Platform"). It is intended to be read alongside our main Privacy Policy and our ASUM & Google Ads Tokens Policy.
This policy applies to all individuals who create a talent profile, self-rate their skills, participate in assessments, or are matched to agencies or employers through the Platform ("you"). It does not cover data collected through agency ranking and advertising accounts, which are addressed in our ASUM & Google Ads Tokens Policy.
2. Data We Collect for Recruitment
We collect the following categories of personal data to facilitate recruitment and skills assessment:
- 1. Profile information: contact details (name, email, phone), professional history (skills, experience, certifications, portfolio), salary expectations, availability, and geographic preferences.
- 2. Self-rated skills: ratings that you provide for your own abilities in specific areas (e.g., paid advertising, analytics, design).
- 3. Assessment results: results of manual or automated tests, including scores, qualitative feedback and certification status. Assessments are carried out by our independent assessment team.
- 4. Work preferences: details about the roles you are interested in, types of contracts (full-time, freelance, etc.), and working arrangements (on-site, hybrid, remote).
- 5. Profile video: a short video (currently up to two minutes) recorded via our platform and hosted on api.video. You may choose to record a video to introduce yourself. The video is stored through api.video’s secure service and is shared only with our recruitment staff and prospective employers when you consent.
- 6. Right-to-work verification: results from third-party identity checks (currently provided by Veriff) confirming your eligibility to work in your country of residence. This may include the verification status and reference numbers but does not include copies of your identity documents. We do not store biometric data; Veriff processes the verification on our behalf.
- 7. Communications: correspondence related to recruitment, interviews, feedback and support requests.
We do not collect or process special category data (e.g., race, ethnicity, health information) for recruitment.
3. Use of Data
We use the data described above for the following purposes:
- 1. Candidate evaluation and matching: to assess your suitability for specific roles based on your skills, experience, salary expectations, location, profile video and right-to-work status, and to present your profile to agencies or employers.
- 2. Skills testing: to design and administer assessments that measure your proficiency in certain areas. Self-rated skills may determine which tests we offer you. Our independent assessment team manually marks tests and assigns scores.
- 3. Ranking of talent profiles: to order profiles in search results presented to agencies. The ranking is influenced by your self-rated skills, assessment scores, experience, certifications and salary expectations; and for roles requiring in-person work, by your proximity to the client’s office or for remote roles by country. We do not rank based on demographic or sensitive personal data.
- 4. Agency evaluation: to transparently present agencies to candidates we showcase ad spend under management, verified certifications, performance metrics and business reviews. Agency ranking is covered in the ASUM & Google Ads Tokens Policy.
- 5. Communication: to schedule interviews, provide feedback and answer your queries.
- 6. Analytics and improvement: to analyse recruitment processes, refine our assessments and improve user experience. We may analyse anonymised video metadata (e.g., completion rate) but not the content itself.
- 7. Compliance and dispute resolution: to comply with legal obligations, maintain records and resolve disputes. For example, we may need to retain right-to-work verification data to demonstrate compliance with employment laws.
We rely on contractual necessity and our legitimate interests to process recruitment data, and we will obtain your consent for optional tests, recording your video or marketing communications.
4. Skills Testing and Assessment Process
- Self-ratings: when you create a profile, you may rate your proficiency in various skills. These self-ratings help us propose appropriate assessments and match you to roles.
- Manual assessments: you may opt to undertake assessments for specific skills. These assessments are reviewed and scored by a neutral, independent assessment team. The results are used to verify your skills and may influence your ranking.
- Certification verification: we may require proof of certifications (e.g., Google Ads certification). Our team verifies these credentials manually.
- Profile video: you may choose to record a short video via our platform. The video is hosted by api.video and allows agencies to get to know you beyond your CV. We will not share the video without your consent and you can delete it at any time by contacting us.
- Right-to-work checks: we use a third-party provider (currently Veriff) to confirm your eligibility to work. The provider processes your identity documents and returns a verification status. We store the status and reference number but not your documents or biometric data.
- Human oversight: although our system can suggest candidates based on scores, experience, video and other factors, a human reviewer always validates matches before presenting you to an agency or employer, and you must provide consent before we submit your profile.
5. Automated Decision-Making and Fairness
Our Platform uses algorithms to match candidates to opportunities and to rank talent profiles. The Information Commissioner’s Office notes that fairness requires handling personal data in ways people reasonably expect and avoiding unjustified adverse effects. To meet these fairness obligations:
- Relevant factors only: our matching algorithm uses only job-relevant factors such as skills, assessment scores, experience, certifications, salary expectations, and location. We do not use any sensitive personal data or right-to-work results beyond verifying eligibility.
- Mitigating bias: AI systems trained on unbalanced or biased data may produce discriminatory outputs. We mitigate this by monitoring our training data, auditing outcomes and adjusting the algorithm where needed.
- Human review: decisions about which candidates to recommend include a human element. Our assessment team and account managers review algorithmic outputs and can override them.
- Right to contest: you have the right to obtain human intervention, express your point of view and contest any automated decision that significantly affects you.
- Transparency: we provide this policy and explain the criteria we use to match and rank candidates. We continuously review our processes to ensure compliance with equality laws and non-discrimination principles.
6. Data Sharing
We share your recruitment data as follows:
- With agencies or employers: when you agree to be considered for a role, we share relevant parts of your profile: including your video (if you consent), assessment results and right-to-work verification status—with the prospective agency or employer.
- Independent assessment team: we share your name, test responses and assessment video with our independent assessment team solely for the purpose of marking skills tests and verifying certifications. They do not use or share your personal data for any other purpose.
- Identity verification provider: we share your identity documents and data only with Veriff to perform right-to-work checks. Veriff processes this data on our behalf and does not use it for any other purpose. We retain only the verification status and reference number.
- Service providers: we use third-party services for hosting (including api.video), analytics, communications and security. These providers process personal data only under our instructions and subject to confidentiality obligations.
- Legal authorities: if required by law or necessary to protect our rights, we may disclose personal data to authorities.
- Aggregated data: we may share aggregated or anonymised statistics that do not identify you.
We do not sell or rent your personal data.
7. Data Retention
- Profile data, self-ratings and profile video: retained for as long as your account is active. If you delete your account or ask us to remove the video, we will delete these data within a reasonable period unless retention is required by law or necessary for disputes.
- Assessment results: stored for as long as necessary to evaluate your suitability for roles and to verify our matching process, after which we may anonymise the data.
- Right-to-work verification results: retained for the duration necessary to demonstrate compliance with employment laws. The underlying identity documents processed by Veriff are not stored by us.
- Communications: retained as needed to provide support and for record keeping.
- Analytics: aggregated or anonymised data may be retained for analysis and improvement.
8. Security and International Transfers
Your recruitment data is stored on secure servers hosted in the UK. We implement encryption, role-based access controls and monitoring to protect data against unauthorised access. We use Firebase Authentication for login, so we do not store your passwords or OAuth tokens; tokens are stored in your browser. If we transfer personal data outside the UK, we use legally recognised transfer mechanisms such as Standard Contractual Clauses.
9. Your Rights
You have the rights set out in our main Privacy Policy, including rights to access, correct, delete and restrict processing of your data; rights to object to certain processing; rights related to automated decision-making; and the right to withdraw consent for your video or other optional data. To exercise your rights, contact dpo@clicktrain.com.
10. Changes to This Policy
We may update this Recruitment & Skills Testing Policy from time to time. When we make significant changes, we will post the updated policy on our website and, where appropriate, notify you. The updated policy will take effect when posted.
11. Contact Us
If you have questions or concerns about this policy or our recruitment processes, please contact dpo@clicktrain.com.