Last updated on 27 March 2026

The present privacy notice explains how the Council of Europe and TestReach (“we”) use the personal data collected from you when you undergo an online assessment procedure. The online assessment is administered by TestReach on behalf of the Council of Europe and may consist of a test, exam, quiz, survey, or other kind of assessment considered appropriate by the Council of Europe for the purposes of the competitive recruitment procedure for which you applied.

1. Who is responsible for data processing?

The Council of Europe is the “data controller” with respect to any assessment-related personal data, it has the decision-making power concerning the data processing. Processing of your personal data is governed by the Council of Europe Regulations on the Protection of Personal Data adopted by the Committee of Ministers on 15 June 2022.

TestReach is a company based in Dublin, Ireland. It has developed a cloud-based solution used to create, deliver and mark any type of assessment. With regard to the processing of personal data within the framework of the online assessment, TestReach is the “data processor”, which means it processes personal data on behalf of the Council of Europe. 

For any personal data that TestReach collects through its websites and software and uses for the purposes related to provision of its service, independently of the assessments performed for the Council of Europe, TestReach is the “data controller”. 

2. What data do we process?

Prior to and during your taking an online assessment administered by TestReach, the Council of Europe may collect, receive or store – using TestReach services – personal information that you provided, which notably includes your name, contact details, date and place of birth.

Online assessment uses remote invigilation, a method by which formal exams are supervised over the web. TestReach will record a video taken by your own computer webcam of you sitting the assessment. TestReach will also ask you to show your photo-ID to the camera for identification purposes at the beginning of recording the video. TestReach does not take photographs of candidates or of their identification documents during the invigilation process.

Should you contact TestReach with support or troubleshooting questions, it may ask you to provide personal information for identification purposes. 
When you are taking an assessment using TestReach software, the TestReach Desktop Application, it automatically records user access and activity data within the system (for instance, when you logged in, when you logged out, when you answered a question, when you paused, etc). 

TestReach also records information about the computer and technology you use to take the assessment. This includes, in particular, your IP address, information about the type and version of your browser, your operating system, installed drivers and external devices connected to your computer, details of other computer processes running, RAM (random-access memory) and CPU (central processing unit) usage statistics.

The TestReach Desktop Application uses cookies to remember your login details. In particular, TestReach keeps records of the preferred language, username, user ID and organisation ID of the last user that logged in so as to make the next login quicker, as you will only need to type the password. Information kept in the cookies expires with the HTTP Session, which is configured to last 24 hours.

3. For what purposes do we process your personal data? 

3.1. Assessment-related data

The Council of Europe will use the information collected for the exclusive purpose of processing your application for the job vacancy you applied for.

TestReach may process your personal data for authentication purposes and to record your activity on the computer during the online assessment. The video recording of the assessment has the sole purpose of ensuring the integrity of the assessment process. 

Upon instructions of the Council of Europe, TestReach may collect and score your responses and derive an assessment score. In this connection, the Council of Europe may use the data collected to generate reports about your results. 
3.2. Data related to provision of service

TestReach may collect and use your personal data for the following purposes: 

• to provide you with a better user experience and to help make the assessment experience more effective, in particular, by ensuring smooth installation and running of the TestReach Desktop Application; 
• for maintenance and improvement of its products and services, including the TestReach Desktop Application; 
• when you contact TestReach with support or troubleshooting questions, for identification purposes, to correspond with you regarding the issue and to improve your support experience.  

TestReach ensures a similar level of protection to the above data as to assessment-related data.

4. What is the legal basis for our processing of your data?

The Council of Europe processes your personal data on the basis of its Staff Regulations and Rules and other applicable internal legal instruments.  

We also process personal data in order to take steps at the request of the individual prior to entering into a contract with her or him.

TestReach also processes data related to the provision of service on the basis of its legitimate interest to improve the quality of its services.

5. Who has access to your data?

Your personal data are accessible to the Council of Europe staff members responsible for recruitment.

The Secretary General and staff members to whom the Secretary General has delegated authority in accordance with the general delegation framework may also have access to your data in accordance with the delegation.

Your personal data are also accessible to TestReach’s online invigilators and staff responsible for technical assistance.

6. How do we store your personal data?

All personal data are stored on the Council of Europe’s and TestReach’s servers located in the European Union. We have put in place measures to protect the security of personal information, including appropriate security measures to prevent the personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. These measures include encrypted servers, limited access to any databases only for those people who need it and secure backup of all data.

7. How long will your data be stored?

The Council of Europe will store your personal data for five years. 

All video data is retained on TestReach systems for a period of six weeks following the online assessment, after which it is deleted, unless particular needs require it to be held for a longer period, for example, in the case of an appeal process.

The information about the computer and technology you use to take the assessment which served the purposes of audit trail of the assessment is securely stored in TestReach database for the duration of the contract between the Council of Europe and TestReach, or until the Council of Europe specifically instructs TestReach to delete it.  

The information used by TestReach with a view to improve its services and technology is stored in a form that does not permit identification.

8. What are your data protection rights?

You have the right to: 

• request access to your personal information held by us;
• request that we correct incomplete or inaccurate personal information that we hold about you;
• request we delete or remove your personal information when there is no valid reason for us to keep it;
• object to the processing of your personal information on specific grounds relating to your situation.

9. Contacts

If you wish to exercise the above rights, or for any queries, concerns, or requests you may have in connection with the way your data is collected and used, please contact the Council of Europe by: 

• sending an email to [email protected]
• sending a request by post to Recruitment and Employment Management Division / Directorate of Human Resources / Council of Europe / F-67075 Strasbourg 
• sending an email to the Council of Europe’s Data Protection Officer at [email protected].

If you feel that we have not adequately responded to your request and consider that your data protection rights have been violated as a result of our processing of your personal data, you have the right to lodge a complaint with the Council of Europe Data Protection Commissioner by sending an e-mail to [email protected].