Introduction

AeroProfessional (“we”, “us”, or “our”) is committed to protecting and respecting the personal data that we hold. This privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights. It applies to personal data provided to us both by individuals themselves or by others. We may use personal data provided to us for the purposes described in this privacy statement or as made clear before collecting personal data.

Personal data is any information relating to an identified or identifiable living person. When collecting and using personal data, our policy is to be transparent about why and how we process personal data.

We process personal data for numerous purposes and the means of collection, lawful basis of processing, use, disclosure and retention periods for each purpose are set out in the relevant sections below.

The personal data that is provided to us is provided either directly from the individual concerned, from a third party acting on behalf of an individual, or from publicly available sources (such as internet searches).

Where we receive personal data that relates to an individual from a third party, we request that this third party informs the individual of the necessary information regarding the use of their data. Where necessary, reference may be made to this privacy statement.

Security

We take the security of all the data we hold seriously. Our staff are trained on data protection, confidentiality and security.

We have a framework of policies and procedures which ensure we regularly review the appropriateness of the measures we have
in place to keep the data we hold secure.

All personal data that is provided to us is stored on our secure servers.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website, systems or apps; any transmission is therefore at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Data that we hold

General

We provide services to individuals as well as organisations. The exact data held will depend on the services to be provided.

Where we engage with individuals, we may collect and process personal data in order to establish and/or satisfy contractual or operational obligations. We request that individuals only provide the personal data that is required for us to fulfil our contractual or operational obligations.

Why do we process data?

Where data is collected it is used for a number of purposes, as follows;

• Providing services to you. Data is processed to either place applicants into a job vacancy, or to advertise a vacancy for a client. This may sometimes be further clarified in written documentation supplied before any data processing may occur.
• Individual needs. When communicating with and assessing the needs of a candidate or client, personal data may be processed in order to ensure that their needs are appropriately satisfied. This may include assessing whether the collection of services provided to our clients are appropriate.
• Administration. In order to manage and administer our business and services, we may collect and process personal data. This may include (but is not limited to) maintaining internal business records, managing candidate and client relationships, hosting recruitment assessment days and administering candidate / client facing applications.
• Regulatory. In order for AeroProfessional to do what it does, we may from time to time be required to collect and process personal data in order to fulfil contractual, regulatory, legal and/or ethical requirements. This may include (but is not limited to) verifying the identity of individuals.

What data is processed?

The data that is processed is dependent on the service that is being provided and on the recipient of this service.

• Services to candidates. Personal data may include (but is not limited to) gender, name, email address, date of birth, country of birth, nationality, contact details, identity document details, job title, employment dates, career history, qualifications, reference information, criminal record details, credit rating details, and any other specifically relevant data.
• Services to clients: Personal data may include (but is not limited to) name, corporate contact details, job title any other specifically relevant data.

How long do we hold data for?

We retain the personal data processed by us for as long as is considered necessary for the purpose(s) for which it was collected. Where personal data is held with a view to placing applicants into job vacancies, we will hold the data for no longer than 5 years after the most recent contact with the applicant or 5 years after the termination of the most recent placement, whichever is later. There may also be occasions which will require data to be kept for longer, however this will typically be for legal purposes.

Our role as a data processor

When supporting some clients with parts of their recruitment process (mainly where candidates apply directly to a client and the client outsources part(s) of the recruitment process to us) AeroProfessional is the data processor and our client is the data controller. Personal data which we process on behalf of our clients is stored on our secure servers and is protected by the same security measures as those which govern how we operate as a data controller.

Why do we process data?

Where we act as the data processor and process personal data on behalf of our clients, this is done for the following purposes;

• To fulfil contractual obligations towards our clients.
• To enable our clients to perform security, quality and risk management activities.
• So that our clients can comply with any requirement of law, regulation or a professional body of which they are a member. Our clients are subject to legal, regulatory and professional obligations. We need to keep certain records to show how our clients comply with those obligations and those records may contain personal data.
• To enable prospective clients to evaluate our products and services.
• Relationship management.
• Administration and management.

What data do we hold and process?

Personal data that we hold and process on behalf of our clients may include (but is not limited to) gender, name, email address, date of birth, country of birth, nationality, contact details, corporate contact details, identity document details, job title, employment dates, career history, qualifications, reference information, criminal record details, credit rating details, details of the communication between us and any other specifically relevant data.

How long do we hold data for?

When holding and processing data on behalf of our clients (where each client is the data controller and we are the data processor) we retain the personal data only for as long as our contractual obligations towards each client requires. If a retention period has not been contractually specified, we will hold the data for no longer than 5 years after the completion of the recruitment process to which the personal data relates.

Business contacts

Personal data from our contacts, which covers both potential and prior customers, as well as potential and prior employees are held in our customer relationship management tool (CRM tool).

This information is entered into our systems after contact is made between a staff member of AeroProfessional and an individual or a business contact individual.

Why do we process data?

Where personal data on business contacts is held, it is used for a number of purposes, as follows;

• Promoting and developing our services.
• Hosting and facilitating events.
• Relationship management.
• Administration and management.

What data do we hold?

Personal data that may be held and processed includes (but is not limited to) name, email address, corporate contact details, job title, details of the communication between us and any other specifically relevant data.

How long do we hold data for?

We retain the personal data processed by us for as long as is considered necessary for the purpose(s) for which it was collected.

Our people

We collect personal data for our people as part of the administration, management and promotion of our business activities.

Our staff handbook explains further how personal data is held for our staff.

Applicants

Where an individual is applying to work for AeroProfessional, personal data is collected through the application process.

There are a number of purposes for which personal data for applicants is collected.

• Employment. We process an applicant’s personal data in order to assess their potential employment at AeroProfessional.
• Administration and management. We may also use this personal data in order to make informed management decisions and for administration purposes.

Personal data collected for applicants is held for as long as necessary in order to fulfil the purpose for which it was collected, or for a maximum of one year where those purposes no longer become necessary.

Suppliers

We collect and process personal data about our suppliers, subcontractors, and individuals associated with them. The data is held to manage our relationship, to contract and receive services from them, and in some cases to provide professional services to our clients.

Why do we process data?

• Receiving goods and services. We process personal data in relation to our suppliers and their staff as necessary to receive the services.
• Providing services to our clients. Where a supplier is helping us to deliver professional services to our clients, we process personal data about the individuals involved in providing the services in order to administer and manage our relationship with the supplier and the relevant individuals and to provide such services to our clients.
• Administering, managing and developing our business and services. We process personal data in order to run our business, including:
  • managing our relationship with suppliers;
  • developing our business and services (such as identifying client needs and improvements in service delivery);
  • maintaining and using IT systems; and
  • hosting or facilitating the hosting of events.
  • administering and managing our website, systems and apps.
• Security, quality and risk management activities. We have security measures in place to protect our and our suppliers’ information (including personal data), which involve detecting, investigating and resolving security threats. Personal data may be processed as part of the security monitoring that we undertake; for example, automated scans to identify harmful emails. We have policies and procedures in place to monitor the quality of our services and manage risks in relation to our suppliers. We collect and hold personal data as part of our supplier contracting procedures. We monitor the services provided for quality purposes, which may involve processing personal data.
• Complying with any requirement of law, regulation or a professional body of which we are a member. We are subject to legal, regulatory and professional obligations. We need to keep certain records to show we comply with those obligations and those records may contain personal data.

What data do we hold?

We will hold supplier’s names, contacts names, and contact details of suppliers.

How long do we hold data for?

We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected. Data may be held for longer periods where required by law or regulation and in order to establish, exercise or defend our legal rights.

People who use our website or apps

When people visit our website or use our apps, personal data is collected both through automated tracking and interacting with various forms on the website or apps.

Personal data may be collected when individuals fill in forms on our website or apps or by corresponding with us by phone, e-mail or otherwise. This includes information provided when an individual registers to use our website or apps, to subscribe to our service or to make an enquiry.

The collection of personal data through automated tracking is achieved through the use of cookies. A cookie is a small data file that certain websites write to your hard drive when you visit them. A cookie file can contain information such as a user ID that the website uses to track the pages you’ve visited, but the only personal data a cookie can contain is information which you supply yourself. A cookie can’t read personal data off your hard disk or read cookies created by other sites. Some parts of our website use cookies to track user traffic patterns. We do this in order to determine the usefulness of our website to our users and to see how effective our navigational structure is in helping users reach certain information.

If you prefer not to receive cookies whilst using our website, you can set your browser to warn you before accepting cookies and refuse the cookie when your browser alerts you to its presence. You can also refuse all cookies by turning them off in your browser, although you may not be able to take full advantage of our website if you do so. In particular, you may be required to accept cookies in order to complete certain actions on our website, including those which require you to be logged-in. You do not need to have cookies turned on, however, to use/navigate through many parts of our website.

Sharing personal data

We will only share personal data with others when we are legally permitted to do so. When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards.

Personal data held by us may be transferred to:

• Third party organisations that otherwise assist us in providing goods, services or information.
• Professional Services: This may include HR, Legal, Medical advisors who may receive your data in order to provide advice
  on your suitability to a vacancy.
• Clients: They may receive your data to assess your suitability for a vacancy applied for.
• Law enforcement or regulatory agencies or those required by law or regulations.
• Business contacts, clients and suppliers, where such sharing is permitted under contract or under applicable law or regulation

Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.

Locations of processing

Where possible, personal data resides within the UK territory but may be transferred to, and stored at, a destination outside the European Economic Area (EEA).

Individual’s rights

Individuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights
as follows:

• Individuals may request access to their personal data held by us as a data controller.
• Individuals may request us to rectify personal data submitted to or held by us or, where appropriate, contact us via the relevant website registration page or by amending the personal details held on relevant applications with which they registered.
• Individuals may request that we erase their personal data.
• Where we process personal data based on consent, individuals may withdraw their consent at any time by contacting us or clicking on the unsubscribe link in certain emails received from us.
• Individuals may have other rights to restrict or object to our processing of personal data and the right to data portability.
• Individuals may request information about, or human intervention into, any automated data processing that we may undertake.

If you wish to exercise any of these rights, please send an email to dataprotection@aeroprofessional.com.

Complaints

We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to dataprotection@aeroprofessional.com. We will look into and respond to any complaints we receive.

You also have the right to lodge a complaint with the UK data protection regulator, the Information Commissioner’s Office (“ICO”). For further information on your rights and how to complain to the ICO, please refer to the ICO website https://ico.org.uk/concerns

Data controller and contact information

The data controller for AeroProfessional is AeroProfessional Limited. When supporting some clients with parts of their recruitment process (mainly where candidates apply directly to a client and the client outsources part(s) of the recruitment process to us) AeroProfessional is the data processor.

If you have any questions about this privacy statement or how and why we process personal data, please contact us at:

AeroProfessional Limited, 33 Hercules Way, Farnborough Aerospace Centre, Farnborough, Hampshire GU14 6UU

Changes to our privacy statement

Updates to this privacy statement will appear on this website. This privacy statement was last updated on 21/05/2018