This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.
The General Data Protection Regulation (GDPR) seeks to protect and enhance the rights of data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU. It should be noted that GDPR does not apply to information already in the public domain.
SG Aviation Services Ltd. is pleased to provide the following Privacy Notice:
SG Aviation Services Ltd. uses the information collected from you to provide recruitment services, make telephone contact and to email you job opportunities which SG Aviation Services Ltd. believes may be of interest to you based on your qualifications. In you making initial contact you consent to SG Aviation Services Ltd. maintaining a recruitment dialogue with you until you either opt out (which you can do at any stage) or we decide to desist in promoting our job opportunities. SG Aviation Services Ltd. does not act as a data processor on behalf of any third parties.
Personal data is any information relating to an identified or identifiable living person. At SG Aviation Services Ltd. we collect personal data from your CV including name, phone number, email ID, date of birth, nationality, licence type, medical status, etc. If you progress to an application for a SG Aviation Services Ltd. client airline then we will collect documents from you including Licence copy, Medical copy, Passport copy, Criminal Record Check, etc. If you progress to an assessment for a SG Aviation Services Ltd. client airline then we will collect further information and documents – including in some cases Reference Checks with your specific consent. If you become a directly engaged contractor where SG Aviation Services Ltd. manages payroll then we will collect your Bank Details. All personal data held at SG Aviation Services Ltd. is processed to assist you in your current or future endeavours to enter into a contract or employment with a SG Aviation Services Ltd. client airline.
Some personal data may be collected about you from the registration or application forms you complete, from records of our correspondence, attachments you add to correspondence and phone calls. Additionally details of your visits to our website, including but not limited to personally identifying information like Internet Protocol (IP) addresses is collected. SG Aviation Services Ltd. may from time to time use such information to identify its visitors. SG Aviation Services Ltd. may also collect statistics about the behavior of visitors to its website. By using our website you consent to us collecting, holding and processing this information.
Any information SG Aviation Services Ltd. holds about you encompasses all the details we hold about you and any job application history.
SG Aviation Services Ltd. will only collect the information needed so that it can provide you with recruitment services. This agency does not sell or broker your data and will never share your data with third parties without your permission. Coincidentally there may be times when your information could be contained in data that SG Aviation Services Ltd. has obtained from a third-party company (for example if your preferences on a jobs board include ‘Allow Recruiter View’ for your uploaded CV).
Legal basis for processing any personal data
CONTRACT – GDPR Article 6 (1) (b)
To meet SG Aviation Services Ltd.’s contractual obligations to client airlines.
To assist you in your current or future endeavours to enter into a contract or employment with a SG Aviation Services Ltd. client airline.
CONSENT – GDPR Article 6 (1) (a)
In certain circumstances SG Aviation Services Ltd. will rely on consent for specific uses of your personal data and, in those cases, you will be asked for your express consent if legally required. Examples of when consent may be the lawful basis for processing include permission to introduce you to an airline client, permission to share your personal data and documents with an airline client, and similar.
Legitimate interests pursued by SG Aviation Services Ltd.
To promote the recruitment services offered by SG Aviation Services Ltd. and to market the job opportunities offered by SG Aviation Services Ltd.’s existing and future airline clients. Pursuance of these legitimate interests include the need to:
- Retain records of our processing and where applicable use such records for establishing compliance with contractual obligations with client airlines
- Address queries that may arise including establishing, exercising or defending any legal claims
- Protect our reputation
- Maintain a backup of our system, solely for the purpose of being able to restore the system to a particular point in the event of a system failure or security breach
- Evaluate quality and compliance including compliance with this Privacy Notice
Through agreeing to this privacy notice you are consenting to SG Aviation Services Ltd. processing your personal data for the purposes outlined. You can withdraw consent at any time by emailing firstname.lastname@example.org or by writing to us (see last section for full contact details). However, please note that we may continue to retain, or otherwise use your personal information thereafter where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary in furtherance of those interests or obligations.
SG Aviation Services Ltd. may on occasion pass your personal data to third parties exclusively to process work on its behalf. To clarify, SG Aviation Services Ltd. utilises services, products and software provided by third parties – e.g. database software, website management – and as a result these parties may have access to certain personal data owned by you. SG Aviation Services Ltd. requires these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice and GDPR regulations.
SG Aviation Services Ltd. may on occasion pass your personal data to our airline clients in order to submit your application and represent your candidacy for specific job opportunities. SG Aviation Services Ltd. will always seek your express consent and permission to do so.
SG Aviation Services Ltd. do not broker or pass on information gained from your engagement with the agency without your consent. However, SG Aviation Services Ltd. may disclose your Personal Information to meet legal obligations, regulations or valid governmental request. The agency may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of SG Aviation Services Ltd., its clients and/or the wider community.
SG Aviation Services Ltd. will process personal data on the following timeframes:
– CVs: up to age 70 (or as applicable dependant on aviation regulatory guidelines)
– Documentation provided in support of job applications: for 6 years after the vacancy has closed to prove compliance with any contractual obligations
– Bank details: for 6 years after the contract has expired
After the timeframes specified above any personal data not needed will be deleted. This does not contravene your rights as a Data Subject – as outlined below.
Data is held in Ireland using multiple servers. SG Aviation Services Ltd. does not store personal data outside the EEA.
Your rights as a data subject
At any point whilst SG Aviation Services Ltd. is in possession of or processing your personal data, all data subjects have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
In the event that SG Aviation Services Ltd. refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.
SG Aviation Services Ltd., at your request, can confirm what information it holds about you and how it is processed.
You can request the following information:
- Identity and the contact details of the person or organisation (SG Aviation Services Ltd.) that has determined how and why to process your data.
- Contact details of the data protection officer, where applicable.
- The purpose of the processing as well as the legal basis for processing.
- If the processing is based on the legitimate interests of SG Aviation Services Ltd. or a third party such as one of its clients, information about those interests.
- The categories of personal data collected, stored and processed.
- Recipient(s) or categories of recipients that the data is/will be disclosed to.
- How long the data will be stored.
- Details of your rights to correct, erase, restrict or object to such processing.
- Information about your right to withdraw consent at any time.
- How to lodge a complaint with the supervisory authority (Data Protection Commissioner).
- Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
- The source of personal data if it wasn’t collected directly from you.
- Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
To access what personal data is held, identification will be required
SG Aviation Services Ltd. will accept the following forms of ID when information on your personal data is requested: a copy of your national ID card, driving licence, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If SG Aviation Services Ltd. is dissatisfied with the quality, further information may be sought before personal data can be released.
All requests should be made to email@example.com or by phoning +353 1 908 1132 or writing to us at the address further below.
In the event that you wish to make a complaint about how your personal data is being processed by SG Aviation Services Ltd. you have the right to complain to SG Aviation Services Ltd.’s CEO. If you do not get a response within 30 days you can complain to the Data Protection Regulator.
The details for each of these contacts are:
SG Aviation Services Ltd.,
attention of the CEO
20 Harcourt Street
Telephone +353 1 908 1132 or email: firstname.lastname@example.org
Data Protection Commission,
Telephone +353 57 8684800 or email: email@example.com