INTRODUCTION

We will from time to time need to collect and use information and data associated with students enquiring or studying at at various Airways Aviation facilities and this information is collected, recorded and used, on paper, electronically via cloud based storage, on computers or recorded by other means.

We regard the lawful and correct treatment of personal information as very important to our successful operation and to maintaining the confidence of those with whom we carry out business. We therefore ensure that we treat personal information lawfully, correctly and respectfully.

To this end we fully endorse and adhere to the principles of the General Data Protection Regulation (GDPR).

This policy applies to the processing of personal data in manual and electronic records kept by us in connection with our teaching function as described below. It also covers our response to any data breach and other rights under the GDPR.

This policy applies to the personal data of prospective, current and completed students. These are referred to in this policy as relevant individuals.

DEFINITIONS

“Personal data” is information that relates to an identifiable person who can be directly or indirectly identified from that information, for example, a person’s name, identification number, location, online identifier. It can also include pseudonymised data.

“Special categories of personal data” is data which may relate to an individual’s health, sex life, sexual orientation, race, ethnic origin, political opinion, religion, and trade union membership and may also include genetic and biometric data (where used for ID purposes).

“Criminal offence data” is data which relates to an individual’s criminal convictions and offences.

“Data processing” is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

DATA PROTECTION PRINCIPLES

Under GDPR, all personal data obtained and held must be processed according to a set of core principles and in accordance with these principles, we ensure that:

• processing will be fair, lawful and transparent
• data be collected for specific, explicit, and legitimate purposes
• data collected will be adequate, relevant and limited to what is necessary for the purposes of processing
• data will be kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay
• data is not kept for longer than is necessary for its given purpose
• data will be processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures
• we will comply with the relevant GDPR procedures for international transferring of personal data

TYPES OF DATA HELD

We keep several categories of personal data on our students in order to carry out effective and efficient processes. We keep this data in files relating to each student and we also hold the data within our computer systems, the cloud, CRM and other platforms like Salesforce, Flight Logger and other student ID and progress monitoring system.

Specifically, we hold the following types of data:

• personal details such as name, address, phone numbers
• medical certificates
• internal and external training documents and certificates
• Images
• Passport & ID Documents

All of the above information is required for our processing activities and more information on those processing activities are included in our various privacy notices and student handbooks. These are always available from the the operational Operations Teams in each Airways Aviation facility. Data will be kept indefinitely.

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YOUR DATA SUBJECT RIGHTS

• You have the right to information about what personal data we process, how and on what basis as set out in this policy.
• You have the right to access your own personal data by way of a subject access request.
• You can correct any inaccuracies in your personal data. To do you should contact admin@airwaysaviation.com
• You have the right to request that we erase your personal data where we were not entitled under the law to process it or it is no longer necessary to process it for the purpose it was collected. To do so you should contact admin@airwaysaviation.com

• While you are requesting that your personal data is corrected or erased or are contesting the lawfulness of our processing, you can apply for its use to be restricted while the application is made. To do so you should contact admin@airwaysaviation.com

• You have the right to object to data processing where we are relying on a legitimate interest to do so and you think that your rights and interests outweigh our own and you wish us to stop.
• You have the right to object if we process your personal data for the purposes of direct marketing.
• You have the right to receive a copy of your personal data and to transfer your personal data to another data controller. We will not charge for this and will in most cases aim to do this within one month.
• With some exceptions, you have the right not to be subjected to automated decision-making.
• You have the right to be notified of a data security breach concerning your personal data.
• In most situations we will not rely on your consent as a lawful ground to process your data. If we do however request your consent to the processing of your personal data for a specific purpose, you have the right not to consent or to withdraw your consent later. To withdraw your consent, you should contact admin@airwaysaviation.com ‍
• To complete a subject access request to access, change or modify data as described in this section, please email: admin@airwaysaviation.com

RESPONSIBILITIES

In order to protect the personal data of relevant individuals, those within our business who must process data as part of their role are made aware of our policies on data protection. We also appoint employees with responsibility for reviewing and auditing our data protection systems.

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LAWFUL BASES OF PROCESSING

We acknowledge that processing may be only be carried out where a lawful basis for that processing exists and where no other lawful basis applies, we may seek to rely on the student’s consent in order to process data.

We recognise the high standard attached to its use. We understand that consent must be freely given, specific, informed and unambiguous and where consent is to be sought, we will do so on a specific and individual basis where appropriate.

ACCESS TO DATA

All students have a right to access the personal data that we hold on them and to exercise this right, students should make an Access Request. We will comply with the request without delay, and within one month unless, in accordance with legislation in each individual jurisdiction, we decide that an extension is required. Those who make a request will be kept fully informed of any decision to extend the time limit.

No charge will be made for complying with a request unless the request is manifestly unfounded, excessive or repetitive, or unless a request is made for duplicate copies to be provided to parties other than the employee making the request. In these circumstances, a reasonable charge will be applied.

DATA DISCLOSURES

The Company may be required to disclose certain data/information to third persons and the circumstances leading to such disclosures include:

• any student benefits operated by third party
• any request by Aviation Authorities
• disabled individuals - whether any reasonable adjustments are required to assist them whilst studying;
• individuals’ health data - to comply with health and safety or occupational health obligations towards the student;
• to assist law enforcement or a relevant authority to prevent or detect crime or prosecute offenders or to assess or collect any tax or duty.

These kinds of disclosures will only be made when strictly necessary for the purpose.

DATA SECURITY

Employees are made aware of their roles and responsibilities when their role involves the processing of data. All employees are instructed and required to store files and/or written information of a confidential nature in a secure manner so that are only accessed by people who have a need and a right to access them. They are to ensure that screen locks are implemented on all PCs and laptops etc when unattended.

Where data is computerised, it is coded, encrypted or password protected both on the cloud, a local hard drive and on a network drive that is regularly backed up. If a copy is kept on removable storage media, that media must be kept in a locked filing cabinet, drawer, or safe.

Students must always use the passwords provided to access the computer system and not abuse them by passing them on to people who should not have them, the same rule applies to all staff and they are fully aware.

Personal data relating to students will not be kept or transported on laptops, USB sticks, or similar devices, unless prior authorisation has been received. Where personal data is recorded on any such device it should be protected by:

• ensuring that data is recorded on such devices only where absolutely necessary.
• using an encrypted system — a folder should be created to store the files that need extra protection and all files created or moved to this folder should be automatically encrypted.
• ensuring that laptops or USB drives are not left where they can be stolen.

Failure to follow the Company’s rules on data security may be dealt with via the Company’s disciplinary procedure. Appropriate sanctions include dismissal with or without notice dependent on the severity of the failure.

THIRD PARTY PROCESSING

Where we engage third parties to process data on our behalf, we will reasonably ensure, with the third party, that the third party takes such measures to provide their own protection and also to maintain the Company’s commitment to protecting data.

There may be circumstances in which personal data may be transferred to countries outside the European Economic Area (EEA).

The hosting facilities for our website are provided external service providers head quartered in the United States or other locations. The company that provide our online scheduling software, Flightlogger are based in Denmark.

The European Commission has made an "adequacy decision" with respect to the data protection laws of each European Country. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.

You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

REQUIREMENT TO NOTIFY BREACHES

All data breaches will be recorded and where legally required, the responsible manager for each territory will report a breach within 72 hours of discovery. In addition, where legally required, we will inform the individual whose data was subject to breach.

TRAINING

All Airways Aviation employees receive training covering information about confidentiality, data protection and the actions to take upon identifying a potential data breach and the nominated data controller/auditors/protection officers for the Company are trained appropriately in their roles under the GDPR.

All employees who need to use the computer system are trained to protect individuals’ private data, to ensure data security, and to understand their are consequences to them as individuals for any potential lapses and breaches of the Company’s policies and procedures.

RECORDS

The Company keeps records of its processing activities including the purpose for the processing and retention periods in its Student Data Records. These records are kept up to date, in Flight Logger so that they reflect current processing activities.

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