Privacy Policy

PURPOSE OF THIS PRIVACY POLICY  

This privacy policy aims to give you information on how CED Aviation Ltd. collects and processes your personal data through your use of this website, when you register as a candidate or search for jobs.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy, together with any other privacy notice that we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.

CONTROLLER  

CED Aviation Limited is the data controller and responsible for your personal data (referred to as “CED Aviation”, “we”, “us” or “our” in this privacy policy).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

CONTACT DETAILS  

Company Name: CED Aviation Limited

Email: info@cedaviation.com

You have the right to make a complaint at any time to the relevant supervisory authority for data protection issues, or your own country’s supervisory authority for data protection. Contact details for the BVI supervisory authorities for data protection issues are set out below. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES  

This version was last updated on 20 Jan 2021.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS  

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2.  THE DATA WE COLLECT ABOUT YOU  

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:

 

  • Contact data including name, email address, address and phone number.
  • Device and browser data, such as IP address, information about your device and browser settings.
  • Marketing and communications data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Employment and educational history data, such as CVs and job titles, qualifications and authorisations.

Where you have registered with us and/or we have provided work-finding services and/or placed you in a permanent or temporary role, we may also collect, use, store and transfer the following categories of your personal data:

  • References where you have provided us with a reference and/or referees’ contact details
  • Eligibility to work data such as passport and visa checks
  • Bank, tax and social security data such as account numbers, tax number and social security number
  • Your preferences such as preferred location, fleet, salary etc.
  • Role data about roles in which you have been placed
  • Medical/Health data (in limited circumstances)
  • Criminal report data (in limited circumstances)
  • Trade union membership data (in limited circumstances)

Sensitive personal data

We acknowledge the sensitivity of the last three categories of data listed and will normally only ever process it when necessary to provide you with a safe place of work, or to comply with legal or industry-specific requirements. We will only process sensitive data with your express consent, unless the processing of your sensitive personal data is necessary for other reasons permitted by law. Please do not disclose any sensitive personal data about yourself to us unless we request it or it is essential to do so. Unsolicited personal data will be deleted.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Where we collect or process any other categories of personal data (including sensitive personal data) about you that is not listed above, we will send you a separate Privacy Notice regarding the processing of such data by us.

IF YOU FAIL TO PROVIDE PERSONAL DATA  

If you fail to provide us with personal data when requested, we may not be able to provide you with work-finding or recruitment services.

3.  HOW IS YOUR PERSONAL DATA COLLECTED?  

We may collect data about you when you register with us, visit our website, or when we communicate by email, SMS, phone or in person.

We use different methods to collect data about you from third parties:

(a)     jobs boards;

(b)     social media platforms, such as LinkedIn;

(c)     analytics providers such as Google based inside and/or outside the EU;

(d)     publicly accessible internet search engines such as Google;

(e)     providers of technical, payment and delivery services such as payroll providers, referencing companies based inside and/or outside the EU;

(f)      publicly available sources such as Companies House and the Electoral Register based inside and/or outside the EU;

(g)     publicly accessible sources such as newspaper articles and public reports;

(h)     where you have provided us with referees’ contact details, we may obtain references from those referees;

(i)      where we have placed you in a role, we may also obtain information about you from the hirer and/or from tax authorities and other government agencies based [inside and/or outside] the EU.

4.  HOW AND WHY WE USE YOUR PERSONAL DATA  

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where we need to comply with a legal or regulatory obligation.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where you consent to our doing so.
  • Where we need to protect vital interests.

In certain circumstances we are required to process certain categories of personal data in order to comply with our legal obligations under relevant tax, social security or other legislation. You are not under any obligation to provide us with your personal data, but if you do not we may be unable to meet our legal obligations and so may not be able to provide you with work-finding or recruitment services.

We also need to process certain categories of your personal data in order to enter into an agreement with you and to comply with our obligations under that agreement.

Where no contractual or legal obligation exists, we may still need to process your personal data in order to pursue our legitimate business interests. Our business involves providing work-finding, recruitment, work provision and related services and so we may need to process your personal data in order to pursue our legitimate interests in achieving this. We may also need to retain personal data in case we need to establish or defend a legal claim. We will balance our legitimate interests against your rights and freedoms and your legitimate interests and expectations.

We may rely on your consent in certain circumstances, for example to process your data for the purposes of sending you direct marketing by email or SMS (text message), to use cookies when you visit our website, or to process sensitive personal data.

In limited circumstances we may also need to process your data in order to protect human life, for example for safety reasons.

MARKETING  

We would like to use your contact details to contact you about news and information which we think may be of interest to you. However we will not contact you with marketing material unless you have consented to our doing so.

You may also receive marketing communications from us if you have previously requested information or services from us and you did not opt out of receiving marketing communications from us at the time.

JOB ALERTS

We may use your personal data to notify you about suitable job opportunities if you have asked us to do so.

You may also receive job alerts from us if you have previously requested job alerts or services from us and you did not opt out of receiving job alerts from us at the time.

THIRD-PARTY MARKETING  

We will obtain your express opt-in consent before we share your personal data with third parties for marketing purposes.

CHANGE OF PURPOSE  

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5.  DISCLOSURES OF YOUR PERSONAL DATA  

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

Your personal information will be processed by our staff and our subcontractors (including IT providers) and will be provided to appropriate third parties such as potential hirers and intermediaries in order to provide you with work-finding services. Please let us know if you do not want your personal information to be disclosed to a particular third party or category of third parties.

We may also share your personal details with your previous or current employers or other third parties identified by you to us as potential referees.

We may be required by law to share certain categories of your personal data with tax authorities and other government agencies.

We may use a third party organisation to check references, employment history and qualifications. We will need to provide them with certain categories of your personal data and they will be under an obligation to process it as instructed by us and in accordance with relevant data protection legislation. We may also need to provide certain categories of personal data to your pension provider, if appropriate.

We may also need to share your data with our professional advisers, such as lawyers and accountants.

We may also share your personal data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We will not share your personal data with any other organisation unless it is necessary and in connection with providing our work-finding and recruitment services.

We will require all third parties to respect the security of your personal data and to treat it in accordance with the law. We only permit third-party service providers to process your personal data for specified purposes and in accordance with our instructions.

6.  INTERNATIONAL TRANSFERS  

Your personal data will be stored both inside and outside the European Economic Area (EEA) on either local or cloud-based servers and will be subject to technical and organisation safeguarding protection measures. The EEA comprises the European Union (EU) member states plus Norway, Iceland and Liechtenstein.

We have an office based in Spain which is inside the EU/EEA and another office based in China, which has been deemed to provide an adequate level of protection for personal data by the European Commission.

Some categories of data may be transferred to other organisations outside the EEA. If you are an EU citizen and it is necessary to transfer your data to another country outside the EEA to assist us in providing work-finding and recruitment services, we will take reasonable steps to protect your data.

7.  DATA SECURITY  

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we will limit access to your personal data to those employees, agents, contractors and other third parties on a ‘need to know’ basis. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We will require all third parties to respect the security of your personal data and to treat it in accordance with the law. We only permit third-party service providers to process your personal data for specified purposes and in accordance with our instructions.

We have put in place procedures to deal with a suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8.  DATA RETENTION

FOR HOW LONG WILL YOU USE OR RETAIN MY PERSONAL DATA?  

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

By law we have to keep certain information about candidates for between 1 and 7 years. Where we have entered into a contract with you, we may also need to retain data for up to 7 years in order to ensure that we can meet our contractual obligations to you. 

As a general rule, if you have been placed by us, we will retain data of your data until the date of mandatory or actual retirement age plus 7 years.

If we have engaged with you in the recruitment process, then we will normally keep your data until the date of your actual or mandatory retirement.

9.  YOUR LEGAL RIGHTS  

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to: 

  1. request access to personal data we hold about you;
  2. object to the processing of your personal data;
  3. ask to have inaccurate data held about you removed or restricted;
  4. ask to have inaccurate data held about you corrected;
  5. if processing of your personal data is based only on consent, to withdraw that consent;
  6. request that your personal data is shared with a third party in a commonly used, machine readable format.

If you wish to exercise any of the rights set out above, please contact us at 

info@cedaviation.com

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