Thank you for using our recruitment website. Because you will be providing us with personal information about you (referred to below as “personal data”) we need to ensure you are aware how and why your personal data will be used and how long it will usually be retained for.

References to “we” in this notice means Airborne Personnel Ltd because under the GDPR we are a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. Our company and contact details are available at the end of this Privacy Notice.

We will comply with data protection law and principles, which means that your personal data will be:

• Used lawfully, fairly and in a transparent way.
• Collected only for specified and legitimate purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and, and where necessary, kept up to date.
• Kept only as long as necessary for the purposes we have told you about.
• Kept securely.

We will only process your personal data as set out in this Privacy Notice if you have given us consent to do so by checking the appropriate section of our consent form. If you wish to withdraw your consent to our processing of your personal data, please contact us using the details set out at the end of this Privacy Notice.

In connection with your application for work, we will collect, store, and use any information you have provided to us as part of your application for positions advertised on this site including your name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications etc.

Where you have given us consent to do so (by checking the appropriate section of our consent form) we may also collect, store and use the following “special categories” of more sensitive personal information:

• Information about criminal convictions and offences.
• Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
• Information about your health, including any medical condition, health and sickness records.

We collect personal information about candidates from the following sources:

• You, the candidate, when you enter your identity and contact details to register an account with us and/or when you upload your CV or add other details to your account.
• Disclosure and Barring Service (or other equivalent body providing the same service) in respect of criminal convictions.
• Referees, both work and personal, relating to your suitability for employment or for obtaining appropriate security clearances.

We will use the personal information we collect about you to:

• Assess your skills, qualifications, and suitability for the role you have applied for.
• Carry out background reference or security checks (5 years employment history references), where applicable.
• Communicate with you about the recruitment process.
• Keep records related to our hiring processes.
• Comply with legal or regulatory requirements.
• If successful, to enter into a contract of employment with you.

Having received your application, we will process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the role you have applied for. If we decide to offer you the role, we will then take up references and/or carry out a criminal record check before confirming your appointment.

If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.

We will use your particularly sensitive personal information in the following ways:

• We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made.
• We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

It is necessary to collect information about your criminal convictions history because we are legally required to do so due to the nature of the role you have applied for.

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

We will only share your personal information with the airlines for whom you have applied to work. Their use of personal data is subject to a separate agreement between us and them regulating their use of such information. We require all airlines to respect the security of your personal information and treat it in accordance with the law.

We do not transfer your personal data outside the EEA.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from our DPO using the contact details at the end of this Privacy Notice.

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

We will retain your personal information for a period of 6 months after the later of (i) you not being offered a position for which you have applied; or (ii) if successful in your application, the termination of your employment, for whatever reason.

We retain your personal information for the above period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with applicable laws and regulations.

You may also consent to us keeping your personal data for up to 12 months (by checking the appropriate section of our consent form) for the purposes of alerting you to alternative positions that may arise in future, if you are unsuccessful in any application. If we wish to retain your personal information on file beyond that point, we will write to you separately to ascertain whether you give us consent to continue to hold your details.

Under certain circumstances, by law you have the right to:

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our DPO in writing using the contact details at the end of this Privacy Notice.

When you apply for a position on this you will be asked to provide your consent to us processing your personal information for the purposes of the recruitment exercise. You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact our DPO using the contact details at the end of this Privacy Notice. Once we have received notification that you have withdrawn your consent, we will no longer process your application and, subject to our retention policy, we will dispose of your personal data securely.

We have appointed a DPO to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO. You have the right to make a complaint at any time to the Office of the Information and Data Protection Commissioner, the Maltese supervisory authority for data protection issues. You may contact the IDPC as follows:

By email:          Please complete the form at https: https://idpc.org.mt/en/Pages/Home.aspx

By phone:         (+356) 2328 7100

By post:            Office of the Information and Data Protection Commissioner – Level 2, Airways House, High Street, Sliema, SLM 1549, Malta

This Privacy Notice was updated in May 2018 and reviewed in March 2019. It may be updated to take into account changes in regulation or legislation.

Updates to this Privacy Notice will be posted on this page – please check back from time to time. We may also inform you of any changes where we hold an appropriate email address for you.

Our full details are as follows:

Name:                                   Airborne Personnel Ltd
Co Number:                         C76037
Reg Address:                       MK Business Centre, 115A, Floor 2, Valley Road, Birkirkara, BKR 9022, Malta

DPO:                                     Gudmundur Hafsteinsson

Tel:                                        +44(0)1293 226 933
Email:                                   gdprap@airbornepersonnel.info

July 2019