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AIRDAT Privacy and Cookies Policy

Last updated: 01 July 2024

To access our archived policy, please contact [email protected]

1.Introduction

1.1 We are committed to safeguarding the privacy of our website visitors and service users.

1.2 Sections 2 to 7 of this policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data. Section 20 of this policy sets out our role as a data processor on behalf of airport operators, and how we collect and use personal data, in connection with drug and alcohol screening of persons at an airport.

1.3 By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

1.4 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications. You can access the privacy controls via your user profile in your AIRDAT account.

1.5 In this policy, “we”, “us” and “our” refer to AIRDAT. For more information about us, see Section 17.

2.How we use your personal data

2.1 In this Section 2 we have set out:

(a) the general categories of personal data that we may process;

(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

(c) the purposes for which we may process personal data; and

(d) the legal bases of the processing.

2.2 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

2.3 We may process your account data (“account data“). The account data may include your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent.

2.4 We may process your information included in your personal profile on our website (“profile data“). The profile data may include your name, address, telephone number, email address, profile pictures, airport ID number, drivers licence number, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent.

2.5 We may process your personal data that are provided in the course of the use of our services (“service data“). The service data may include vehicle registration number, permit generation, qualification records, point records and notes . The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent.

2.6 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.2.7 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data“). The transaction data may include your contact details, your card details and the transaction details which may include specific details on the transaction such as the name linked to the purchase or the registration number of a vehicle. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.

2.8 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.

2.9 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

2.10 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.11 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

2.12 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2.13 Please do not supply any other person’s personal data to us, unless we prompt you to do so.

3.Automated decision-making

3.1 We will use your personal data for the purposes of automated decision-making in relation to training pre-requisites, company training restrictions and company credit control.

3.2 This automated decision-making will involve removing the ability to book into a course or launch elearning.

3.3 The significance and possible consequences of this automated decision-making are a user not being able to complete training before the required time.

4.Providing your personal data to others

4.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

4.2 When you register to specified airport within our website, your personal data will become accessible to the affiliated airport administrators, trainers and points administrators, insofar at access permissions are granted, for the purpose of facilitating Service-related request and reporting.

4.3 When you select your company or move to another company, your personal data will become accessible to the affiliated company administrator(s) for the purpose of facilitating Service-related requests and reporting.

4.4 Personal data (name, telephone number, email) of company administrators will be made accessible to affiliated company employees.

4.5 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4.6 We may disclose any of your personal data  to our suppliers or subcontractors identified at https://www.airdat.org/partners insofar as reasonably necessary for processing and providing our services requested by you, your employer or relative Airport.

4.7 Financial transactions relating to our website and services may be handled by our payment services providers, Stripe, Kashflow, ADVAM, Sun Accounts or authorities at the applicable Airport which you have requested our services. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at https://stripe.com/gb/privacy, https://www.kashflow.com/privacy-policy/, https://advam.com/privacy-policy/, https://www.sunaccounts.com/privacy/ .

4.8 We may disclose your enquiry data to one or more of those selected third party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data.

4.9 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5.International transfers of your personal data

5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

5.2    Processing of some personal data is managed by sub-processors (https://www.airdat.org/partners) some of which are situated in the USA. Transfers to the USA will be protected by appropriate safeguards, namely EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework (www.privacyshield.gov).

5.3 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.

6.Retaining and deleting personal data

6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3 We will retain your personal data as follows:

(a) usage data will be retained for a minimum period of 7 days following the date record was made, and for a maximum period of 1 month following the date record was made;

(b) enquiry data will be retained for a minimum period of 7 days following the date the enquiry was made, and for a maximum period of 5 years following the date the enquiry was made; and

(c) transaction data will be retained for a minimum period of 2 years following the date the transaction was made, and for a maximum period of 5 years following the last transaction 

6.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

(a) the period of retention of profile, service, notification, correspondence and account data will be determined based on account inactivity and the overall maximum validity of recurrent training qualification which is 5 years.

OR

(b) where AIRDAT acts as Data Processor the retention of data will be determined by the Data Controller.

6.5 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

7.Security of personal data

7.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.

7.2 We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.

7.3 The following personal data will be stored by us in encrypted form: password(s).

7.4 Data relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.

7.5 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

7.6 You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website).

8.Amendments

8.1 We may update this policy from time to time by publishing a new version on our website.

8.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

8.3 We may notify you of changes to this policy by email or through the private messaging system on our website.

9.Your rights

9.1 In this Section 9, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

9.2 Your principal rights under data protection law are:

(a) the right to access;

(b) the right to rectification;

(c) the right to erasure;

(d) the right to restrict processing;

(e) the right to object to processing;

(f) the right to data portability;

(g) the right to complain to a supervisory authority; and

(h) the right to withdraw consent.

9.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by visiting your profile  when logged into our website.

9.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

9.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

9.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

9.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

9.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

9.9 To the extent that the legal basis for our processing of your personal data is:

(a) consent; or

(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

9.10 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

9.11 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

9.12 You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 9.

10.Third party websites

10.1 Our website includes hyperlinks to, and details of, third party websites.

10.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.

11.Personal data of children

11.1 Our website and services are targeted at persons over the age of 16.

11.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.

12.Updating information

12.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.

13.Acting as a data processor

13.1 In respect of some transaction data, profile data and service data , we do not act as a data controller; instead, we act as a data processor.

13.2 Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.

14.About cookies

14.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

14.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

14.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

15.Cookies that we use

15.1 An exhaustive list of the cookies that we use on our public site and within our systems can be found in our Cookies Policy (https://www.airdat.org/cookies). This list is updated regularly, providing a detailed insight into how cookies are being used.

On the public site, you can easily opt-in or out of cookies that are defined as functional, performance, analytics and advertisement or others. Every time we update the cookies used, you will be prompted to provide consent again.

With Passport and Onboard, you will need to manage cookies via your browser. More information on how to do this can be found on the cookies page.

15.2 We use cookies for the following purposes:

(a) authentication – we use cookies to identify you when you visit our website and as you navigate our website (cookies used for this purpose are: user name, Airport ID); and

(b) personalisation – we use cookies to store information about your preferences and to personalise our website for you (cookies used for this purpose are: search filters).

(c) data analytics – we use cookies to understand how you use our site (e.g. review how long you spend on the site and the pages that you visit) so that we can continue to produce engaging content and improve your browsing experience.

(d) advertising – we advertise on Google Search Results and cookies are used for ads personalisation. Please see Google’s Privacy and Terms site for information on how you can control the information collected by Google on our site and apps.

16.Managing cookies

16.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e) https://support.apple.com/en-is/guide/safari/sfri11471/17.0/mac/14.0 (Safari); and

(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

16.2 Blocking all cookies will have a negative impact upon the usability of many websites.

16.3 If you block cookies, you will not be able to use all the features on our website.

17.Our details

17.1 This website is owned and operated by Airside Data and Training Ltd (AIRDAT).

17.2 We are registered in England and Wales under registration number 05789366, and our registered office is at 19 Cherry Garden Road Canterbury West KENT CT2 8EL.

17.3 Our principal place of business is at 19 Cherry Garden Road Canterbury West KENT CT2 8EL.

17.4 You can contact us:

(a) by post, to the postal address given above;

(b) by telephone, on the contact number published on our website from time to time; or

(c) by email, using the email address published on our website from time to time.

18.Data protection registration

18.1 We are registered as a data controller with the UK Information Commissioner’s Office.

18.2 Our data protection registration number is Z9756212.

19.Data protection officer

19.1 Our data protection officer’s contact details are: [email protected].

20 Airport Drug and Alcohol Screening 

20.1 This section 20 of this notice applies to you if you work at, or are visiting, an airport, and you have consented to undertake a drug and alcohol test administered by us (or one of our subcontractors).

20.1.1 How we collect your data

20.1.1.1 We collect your personal data through disclosures you, a third party or our subcontractors, make to us about you, and through our, or one of our subcontractor’s, drug and alcohol testing processes.

20.1.2 What data will we collect

20.1.2.1 We may collect your name, airport identification pass number, date of birth, medical information (including details of medication and health concerns), medical test results (including the presence of drugs and alcohol shown by such test results) and your signature.

20.1.3 Why we need your data

20.1.3.1 We need to know your personal data for the purposes of undertaking drug and alcohol screening on behalf of the operator of the airport you work at or are attending. The operator of that airport uses your personal data to:

  1. maintain security within that airport;
  2. maintain the health and safety of persons at that airport; 
  3. ensure the orderly administration and operation of that airport; 
  4. investigate accidents and incidents occurring at that airport;
  5. dealing with any complaints or enquiries you make;
  6. dealing with any legal claims which arise following an accident or incident at that airport; and
  7. to fulfil its regulatory reporting requirements to its regulators.

20.3.2 If we do not collect your personal data, the relevant airport operator may not be able to fulfil these purposes. We will only collect the personal data about you which the airport operator needs for these purposes alone.

20.3.3 The lawful basis for our processing of your personal data is based on your consent to undertake a drug and alcohol test administered by us (or our subcontractors).

20.4 What we do with your data

20.4.1 All the personal data we process is processed by our, or our subcontractor’s, staff in the UK. We may provide your data to:

20.4.1.1 our sub-contractors (including Cotton Nursing Solutions Ltd) for the purposes of obtaining drug and alcohol samples, and testing samples for drugs and alcohol;  

20.4.1.2 the third party you work for, for the purposes of notifying them of the results of any drug and alcohol test you have taken which was administered by us (or our subcontractors); and

20.4.1.3 the operator of the airport you work at or are visiting (including London Luton Airport Operations Limited if you work at or are visiting London Luton Airport).

20.4.2 Your data will not be transferred outside of the UK by us or any 3rd parties. We do not use personal data in connection with any automated decision making.

20.5 How long we keep your data

20.5.1 We may keep the data we collect about you for up to 12 months, after which date it will be destroyed by us. 

20.6 Airport Operator’s Privacy Notice

20.6.1 If you work at or are visiting London Luton Airport, we may provide your personal data to London Luton Airport Operations Limited (LLA). For more details about the personal information LLA collects, how LLA collects it, why LLA needs it, what LLA does with it, how long LLA will be keep it and what your rights are, please see LLA’s privacy notice at https://www.london-luton.co.uk/privacy-notice.

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