GDPR Candidate Agreement

The legal bases we rely upon to offer these services to you are: 

• Your consent  

• Where we have a legitimate interest  

b. Legitimate interest  

This is where the Company has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us.  Where the Company has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows: 

• Managing a recruitment database and keeping work-seeker records up to date;  

• Contacting you to seek your consent when we need it;  

• Providing work-finding services to you, including sending your information to our clients where you have demonstrated an interest in doing that particular type of work but not expressly consented to the Company passing on your cv; and 

• Contacting you with information about similar products or services to those the Company has provided you with recently. 

c. Recipient/s of data 

The Company may process your personal data and/or sensitive personal data with the following recipients: 

• Clients that we introduce or supply individuals to within the aviation industry; 

• Your former or prospective new employers that we obtain or provide references to; 

• Any other third parties who carry out audits to ensure the Company’s compliance with industry standards and legal obligations; 

• Payroll service providers who may manage our payroll for temporary workers; 

• Other recruitment agencies in the supply chain (e.g. master/neutral vendors and second tier suppliers); 

• Our insurers; 

• Our legal advisers; 

• Social networks;  

• Our IT and CRM providers; 

• Any public information sources and third-party organisations that we may use to carry out suitability checks on work-seekers e.g. Companies House, the Disclosure and Barring Service (DBS) or equivalent in your country,  DVLA and credit reference agencies; 

• Government, law enforcement agencies and other regulators e.g the Police, Home Office, HMRC, UK CAA or equivalent aviation authority in your country, Employment Agencies Standards Inspectorate (EASI), Local Authority Designated Officers (LADOs) and GLAA; 

• Trade unions;  

• Any of our current or future group companies; and  

• Any other organisations you ask the Company to share your data with. 

2. Overseas Transfers  

The Company may transfer only the information you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of providing you with work-finding services. We will take steps to ensure adequate protections are in place to ensure the security of your information. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.  

3. Data retention 

The Company uses third party recruitment software as the primary medium for processing personal data. All information stored on our recruitment software is secured through the Microsoft Azure Infrastructure and located at two data centres locations within Europe. Our primary centre is located in Microsoft’s Western European centre, and these facilities are secured by a series of measures, including (but not limited to) biometric access, security alarm systems and round-the-clock security staff. Additional security information on Microsoft’s data centres can be found here. 

The Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from (a) the date of their creation or (b) after the date on which we last provide you with work-finding services. 

The Company will retain your personal data only for as long as is necessary for the purpose we collect it.  We retain different types of data for differing periods of time. The criteria we use to determine whether we should retain your personal data and how long for includes: 

• The nature of the personal data 

• Its perceived accuracy of your date 

• Your engagement levels with our services 

• Our legal obligations following an offer or when a placement has been made. 

We may archive part or all of your personal data, or retain it on our financial systems but delete all or part of it from our recruitment software system. On removal, we may anonymise parts of your data – particularly following a request for suppression or deletion of your data – to ensure we do not re-enter your personal data to our database, unless you have requested us to do so. 

Our current retention period for data on candidates who have not been placed, or are no longer showing any signs of engagement with our website, is 12 months. 

Where the Company has obtained your consent to process your personal and/or sensitive personal data, we will do so in line with our retention policy above. Upon expiry of that period the Company will seek further consent from you. Where consent is not granted the Company will cease to process your personal data and/or sensitive personal data.  

4. Your rights 

Please be aware that you have the following data protection rights: 

• The right to be informed about the personal data the Company processes on you; 

• The right of access to the personal data the Company processes on you; 

• The right to rectification of your personal data; 

• The right to erasure of your personal data in certain circumstances; 

• The right to restrict processing of your personal data; 

• The right to data portability in certain circumstances; 

• The right to object to the processing of your personal data that was based on a public or legitimate interest; 

• The right not to be subjected to automated decision making and profiling; and 

• The right to withdraw consent at any time. 

Where you have consented to the Company processing your personal data and/or sensitive personal data you have the right to withdraw that consent at any time by contacting the Company at privacy@skychaser.aero.  

There may be circumstances where the Company will still need to process your data for legal or official reasons. We will inform you if this is the case. Where this is the case, we will restrict the data to only what is necessary for the purpose of meeting those specific reasons.  

If you believe that any of your data that the Company processes is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check its accuracy and correct it where necessary.  

You can also contact us using the above details if you want us to restrict the type or amount of data we process for you, access your personal data or exercise any of the other rights listed above. 

5. Automated decision-making 

The Company uses automated decision making to ensure that candidates meet the minimum requirements for advertised jobs as agreed with our clients. These requirements are in line with the minimum qualifications required to perform a role (such as holding a particular licence or qualification) or the minimum experience/qualifications our clients have otherwise indicated are required to perform the role. This means that if you do not meet the minimum experience requirements as advertised for a particular role, your application may not be progressed further. 

6. Complaints or queries 

If you wish to complain about this privacy notice or any of the procedures set out in it please contact: privacy@skychaser.aero.  

Annex A 

The lawfulness of processing conditions for personal data are: 

1. Consent of the individual for one or more specific purposes. 

2. Processing is necessary for the performance of a contract with the individual or in order to take steps at the request of the individual to enter into a contract. 

3. Processing is necessary for compliance with a legal obligation that the controller is subject to. 

4. Processing is necessary to protect the vital interests of the individual or another person. 

5. Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller. 

6. Processing is necessary for the purposes of legitimate interests pursued by the controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the individual which require protection of personal data, in particular where the individual is a child. 

The lawfulness of processing conditions for sensitive personal data are: 

1. Explicit consent of the individual for one or more specified purposes, unless reliance on consent is prohibited by EU or Member State law. 

2. Processing is necessary for carrying out data controller’s obligations under employment, social security or social protection law, or a collective agreement, providing for appropriate safeguards for the fundamental rights and interests of the individual. 

3. Processing is necessary to protect the vital interests of the individual or another individual where the individual is physically or legally incapable of giving consent. 

4. In the course of its legitimate activities, processing is carried out with appropriate safeguards by a foundation, association or any other not-for-profit body, with a political, philosophical, religious or trade union aim and on condition that the processing relates only to members or former members (or those who have regular contact with it in connection with those purposes) and provided there is no disclosure to a third party without the consent of the individual. 

5. Processing relates to personal data which are manifestly made public by the individual. 

6. Processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity. 

7. Processing is necessary for reasons of substantial public interest on the basis of EU or Member State law which shall be proportionate to the aim pursued, respects the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and interests of the individual. 

8. Processing is necessary for the purposes of preventative or occupational medicine, for assessing the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of EU or Member State law or a contract with a health professional and subject to the necessary conditions and safeguards.  

9. Processing is necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health or ensuring high standards of quality and safety of healthcare and of medicinal products or medical devices, on the basis of EU or Member State law which provides for suitable and specific measures to safeguard the rights and freedoms of the individual, in particular professional secrecy.  

10. Processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard fundamental rights and interests of the individual.