This privacy statement explains what information we receive from you, how it is used and how it is protected by Crewlink. This privacy statement and the procedures outlined herein comply with EU General Data Protection Regulation 2016/679 of 27 April 2016 (“GDPR”) and the relevant national legislation of the EU Member States implementing the GDPR (together the “Regulations”). For the purposes of this privacy statement “Crewlink” refers to Crewlink (Recruitment, Training and Human Resources), Dalmac, Workforce International Contractors ltd, Nobox HR Outsourcing Solutions, Cabin Crew Europe and associated companies, third party contractors and client airlines. CREWLINK is considered a data controller under the Regulations.
Crewlink collects and uses certain personal data that we have received either directly from you or indirectly e.g. via authorities or social security agencies. Typically, the personal data that Crewlink processes about you is your name, address, contact details, email address, telephone number, tax information, banking information, nationality, passport or identity card, date of birth, psychometric tests, family status, health information, flying licenses and records, photographs and information for any security checking and id procedures. Some of this data is regarded as special categories of personal data within the regulation (e.g., health information).
Processing and purpose of use
Crewlink uses the personal data collected to provide requested recruitment, training and employment services. Crewlink therefore collects, uses, administers, records, transfers and stores (“Processes”) personal data in order to efficiently perform the agreed services. Among other things, Crewlink Processes personal data:
- To provide recruitment, training, employment and/or related intermediary services to or for you and to facilitate the recruitment process;
- To allow you to apply for specific jobs or to subscribe to receive information about Training Courses or related information.
- To determine whether candidates meet the relevant skills and requirements to fulfil available roles;
- To send you relevant updates and keep you informed where you have requested this;
- To perform, manage and/or maintain your employment or assignment relationship where applicable;
- For accounting and payment processing;
- To manage communication and transactions;
- To answer queries or complaints;
- To carry out analysis and research.
Crewlink also processes data to comply with applicable laws, e.g. export regulations, and generally for any other purpose that is necessary or related to the relationship between you and Crewlink.
These are collectively identified as “Purposes”.
This is considered necessary to protect the legitimate interests of Crewlink in accordance with the applicable legislation and to give proper consideration to your interests.
Crewlink processes your personal data only in accordance with the Regulations as applicable. Crewlink reserves the right to update and amend this privacy statement from time to time to the extent necessary in relation to our legitimate business interests such as amendments to the Regulations or updates to the services provided by Crewlink.
Disclosure of personal data
Crewlink may disclose your personal data to relevant members of the Crewlink group (e.g. Training, Human Resources, Dalmac, Workforce International Contractors ltd, Nobox HR Outsourcing Solutions, Cabin Crew Europe and associated companies), prospective employers or airline clients and relevant third parties who perform related functions on Crewlink’s behalf. Any such disclosure will be only to the extent required for the Purposes and in accordance with the Regulations. Crewlink may disclose personal data in order to comply with legal requirements (e.g. in relation to legal claims, audits, investigations or consultations with competent authorities and social security agencies), to respond to demands or to protect the interests of individuals. Disclosures shall be made in accordance with the Regulations.
Crewlink may disclose your personal data to associated companies (e.g. affiliates), business and joint venture partners, as well as subcontractors at home and abroad. We will only disclose your personal data once it has been ensured that there is an adequate level of data protection and/or when we have signed a personal data processing agreement in accordance with the Regulations.
International data transfers
Crewlink operates in multiple jurisdictions some which are located outside the European Economic Area (EEA). Countries located outside the EEA may have data protection laws which do not provide the same level of protection for personal data as within the EEA. Crewlink transfers personal data outside the EEA only to the extent required for legitimate business purposes. Crewlink utilizes standard means under the Regulations to legitimize data transfers outside the EEA.
Protection of personal data
Crewlink regards your personal data as an asset that must be protected. We are committed to ensuring that your personal data is stored securely, is only accessible by authorized persons, is only transferred in accordance with this Privacy Statement and after the implementation of appropriate technical, security and organizational measures in compliance with the Regulations. Nonetheless there are third parties that may unlawfully try to access systems or intercept transmissions or communications containing personal data. Crewlink continuously uses its reasonable efforts in line with industry standards to protect personal data of customers but cannot absolutely guarantee that such unlawful actions will not occur. Crewlink has in place a data breach response plan.
Rights of data subjects
As a data subject whose personal data is processed by Crewlink for the Purposes mentioned above, in applicable circumstances you have the right to access your personal data, request a copy of it and request to update or correct your personal data held by Crewlink. To the extent that the processing of personal data by Crewlink occurs on the basis of your consent you have the right to withdraw such consent. Such withdrawal will however not restrict Crewlink in continuing to process personal data if the justification therefore does not rely on your consent and is still necessary for any of the mentioned Purposes. You also have the right to object to the processing of your personal data by Crewlink, to request that Crewlink restrict the processing of your personal data or request that Crewlink erase your personal data, all on the grounds mentioned in the Regulations. Crewlink will respond to all such requests in accordance with the Regulations.
You have the right to lodge a complaint with the competent personal data protection authority if you believe that the processing of your personal data is not in compliance with Regulations, or if Crewlink does not respond to your requests in timely and/or appropriate manner, or if they are not answered at all.
Crewlink will only store your personal data for the duration necessary and in a manner permitted by the Regulations or other applicable laws.
Contact details and further information
If you have any questions in connection with this notification or the processing of personal data by Crewlink in general or if you have questions or requests for information, you can contact Crewlink as follows:
Telephone: + 353 (0)1 895 2065
Address: 19 Grange Parade, Baldoyle, Dublin 13, Ireland
The Regulations may require that Crewlink ask for your specific consent if certain elements of the personal data that Crewlink processes qualify as special categories, namely medical data and criminal records. That consent needs to be given freely by way of an explicit, affirmative action and after you have been properly informed. In this respect, Crewlink provides this privacy statement to its candidates.
If you submit your personal data to Crewlink (irrespective of the manner or form), you agree to the terms of this privacy statement and to its processing in accordance with the Regulations.
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