Privacy Policy

PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how GC4 Engineers collects and processes your personal data through your use of this website, when you register as a pilot, candidate, or search for jobs.

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

The contents of this website do not constitute legal advice, are not intended to be a substitute for legal advice and should not be relied upon as such. You should seek legal advice or other professional advice in relation to any particular matters you or your organisation may have.

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

GC4 Engineers is the data controller and responsible for your personal data (referred to as “LHP Services”, “we”, “us” or “our” in this privacy policy).

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.

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

This version was last updated on 15 Feb 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.

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.

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, such as Flight Global and Aviation Job Search;

(b) social media platforms, such as LinkedIn;

(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 and UK.

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.

If you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

-Document / Personal Data: Why we need it

Our lawful ground for processing it

-Name, address, DOB

To verify your identity and CV or employment history, qualifications and authorisations

Legal obligation (if applicable).

Contractual obligation (if applicable).

Legitimate interests.

-Contact details

To communicate with you and notify you about suitable roles and other important information

Legal obligation (if applicable).

Contractual obligation (if applicable).

Legitimate interests.

-Role requirements

To find you the right candidate, role or assignment

Legal obligation (if applicable).

Contractual obligation (if applicable).

Legitimate interests.

-CV, employment history, qualifications, authorisations

To check your suitability for a role or assignment

Legal obligation (if applicable).

Contractual obligation (if applicable).

Legitimate interests.

-ID and immigration checks

To verify your identity and right to work

Legal obligation (if applicable).

Contractual obligation (if applicable).

Legitimate interests.

-Confirmation that you are willing to work in a particular role

To find you the right role or assignment

Legal obligation (if applicable).

Legitimate interests.

Interview details

To set up interviews with hirers

Contractual obligation (if applicable).

Legitimate interests.

-Notes, assessments, comments, feedback from interview.

To find you the right role or assignment

Contractual obligation (if applicable).

Legitimate interests.

-Emails and correspondence with you and with potential hirers and intermediaries

To find you the right role or assignment

Contractual obligation (if applicable).

Legitimate interests.

-References (collected from third parties)

To verify your experience and suitability for a particular role or assignment

Legal obligation (if applicable).

Contractual obligation (if applicable).

Legitimate interests.

-Details of placement/assignment and hirer

To keep records of placements made or assignments arranged by us

Legal obligation (if applicable).

Contractual obligation (if applicable).

Legitimate interests.

-Candidate/work-finding Agreement

To set out the basis of the relationship between you and us

Legal obligation (if applicable).

Legitimate interests.

-Sensitive personal data - health data

To check your suitability for a role or assignment and to ensure your health and safety

Legal obligation (if applicable).

Contractual obligation (if applicable).

Legitimate interests.

-Explicit consent or necessary for the performance of our employment or social security obligations.

Sensitive personal data – criminal convictions

To check your suitability for certain roles or assignments

Legal obligation (if applicable).

Contractual obligation (if applicable).

Legitimate interests.

Explicit consent or necessary for the performance of our employment or social security obligations.

-Sensitive personal data – trade union membership

To process membership fees and/or payments

Contractual obligation (if applicable).

Legitimate interests.

Explicit consent or necessary for the performance of our employment or social security obligations.

-Bank details

To pay you

Legal obligation (If applicable).

Contractual performance.

-Social security information, tax information, tax and social security number(s)

To report to relevant authority and to perform our services for you

Legal obligation (If applicable).

Contractual performance.

-Information about your pay and conditions

To protect your rights and to pay you

Legal obligation (if applicable).

Contractual obligation (if applicable).

Legitimate interests.

-Other necessary, relevant personal information

To perform our services for you

Contractual obligation (if applicable).

Legitimate interests.

-IP address, browser and device data

To deliver relevant website content and administer our website

Legitimate interests.

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.

You have the right to unsubscribe at any time, by clicking the link which appears in the footer of all marketing emails.

WEBSITE CONTENTS

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.

You have the right to unsubscribe to automated job alerts at any time, by clicking on the link which appears in the email footers.

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.

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.

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 Sweden which is inside the EU/EEA and another office based in New Zealand, 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/UK 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.

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 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.

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.

YOUR LEGAL RIGHTS

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

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

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**The contents of this website do not constitute legal advice, are not intended to be a substitute for legal advice and should not be relied upon as such. You should seek legal advice or other professional advice in relation to any particular matters you or your organisation may have.

Privacy Policy