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NOTICE OF PRIVACY FOR RECRUITMENT AND SELECTION PROCESS FOR FLIGHT CREW MEMBERS, CABIN CREW MEMBERS

 

1.       WHO ARE WE AND HOW YOU CAN CONTACT US

UAB “Avion Express”, company code 300087830, address: Dariaus ir Girėno g. 21A (38A – from April 2025), 02188 Vilnius, Lithuania, and / or Avion Express Malta Ltd, company code C 87300, address: NuBis Centre, Mosta Road, Lija LJA 9012, Malta.

When processing your data UAB “Avion Express” and Avion Express Malta Ltd each acts separately or both act together as joint controllers (hereinafter “We”, “Ours”, “Company”, “Avion Express”).

Avion Express will process the personal data you provide in your application for recruitment (in any professional engagement capacity) purposes.

This Privacy Notice (hereinafter referred to as the “Privacy Notice”) outlines how we comply with applicable privacy requirements and how we deal with your personal data that you provide us via our website, air crew recruitment events or we collect it via other sources, such as recruiting agencies, job search portals, publicly accessible business-related special media sources (such as LinkedIn), and other.

If you have any questions regarding this Privacy Notice or requests regarding the processing of your personal data, please contact our Data Protection Team by email: [email protected].

Information about the application process can be found on our website https://careers.avionexpress.aero/.

Please note that You have the right to withdraw your consent and application at any time by emailing [email protected] without affecting the lawfulness of processing based on consent before its withdrawal. Upon withdrawal, the Company will delete your personal data promptly.

We may change this Privacy Notice from time to time. We encourage you to review this Privacy Notice periodically.

In processing the personal data, we responsibly comply to the regulation No 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“GDPR”), and other directly applicable legal acts regulating the protection of personal data, as well as instructions from competent authorities. The Company applies the highest technical and legal standards of protection and taking all necessary measures to prevent possible breaches of personal data protection.

UAB “Avion Express” and Avion Express Malta Ltd are the part of companies’ group of AVIA SOLUTIONS GROUP (ASG) PLC, legal entity code: 727348, address (as may be changed from time to time): Building 9, Vantage West, Central Park, Dublin, D18 FT0C, Ireland. In certain cases, Company, AVIA SOLUTIONS GROUP (ASG) PLC and its subsidiaries may jointly act as controllers of your personal data. The contact details of each Avia Solutions Group company can be found here.

2.       WHAT PERSONAL DATA WE PROCESS?

For recruitment purposes We collect and process your personal data to assess your suitability for employment or other types professional engagement. This includes evaluating your qualifications, skills, personal qualities, and background in relation to a specific role, as well as verifying the accuracy of the information you provide. Where applicable, we may conduct reference and background checks. This process may also involve the collection and processing of sensitive data, such as health information, psychological assessment results, and criminal record data, where necessary and permitted by law. Additionally, we use your personal data to manage the recruitment process and communicate with you throughout, including informing you about the status of your application and any potential next steps.

2.1    FLIGHT CREW (Captain or First Officer)

2.1.1   What kind of categories of personal data we process?

  • Flying Experience: Type Rating, Rank, Block Hours Information; Date; Copy of Logbook; CV etc.
  • Personal Details: Full Name, Date of Birth; Valid EEA Passport Information; Nationality, Phone Number; Email Address, Home Airport, Rejoining Company Information; ICAO English Language Proficiency Information; Copy of Passport etc.
  • License Details.
  • Visa Information.
  • Employment / Professional Engagement History: Company Name; Start and End Dates; Position; Reason for Leaving.
  • Non – Criminal Records Certificate Information.
  • Information about the source of the candidate’s application.
  • Medical Certificate Details.
  • Test Results: Technical Test, Personality Test Results, Flight Simulator Assessment Results.
  • References information.
  • Interview notes.

This list of information is not exhaustive.

2.1.2     On what legal basis do we process personal data?

  • Article 6 (1) (a) (data subject consent) of the GDPR.
  • Article 6 (1) (b) (processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract) of the GDPR.
  • Article 6(1)(f) of the GDPR (legitimate interest) allows processing when necessary for the legitimate interests of the controller or a third party, such as when the company proactively searches for candidate information through job portals, recruiting agencies, public sources, or former employers.
  • Criminal records data – Article 6(1) (c) of GDPR (legal obligation) processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Health information (Medical Certificate) – Article 6(1)(c) and GDPR 9(2)(g) processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller.
  • Health information (Personality Test Results) – Article 6(1)(c) and GDPR 9(2)(g) processing is necessary for the purposes of carrying out the obligations of the controller according Commission Regulation (EU) 2018/1042 of 23 July 2018 amending Regulation (EU) No 965/2012, as regards technical requirements and administrative procedures related to introducing support programmes, psychological assessment of flight crew, as well as systematic and random testing of psychoactive substances to ensure medical fitness of flight and cabin crew members, and as regards equipping newly manufactured turbine-powered aeroplanes with a maximum certified take-off mass of 5700 kg or less and approved to carry six to nine passengers with a terrain awareness warning system.

2.1.3   Retention period

  • We will process your personal information for the recruitment process for a period of 12 (twelve) months from the date of receiving your application, unless the selection process extends beyond this timeframe.
  • If your application for a specific position is unsuccessful, you may consent to having your personal data stored. In this case, we may contact you regarding similar positions for up to 3 years from the end of the selection process or from the date we receive your data, whichever is later. This consent will remain valid for 3 years.
  • Additionally, you can provide separate consent to receive communications from the Company, including newsletters, emails, online advertisements, phone calls, postcards, and other promotional materials. This consent will also remain valid for 3 years.
  • If your application is successful, we will retain your data for the duration of your employment/ professional engagement contract.

2.2    CABIN CREW

2.2.1 What kind of categories of personal data we process?

  • Personal Details: Full Name, Date of Birth; Valid EEA Passport Information; Nationality, Phone Number; Email Address, Country of Residence, Rejoining Company Information; Earliest Availability, Language Proficiency Information, etc.
  • Work Experience: EASA Cabin Crew Attestation, Block Hours Information.
  • Education information.
  • Visa Information.
  • Employment / Professional Engagement History.
  • Medical Report Details: EASA Cabin Crew Medical report. Yellow Fever vaccination certificate (yes/no).
  • Non – Criminal Records Certificate Information.
  • References information.
  • Interview Notes.

This list of information is not exhaustive.

2.2.2 On what legal basis do we process personal data?

  • Article 6 (1) (a) (data subject consent) of the GDPR.
  • Article 6 (1) (b) (processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract) of the GDPR.
  • Article 6(1)(f) of the GDPR (legitimate interest) allows processing when necessary for the legitimate interests of the controller or a third party, such as when the company proactively searches for candidate information through job portals, recruiting agencies, public sources, or former employers.
  • Criminal records data – Article 6(1)(c) of GDPR (legal obligation) processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Health information (Medical Certificate, Yellow Fever vaccination certificate)– Article 6(1)(c) (legal obligation) and GDPR 9(2)(b) processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller.

2.2.3 Retention period

  • We will process your personal information for the recruitment process for a period of 12 (twelve) months from the date of receiving your application, unless the selection process extends beyond this timeframe.
  • If your application for a specific position is unsuccessful, you may consent to having your personal data stored. In this case, we may contact you regarding similar positions for up to 3 years from the end of the selection process or from the date we receive your data, whichever is later. This consent will remain valid for 3 years.
  • Additionally, you can provide separate consent to receive communications from the Company, including newsletters, emails, online advertisements, phone calls, postcards, and other promotional materials. This consent will also remain valid for 3 years.
  • If your application is successful, we will retain this data for the duration of your employment or other professional engagement.

3. VETTING AND BACKGROUND CHECKS

As part of our application process, we may carry out necessary vetting procedures, which may include, but are not limited to, right-to-work verification, identity checks, criminal record checks, and verification of relevant employment / professional engagement history and professional qualifications, background check. These checks will be conducted in accordance with applicable laws and regulations, ensuring that your personal information is processed securely and responsibly.

To complete this process, we may request or check information from the last 5 years, including but not limited to: your residence history, employment / professional engagement history, any break periods, your father and mother’s full names, address, citizenship, education details, information on aviation security-related training courses, and criminal record details, intelligence and any other relevant information available to the competent national authorities that they consider may be relevant to the suitability of a person to work in a function which requires an enhanced background check.

We may also involve third-party background screening companies and national authorities in this process.

The legal basis for this step is Article 6(1)(c) of the GDPR (legal obligations) and Commission Implementing Regulation (EU) 2015/1998 of 5 November 2015 laying down detailed measures for the implementation of the common basic standards on aviation security.

4.  THE SOURCES WE COLLECT PERSONAL DATA FROM

We may collect personal data about candidates from the following sources:

  • Directly from you.
  • Job search portals and recruiting agencies.
  • AVIA SOLUTIONS GROUP (ASG) PLC and its subsidiaries.
  • Third-party companies that conduct background screening.
  • National authorities (background check).
  • Former/current employers (your qualifications, professional skills, business qualities, performance during previous/current employment, etc.).
  • From publicly accessible sources, such as LinkedIn and other business-related social media sources and/or collaboration platforms, websites or publicly available publications where you have added information about yourself (your name, surname, e-mail address, work history, and other data included on your profile).

5.  IF YOU FAIL TO PROVIDE PERSONAL INFORMATION

We collect relevant personal information based on the vacancy in order to process your application and/or for a pre-contractual relationship. It is in our legitimate interest to determine whether to appoint you to the role, as selecting a suitable candidate is beneficial to our business. Without the necessary personal information, we cannot proceed with your application or the selection process. If you fail to provide requested information, we will be unable to process your application successfully and continue with the recruitment process.

6.  DATA SHARING INSIDE EEE/EU

We may disclose your personal information to the following third parties for the purposes of the recruitment process:

  • Third-party service providers acting on our behalf (e.g., test service providers).
  • Government authorities, courts, and law enforcement agencies.
  • Professional advisors, auditors, lawyers, and financial advisers.
  • Third-party recruitment agencies assisting in the recruitment process.
  • Third-party background screening companies.

7.  DATA TRANSFER OUTSIDE EEE/EU

In most cases, your personal data will be processed within the countries of the European Economic Area (EEA). However, there may be instances where your personal data is transferred to countries outside the EEA. We may work with trusted third-party processors (such as data centers, cloud service provides, site administration and related services, software developers, companies providing information technology infrastructure services, companies providing communication services) that are located outside the EEA.

Please note that countries outside the EEA may not offer the same level of data protection as those within the EEA. When transferring your data outside the EEA, we have entered into Standard Contractual Clauses approved by the European Commission, or we follow other grounds and conditions set out in the GDPR or decisions of the European Commission.

8.  DO WE APPLY AUTOMATED DECISION-MAKING OR PROFILING?

We do not use automated decision-making processes, including profiling. We value your privacy and ensure that no automated systems are used to analyse or evaluate your personal data in a way that would result in legal consequences or similarly significant effects.

9.  YOUR RIGHTS IN CONNECTION WITH PERSONAL INFORMATION

We guarantee the implementation of these rights and the provision of any related information at your request or in case of your query:

  • Access: Request a copy of your personal data.
  • Correction: Request correction of inaccurate or incomplete information.
  • Erasure: Request deletion of personal data if there is no valid reason to retain it.
  • Object to Processing: object to processing based on legitimate interests.
  • Restriction of Processing: request to suspend processing while we verify its accuracy.
  • Data Portability: request your data be transferred to another organization or to you.
  • Withdraw Consent: you can withdraw consent and application at any time without affecting the lawfulness of processing based on consent before its withdrawal. Upon withdrawal, the Company will delete your personal data promptly.

To exercise these rights, contact the Company at [email protected]. Each request will be assessed on a case-by-case basis. The Company may not be legally required to comply with your request due to applicable data protection legislation exemptions.

10.  COMPLAINTS:

If you disagree with our actions or the response to your request, you have the right to file a complaint with the relevant supervisory authority. A list of supervisory authorities in each EU country can be found here: https://edpb.europa.eu/about-edpb/board/members_en.

However, we recommend that you contact us first to allow us the opportunity to resolve the issue before you submit a formal complaint.

Thank you for your application. For any questions about your personal data, please contact us at [email protected].