FlightSafety International Privacy Notice
Scope:
FlightSafety International’s Privacy Notice applies to personal data (any information relating to an identified or identifiable individual) about our customers, clients, contractors, and other individuals collected and used by FlightSafety International and its wholly owned subsidiary of FlightSafety Services Corporation.
For the purposes of this Privacy Notice FlightSafety International includes its Corporate Headquarters, Divisions and all of its Learning Centers and facilities located both in the United States and around the world. Our Learning Centers operate under subsidiaries and/or joint ventures in locations worldwide, including without limitation, Australia, Canada, France, Hong Kong, Japan, Middle East, Netherlands, Norway, Saudi Arabia, Singapore, South Africa, Thailand, and the United Kingdom.
Information FlightSafety Collects:
FlightSafety International collects information about you from a variety of sources, including:
- Information we collect directly from you.
- Information we collect about you when you contact us, visit our Learning Centers and other sites, visit our websites, visit our booths at industry shows/events, use our mobile and web-based applications and interact with ours Sales team and marketing information.
- Information we collect about you during the course of your contract with us.
- Information we collect about you when you train with us.
- Information we collect about you from public and commercially available sources.
All information that FlightSafety International collects about you may be combined to improve our communications with and service to you as well as to enable us to develop and maintain world-class products and services.
Uses/Information Sharing:
FlightSafety International is a global business. We may transfer your personal information to other countries which may not have the same data protection laws as the country in which you initially provided the information, but we will protect your personal information in accordance with this International Privacy Notice, or as otherwise disclosed to you.
FlightSafety International collects and uses your Personal Information in connection with our Website and Services to:
- Provide the products and services you request.
- To tell you about our products and services.
- To manage and improve our Learning Centers, sites, products, and services.
- To manage your employment with us.
We do not sell your personal data to companies outside of FlightSafety International.
We may share your information:
- Internally to administer your account(s) and provide the products and services you request.
- With our carefully selected business partners but only if we have your consent.
- With third-party service providers who perform business operations on our behalf.
- To protect your vital interests.
- To protect and defend FlightSafety International.
- When required by law and/or governmental authorities.
In some cases, if you do not provide your personal information to us we may be unable to provide the products and services you request.
Lawful Basis for Processing:
Data Protection Law requires us to have a legal justification to process your personal information. We use the following depending on the type of data and the type of processing:
- Consent
- Performance of a Contract
- Compliance with a Legal Obligation
- Protecting Vital Interests
- Necessity
- Legitimate Interests
Privacy Notice Distribution and Updates:
- FlightSafety International’s Privacy Notice is published and maintained on all company websites:
- FlightSafety International also publishes and maintains a Teammates and Prospective Teammate Privacy Notice on:
- Privacy Notices are provided annually to all data subjects and at the time of data collection.
- FlightSafety International reserves the right to update this privacy notice at any time without prior notice. Upon a change in notice, we will alert you with a conspicuous website banner.
- Use the “Last Updated” date in this policy and the Revision Log to determine when and what changed.
Types Of Personal Data Collected:
Below are examples of the types of personal data elements FlightSafety International may collect, process, share, or use for each data subject type. These lists are examples and do not represent all data elements nor does it imply that all listed data elements are collected, processed, shared, or used for all data subjects in that category:
- Customers – Examples: legal name, company/entity, job title, location, education and training history, qualifications/certifications, professional memberships, contract type, credit check, IP Addresses, email, etc.
- Clients – Examples: gender, national identification number, legal name, company/entity, home address, job title, location, education and training history, course performance metrics, qualifications/certifications, professional memberships, contract type, emergency contact details, Airline, Hotel, and Car Rental Membership Numbers, photography, etc.
- Contractors – Examples: national identification number, legal name, home address, job title, location, salary/wage, education and training history, etc.
Types Of Sensitive And Criminal Data Collected:
Below are examples of the types of sensitive and criminal data elements FlightSafety International may collect, process or use for each data subject type. These lists are examples and do not represent all data elements nor does it imply that all listed data elements are collected , processed or used for all data subjects in that category:
- Customers – Examples: racial or ethnic origin, religion or religious beliefs, etc.
- Clients – Examples: racial or ethnic origin, religion or religious beliefs, etc.
- Contractors – Examples: drug test results, legal records, health and safety related information, racial or ethnic origin, etc.
Data Retention:
- FlightSafety International’s data retention policies vary by data type and type of processing. In general our retention policies align with the respective regulatory requirements.
- More information is available by contacting our Data Protection Officer at DataProtection@FlightSafety.com.
Your Rights:
- You have the Right to be Informed as to what personal data FlightSafety International collects, stores, shares, and processes and how that data is used.
- You have the Right to Access the personal data FlightSafety holds on you. FlightSafety International will provide a copy of this information to you at no cost under most circumstances.
- You have the Right to Rectification if the data is inaccurate or incomplete.
- You have the Right to Object to processing of your data. FlightSafety International will make every attempt to comply with your request.
- You have the Right to object to Automated Decision Making and request human intervention in the decision making process.
- You have the Right to Restrict and request a ‘block’ on processing of your personal data. FlightSafety International will make every attempt to comply with your request.
- You have the Right to Data Portability and to request your personal data back so that it can be reused for the purpose of buying or using similar services from other organizations.
- You have the Right to Erase and request the deletion or removal of your personal data where there is no compelling reason for its continued processing.
- Please contact our Data Protection Officer at DataProtection@FlightSafety.com to learn more about or to exercise such rights.
Information Security:
- FlightSafety International employs a robust information security program that protects personal data from loss, misuse, and unauthorized access and disclosure.
- The Information Security Program takes into due account the risks involved in the processing and nature of the personal data and incorporates Privacy-by-Design principles.
- A copy of our Information Security Program Overview is available by contacting our Data Protection Officer at DataProtection@FlightSafety.com.
Important Information:
- FlightSafety International is committed to working with customers, clients, contractors, and other individuals to resolve any privacy concern.
- FlightSafety International complies with all applicable data protection laws.
- You can read our full Privacy Policy on www.flightsafety.com or by contacting us for a paper copy.
How To Contact Us:
- To find out more about the use and disclosure of your information, to learn how to limit it, for all other inquires related to this notice, or to file a complaint, please contact our Data Protection Officer at DataProtection@FlightSafety.com.
Contact Our Corporate Headquarters:
FlightSafety International
Marine Air Terminal – LaGuardia Airport
Flushing, NY 11371
United States of America
(718) 565-4100
EU-US Privacy Shield:
- FlightSafety International is committed to comply with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. To learn more about the Privacy Shield program please visit https://www.privacyshield.gov/.
- FlightSafety International intends to certify to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern.
- In compliance with the Privacy Shield Principles, FlightSafety International commits to resolve complaints about our collection or use of your personal information. European Union individuals with inquiries or complaints regarding our Privacy Shield policy should first contact our Data Protection Officer at DataProtection@FlightSafety.com.
- We employ other companies (“agents”) and people to perform tasks on our behalf and need to share, and may internationally transfer, your information with them to provide products or services to you;. FlightSafety International is liable under the EU-U.S. Privacy Shield Principles for its agents to process transferred Personal Information in a manner consistent with the Principles.
- Under certain limited circumstances, European Union individuals may invoke binding Privacy Shield arbitration as a last resort if all other forms of dispute resolution have been unsuccessful. To learn more about this method of resolution and its availability to you, please visit https://www.privacyshield.gov/.
- FlightSafety International is subject to the jurisdiction of the Federal Trade Commission for purposes of Privacy Shield enforcement.
- FlightSafety International is required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Dispute Resolution:
FlightSafety International commits to cooperate with the panel established by the EU data protection authorities (DPAs) and comply with the advice given by the panel with regard to human resources data transferred from the EU in the context of the employment relationship.
Privacy Shield organizations must respond within 45 days of receiving a complaint.
If you have not received a timely or satisfactory response to your question or complaint from FlightSafety International’s Data Protection Officer, please contact the independent recourse mechanism listed below:
Non-HR Recourse
Federal Trade Commission (DPAs)
600 Pennsylvania Avenue, NW
Washington, DC 20580
Tel. +1 202 326 2222
HR Recourse
EU Data Protection Authorities
Revision Log:
Revision: 1.4
Date: 2-NOV-2018
Implementation Information: Effective 2NOV2018
Description of Changes:
- Clarifying language regarding the collection of data during training courses
- Clarifying language regarding the use of data for quality improvement purposes
- Addition of ‘share’ to align with use and sharing section
Revision: 1.3
Date: 21-JUN-2018
Implementation Information: Effective 21JUNE2018
Description of Changes:
- Global Business Statement
- Lawful basis for processing
- Data Retention
- Other minor grammatical/content corrections
Revision: 1.2
Date: 30-APR-2018
Implementation Information: Effective 1MAY2018
Description of Changes:
- Remove Data Subject – Teammates
- Add Reference to Prospective Teammates and Teammates Notice
Revision: 1.1
Date: 24-APR-2018
Implementation Information: Effective 24FEB2018
Description of Changes:
- Your Rights – header updated to European Data Subjects’ Rights
- Important Information – FlightSafety changed to FlightSafety International
Revision: 1.0
Date: 15-FEB-2018
Implementation Information: Effective 15FEB2018
Description of Changes:
- Original Issue