RISHWORTH AVIATION PRIVACY NOTICE

Candidate Privacy Notice

Welcome to the Rishworth Aviation privacy notice.

Rishworth Aviation respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from), when you register with us or ask us to find you work, and when we place you in a role. This notice will also tell you about your privacy rights and how the law protects you.

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE

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

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

It is important that you read this privacy notice, 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 notice supplements the other notices and is not intended to override them.

If you have any questions about this privacy notice, please contact us at dataprotection@empresaria.com.

CONTROLLER

Rishworth Aviation Limited is the data controller and responsible for your personal data (referred to as “Rishworth Aviation”, “we”, “us” or “our” in this privacy notice).

We are part of the Empresaria group of companies and your information may also be used by our affiliated entities and group companies (our ‘Group Companies’), full details of which can be found at https://www.empresaria.com/.

In this notice, references to ‘we’ or ‘us’ mean the Rishworth Aviation and our Group Companies. We may act as joint data controllers with our parent company, Empresaria Group plc, in respect of some personal data. The Empresaria Group privacy policy appears on our website https://www.rishworthaviation.com/legal_documents/privacy_policy.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.

CONTACT DETAILS

Our full details are:

Company name: Rishworth Aviation Limited

Address: Level 2, 2 Owens Road, Epsom, Auckland 1023, New Zealand

Email: dataprotection@empresaria.com

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

This version was last updated on 13 July 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.

2. 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
Criminal report data
Trade union membership data

Sensitive personal data

We acknowledge the sensitivity of the last three categories of data listed and will normally only process it when necessary to provide you with a safe place of work, to comply with legal or industry-specific requirements or to safeguard passenger safety. 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 notice.

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.

3. 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;

(c) analytics providers such as Google based inside and/or outside the EU;

(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 or outside the EU.

4. 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 passenger 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, please contact us.

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	Legal obligation (if applicable). 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	Legal obligation (if applicable). Contractual obligation (if applicable). Legitimate interests.
IP address, browser and device data	To deliver relevant website content and administer our website	Legitimate interests.

DIRECT MARKETING

We would like to use your contact details to contact you about job opportunities, 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 and you have the right to unsubscribe at any time.

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.

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.

5. 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 share your personal data with our other Group Companies.

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 notice.

We will not share your personal data with any other organisation unless it is 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.

6. 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. Our parent company is based in the UK. Some of our Group Companies are based in third countries.

Some categories of data may be transferred to other organisations outside the EEA. If you are an EU 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.

We will only transfer your personal data to organisations located in countries outside New Zealand or the EEA (including to our Group Companies), if you have given us your explicit consent and/or the organisation:

is based in a country which has been deemed to provide an adequate level of protection for personal data by the European Commission; or
has entered into an agreement with us which contains standard contractual clauses approved by the European Commission which give personal data the same protection that it has in the EU.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA or New Zealand.

7. 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.

8. 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.

9. 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.

If you wish to exercise any of the rights set out above, please contact us at dataprotection@empresaria.com.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a fee if requests are repeated or obviously excessive.

10. COOKIE SETTINGS

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Airline Contact Privacy Notice

Rishworth Aviation Limited is the data controller and responsible for your personal data (referred to as “Rishworth Aviation”, “we”, “us” or “our” in this privacy notice).

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.

CONTACT DETAILS

Our full details are:

Company name: Rishworth Aviation Limited

Address: Level 2, 2 Owens Road, Epsom, Auckland 1023, New Zealand

Email: dataprotection@empresaria.com

Source of your personal data

We obtained the following categories of your personal data either from one of our candidates or from previous contact with you (not publicly accessible sources), or from LinkedIn, your company's website or the CH-Aviation contacts database (publicly accessible sources):

Your contact details
Your rank/title and employer

Further details about how we process your personal data can be found at https://www.rishworthaviation.com/candidate-privacy-notice

The purposes for which your personal data will be processed

We need to process your personal data for the purposes of engaging clients and identifying opportunities to provide recruitment and work-finding services.

The basis for processing your personal data

We will only use your personal data when the law permits us to do so, for example:

Where we need to comply with a legal or regulatory obligation;
Where it is necessary for our legitimate interests (or those of third parties) and your interests, rights and freedoms do not override those legitimate interests;

Our business involves providing work-finding and recruitment services in the commercial aviation sector 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 also need to process your personal data where it is in the legitimate interests of third parties for us to do so.

Document / Personal Data	Why we need it	Our lawful ground for processing it
Name, business address	To communicate with you To verify your identity	Legal obligation (if applicable). Legitimate interests (of RAL & passengers).
Contact details	To communicate with you To verify your identity	Legal obligation (if applicable). Legitimate interests (of RAL & passengers).
Emails and correspondence with you	To communicate with you	Legal obligation (if applicable). Legitimate interests (of RAL & passengers).

Sharing your personal data

Your personal information will be processed by our staff and our subcontractors (including IT providers) in order to provide our recruitment and work-finding services. 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 share your personal data with our other Group Companies. We may also need to share your data with our professional advisers, such as lawyers and accountants.

We will not share your personal data with any other person or organisation unless it is necessary and in connection with providing our work-finding and recruitment services.

Overseas transfers

The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein. We have offices in Sweden, which is inside the EEA, and in New Zealand, which is outside of the EEA but has been determined by the EU Commission to provide adequate data protection for personal data by the EU Commission. Our parent company is based in the UK. Your data will be subject to technical and organisational safeguarding protection measures.

is based in a country which has been deemed to provide an adequate level of protection for personal data by the European Commission; or
has entered into an agreement with us which contains standard contractual clauses approved by the European Commission which give personal data the same protection that it has in the EU.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA or New Zealand.

Accuracy of your data

We will endeavour to keep your personal data accurate and up to date and will only process it for the specific purposes notified above. Data that is inaccurate or out of date will be deleted. Please notify us if your personal details change or if you become aware of any inaccuracies in the personal data we hold about you.

Retaining your data

We may also retain your personal data in order to pursue our legitimate interests. We will not store your data for any longer than is necessary to comply with our legal obligations or to pursue our legitimate interests or those of third parties. We will delete your data in line with the Empresaria Group privacy policy which appears on our website https://www.rishworthaviation.com/legal_documents/privacy_policy.

Your rights

Whilst we are processing your data, you have 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;
ask to have inaccurate data held about you or 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.

If you wish to exercise any of the rights set out above, please contact us at dataprotection@empresaria.com.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a fee if requests are repeated or obviously excessive.

Cookie Settings.

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Data security

We will ensure that appropriate measures are taken against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data. We have in place procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction.

We will require all third parties to respect the security of your personal data and to treat it in accordance with the law. Maintaining data security means guaranteeing the confidentiality, integrity and availability (for authorised purposes) of the personal data.

Further information and breach reporting

If you require any information about the way in which we process your data or if you wish to report a complaint or a data breach, please contact dataprotection@empresaria.com. All enquiries will be responded to as quickly as possible and all data breaches will be taken very seriously.

If for any reason you are dissatisfied with the way in which your personal data has been processed, you can complain to your country’s supervisory authority for data protection.