Birmingham Airport Limited –Privacy Notice
Department – Human Resources
Purpose - Recruitment
Birmingham Airport is collecting your personal data. When we collect personal data, we are obliged legally to provide you with certain information, it is called the “Right to be Informed”. That information is contained in the below Notice. If any of the information we provide to you is not clear enough, there are contact details for Birmingham Airports Data Protection Officer further down this Notice, please do not hesitate to make contact and ask for further information.
- Why we need it - the purpose of processing
We are collecting your information as part of our recruitment process. This is to ensure that you are suitable for the role to which you are applying, and that we have all the information we require to assess that suitability.
We will use your gender, ethnicity, and disability information to comply with equality laws.
We will also use your personal information to produce any feedback you might request from us on your performance.
We will use your information to do any necessary background checks, as needed by the Civil Aviation Authority Regulations. This includes continuous checks via West Midlands Police and their Counter Terrorism Unit, and the Home Office and an external vetting company.
- Why we’re allowed to process your personal information in this way – the legal basis
- Article 6 condition – for the establishment or performance of a contract (employment contract).
- Article 9 condition - carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law.
- Article 9 condition - processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee.
- Who we will share your personal information with?
Employee data is kept on the HR software system I-Trent, this is provided to us by MHR.
They will have access to the personal data held in the software for the purposes of supporting the IT infrastructure only, they will not have access to the information for any other purpose.
Your personal data will also be shared with the recruiting manager and the HR Team as part of the recruitment process.
We will share your personal data with West Midlands Police, including their Counter Terrorism Unit, and the Home Office weekly, to continue checking your records against any disqualifiable criminal records, as per Regulations from the Civil Aviation Authority, or any intelligence which places you or the Airport and its occupants at serious risk.
Depending on recruitments levels, the Airport uses an external company to carry out the Airport reference checks. These are required for you to hold an ID Pass at the Airport. Without this check being carried out you are not allowed to work on site at the Airport, and your employment could be refused. The company currently being used is ARR and your personal information will be shared with them to carry out any vetting required for your post.
- Where your personal information will be stored or transferred to – will it be sent outside of the European Economic Area?
Your personal information will be kept on the I-Trent system, as mentioned above. I -Trent servers are based in the UK, and your personal information will not be transferred outside of the European Economic Area (EEA).
- How long we will keep your personal information for.
If you are successful in the recruitment process and are offered a position within Birmingham Airport you will be provided with another of these Notices, which will explain how long your personal information will be kept as an employee.
If you are unsuccessful on this occasion, your personal information will be kept for no longer than 6 months from the recruitment process, this will include any feedback we provide to you.
- Your rights
You are entitled to request the following from Birmingham Airport. These are called your Data Subject Rights and there is more information on Birmingham Airports website about each of these and what they mean to you. You can find this information on the airports website birminghamairport.co.uk/dataprotection
- Right of access
- Right to rectification
- Right to restriction of processing
- Right to data portability
- Rights with regards to automated individual decision making, including profiling
Right to object
The right to object is particularly important if we are processing your information under the conditions of a “public task”, or “legitimate interests”, and you can check that information above in section 2. These is because these conditions must be based on not overriding your rights and freedoms against our purposes for using your personal information. If we are using your personal information on these grounds and you wish to object, please contact us on [email protected]
If you have any questions, or wish to contact us and ask us to look at your rights at any time, please contact Birmingham Airports Data Protection Officer on the below details.
Birmingham Airport Limited
Email: [email protected]
- If you are unhappy with the way in which we use your personal information
If you are unhappy with the way in which Birmingham Airport has used your personal information and you have already been in contact with us (on the above details) and feel we did not resolve your issues to your satisfaction, you can contact the Information Commissioners Office (The UK’s Data Protection Regulator), the details are below. However, the Information Commissioner does prefer that you have contacted Birmingham Airport first with your concerns before you then take those concerns to them as the Regulator.
Information Commissioners Office
Email: [email protected]
Telephone number: 0303 123 1113 for local rate calls or 01625 545745 for the national rate.
- Is your personal data being processed because of a regulatory or contractual requirement?
Yes, the vetting we do against any criminal checks is a regulatory requirement by the Civil Aviation Authority.
- Are we using automated decision making or profiling with regards to your personal data?
Yes, we are using automated decision making and profiling as part of the recruitment process. When you fill in the online application form, there are some questions which cause the system to decide on whether to allow you to continue in the recruitment process based on your answers.
The reason behind using automated decision making in this way is to stop the recruitment is you can’t answer certain questions straight the way. These questions are about your eligibility to work in the UK, and or for example, whether you hold certain certificates which are required for certain jobs. Legally we need to ask these questions, or we need to ensure you have the qualification or training required to do the job.
If you are unable to provide the answers that are required, the system will automatically stop the application process, and give you an explanation as to why this has happened. It will save you time, by not allowing you to go through the application process, which takes some time, and allows our Human Resources department to only access applicants who have the correct eligibility to apply.
If you would like further information on this, or are unhappy with the way in which the decision has been made, please contact the Airports Data Protection Officer on the above contact details.