Birmingham Airport Wifi Privacy Notice

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.

  1. Why we need it - the purpose of processing

We will use your name and email address for the purposes of signing up to our free WIFI services, and by doing so you will then have the opportunity to receive marketing communication.

If you have ticked the opt in box, we will send you electronic marketing information via your email address.  This would include information about the latest destinations, airline offers, our airport partners, parking and shopping offers as well as advice on how to prepare for your journey through the airport.

When you use Birmingham Airport free WiFi we will collect your MAC address. A MAC address is a hardware (device such as a smartphone, tablet, laptop, or PC) identification number that uniquely identifies each device on a network. 

The free WiFi at the Airport is for use by anyone on the site.  This includes but is not limited to the following.

  • Passengers
  • Visitors
  • Airport employees
  • Onsite partner employees
  • Contractors

The MAC address allows the software to recognise the device and allow instant access, rather than the user having to go through the logon process again.

 

  1. Why we’re allowed to process your personal information in this way – the legal basis

When you initially provide us with your personal data, you will be provided with the opportunity to receive marketing communications from us. In doing so, you are providing us with your consent under Article 6 of the UK GDPR and the Privacy and Electronic Communications (EC Direction) Regulations 2003.

You can withdraw your consent for us to send you marketing by email at any time by clicking on the unsubscribe link at the bottom of any marketing email we send you.

If when signing up to the WiFi you do not provide us with your consent to receive marketing communications, then we will rely on the lawful basis of contract under Article 6 of the UK GDPR, to provide our WiFi service. Your data will be retained for a period of 24 hours before it is deleted.

MAC addresses will be collected under the lawful basis of legitimate interests, as this will allow users to gain instant access when logging in and out of the WiFi while in the airport.

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.

 

  1. Who will we share your personal information with?

We use an email broadcasting platform called Campaigner to create and dispatch our marketing communications, so your information will sit in their software and on their servers. They will only process your data for marketing purposes.

Since your information is captured on the Wi-Fi landing pages, Birmingham Airport will capture your marketing information, as long as you have given your consent. 

Birmingham Airport will have access to the personal data held in its software for the purposes of supporting the IT infrastructure only, they will not have access to the information for any other purpose.

Your MAC address will only be used within Birmingham Airport’s IT department.  This information will not be used to identify individuals. The Airport does not have the information available to match a MAC address to an individual, nor are we collecting it with this intent.

 

  1. Where your personal information will be stored or transferred to – will it be sent outside of the European Economic Area?

Birmingham Airport will hold your information in our secure servers in the UK.

 

  1. How long we will keep your personal information for

We have a re-engagement programme in place, meaning you will be removed from our marketing database if you have not engaged with us for two years.  At this point we will remove your information from our marketing database over the next year, meaning your information will not be kept any longer than 3 years after your last engagement. If you are engaging with us, we will continue to send you marketing until you withdraw your consent.

Your MAC address will be kept for 100 days.  This time span is required to allow regular users to be able to gain instant access, rather than having to logon each time.

 

  1. 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 by going to birminghamairport.co.uk/dataprotection

  • Right of access
  • Right to rectification
  • Right to erasure
  • 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 about them 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.

 

Postal Address:

Information Security

Birmingham Airport Limited

Diamond House

Airport Way

Birmingham

B26 3QJ

Email: [email protected]

 

  1. 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 the Regulator.

Postal Address:

Information Commissioners Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Email: [email protected]

Telephone number: 0303 123 1113 for local rate calls or 01625 545745 for the national rate

 

  1. Is your personal data being processed because of a regulatory or contractual requirement?

 With regards to sending you marketing information, there is no contractual or regulatory requirement for this.

 

  1. Are we using automated decision making or profiling with regards to your personal data?

No, there is no automated decision making or profiling carried out on your personal data for this purpose.

 

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