This policy explains what personal data Avolon will hold about you, how we collect it, and how we will use and may share information about you during the application process. We are required to notify you of this information under data protection legislation including the General Data Protection Regulation (EU 2016/679) (“GDPR”) and any data protection legislation from time to time in force in Ireland including the Data Protection Acts 1988 & 2003 and/or any successor legislation. Please ensure that you read this and any other similar policy we may provide to you when we collect or process personal data about you.
2 Who collects your personal data
Avolon Aerospace Leasing Limited (the “Company”) is a ‘data controller’ and gathers and uses certain information about you. This information may also be used by our ultimate parent company Avolon Holdings Limited and its subsidiaries (our “group companies”) and so, in this policy, references to ‘we’ or ‘us’ mean the Company and our group companies.
3 Data protection principles
We will comply with the data protection principles as set out in Article 5 of the GDPR when gathering and using your personal data.
4 Personal Data we collect and hold on you
We may collect the following information up to and including the shortlisting stage of the recruitment process:
- Your name and contact details (i.e. address, home and mobile phone numbers, email address);
- Details of your qualifications, experience, employment history (including job titles, salary and working hours) and interests; and
- Any other information you may provide to us as part of your application.
We may collect the following information when we issue a conditional offer of employment:
- Information about your previous academic and/or employment history, from references obtained about you from previous employers and/or education providers;
- Information regarding your criminal record, in criminal records certificates and enhanced criminal records certificates ;•
- Your nationality and immigration status and information from related documents, such as your passport or other identification and immigration information;
- A credit check;
- A social media network check; and
- Information on prior addresses.
5 How we collect your personal data
We collect your personal data either directly from you or through a trusted third party who will work directly with you to obtain details of your referees (details of whom you will have provided), your educational institution, any relevant professional bodies, and relevant regulatory authorities. We will undertake all reasonable steps to ensure that our third party providers will process and store your personal data under the same high standard that we take to protect it.
6 Why we collect your personal data and how we use it
We will typically collect and use your personal data for the following purposes:
- to assess your suitability for employment with Avolon;
- to take steps to enter into an employment contract;
- for compliance with a legal obligation (e.g. our obligation to check that you are eligible to work for Avolon); and/or
- for the purposes of our legitimate interests, but only if these are not overridden by your interests, rights or freedoms.
We seek to ensure that the personal data we collect and process is always proportionate. We will notify you of any changes to the purposes for which we collect and process your personal data.
7 How we may share your personal data
We may also need to share some of the above categories of personal data with HR consultants, service providers and/or professional advisers (“other parties”). The recipient of your information will be bound by similar obligations to protect your personal data. We may also be required to share some of your personal data with regulators or as required to comply with applicable laws and regulations.
8 Where your personal data may be held
Personal data captured may be held at our offices and those of our group companies, and other Parties as defined above. This data may also be stored on our document storage platforms which are located in the EU, Singapore, Hong Kong and the USA.
9 How long we keep your personal data
We keep the personal data that we obtain about you during the recruitment process for no longer than is necessary. How long we keep your personal data will depend on whether your application is successful, the nature of the information concerned and the purposes for which it is processed.
10 Your rights to correct and access your personal data and to ask for it to be erased
Please contact Avolon’s HR Data Privacy Lead who can be contacted at email@example.com if you would like to correct or request access to your personal data (in accordance with applicable law). You also have the right to ask the HR Data Privacy Lead for your personal data which we hold to be erased (the ‘right to be forgotten’) in accordance with applicable laws and regulations.
11 Keeping your personal data secure
We have appropriate security measures in place designed to prevent your personal data from being lost, used or accessed in an unauthorised way.
We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so and within the prescribed time periods under Personal Data Protection Law.
12 Questions and complaints
Our HR Data Privacy Lead should be able to answer any queries or resolve any concerns you have regarding the use of your personal data, and is contactable at firstname.lastname@example.org
If you are not satisfied with our replies, you may contact the Data Protection Commission for further information about your rights and how to make a formal complaint.