Candidate privacy Policy

CANDIDATE PRIVACY NOTICE OF THE AVIA SOLUTIONS GROUP OF COMPANIES

 

  1. GENERAL INFORMATION.

This Candidate Privacy Notice (the “Candidate Privacy Notice”) explains how the Avia Solutions Group of companies (‘we”, “us”, the “ASG Group”) comply with applicable privacy requirements and sets out minimum standards for how we deal with all personal data that we collect from you, or that you provide to us including via this website and any other websites or applications of the affiliates of the companies group of Avia Solutions Group (collectively, the “Websites”), through other recruitment routes, such as recruitment agencies, job boards and other means, such as by post or email.

The Avia Solutions Group of companies includes these companies https://aviasg.com/en/the-group/general-contacts. The companies of the ASG Group of companies are processing your personal data as the Joint controllers.

PLC Avia Solutions Group, the Address: Dariaus and Gireno st. 21a, LT-02189 Vilnius, Lithuania is the administrator of the website https://careers.aviasg.com/en and the joint controller with the other ASG Group companies.

This Candidate Privacy Notice describes ASG Group's efforts to be compliant with the European General Data Protection Regulation 2016/679 of 27 April 2016 (the “EU GDPR”) and any applicable national data protection laws.

  1. DATA PROTECTION PRINCIPLES

We will comply with data protection law and principles in relation to your personal information, which means that:

  • We will use your personal information lawfully, fairly and in a transparent way.
  • We will collect your personal information only for valid legitimate business purposes that we have clearly explained to you, and we will not use that recruitment information in any way that is incompatible with those purposes.
  • We will use your personal information as is relevant to the purposes we have told you about, and which is limited only to those purposes – i.e. not excessive.
  • We will keep your personal information, accurate and up to date.
  • We will keep your personal information only for as long as is necessary, for the purposes we have told you about.
  • We will keep your personal information secure; we protect it against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure or access, using appropriate technical and organisational measures; we process it in accordance with your applicable legal rights.
  1. THE KIND OF INFORMATION WE HOLD ABOUT YOU

In connection with your application for work with us, we will collect, store, and use the following categories of personal information about you:

  • The information you have provided to us in your CV and covering letter or email, which will generally tell us who you are and help us decide if you are suitable for certain positions within the organization.  This type of information may include your name, title, address, telephone number, personal email address, date of birth, employment history, qualifications, information about the type of work and projects you have been involved with, and any other information you may wish to provide to us as part of your application.
  • Any information you provide to us, or which is collected during an interview; information on your performance at assessment centres, information provided by your referees (to the extent we are permitted to contact them), etc.
  • Future or other opportunities information (subject to your consent): This is information collected during your initial application to us and we may retain it in order to keep in touch with you about future or other job opportunities within the ASG group and to identify such suitable opportunities for you, this information includes your name, personal email address, location, the field of expertise and the kind of role you are interested in; there may be opportunities within the ASG group worldwide for which you may be suitable, but which are not in the same country as the role which you have applied for originally, or the country where you live.
  1. HOW IS YOUR PERSONAL INFORMATION COLLECTED?

We collect personal information about candidates from the following sources:

  • You, the candidate (for example when you provide information as part of your application or during the recruitment process);
  • The recruitment agency (if applicable for your application), from which we collect the following categories of data: your CV, name, address, date of birth, previous roles, reasons for wanting to change roles or work.
  • Your named referees, from whom we collect reference details such as your previous employer/contractor, details of the role or work carried out by you in the past (e.g. job title) and the dates during which you were employed or carried out that work / project (only to the extent we are permitted to contact your referees and to collect such information from your referees);
  • The data from third parties from a publicly accessible source: for example, LinkedIn, or other business or employment-oriented services that operate via websites where you have added information about yourself; publications which you have written/contributed to, and which are publicly available;
  • From other companies of the Avia Solutions Group of companies under your consent to transfer the personal data for the purpose of the recruitment to ASG Group.
  1. HOW WE WILL USE INFORMATION ABOUT YOU AND ON WHICH LEGAL BASES WE RELY

To the extent permitted by applicable law, we will use the personal information we collect about you to:

  • Assess your skills, qualifications, and suitability for the work or position, including through assessment centers, and generally to process your application, including validation of your information via your references (only to the extent we are permitted to contact your referees and to collect such information from your referees);
  • Communicate with you about the recruitment process, including where applicable arranging travel / accommodation / travel cost payments, in respect of the interview process;
  • Communicate with relevant ASG Group employees about the recruitment process, and also with the recruitment agency that referred you to us;
  • Communicate with you for future offers of the employment (only if you have given the consent).

We rely on the following legal bases to collect and process your personal data:

  • The processing is necessary for hiring decisions and in order to take steps at your request to enter into an employment contract.
  • We have an overriding legitimate interest in processing your data, such as it is in our legitimate interests to decide whether to appoint you to a role or work since it would be beneficial to our business to appoint someone to that role or work. 
  • The processing may be necessary to comply with our legal obligations, including those in the field of employment.
  • At other times, ASG Group will be processing your personal information because you have consented to ASG Group doing so (e.g. the consent for the transmission of your personal data to other companies of the Avia Solutions Group of companies, the consent to storage your personal data for the future selections, etc.) In which case you can withdraw such consent at any point.

If you fail to provide personal information

Your personal information is necessary for processing your application and/or for a pre-contractual relationship with us with the exception of the following information, which is not necessary: future or other opportunities information. Without your necessary personal information, we are generally not able to continue the job application process or the selection procedure. If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully and continue with the application process. If we request personal information from you, which is more than is necessary as referred to in this notice, we will tell you separately, that this additional information is provided by you on a voluntary basis. 

  1. DATA RETENTION 

We will process the personal information until the selection process for the vacancy for which you have applied has been completed. The end of the selection process is considered to be the end of the probationary period of the candidate who has signed the employment contract (maximum 3 (three) months). If an employment contract has been concluded with you, your data will be stored for the entire period of the employment contract.

If you are unsuccessful in your application with us (or if you reject the position), but you would like to be in the database of the candidates, under your consent the personal data will be stored 2 years from receiving the consent.

  1. DATA SHARING AND/OR TRANSFER OUTSIDE EEE/EU

Data sharing inside EEE/EU

We could only disclose your personal information with the following third parties for the purposes of recruitment process: (i) third party services providers acting on our behalf and our instructions (the data processors); (ii) other companies within the ASG group (for example one of the ASG company offering the position that you are applying for, or ASG companies where the responsible HR managers or the hiring manager(s), for your application are located) for all processing purposes identified above; (iii) governmental authorities (local and foreign), courts, law enforcement authorities, external consultants to the extent required or permitted by law. All our third-party service providers and other ASG Group companies are required to take appropriate security measures to protect your personal information. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

Your personal information may be transferred to other ASG Group’s companies whenever such is necessary to meet a contractual obligation towards you, and/or in order to process your application and manage the recruitment process (e.g. application for a job in another country; or the position involves managing people in another country; or being managed by someone in that country, or the position you are applying for means managers in another country have a need to know about your personal information). We may also disclose your personal information if you consent to share with other ASG Group's companies for purposes of the recruitment.

Data transfer outside EEE/EU

The recipients (the data processors or independent controllers) of your personal information may be located in countries outside of the EU/EEA, including the UK, and ASG will take the appropriate safeguards as required by the GDPR. In particular:

Your personal information may be transferred to ASG Group’s companies and other recipients, such as service providers, which are located in countries outside the EU/EEA, in which case ASG and/or other  ASG Group’s company will take the necessary measures to protect the personal information: For recipients located outside the EU/EEA, some are located in countries with adequacy decisions pursuant to Art. 45 GDPR, and, in each case, the transfer is thereby recognized as providing an adequate level of data protection from a European data protection law perspective.

Other recipients are located in countries, which do not adduce an adequate level of protection from an EU/EEA data protection law perspective, we will take all necessary measures to ensure that transfers out of the EU/EEA or UK, as the case may be, are adequately protected as required by applicable data protection laws.

For example, we will base the transfer on appropriate safeguards, such as standard contractual clauses adopted by the European Commission (Art. 46(2)(c) or (d) GDPR), or approved certification mechanisms together with binding and enforceable commitments of the recipient (Art. 46 (2)(f) GDPR). You can ask for an information of such appropriate safeguards by contacting us at privacy@aviasg.com.

Depending on the data protection law applicable to you, you may have the right to make a complaint at any time to the relevant supervisory authority for data protection issues.  For example, in Lithuania this is the State Data Protection Inspectorate (https://vdai.lrv.lt/en/).

  1. YOUR RIGHTS IN CONNECTION WITH PERSONAL INFORMATION

Under certain circumstances, by law you may have the right to:

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • Right to object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, or request that we transfer a copy of your personal information to another party, please contact our Data Protection Officer by sending an email to privacy@aviasg.com. Any request to exercise one of these rights will be assessed by us on a case-by-case basis. There may be circumstances in which ASG Group’s company is not legally required to comply with your request or because of relevant legal exemptions provided for in applicable data protection legislation.

As referred to above, you may have the right in certain circumstances, to file an objection at any time against the processing of your personal information. If you file an objection, we may not be able to continue to process your personal information – but in some cases, we will still be able to: for example, if our use of your personal information outweighs your interests or the processing serves the purpose of asserting, exercising or defending legal claims.

Of course, you can withdraw your application at any time.

Right to withdraw Consent 

In some circumstances, you may have provided consent to us, to enable the processing of your personal information for the purposes of the recruitment exercise (the possibility to be in the candidates' database). You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact our Data Protection Officer by sending an email to privacy@aviasg.com. Once we have received notification that you have withdrawn your consent, we will no longer process your personal information and, subject to our retention policy, we will dispose of your personal information securely.

  1. CONTACTS

If you have any questions about this Candidate Privacy Notice or wish to contact us for any reasons in relation to the processing of your personal data, please contact our Data Protection Officer by sending an email to privacy@aviasg.com, or by sending a dated and signed request to the office address: Dariaus and Gireno st. 21a, LT-02189 Vilnius, Lithuania.