A Peer Support Programme (the “PSP”) is defined as a system whereby a pilot needing help can get support with mental wellbeing or life stress issues from a dedicated and trained colleague (peer) in a confidential manner; the system is also accessible to family, colleagues or friends of a pilot who have serious concerns about his/her mental wellbeing and fitness to fly.
Peer (the “Peer”) is a pilot who is a part of PSP, supports his fellow pilots, does not hold managerial position in the airline, and is trained in basic listening and counselling skills.
In processing the personal data, we responsibly comply with the regulation No 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (the “GDPR”), the Law on the Legal Protection of Personal Data of the Republic of Lithuania, and other directly applicable legal acts regulating the protection of personal data, as well as instructions from competent authorities.
When processing your personal data, we:
|The categories of processed Personal Data. What kind of categories of Personal Data we process?||The purpose of the processing of Personal Data. Why we process personal data?|
|Your Name (may be real or pseudonym, depending on your preference and the source from where it is received).||For your identification and communication with you.|
|Your phone number and e-mail address.||For getting in touch with you|
|Name of your organisation (airlines, aviation academy).||For meeting your preference concerning the Peer‘s organization.
For provision of feedback to your organization.
|Summary of communication with you (the essence of the problem, what was agreed during the consultation, number of consultations carried out, the status of the case (open or closed)).||For tracking statistics about effectiveness of the PSP, for the provision of feedback to your organization.|
|Information on your mental health and/ or information about your issues of substance abuse.||For provision of appropriate advice and assistance to you, for assessing potential threats to air safety and taking actions to ensure it.|
If you do not provide Personal Data, the provision of which to us is necessary for the performance of the PSP, we will not be able to provide you with services.
Our use of your Personal Data will always have a lawful basis. Most commonly, we use your Personal Data where:
We will usually process your Personal Data submitted by you to us by filling in the application form in our website www.politpeer.com.
In some other cases we might receive information about you from:
We assume the obligation of confidentiality with the highest respect to you. Usually, your Personal Data will only be provided to the Peer, assigned to contact and talk to you, and also, in situations where this is necessary and only having your consent – to a psychiatrist. However, we assure you that we have selected these individuals carefully, making sure that they will handle your Personal Data responsibly and in compliance with the relevant confidentiality obligations.
We will provide only statistical anonymized data about the PSP services to your organisation (airlines) – we guarantee that, there will be no possibility to identify specifically you from the data provided, except the following. Only in very rare cases, when the threat to public safety is presumed, your Personal Data might be shared with your organisation (airlines). In this case, the Personal Data is transferred and exchanged on the basis of a Joint Controllers Agreement signed between us and your organisation (airlines). You may, at your request, have access to the main provisions of this agreement by informing us of such a request by email [email protected]
We may also share your Personal Data under the following circumstances:
We ensure and take all necessary measures to avoid storing outdated or unnecessary Personal Data about you. At the end of the Personal Data retention period, the Personal Data is destroyed or anonymized in such a way that the person cannot be identified.
We responsibly implement appropriate organisational and technical Personal Data security measures intended for the protection of Personal Data against accidental or unlawful destruction, alteration and disclosure as well as against any other unlawful processing. The security measures we implement include the protection of personnel, information, IT infrastructure, internal and public networks as well as office buildings and technical equipment.
In the event of Personal Data breach of security that could seriously jeopardise your rights or freedoms and determine the circumstances with which unauthorised access to Personal Data has been obtained, we will immediately inform you about it.
As a general rule, your Personal Data will be processed in the countries of the European Economic Area (the “EEA”). However, in certain cases, your Personal Data may be transferred to non-EEA countries. Please note that in non-EEA states, Personal Data may be subject to less protection than within the EEA, but we carefully evaluate the conditions under which such Personal Data will be processed and stored after being transferred to the above-mentioned entities.
Please note that if the European Commission has determined that the third country, territory or one or more specified sectors in that third country or international organization concerned provides an adequate level of Personal Data protection, the transfer must take place in the same manner as in the EEA. Please be informed that you can have access to the information as to the states in respect of which the decision of the European Commission has been taken, here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.
In other cases, we take all necessary measures to ensure that your Personal Data is transferred to the recipient safely processing the Personal Data. The tools we use: a contract with a non-EEA recipient of Personal Data includes specific clauses for the secure processing of the Personal Data. In certain cases, we ask for your consent to transfer your Personal Data outside the Republic of Lithuania or the EEA.
We guarantee the implementation of these rights and the provision of any related information at your request or in case of your query:
In order to exercise your rights, please send us the request by e-mail [email protected]
Upon receipt of your request, we may ask you to provide proof of your identity or other identifying information to ensure that we are exercising your rights as a Personal Data subject and to prevent unauthorized disclosure of Personal Data or information to others who are not entitled to it. If we are unable to identify you, we will not be able to exercise your rights as a Personal Data subject.
We provide information about the processing of your Personal Data free of charge. If your request is unfounded, repetitive or disproportionate, we may charge a fee commensurate with our administrative costs.
Upon receipt of your request, we will respond to you within 30 (thirty) calendar days of receipt of your claim and the due date for submission of all documents necessary to prepare the answer.
By refusing to comply with your requirement, we will clearly indicate the grounds for such refusal.
If you disagree with our actions or the response to your request, you can complain to the State Data Protection Inspectorate (www.vdai.lrv.lt). In all cases, we recommend that you contact us before making a formal complaint so that we can find the mutual solution.
We may, from time to time, expand or reduce the scope of our business operations and this may involve the sale and/or the transfer of control of all or part of our business. Any Personal Datathat you have provided will, where it is relevant to any part of our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this notice, be permitted to use that Personal Data only for the same purposes for which it was originally collected by us.
Our websitemay contain links to other websites or services, which are not operated by us. We have no control over how your Personal Data is collected, stored, or used by such other websites and we advise you to check the privacy policies of any such websites before providing any Personal Data to them.