This Privacy Policy (the Privacy Policy) covers the processing of personal data performed by UAB “BAA Training”, legal entity code 300618099, address Dariaus ir Girėno g. 21, 02189 Vilnius, Lithuania, phone No. +370 5 252 55 36, [email protected], as a data controller (“Us” or “We”) in running of Peer Support Programme.
This Privacy Policy sets out the basic rules for the collection, processing and storage of your personal data and other information related to you, including the scope, purposes, sources, recipients of your personal data and your rights as a personal data subject and other important aspects of your use of PSP (as defined below), provided by us, and the usage and browsing of the website www.pilotpeer.com. This information is important, so please read it carefully.
The term “personal data” (the “Personal Data”) in this Privacy Policy means any information about you relating to you as a natural person, a data subject whose identity is known or can be directly or indirectly identified through the use of certain data (e.g. name, surname, address, telephone number, etc.).
A Peer Support Programme (the “PSP”) is defined as a system whereby a pilot, a student learning to become a pilot or flight instructor 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, students learning to become pilots or flight instructors, does not hold managerial position in the airline or aviation academy, 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.
In the event that you provide us with personal information other than your own (for example, you are reporting to us about the colleague/ family member/ friend you are concerned about), please inform them of this Privacy Policy and its content.
If you have any questions regarding this Privacy Policy or requests regarding the processing of your personal data, please contact our Data Protection Officer by email: [email protected]
By visiting our website www.pilotpeer.com and/or using the information contained therein and/or our services, you acknowledge and confirm that you have read and understood this Privacy Policy.
This Privacy Policy is designated to persons who use or intend to use PSP or visit the website www.pilotpeer.com (the „Data subjects“ or „You“).
The terms and conditions of the Privacy Policy apply to you every time you access the content and/or the service we provide, regardless of which device (computer, cell phone, tablet, etc.) you are using.
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 organization (airlines you are providing pilot services to, aviation academy where you are studying to become a pilot or are providing the services as flight instructor). | 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. |
| Contact data of your familly members or friends | For the psychiatrist to contact and evaluate the information provided by airlines about your positive psychoactive test result. |
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 organization (airlines you provide pilot services to or aviation academy where you are studying to become a pilot or are providing services as flight instructor) – we guarantee that, there will be no possibility to identify specifically you from the data provided, except the following:
We may also share your Personal Data under the following circumstances:
Personal Data held by us is processed no longer than needed to achieve and fulfil the purposes set out in this Privacy Policy, as well as for the purposes of having evidence to justify the lawfulness of our Personal Data processing operations. Personal Data will be usually processed for the aforementioned purposes no longer than 1,5 (one and a half) years after provision of PSP service to you. In exceptional cases when a threat to public or air safety is identified, the Personal Data might be kept for 3 (three) years from the time when the case was closed.
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.
When you visit our website, we are collecting cookies. The list of used cookies is provided in our Cookie Policy, which is published at our website www.pilotpeer.com
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. TThe 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.
In exceptional circumstances, which may require us to have additional time, the deadline for replying may be extended for a further two months, depending on the complexity of the situation. In this case, we will inform you in writing about such extension within 1 (one) month from the receipt of the request and indicate the reasons for the delay. If we think we need to, we will cease the processing of your Personal Data, except for storage, until your application is resolved. If you have legally waived your consent, we will immediately terminate the processing of your Personal Data and within no more than 30 (thirty) calendar days, except in the cases provided for in this Privacy Policy and in the cases provided for by law when further processing of your Personal Data is binding on us by the legislation in force, the legal obligations we are facing, court judgements or binding instructions from the authorities. The response will be provided in the same way as your request was received.
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.
We reserve a right to change this Privacy Policy unilaterally from time to time (for example, if the law changes). Any changes will be immediately posted on the website.
This Privacy Policy applies from the date it is posted on the Websites. Last review of the Privacy Policy: 30 August 2021. If you continue to use our services after changing the terms of the Privacy Policy, you will be deemed to have read and understood the changed terms of the Privacy Policy.
Terms:
| Peer | Professional pilot volunteer who went through specifically designed selection process, 28 hour long training program and is here to support their fellow pilots or students learning to become pilots or flight instructors in time of need. |
| Support program manager | Manager of Pilot peer Support Program with master degree in psychology and extensive experience in aviation. His main goals are to support Peers, assure that the program is running smoothly and provides you with support needed. |
| Mental health professional | Certified psychiatrist with experience in aviation who cooperates with Pilot Peer Support Program. His main goals are to support Peers and Support Program Manager with his expertise in area of mental health and make final evaluations regarding possible threat to safety. |
| Organization | Airline you are currently employed in or aviation academy you are currently studying in or working for. |
* The only exception to this is if you tell us something that indicates rather clearly that either you or someone else is in imminent danger or that may cause danger to the public or air safety. In that case, having a proper legal basis (public interest or your consent) we may disclose your data. This may include waiving your confidentiality, i.e.:
Then your organization will make the decision if you should be suspended from flying for a particular period of time till you regain proper mental wellbeing.