Privacy Policy | JMC Aviation

Privacy Notice : Work-Seekers, E-Learning Programme Users, General Website Users, Business Contacts and ICE Contacts

PLEASE READ THIS DOCUMENT CAREFULLY – IT CONTAINS IMPORTANT INFORMATION ABOUT THE WAY WE PROCESS PERSONAL DATA WE HOLD ABOUT YOU.

PLEASE ENSURE THAT DATA YOU PROVIDE TO US IS CORRECT AND UP TO DATE AND ADVISE US OF ANY CHANGES TO YOUR PERSONAL DATA AS AND WHEN THE SAME ARISE.

IF YOU ARE A DATA SUBJECT IN THE UK, THE SUPERVISORY AUTHORITY IS THE INFORMATION COMMISSIONERS’ OFFICE. IF YOU ARE A DATA SUBJECT IN ANOTHER JURISDICTION, THEN WE HAVE NOTED RELEVANT INFORMATION ABOUT SUPERVISORY AUTHORITIES TOWARDS THE END OF THIS NOTICE. IF YOUR JURISDICTION IS NOT MENTIONED, PLEASE CONTACT OUR DATA PROTECTION OFFICER.

WHERE YOU PROVIDE US WITH DETAILS OF AN ICE CONTACT, YOU MUST SHARE THIS PRIVACY NOTICE WITH THAT PERSON.

YOUR ATTENTION IS DRAWN TO PARAGRAPH 29, 29A AND 30 WHICH CONTAIN SOME INFORMATION ABOUT BIOMETRIC DATA USE.

SECTION 1 (PREAMBLE)

(A) Introduction

Wewant You to be absolutely clear about the use We make of any Personal Data (including Special Categories of Personal Data) that You supply to Us and/or We learn about You. This Privacy Notice seeks to achieve this and let You know all the details We believe You need (including detailing the rights You have); however if You believe further information is required and/or You have any queries, then please do not hesitate to contact Our Data Protection Officer, whose contact details can be found below.

Throughout this Privacy Notice, definitions are used (usually identifiable by capital letter use at the beginning of the word, for example: Processing, Privacy Notice, We) and We have included a definitions section at the end of this Privacy Notice.

Please be aware that from time to time (and at Our absolute discretion) We may update this Privacy Notice (this is version June 2026) and where this is the case, the newest version shall be published on Our Website. It is therefore recommended that You periodically check the Website for relevant details. This Privacy Notice does not form part of any contract and/or agreement We may have with You.

(B) Background

You will be viewing this Privacy Notice because:

You are registered/engaged with Us in connection with: (a) Our Temporary Labour Services; and/or (b) Our Engineering Services; and/or (c) Our Permanent Recruitment Services; and/or
You are considering becoming registered with Us in connection with: (a) Our Temporary Labour Services; and/or (b) Engineering Services; and/or (c) Our Permanent Recruitment Services; and/or
You have previously been registered/engaged with Us in connection with: (a) Our Temporary Labour Services; and/or (b) Engineering Services; and/or (c) Our Permanent Recruitment Services; and/or
You wish to use/have used an E-Learning Programme We provide; and/or
You have visited Our Website with general interest;
You are a Business Contact and wish to understand how We use Your Personal Data; and/or
You are an ICE Contact and wish to understand how We Process Your Personal Data; and/or
You are seeking to understand how We Process Personal Data We hold about You and/or Your rights in connection with that Processing.

It will depend on Your relationship with Us as to how We Process Your Personal Data and it is therefore important that You read this Privacy Notice in its entirety, but also remain aware that not necessarily all of it will be relevant to You.

We are a Data Controller. This means that we are responsible for deciding how We hold and use personal information about You. We are required under data protection legislation to notify You of the information contained in this Privacy Notice.

(C) Contact Details and Data Protection Officer/Privacy Officer/UK Complaints

Our Data Protection Officer can be contacted by: (a) post, by writing to The Data Protection Officer, JMC Aviation Limited, Third Floor, Hangar 1, Exeter Airport, Exeter, EX5 2BA, UK; or (b) by email: dpo@jmc-aviation.com. Please ensure You include Your contact details clearlyin any communications. For the sake of completeness, We confirm that Our UK registered company name and address are as follows: JMC Aviation Limited (registered in England and Wales with company number: 06583787) with Our registered office at Third Floor, Hangar 1, Exeter Airport, Exeter, EX5 2BA, UK.

For data subjects in the European Union and/or for processing carried out in the European Union, our branch office and establishment in the European Union is based in Malta. The DPO can be contacted using the above email or at JMC Recruitment Solutions Limited, 17, Triq it, Tempesta, Qrendi, Malta.

For data subjects based in the United States and/or Canada, please contact the appointed Privacy Officer, at dpo@jmc-aviation.com or via telephone +44 (0) 1392 268310 or via post at the UK address detailed above or in Canada at the following address: Unit 1003, 1243 Islington Ave, Etobicoke, Ontario, M8X 1Y9.

UK Complaints: under UK legislation, You have the right to make a complaint to Us (this is in addition to other rights which are set out elsewhere in this notice). Useful information about this is included here. How to make a data protection complaint to an organisation | ICO. Complaints should be sent to the DPO at dpo@jmc-aviation.com or via post to JMC Aviation Limited, Third Floor, Hangar 1, Exeter Airport, Exeter, EX5 2BA, UK.

Please note, email is the preferred and quickest and recommended method of communication for all data protection matters.

SECTION 2 (TYPES OF PERSONAL DATA WE PROCESS)

The Personal Data that We Process about You will depend on the nature of Our relationship with You.

(A) General website use

With regard to each of Your visits (to our Website irrespective of whether You are a general visitor or using Our services) We may automatically collect the following information:

technical information, including the Internet protocol (“IP”) address used to connect Your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
information about your visit, including the full Uniform Resource Locators (“URL”) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
Our Website uses cookies to distinguish You from other users of Our Website. This helps Us to provide You with a good experience when You browse our Website and also allows Us to improve Our Website. For detailed information on the cookies We use and the purposes for which We use them see Our Cookie Policy (found on Our Website).

We may also collect details that You input into forms and/or submit to Us via Our Website (these will form part of the Personal Data collected by Us for the services We provide and more details is set out below).

(B) Registered and/or have been registered with Us in connection with Temporary Labour Services and/or Engineering Services and/or Permanent Recruitment Services

Generally where You are registered or have been registered with Us (where We use the term registered with Us We mean formally registered with Us as opposed to where You have just made contact) in connection with either Our Temporary Labour Services and/or Engineering Services and/or Our Permanent Recruitment Services, You will have provided and/or We may have obtained from a third party source (for example from a job search website) a great deal of information about You, much of which is Personal Data and some of which is Special Categories of Personal Data. We may also have details of any criminal convictions.

Below is a broad list of the categories of the kind of Personal Data We may Process about You (it is not exhaustive and not all may be relevant to You):

Your name, address and other contact details;
Your date of birth;
Gender;
Your qualifications, training and employment history;
Authorisations (as required by law, a regulatory body and/or a Client);
Your curriculum vitae;
References (including for some purposes extensive referencing looking back over a number of years);
Copies of Your certificates and approvals;
Details of pay;
Work locations and durations;
Bank account details;
Next of kin details and emergency contact details;
Clothing size;
Marital Status;
Your passport details (including a copy of Your passport) and right to work eligibility;
Other identity verification documentation (including that collected via an identity verification service provider using biometric means); and
A copy of Your driving licence.

We may also Process the following Special Categories of Personal Data about You (again this may not all be relevant to You and is not an exhaustive list):

Details about Your health;
Details for alcohol and drugs testing purposes;
Data that reveals Your race or ethnic origin;
Biometric data in connection with identity verification (using an identity verification service provider for this purpose); and
Details of Your religious beliefs.

In some circumstances, We may also Process information about any criminal convictions and offences You may have (if any).

During the course of Our relationship with You, We may obtain and Process additional Personal Data about You including Personal Data provided to Us by any Clients that We place You with (for example from feed-back forms and assessments) and/or other Personal Data that You provide Us with during the course of Our relationship. We anticipate that this additional Personal Data (including any Special Categories of Personal Data) will fall into one of the categories identified above.

(C) Not registered with Us yet for either Temporary Labour Services and/or Engineering Services and/or Permanent Recruitment Services

When You are contacting Us in relation to potentially using Our Temporary Labour Services and/or Engineering Services and/or Permanent Recruitment Services, We Process the information You give Us. This information may be Personal Data and Special Categories of Personal Data and in many cases You may be asked to provide many of the same details mentioned in Section 2(B) (at paragraphs 12 and 13) above.

We may also obtain details from third party sources about You, including from job search websites where You may have a match to a vacancy that We have and Clients. In these circumstances, typically We will obtain details of Your curriculum vitae and contact details from this third party source and will then make contact with You to obtain further information.

(D) Using Our E-Learning Programmes

When using Our E-Learning Programmes, You will be asked to provide to Us the following Personal Data:
First Name;
Last Name;
Nickname (Username);
Email Address;
Billing Address; and
Phone Number.

Payments for this service are made using third party providers, who may also obtain details from You and will let Us know that payments have been made. We do not store PCI data.

(E) Business Contacts

We may collect Personal Data from You including Your name, contact details (including work email, address and telephone number) and the position You hold.

(F) ICE Contacts

Name and contact details held, as provided to Us by the relevant data subject, to be used as a contact in an emergency.

SECTION 3 (PURPOSE AND LEGAL BASIS FOR PROCESSING PERSONAL DATA)

(A) General website use

Information that We collect about You when browsing Our website is collected for the legitimate purpose (the legal basis We use for processing such information) of enhancing Your experience in using Our Website and assisting Us with Our Website delivery, administration and security.

This differs from any information collected from You when You complete any form and/or input any information onto Our Website, which be treated as information collected from You in relation to either: (a) registering with Us in connection with any service We may provide to you; and/or (b) any service you are already registered with Us for.

(B) Registered and/or have been registered with Us in connection with Temporary Labour Services and/or Engineering Services and/or Permanent Recruitment Services

We may act as a supplier of contingent labour, as a supplier of permanent recruitment services and as a supplier of engineering services to Our Clients. We may also be engaging with You on an independent contractor / consultant basis for the provision of services and/or for the purposes of sub-contracting work We are engaged in.

The primary purpose for which We shall have Processed and will Process Personal Data about You shall be in connection with these relationships.

In order to ensure that We can provide Our best service to You and to Our Clients, We need to Process Your Personal Data so that We can, as a general purpose, provide Our services to You, engage with You on an appropriate basis and correctly match You to opportunities and/or projects that require Your skills, this shall include amongst other matters, Processing Your Personal Data (including Special Categories of Personal Data) to ensure that:

You have the qualifications and skill set required for the work/project;

We can carry out any background/other checks necessary to establish Your suitability for work (including checking Your identity);

If appropriate, We can keep You informed of suitable vacancies and/or projects (or where applicable, so We know not to contact You);

Where applicable, We can arrange for payments to be made for services provided by You;

Where applicable, We can make and book travel arrangements and accommodation for You;

Where applicable, We can arrange for documentation to be obtained on Your behalf (including airside passes, visas etc). This may involve sharing Your information with regulatory bodies, airports, Clients and other authorities as part of the process;

We can hire cars for You; and

We can keep records for statutory and other purposes.

There are four main legal basis upon which We Process Your Personal Data as described above:

We have a legitimate interest (which is not overridden by Your interests or fundamental rights and freedoms) in undertaking the Processing, which is the carrying on of our business; and/or

The Processing is necessary for the performance of a contract to which You are a party or in order to take steps (at Your request) prior to You entering into a contract; and/or

There is a recognised legitimate interest, for example the prevention of crime; and/or

The Processing may be necessary for compliance with a legal obligation to which We are subject.

In the event that one of these legal basis cease to apply, then We shall rely upon the other(s). We may also have another legal basis upon which We process Your Personal Data:

You may have provided Us with consent for the Processing. Please be advised that where We are using consent, should You wish to withdraw that consent, you can do so by contacting us at dpo@jmc-aviation.com. We may still have alternative bases for processing and processing already done will not be impacted.

We may Process Special Categories of Personal Data about You.

We Process Special Categories of Personal Data as part of the same purposes for which We process Personal Data (as outlined in paragraph 26 above) but in particular:

We Process data about You concerned with your health (which may include testing for drugs, alcohol and diseases), religion, race or ethnic origin in connection with: (a) making applications for and/or obtaining visa and/other immigration documentation; and/or (b) applying for and/or obtaining airside passes; and/or (c) providing details in connection with medical/health and safety requirements for Clients and/or regulatory authorities; and/or (d) ordering airline/other meals;

We make use of biometric data for the purposes of checking identity, airside pass requirements and satisfying right to work and other regulatory, compliance and contractual requirements (where you do not wish for Us to use biometric data for this purpose alternative forms of identification checks may be utilised, and You should speak to Your contact at JMC); and

We Process information about your physical or mental health, or disability status to ensure proper consideration to health and safety is given.

29A. We make use of biometric data as described in the second bullet of Paragraph 29. We utilise third party identity service verification providers for this purpose. You will typically have to input Your own data into this service providers “app” or other information gathering mechanism. The service provider will typically be a data controller in its own right and You should familiarise Yourself with their privacy notice. The service provider shares Your personal data with Us, and We keep this information as part of Our records. In inputting Your personal data onto the service providers app and/or other information gathering mechanism, You may be asked to consent to that service providers terms and use of Your personal data in this manner. As stated above, alternative methods can be used, and You should speak to Your contact at JMC if You wish to use another method.

In order to Process Special Categories of Personal Data about You, We need (in the UK and the EU) to adhere to the requirements of paragraph 2 of Article 9 of the GDPR, in other jurisdictions We consider it prudent to adhere to these requirements. We may rely on the following legal basis for any Processing of Special Categories of Personal Data:
Explicit consent;
That Processing is necessary for the purposes of carrying out obligations and exercising specific rights of Us or You in the field of employment and social security and social protection law and We have appropriate policy documentation and safeguards which comply with the legal requirements; and/or
That Processing is necessary for reasons of substantial public interest. Here we shall only Process Special Categories of Personal Data where the Processing is necessary for the exercise of a function conferred on Us by law and where We have appropriate policy documentation and safeguards which comply with the legal requirements; and/or
That Processing relates to Personal Data which you have manifestly made public; and/or
That We have a recognised legitimate interest in undertaking the Processing (for instance in the Processing of biometric data to check ID and/or verify time worked, this is done in order to ensure legal compliance and prevent crime (including fraud); and/or
That Processing is necessary for the establishment, exercise or defence of legal claims and/or obtaining advice in connection with the same.

Nothing in this Privacy Notice (including in this paragraph 30) shall create and/or infer any employer/employee relationship between You and Us. Where in a particular jurisdiction, we cannot rely on the exact bases outlined in this paragraph 30, but there are equivalent and/or similar provisions, then we may use those as an alternative.

We may also Process information about criminal convictions as part of the purposes outlined in paragraph 26 above, usually in connection with applications for airside passes or the hiring of cars. The legal basis upon which We shall rely to undertake such processing shall usually be that We have obtained Your consent to Process this criminal convictions information, but in the alternative We may rely on any of the following:
That Processing is necessary for the purposes of carrying out obligations and exercising specific rights of Us or You in the field of employment and social security and social protection law and We have appropriate policy documentation and safeguards which comply with the legal requirements; and/or
That Processing is necessary for reasons of substantial public interest. Here we shall only Process Special Categories of Personal Data where the Processing is necessary for the exercise of a function conferred on Us by law and where We have appropriate policy documentation and safeguards which comply with the legal requirements; and/or
That Processing relates to Personal Data which you have manifestly made public; and/or
That the Processing is done of the basis of a recognised legitimate interest; and/or
Legal Claims so that:
Processing is necessary for or in connection with any legal proceedings; or
Processing is necessary for obtaining legal advice; or
Processing is otherwise necessary for the purposes of establishing, exercising or defending legal rights.

Nothing in this Privacy Notice (including in this paragraph 31) shall create and/or infer any employer/employee relationship between You and Us. Where in a particular jurisdiction, we cannot rely on the exact bases outlined in this paragraph 31, but there are equivalent and/or similar provisions, then we may use those as an alternative.

(C) Not registered with Us yet

Where We Process Personal Data about You when You are not yet registered with Us, We are Processing this Personal Data to allow Us to, inter alia,find out more about You, assess Your suitability for roles/projects, determine with You whether or not You wish to be registered with Us, utilise Our services and how You may engage appropriately with Us.

Assuming You do wish to register with Us, then the Personal Data will be Processed to allow the registration process to be completed. Once You are registered with Us, Personal Data and Special Categories of Special Data will be Processed in line with Section 3(B) above.

The legal basis that We rely upon for processing Personal Data before and during registration with Us is that:

We have a legitimate interest (registering You with Us) in Processing the Personal Data so that We can offer You opportunities and/or engage with You. We believe that this legitimate interest overrides Your interests or fundamental rights and freedoms; and/or

The Processing is necessary for the performance of a contract to which You are a party or in order to take steps at the request of You prior to entering into a contract (You are requesting Us to register You prior to entering into a contract with Us/another party); and/or

The processing is necessary for compliance with a legal obligation to which We are subject.

If any of the above ceases to apply, then We shall seek to rely on the other(s). We may also rely on Your consent to Processing (where this has been obtained).

Insofar as any of the data We Process at the pre-registration and registration stage is Special Categories of Special Data, We may obtain Your explicit consent to the Processing or utilise the recognised legitimate interest basis, or in the alternative shall rely upon the field of employment basis for Processing (as more particularly described in paragraph 30above) or, if necessary, inform You at the time of the basis that We are relying on for such Processing. Nothing in this Privacy Notice (including in this paragraph 35) shall create and/or infer any employer/employee relationship between You and Us.

(D) Users of Our E-Learning Programmes

We Process Personal Data about You in connection with Our E-Learning Programmes for the purpose of allowing Us to provide the services You request from Us to You and keeping relevant records in connection with this service. We store information about You to allow You to re-access the services and further use the same at a later date. Your Personal Data is also saved so that others can verify the authenticity of a certificate (via its unique number) and check it is Your qualification. We may also Process Your Personal Data so that We may (but shall not be obliged to) remind You from time to time of when qualifications may require renewal (subject to Your agreement to this).

We rely on the following legal basis for this Processing:

That the Processing is necessary for the performance of a contract to which You are a party (You have requested a service from Us and We therefore provide it); and/or

We have a legitimate interest in the Processing, being the maintenance of Your records for You, allowing reminders to be generated (if appropriate) and allowing the authenticity of qualifications to be verified by third parties.

If any of the above ceases to apply, then We shall seek to rely on the other. We may also rely on Your consent to Processing (where this has been obtained).

(E) Business Contacts

We process Personal Data about You to allow us to establish and continue communications with You for the purposes of furthering Your and Our respective business interests.

We rely on the following legal basis for this Processing:

That the Processing is necessary for the performance of a contract to which We and Your business are a party and in which You are a named contact; and/or

We have a legitimate interest in the Processing to further business relations between Us and Your business and/or to otherwise contact You in connection with Our or Your business.

If any of the above ceases to apply, then We shall seek to rely on the other. We may also rely on Your consent to Processing (where this has been obtained).

(F) ICE Contacts

We Process the information so that we have emergency contact details for other data subjects. We have a legitimate interest in undertaking this Processing and it is also done for matters of safeguarding and health and safety.

(G) General: Applicable to All

If We are required by law (for example for the administration of justice) to Process any Personal Data and/or Special Categories of Personal Data, then We shall, provided We are comfortable that We are required to, undertake such Processing.

We may also Process Your Personal Data for the establishment, exercise or defence of legal claims and/or for obtaining professional advice in connection with the same.

SECTION 4 (DATA SHARING)

(A) General Website Use Data Collection

Generally, this Personal Data is not shared, but We may from time to time share the information with analytics and search engine providers. If and where We are required by law to share the Personal Data, then We will do so.

(B) Registered and/or Have Been Registered With Us With Us in connection with Temporary Labour Services and/or Engineering Services and/or Permanent Recruitment Services

Primarily Personal Data collected about You by Us is shared with Our Clients when You are put forward for any opportunity with any Client and/or will be providing services to Us in connection with a project at a Client site.

If you are using a service company and/or a payroll company, then We will share Personal Data with these organisations to the extent required.

We utilise identification verification service providers for the purposes of checking identification and right to work.

Your Personal Data may also be shared with official bodies/ authorities, airports, Clients and other relevant third parties (including Our service providers) in connection with the obtaining of airside passes.

Your Personal Data may also be shared with third parties in connection with making reservations and bookings for You, for example for airline tickets, accommodation, car-hire (which may require the sharing of data about offences).

We share limited Personal Data with Our bank in order to facilitate payments to You (where relevant).

From time to time, We may wish to share Your Personal Data with third party companies where We believe You may be interested in the services they provide, We will approach You to obtain consent for this before the sharing of any such information.

(C) Not Registered With Us Yet With Us for Either Temporary Labour Services and/or Engineering Services and/or Permanent Recruitment Services

Typically, We would not envisage sharing any Personal Data with Our Clients until You are registered with Us, but there may be circumstances where We do so in order to achieve efficiencies. Similarly, in order to assist in achieving such efficiencies, if We need to make reservations on Your behalf and/or obtain visas and/or airside passes and/or make a payment to You, then We may need to share Your Personal Data (as described in paragraphs 44 to 50 (inclusive) above).

In order for Your relationship with any payroll company and/or service company to be established, We may need to share Your Personal Data with such organisations.

(D) Users of Our E-Learning Programmes

Some of Your Personal Data held on the E-Learning Programme platform will be shared with anyone to whom You have provided a training certificate and who logs on to check its authenticity.

The Personal Data held by Us in relation to Our E-Learning Programmes is hosted by a third party and so the Personal Data is shared with them to the extent that it is transmitted to their server, stored and backed up by them.

(E) Business Contacts

Other than as set out in section G below, We donot envisage sharingYour Personal Data.

(F) ICE Contact

Your details may be shares with Clients for health and safety contact purposes.

(G) General – Applicable to All (references to Personal Data in this Section (G) includes Special Categories of Personal Data and criminal convictions and offences details)

Where We are required to share any of Your Personal Data with any regulatory body and/or if we are required by any law to provide Personal Data (for example for the administration of justice), then We shall do so.

We engage third party IT support who may (in very limited circumstances) have sight on Your Personal Data on Our IT Systems.

We may use external record keeping systems (including in the cloud) and back-up Our systems with off-site back-up solutions (and for the purposes of such storage and back-ups Personal Data is accordingly shared with the relevant providers).

We may share your Personal Data in connection with the entering into and/or performance of a contract or arrangement to which We are a party or subject and/or in connection with business transactions and/or restructures. We may also share Your Personal Data with Our professional advisors in connection with any legal matters, claims and/or disputes.

We may share Personal Data with companies within Our group of companies.

We may share Your personal data with Our service providers where this is relevant to You or Your engagement.

We may share Personal Data with those that You give Us consent to share Personal Data with.

Clients, service companies/providers and pay-roll companies and other third parties (including regulatory authorities) may be data controllers in their own right with a requirement to determine the purposes and means of processing in connection with Your Personal Data (held by them); You should therefore be aware of any policies they have in connection with this and ensure that You understand the same.

SECTION 5 (WHERE THERE ARE RESTRICTIONS ON THE TRANSFER OF PERSONAL DATA TO OTHER JURISDICTIONS)

Where there are restrictions in place to restrict the transfer of Personal Data to other jurisdictions, We will ensure that appropriate safeguards are in place to permit the transfer.

If We utilise consent for a data transfer, then You should be aware that We cannot guarantee that the jurisdictions that such recipients are based in shall have data protection legislation designed to safeguard Your Personal Data in the same manner as that within your home jurisdiction, there may therefore be risks associated with transferring Your Personal Data to such jurisdictions

SECTION 6 (DATA STORAGE)

Data protection legislation requires that We keep Your Personal Data only for as long as the purposes we have told You about. Whilst You are actively engaged with Us (for whatever reason), then generally We shall Process Your Personal Data for the relevant purpose as described above. When:
- You are no longer actively engaged with Us; and/or
- there is a particular type of Personal Data We do not need to continue to keep,

then in order to help You understand how long We shall keep Your Personal Data, please see the table below. The retention period in this table are subject always to paragraph 68.

Row Number	Data Subject Type	Data Held	Retention Period	Reason for Retention

1.	General website user	Information about website visit	Variable (dependent on when browser options cleared by You)	To enhance website use. Clearing of the browser history is within Your control.

2.	Individual who is actively engaged with Us for temporary labour and/or providing services and where there is/has been a supply and where We have no reason to keep Personal Data for a longer period*.	Details about payments made (Note: other data is kept and Processed and is then subject to the retention periods in row 3 when services cease).	7 years from the date that a payment was last made to You/in respect of You or any longer period required by a contract with any Client.	To allow compliance with taxation legislation; To allow time for any insurance matter/claim to be raised/made; To allow any contractual claims/matters to be raised/resolved; To allow compliance with relevant legislation and/or regulation; Contractual compliance; Internal compliance requirements.

3.	Individual who has supplied services to Us / a Client/Clients but who no longer wishes to be actively engaged / providing services and has communicated this to Us (which will be evidenced where We have had notice from You to this effect/You have opted-out of receiving information from Us) and where We have no reason to keep Personal Data for a longer period*.	All Personal Data collected by Us relating to You (subject to any deletion in accordance with row 2 above).	7 years from the date that We last made a payment to You/in respect of You or any longer period required by a contract with any Client.	To allow compliance with taxation legislation; To allow time for any insurance matter/claim to be raised/made; To allow any contractual claims/matters to be raised/resolved; To allow compliance with relevant legislation and/or regulation; Contractual compliance; Internal compliance requirements.

4.	Individual registered with Us, who has not supplied services and no longer wishes to be engaged / providing services and has communicated this to Us (which will be evidenced where We have had notice from You to this effect/You have opted-out of receiving information from Us) and where We have no reason to keep Personal Data for a longer period*.	All Personal Data collected by Us relating to You.	2 years from the date that You communicated to Us that you did not wish to be engaged / provide services.	To allow compliance with relevant legislation and/or regulation; Internal compliance requirements.

5.	Individual who has contacted Us in relation to our business (who We have not supplied / engaged with for services) and has not registered with Us and who has communicated to Us that they do not wish to engage with Us (for example You did not opt-in to receiving information about roles/You told Us did not want to hear about roles/You opted-out) and where We have no reason to keep Personal Data for a longer period*.	All Personal Data collected by Us relating to You.	1 year from the date that You communicated to Us that you did not want to use Us / engage with Us or any longer period required by a contract with any Client.	To allow compliance with relevant legislation and/or regulation; Contractual compliance; Internal compliance requirements.

6.	Individual registered with Us for permanent recruitment services and who is no longer actively using Our services and who has communicated this to Us (which will be evidenced where we have had notice from You to this effect/You have opted-out of receiving information from Us/You did not opt-in) and where We have no reason to keep Personal Data for a longer period*.	All Personal Data collected by Us relating to You.	2 years from the date that You communicated to Us that you did not want to use Us or any longer period required by a contract with any Client.	To allow compliance with relevant legislation and/or regulations; Contractual compliance; Internal compliance requirements.

7.	Individual who has contacted Us for permanent recruitment services but who has not registered with Us and does not wish to actively use Us and who has communicated this to Us (for example You did not opt-in to receiving information about roles/You told Us did not want to hear about roles/You opted-out) and where We have no reason to keep Personal Data for a longer period*.	All Personal Data collected by Us relating to You.	1 year from the date that You communicated to Us that you did not want to use Us or any longer period required by a contract with any Client.	To allow compliance with relevant legislation/or and regulation; Contractual compliance; Internal compliance requirements.

8.	Individual who We have not contacted and who has not contacted Us for over 10 years (and there has been no supply and/or any other interaction during that period) and where We have no reason to keep Personal Data for a longer period*.	All Personal Data collected by Us relating to them.	Promptly upon identifying this individual type and or any longer period required by a contract with any Client.	To allow relevant and/or required records to be kept and maintained.

9.	Individual who does not want Us to contact them at all in relation to opportunities / projects and who no longer falls into one of the rows 3, 4, 5, 6 or 7 above. Individual who was a Business Contact and does not wish Us to contact them.	Name and contact information.	Indefinitely.	Where You have told Us not to contact You (and We have deleted Your details generally), the only way We can be clear that We cannot contact You is if We have a record of Your name and contact details and a note that You are not to be contacted.

10.	E-Learning Programme User.	Personal Data stored on the E-Learning platform.	Where there is a Human Factors Initial Certificate, then 50 years, but in all other cases, 10 years from the date that last certificate expired.	To allow any contractual claims/matters to be resolved; To allow certificate authentication from third parties (including regulatory bodies); To allow You to use account after a period of absence if required; To allow Us to contact You with reminders regarding training (if permissible).

11.	Business Contact	Name, contact details (including in some instances home address) and job role.	When We determine that there is no practical benefit to Us retaining Your details, then We shall delete the same.	To allow continued business relations and communications and an understanding of client and customer network and opportunities.

12.	Anyone who sends Us an email and/or receives an email from Us	Email Network Information	At least 90 days.	For security and traceability purposes and to monitor email traffic.

13	Employed individual for Our provision of Engineering Services	All Personal Data collected by Us relating to You.	During term of employment and for 7 years thereafter.	To allow compliance with taxation legislation; To allow time for any insurance matter/claim to be raised/made; To allow any contractual claims/matters to be raised/resolved; To allow compliance with relevant legislation and/or regulation; Contractual compliance; Internal compliance requirements.

14	Emergency contact information	Details provided to Us	In line with the relevant data subject’s personal data retention period.	Internal compliance requirements.

* There may be circumstances where We need to retain the Personal Data longer than the stated periods, where for example there is an ongoing claim or there is an internal compliance requirement. Where this is the case (and subject always to paragraph 65 below) the retention period shall be, unless We advise You separately, in the case of an ongoing claim, 7 years after that claim/investigation is finally determined or in all other cases 15 years from the date You communicated to Us You did not wish to be contacted. This is to ensure that a matter is fully resolved, that proper and full records can be kept and ensure compliance with any legal obligations and/or internal audit requirements.

If We need to retain any Personal Data because it seems prudent to Us in the case of establishing, exercising or defending legal claims, then insofar as that reason for retaining it remains, We shall retain the Personal Data irrespective of the retention periods noted elsewhere.

SECTION 7 (YOUR RIGHTS)

You have a number of rights in connection with Our Processing of Your Personal Data and these are listed below. The rights below are those relevant for Data Subjects based in the UK or the EU but are extended to Data Subjects based elsewhere and where other jurisdictions have differing rights, then these are included by reference in the list below. Please contact Our Data Protection Officer/Privacy Officer (contact details are located earlier on in this Privacy Notice) if You wish to Exercise any of these rights:
The right of access.
- The right to obtain from Us confirmation of whether or not Personal Data is being Processed and, where Personal Data is being Processed, the following information: the purpose of the Processing; the categories of Personal Data concerned; the recipients to whom the Personal Data has been or will be disclosed (in particular recipients in third countries or international organisations); where possible the envisaged period for which the Personal Data will be stored, or, if not possible, the criteria used to determine that period; the existence of the right to request from Us rectification or erasure of Personal Data or restriction of processing of Personal Data or to object to such Processing; the right to lodge a complaint with the supervisory authority; where Personal Data is not collected from You, any available information about the source; and the existence (if any) of automated decision making, including profiling and meaningful information about the logic involved, as well as the significance and the envisaged consequences of such Processing for You.
- Where Personal Data are transferred to a third country or international organisation, You have the right to be informed of the appropriate safeguards (if any) pursuant to Article 46 of the GDPR relating to the transfer.
- We shall if requested provide a copy of the Personal Data being Processed by Us (for any further copies, We may request a reasonable fee based on administrative costs). Where the request is made by electronic means, the Personal Data shall unless You request otherwise be provided to You by electronic means.
The right to rectification.
- The right to obtain from Us without undue delay, the rectification of inaccurate Personal Data, which may include (depending on the purposes of the processing) the right to have incomplete Personal Data completed (including by means of a supplementary statement).
The right to erasure.
- Where any of the following apply, You have the right to obtain from Us the right to erasure of Personal Data without undue delay and We have the obligation to erase the same:
  - the Personal Data are no longer necessary for the purposes for which they are collected or otherwise Processed (please refer to the earlier sections for details of the purposes for which Personal Data is collected and the duration it is retained);
  - You withdraw consent where this has been given as a ground for processing and no other legal ground for Processing exists;
  - You object to processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the Processing, or You object to the Processing under Article 21(2) of the GDPR;
  - The Personal Data have been unlawfully Processed;
  - The Personal Data have to be erased for compliance with a legal obligation to which We are subject;
  - The Personal Data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.
- The right to erasure shall not apply to the extent that any Processing is necessary:
  - For the exercising of freedom of expression and information;
  - For compliance with a legal obligation which requires Us to Process the Personal Data or there is task that We need to carry out in the public interest or in the exercise of official authority;
  - The Personal Data requires Processing in the area of public health for reasons of public interest;
  - For archiving reasons in the public interest, scientific or historical research purposes or for statistical purposes in accordance with Article 89(1) in so far as the exercise of the right to erasure will render impossible or seriously impair the achievement of the objectives of that processing; or
  - For the establishment, exercise or defence of legal claims.
The right to restriction of processing.
- You may request the restriction of Processing by Us when one of the following applies:
  - The accuracy of the Personal Data is contested by You, so Processing is restricted for a period to enable Us to verify the accuracy of the Personal Data;
  - The Processing is unlawful and You oppose the erasure of the Personal Data and instead request restricted use;
  - We no longer require the Personal Data for Our purposes, but they are required by You for the establishment, exercise or defence of a legal claim;
  - You have objected to Processing pursuant to Article 21(1) pending the verification of whether the legitimate grounds of Us override those of You.
The right to data portability.
- You have the right to receive Your Personal Data in a structured and commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance where:
  - The Processing is based on point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR or in a contract pursuant to point (b) of Article 6(1) of the GDPR; and
  - The Processing is carried out by automated means.
- If technically feasible You shall have the right to have this Personal Data transmitted from Us to another controller.
The right to object.
- You have the right to object, on grounds relating to Your situation, at any time to the Processing of Your Personal Data which is based on point (e) or point (f) of Article 6 (1) of the GDPR, including Profiling based on these provisions.
- Where Your Personal Data is used for direct marketing purposes, You have the right to object to any Processing of Your Personal Data for such marketing, which includes Profiling to the extent its related to such direct marketing.
The right not to be subject to a decision based solely on automated processing.
- You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning You or similarly significantly affects You.
- If the decision is necessary for the entering into a contract between You and Us, is authorised in law, or is based on Your explicit consent then this right shall not apply.
The right to withdraw consent.
- Where any Processing is based on point (a) of Article 6 of the GDPR or point (a) of Article 9(2) of the GDPR, then You may withdraw consent at any time without affecting the lawfulness of the processing based on consent before its withdrawal.
The right to lodge a complaint to a supervisory authority (this should lodged with the supervisory authority, the Information Commissioner’s Office, and not Our Data Protection Officer). Contact details for the Information Commissioner’s Office can be found at https://ico.org.uk/concerns/. For data subjects based in the European Union and/or for the processing We carry out in the European Union, the relevant supervisory authority is the Maltese one. Contact details can be found here: https://idpc.org.mt/contact/ or telephone +356 2328 7100. In the United States, please contact the relevant data protection authority body in the relevant state for details or contact the FTC Protecting Consumer Privacy and Security | Federal Trade Commission (ftc.gov). In Canada please refer to the Office of the Privacy Commissioner for Canada website for guidance: Report a concern – Office of the Privacy Commissioner of Canada.
The right to complain to Us is covered in Section 1 (C) of this Privacy Notice.

SECTION 8 (GENERAL)

Some of the Personal Data We require from You is collected in order to comply with statutory requirements and/or to satisfy contractual obligations of either You and/or Us or permit the entry into a contract. It is the nature of the services that We offer and provide that this information is required and without it, We would not be in a position to be able to engage with You and/or may not be able to provide Our services effectively and/or (in some cases) lawfully.

Profiling/Automated Decision Making: We may from time to time use systems that permit the Processing that allows automated decision making and We may also use automation. In the event that there is a decision based on automated Processing which produces an adverse legal effect or significantly affects You, then there will be a “human” review (unless the law allows for such decision without human intervention). As part of Our airside pass procedure, We utilise third party providers where documentation will be uploaded by You directly onto that system or onto that system by Us on Your behalf. These systems may use artificial intelligence to read documentation, including identifying any employment history gaps; this will be reviewed by a human. Identification using biometric data may also utilise artificial intelligence as part of the process; if needed other options may be utilised where human review is included.

Security: We take appropriate technical and organisational measures to protect Personal Data. It is important to understand that no security measures are absolute. We cannot guarantee the safety of any information you provide to Us.

If there are any areas of this Privacy Notice that You would like clarification on, then please contact Our Data Protection Officer/Privacy Officer. Similarly, We rely on You to keep Your information current and up to date, so please ensure that information You provide to Us is correct and updated when the need arises.

SECTION 8 (DEFINTIONS)

Where We have used definitions, then these are captured below. We suggest that You also review Article 4 of GDPR for their comprehensive list of the terms used in data protection legislation. Please be aware that a reference to the plural used in this Privacy Notice includes a reference to the singular and vice versa and the terms “including”, “such as”, “for example” and similar expressions shall be construed as illustrative and shall not limit the sense of the words preceding those terms.

Definition Used	Meaning
Business Contact	An individual who works for a potential Client, actual Client or other business We may wish to engage with and who has either provided Us with his/her details and/or whose details We have been provided with.
Client	Any current and/or past client and/or customer of JMC Aviation Limited and Clients shall mean all of them.
Data Controller / Controller	The natural or legal person, public authority, agency or other body which alone or jointly with others, determines the purposes and means of the processing of the Personal Data.
Data Protection Officer/Privacy Officer	The person holding the role of data protection officer/privacy officer at JMC Aviation Limited.
ICE Contact	A person whose details are provided to Us as being a person to contact in case of an emergency in connection with the data subject who provided the details.
Privacy Notice	This document as amended from time to time by Us (at Our absolute discretion).
DPA	The Data Protection Act 2018 (as amended).
Engineering Services	Where We supply engineering and/or other services to Our Clients
E-Learning Programme	An electronic learning programme provided by Us.
E-Learning Programme User	A user of (or someone who has used) an E-Learning Programme.
GDPR	The General Data Protection Regulation, being Regulation (EU) 2016/679 of the European Parliament and of the Council and also used to refer to the UKGDPR for ease of reference.
General Website User	A user of (or someone who has used) Our Website.
JMC Aviation Limited	Means: JMC Aviation Limited, registered in England and Wales with company number: 06583787 and with its registered address at Third Floor, Hangar 1, Exeter International Airport, Exeter, EX5 2BA, UK (“JMC”); andthe subsidiaries, related group companies and branch offices and local registrations of JMC from time to time, including (i) JMC Aviation (USA) Limited (registered in Delaware, USA) and its local state registrations; and (ii) JMC Recruitment Solutions (Canada) Limited (registered in Nova Scotia, Canada) and its local province registrations; and (iii) JMC Recruitment Solutions Limited (the branch office in Malta).
Our	JMC Aviation Limited.
Personal Data	Any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Permanent Recruitment Services	Where Our services are to source permanent staff for Our Clients.
Process/Processing	Any operation or sets of operations which is performed on Personal Data or sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaption or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination restriction, erasure or destruction.
Profiling	Any form of automated Processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relation to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
Special Categories of Personal Data	Information which reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union memberships, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data.
Temporary Labour Services	Where we supply labour and/or other services to Our Clients.
Us	JMC Aviation Limited.
UKGDPR	The General Data Protection Regulation, Regulation (EU) 2016/679, as it forms part of domestic law in the United Kingdom by virtue of section 3 of the European Union (Withdrawal) Act 2018 (including as further amended or modified by the laws of the United Kingdom or of a part of the United Kingdom from time to time)
We	JMC Aviation Limited.
Website	www.jmc-aviation.com or such other website as We inform You of from time to time (at Our absolute discretion).
Work-Seeker	Those registered and/or considering registration and/or who have been registered/engaged by Us in connection with the provision of Our Temporary Labour Services and/or Engineering Services and/or Permanent Recruitment Services.
You	You the person to whom this Privacy Notice applies.

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Privacy Notice : Work-Seekers, E-Learning Programme Users, General Website Users, Business Contacts and ICE Contacts