Data Protection Policy

Private Jet Charter LLC, trading as AircraftCharter (hereinafter referred to as ‘the Company’).

Policy version supplied: August 2024

Overview
1. We take the security and privacy of your data seriously. We need
  to gather and use information or ‘data’ about you as part of our
  business and to manage our relationship with you. We intend to comply
  with our legal obligations under the Data Protection Act 2018 (the ‘2018
  Act’) and the EU General Data Protection Regulation (‘GDPR’) in respect
  of data privacy and security. We have a duty to notify you of the
  information contained in this policy.
2. This policy applies to current and former employees, workers,
  volunteers, apprentices and consultants. If you fall into one of these
  categories then you are a ‘data subject’ for the purposes of this
  policy. You should read this policy alongside your contract of
  employment (or

contract for services) and any other notice we issue to you from time
to time in relation to your data.

The Company has measures in place to protect the security of your
data.
The Company will hold data for as long as necessary for the
purposes for which we collected it.
The Company is a ‘data controller’ for the purposes of your
personal data. This means that we determine the purpose and means of the
processing of your personal data.
This policy explains how the Company will hold and process your
information. It explains your rights as a data subject. It also explains
your obligations when obtaining, handling, processing or storing
personal data in the course of working for, or on behalf of, the
Company.
This policy does not form part of your contract of employment (or
contract for services if relevant) and can be amended by the Company at
any time. It is intended that this policy is fully compliant with the
2018 Act and the GDPR. If any conflict arises between those laws and
this policy, the Company intends to comply with the 2018 Act and the
GDPR.

Data Protection Principles
1. Personal data must be processed in accordance with six ‘Data
  Protection Principles.’ It must:
  - be processed fairly, lawfully and transparently;
  - be collected and processed only for specified, explicit and
    legitimate purposes;
  - be adequate, relevant and limited to what is necessary for the
    purposes for which it is processed;
  - be accurate and kept up to date. Any inaccurate data must be
    deleted or rectified without delay;
  - not be kept for longer than is necessary for the purposes for
    which it is processed; and
  - be processed securely.

We are accountable for these principles and must be able to show that
we are compliant.

How We Define Personal Data
1. ‘Personal data’ means information which relates to a living person
  who can be identified from that data (a ‘data subject’) on its own, or
  when taken together with other information which is likely to come into
  our possession. It includes any expression of opinion about the person
  and an indication of the intentions of us or others, in respect of that
  person. It does not include anonymised data.
2. This policy applies to all personal data whether it is stored
  electronically, on paper or on other materials.
3. This personal data might be provided to us by you, or someone else
  (such as a former employer, your doctor, or a credit reference agency),
  or it could be created by us. It could be provided or created during the
  recruitment process or during the course of the contract of employment
  (or services) or after its termination. It could be created by your
  manager or other colleagues.
4. We will collect and use the following types of personal data about
  you:
  - recruitment information such as your application form and CV,
    references, qualifications and membership of any

professional bodies and details of any pre-employment
assessments;

your contact details and date of birth;
the contact details for your emergency contacts;
your gender;
your marital status and family details;
information about your contract of employment (or services)
including start and end dates of employment, role and location, working
hours, details of promotion, salary (including details of previous
remuneration), pension, benefits and holiday entitlement;
your bank details and information in relation to your tax status
including your national insurance number;
your identification documents including passport and driving
licence and information in relation to your immigration status and right
to work for us;
information relating to disciplinary or grievance investigations
and proceedings involving you (whether or not you were the main subject
of those proceedings);
information relating to your performance and behaviour at
work;
training records;
electronic information in relation to your use of IT systems/
swipe cards/telephone systems;
your images (whether captured on CCTV, by photograph or video);
and
any other category of personal data which we may notify you of
from time to time.

How We Define Special Categories Of Personal Data
1. ‘Special categories of personal data’ are types of personal data
  consisting of information as to:
  - your racial or ethnic origin;
  - your political opinions;
  - your religious or philosophical beliefs;
  - your trade union membership;
  - your genetic or biometric data;
  - your health;
  - your sex life and sexual orientation; and
  - any criminal convictions and offences.

We may hold and use any of these special categories of your personal
data in accordance with the law.

How We Define Processing
1. ‘Processing’ means any operation which is performed on personal data
  such as:
  - collection, recording, organisation, structuring or storage;
  - adaption or alteration;
  - retrieval, consultation or use;
  - disclosure by transmission, dissemination or otherwise making
    available;
  - alignment or combination; and
  - restriction, destruction or erasure.

This includes processing personal data which forms part of a filing
system and any automated processing.

How Will We Process Your Personal Data?
1. The Company will process your personal data (including special
  categories of personal data) in accordance with our obligations under
  the 2018 Act.
2. We will use your personal data for:
  - performing the contract of employment (or services) between
    us;
  - complying with any legal obligation; or
  - if it is necessary for our legitimate interests (or for the
    legitimate interests of someone else). However, we can only do this if
    your interests and rights do not override ours (or theirs). You have the
    right to challenge our legitimate interests and request that we stop
    this processing. See details of your rights in section 12
    below.

We can process your personal data for these purposes without your
knowledge or consent. We will not use your personal data for an
unrelated purpose without telling you about it and the legal basis that
we intend to rely on for processing it.

If you choose not to provide us with certain personal data you should
be aware that we may not be able to carry out certain parts of the
contract between us. For example, if you do not provide us with your
bank account details we may not be able to pay you. It might also stop
us from complying with certain legal obligations and duties which we
have such as to pay the right amount of tax to HMRC or to make
reasonable adjustments in relation to any disability you may suffer
from.

Examples Of When We Might Process Your Personal Data
1. We have to process your personal data in various situations during
  your recruitment, employment (or engagement) and even following
  termination of your employment (or engagement).
2. For example (and see section 7.6 below for the meaning of the
  asterisks):
  - to decide whether to employ (or engage) you;
  - to decide how much to pay you, and the other terms of your
    contract with us;
  - to check you have the legal right to work for us;
  - to carry out the contract between us including where relevant,
    its termination;
  - training you and reviewing your performance*;
  - to decide whether to promote you;
  - to decide whether and how to manage your performance, absence or
    conduct;
  - to carry out a disciplinary or grievance investigation or
    procedure in relation to you or someone else;
  - to determine whether we need to make reasonable adjustments to
    your workplace or role because of your disability;
  - to monitor diversity and equal opportunities;
  - to monitor and protect the security (including network security)
    of the Company, of you, our other staff, customers and others;
  - to monitor and protect the health and safety of you, our other
    staff, customers and third parties;
  - to pay you and provide pension and other benefits in accordance
    with the contract between us;
  - paying tax and national insurance;
  - to provide a reference upon request from another
    employer;
  - monitoring compliance by you, us and others with our policies and
    our contractual obligations*;
  - to comply with employment law, immigration law, health and safety
    law, tax law and other laws which affect us*;
  - to answer questions from insurers in respect of any insurance
    policies which relate to you*;
  - running our business and planning for the future;
  - the prevention and detection of fraud or other criminal
    offences;
  - to defend the Company in respect of any investigation or
    litigation and to comply with any court or tribunal orders for
    disclosure*; and
  - for any other reason which we may notify you of from time to
    time.
3. We will only process special categories of your personal data (see
  above) in certain situations in accordance with the law. For example, we
  can do so if we have your explicit consent. If we asked for your consent
  to process a special category of personal data then we would explain the
  reasons for our request. You do not need to consent and can withdraw
  consent later if you choose by contacting Anne Braganza.
4. We do not need your consent to process special categories of your
  personal data when we are processing it for the following purposes,
  which we may do:
  - where it is necessary for carrying out rights and obligations
    under employment law;
  - where it is necessary to protect your vital interests or those of
    another person where you/they are physically or legally incapable of
    giving consent;
  - where you have made the data public;
  - where processing is necessary for the establishment, exercise or
    defence of legal claims; and
  - where processing is necessary for the purposes of occupational
    medicine or for the assessment of your working capacity.
5. We might process special categories of your personal data for the
  purposes in paragraph 7.2 above which have an

asterisk beside them. In particular, we will use information in
relation to:

your race, ethnic origin, religion, sexual orientation or gender
to monitor equal opportunities;
your sickness absence, health and medical conditions to monitor
your absence, assess your fitness for work, to pay you benefits, to
comply with our legal obligations under employment law including to make
reasonable

adjustments and to look after your health and safety; and

your trade union membership to comply with our legal obligations
in respect of trade union members.
We do not take automated decisions about you using your personal
data or use profiling in relation to you.

Sharing Your Personal Data
1. Sometimes we might share your personal data with our contractors
  and agents to carry out our obligations under our contract with you or
  for our legitimate interests. These include instructing third parties to
  provide payroll and pensions services on our behalf.
2. We require those companies to keep your personal data
  confidential and secure and to protect it in accordance with the law and
  our policies. They are only permitted to process your data for the
  lawful purpose for which it has been shared and in accordance with our
  instructions.
3. We do not send your personal data outside the European Economic
  Area. If this changes you will be notified of

this and the protections which are in place to protect the security
of your data will be explained.

How Should You Process Personal Data For The Company?
1. Everyone who works for, or on behalf of, the Company has some
  responsibility for ensuring data is collected, stored and handled
  appropriately, in line with this policy.
2. The Company’s Data Protection Officer, Anne Braganza, is
  responsible for reviewing this policy and updating the Board of
  Directors on the Company’s data protection responsibilities and any
  risks in relation to the processing of data. You should direct any
  questions in relation to this policy or data protection to this
  person.
3. You should only access personal data covered by this policy if
  you need it for the work you do for, or on behalf of the Company and
  only if you are authorised to do so. You should only use the data for
  the specified lawful purpose for which it was obtained.
4. You should not share personal data informally.
5. You should keep personal data secure and not share it with
  unauthorised people.
6. You should regularly review and update personal data which you
  have to deal with for work. This includes telling

us if your own contact details change.

You should not make unnecessary copies of personal data and
should keep and dispose of any copies securely.
You should use strong passwords.
You should lock your computer screens when not at your
desk.
Consider anonymising data or using separate keys/codes so that
the data subject cannot be identified.
Do not save personal data to your own personal computers or other
devices.
Personal data should never be transferred outside the European
Economic Area except in compliance with the law and authorisation of the
Data Protection Officer Anne Braganza.
You should lock drawers and filing cabinets. Do not leave paper
with personal data lying about.
You should not take personal data away from Company’s premises
without authorisation from your line manager or Data Protection
Officer.
Personal data should be shredded and disposed of securely when
you have finished with it.
You should ask for help from our Data Protection Officer if you
are unsure about data protection or if you notice any areas of data
protection or security we can improve upon.
Any deliberate or negligent breach of this policy by you may
result in disciplinary action being taken against you in accordance with
our disciplinary procedure.
It is a criminal offence to conceal or destroy personal data
which is part of a subject access request (see below). This conduct
would also amount to gross misconduct under our disciplinary procedure,
which could result in your dismissal.

How To Deal With Data Breaches
1. We have robust measures in place to minimise and prevent data
  breaches from taking place. Should a breach of personal data occur
  (whether in respect of you or someone else) then we must take notes and
  keep evidence of that breach. If the breach is likely to result in
  a

risk to the rights and freedoms of individuals then we must also
notify the Information Commissioner’s Office within 72 hours.

If you are aware of a data breach you must contact Anne Braganza
immediately and keep any evidence you have in relation to the
breach.

Subject Access Requests
1. Data subjects can make a ‘subject access request’ (‘SAR’) to find
  out the information we hold about them. This request must be made in
  writing. If you receive such a request

you should forward it immediately to the Data Protection Officer who
will coordinate a response.

If you would like to make a SAR in relation to your own personal
data you should make this in writing to Anne

Braganza. We must respond within one month unless the request is
complex or numerous in which case the period in which we must respond
can be extended by a further two months.

There is no fee for making a SAR. However, if your request is
manifestly unfounded or excessive we may charge a reasonable
administrative fee or refuse to respond to your request.

Your Data Subject Rights
1. You have the right to information about what personal data we
  process, how and on what basis as set out in this policy.
2. You have the right to access your own personal data by way of a
  subject access request (see above).
3. You can correct any inaccuracies in your personal data. To do you
  should contact Anne Braganza.
4. You have the right to request that we erase your personal data
  where we were not entitled under the law to process it or it is no
  longer necessary to process it for the purpose it was collected. To do
  so you should contact Anne Braganza.
5. While you are requesting that your personal data is corrected or
  erased or are contesting the lawfulness of our processing, you can apply
  for its use to be restricted while the application is made. To do so you
  should contact Anne Braganza.
6. You have the right to object to data processing where we are
  relying on a legitimate interest to do so and you think that your rights
  and interests outweigh our own and you wish us to stop.
7. You have the right to object if we process your personal data for
  the purposes of direct marketing.
8. You have the right to receive a copy of your personal data and to
  transfer your personal data to another data

controller. We will not charge for this and will in most cases aim to
do this within one month.

With some exceptions, you have the right not to be subjected to
automated decision-making.
You have the right to be notified of a data security breach
concerning your personal data.
In most situations we will not rely on your consent as a lawful
ground to process your data. If we do however

request your consent to the processing of your personal data for a
specific purpose, you have the right not to consent or to withdraw your
consent later. To withdraw your consent, you should contact Anne
Braganza.

You have the right to complain to the Information Commissioner.
You can do this be contacting the Information Commissioner’s Office
directly. Full contact details including a helpline number can be found
on the Information Commissioner’s Office website (www.ico.org. uk). This website has
further information on your rights and our obligations.

Back to home

Data Protection Policy

Overview

Data Protection Principles

How We Define Personal Data

How We Define Special Categories Of Personal Data

How We Define Processing

How Will We Process Your Personal Data?

Examples Of When We Might Process Your Personal Data

Sharing Your Personal Data

How Should You Process Personal Data For The Company?

How To Deal With Data Breaches

Subject Access Requests

Your Data Subject Rights