AGOT Global Synergies Limited Privacy Statement

Introduction

AGOT Global Synergies Limited is an aviation and aerospace consulting and recruitment organisation. The Company's recruitment business serves the global aviation and aerospace industries, specialising in flight crew, aviation and aerospace engineering staff, aviation and aerospace executive searches, industry specialists and assessment and management consultancy Services (“our Services”). We identify individuals to fill roles with clients' organisations. We operate through several separately constituted and regulated legal entities which provide these Services in accordance with the relevant laws of the jurisdictions in which they respectively operate. AGOT Global Synergies must process personal data (including sensitive personal data) to provide these services – in doing so, AGOT Global Synergies acts as a data controller.

This Privacy Statement outlines how our organisation processes job candidate’s personal information (“Personal Data”) that AGOT Global Synergies Ltd (“we”, “our”, or “us”) receive, use, and store, being part of its recruitment process relevant to employment or other individual engagement.

AGOT Global Synergies Limited (“we”, “us”, or “our”) is committed to protecting and respecting the personal data that we hold and is committed to keeping your information secure and managing it in accordance with our legal responsibilities under the privacy and data protection laws applicable wherever we operate in the world, as well as the Data Protection Act 2018 and UK GDPR and along with the General Data Protection Regulation (Regulation (EC) 2016/679 (“GDPR”) in the European Union (“EU”).

This privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights. It applies to personal data provided to us by individuals or others. We will usually collect and process personal information about you that you directly provide by registering and/or submitting your application for a role advertised by AGOT Global Synergies. We may use personal data provided to us for the purposes described in this privacy statement or as made clear before collecting personal data.

Personal data is any information relating to an identified or identifiable living person. When collecting and using personal data, our policy is to be transparent about why and how we process personal data.

This website is not intended for children, and we do not knowingly collect data relating to children.

We process personal data for numerous purposes. The means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose are set out in the relevant sections below.

The personal data provided to us is provided either directly from the individual concerned, from a third party acting on behalf of an individual, or from publicly available sources (such as internet searches).

Where we receive personal data that relates to an individual from a third party, we request that this third party informs the individual of the necessary information regarding the use of their data. Where necessary, reference may be made to this privacy statement.

You must read this privacy policy, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

This privacy policy supplements the other notices and policies and is not intended to override them.

Third-party links

This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Security

We take the security of all the data we hold seriously. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. Our staff are trained in data protection, confidentiality, and security. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties on a ‘need to know’ basis. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have a framework of policies and procedures which ensure we regularly review the appropriateness of the measures we have in place to keep the data we hold secure. All personal data provided to us is stored on our secure servers.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website, systems, or apps; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to prevent unauthorised access.

Data that we hold

We provide services to individuals as well as organisations. The exact data held will depend on the services to be provided. Where we engage with individuals, we may collect and process personal data to establish and/or satisfy contractual or operational obligations. We request that individuals only provide the personal data required to fulfil our contractual or operational obligations.

Our clients expect that we identify the best individuals to fill roles within their organisations. So, we must research systems, online databases and other information sources and talk to many individuals. Besides our clients, these will include referees and sources to help inform our decision-making process.

The nature of our work means that occasionally, we are required to process personal data quickly, confidentially, and often without reference to the data subject. Accordingly, we process such data in accordance with the Data Protection Laws, regularly using our legitimate interest where it is not possible or feasible to speak directly with the data subject. Beyond this, we will seek consent in the circumstances explained later in this policy document.

Why do we process data?

Where data is collected, it is used for several purposes, as follows:

• Providing services to you: We specialise in processing job applications in collaboration with our clients, acting under their instruction to assist in filling job vacancies. When you apply for a specific position, your application details may be shared with the relevant client to advance the recruitment process. To ensure transparency and compliance, any transfer of your details will be clearly outlined in written documentation provided before any data processing activities. This approach not only streamlines the application process but also maintains the integrity and confidentiality of your personal information.

• Individual needs: We conduct discreet recruitment assignments, often where the client's identity remains confidential initially. In such cases, if your profile aligns with a specific role, we may share your basic information with the relevant client for preliminary consideration. Should the client find your candidacy potentially suitable, we will engage in a more detailed discussion with you about the opportunity. This process may include an interview conducted by one of our consultants. If this interview is successful and you are shortlisted, we will then provide additional details about you to the client. At this stage, you may also start receiving direct communications from the client. This stepwise approach ensures confidentiality is maintained while also keeping you informed and engaged throughout the recruitment process.

• Research: From time to time, we conduct mapping or research exercises on behalf of our clients. This is to enable them to understand a particular market. Here, we may include certain aspects of your personal data. You will not be contacted by any third party about this unless we first obtain your consent.

• Administration: To manage and administer our business and services, we may collect and process personal data. This may include (but is not limited to) maintaining internal business records, managing candidate and client relationships, hosting recruitment assessment days and administering candidate/client-facing applications.

• Compliance and Regulation: In order to fulfil our operational duties at AGOT Global Synergies Limited, the collection and processing of personal data are sometimes necessary to meet contractual obligations, comply with regulations, adhere to legal standards, and uphold ethical practices. Essential activities in this regard include, but are not limited to, identity verification of individuals. This ensures that our operations not only align with legal and ethical standards but also support the integrity and security of our business processes.

• Diversity Monitoring: To assess the diversity of our applicant pool, we collect data for equality monitoring purposes, strictly in accordance with applicable laws. This information is anonymised and aggregated, ensuring individual privacy while enabling us to understand and improve the inclusiveness of our recruitment processes.

• Marketing: For direct marketing purposes, to understand how you use and interact with our recruitment Services, our website, and previous communications we have sent you, and to then send you information on our Services, white papers, newsletters, events and so forth which we believe will be relevant to your expressed or inferred interests, or which would generally be relevant to someone in your position. Please note you may opt out of receiving marketing materials at any time by writing to us.

Data which is processed

The data that is processed is dependent on the service that is being provided and on the recipient of this service.

• Candidate Services (Application Data): We collect various personal data from candidates, which is essential for the application process. This includes but is not limited to: - Basic Personal Details: Gender, full name (including middle and other names, if any), date and country of birth, nationality. - Contact Information: Residential address with proof of address documentation, email address, telephone numbers, and other alternative contact details. - Digital Footprint: Device and browser data such as IP address. - Identification Data: Details from identity documents. - Professional Information: Job title, compensation expectations, employment history including dates and roles, reasons for employment termination, discipline or performance records. - Financial and Legal Data: Payroll records, tax and social security/insurance information, credit ratings, and criminal record details, where relevant.

• Qualifications and References: Educational and professional qualifications, test scores, and reference information. - Additional Application Details: Any voluntary information included in your CV and cover letter, right-to-work documentation. - Role-Specific Data: Any other data relevant to the specific role you are applying for. All collected data is treated with strict confidentiality and used solely for the purpose of assessing suitability for the role in question.

• Assessment Data: Our candidate assessment process involves various forms of testing, including technical, behavioural, and psychometric evaluations, along with interviews and other relevant methods to evaluate your application thoroughly. We prioritise your privacy and autonomy in this process; therefore, we will explicitly seek your consent before administering or processing any behavioural and psychometric assessments. This ensures that all evaluations are conducted with your full awareness and agreement.

• Pre-employment screening: Date of birth, personal identification, personal business-type photograph, bank account details, personal income tax resident status, medical information and declarations, criminal record, credit history report, and dependents details.

Sensitive data

From time to time, we may request your consent to process your personal data for certain well-defined and limited purposes. In line with our commitment to privacy and ethical practices, this is especially pertinent before we process any sensitive personal data, including but not limited to, information regarding racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sexual life and orientation, as well as genetic and biometric data. We advise against providing us with such sensitive personal information unless we explicitly request it and you have given your informed consent. This approach ensures that your most private data is handled with the utmost care and respect, in accordance with legal and ethical standards.

We may also collect, store, and use the following “Special Categories” of more sensitive personal information, if relevant to the position:

• Information about your health, including any medical condition, health, and sickness records.

• Information about criminal convictions and offences

• Information you submit as part of your application must be true, accurate, complete, and not misleading. You understand that any false or misleading statements or omissions made by you during the application process, including your application and any assessments and interviews, may be sufficient cause to justify the rejection of your application.

• If you provide information about your family or any other third party to us as part of your application, then before providing us with such information, you must inform the relevant individuals that you will disclose their personal data to us and provide a copy of the information in this Notice to them.

• Occasionally, we ask you to provide information about protected characteristics, such as your race or marital status. We do this for equal opportunity monitoring purposes and occasionally online, but only if that’s admissible under local law. This information is always anonymised and aggregated and will not be revealed to third parties without your specific consent.

Local agreements

We will not collect personal data from you in certain countries unless you have specifically agreed to this. Your agreement might come via an electronic tick-box on our website or other electronic channels or via other similar measures required by local privacy and data protection laws.

We offer services to clients in various countries, including employee assessment and coaching. The handling of your personal data in these services depends on the nature of the assignment. In some cases, we process your data to align with the legitimate interests of the client. In other instances, we act on explicit instructions from the client. When our services involve psychometric assessments or psychological testing, and we are not acting on instructions from your employer, we will seek your explicit consent.

Additionally, in specific locations, we provide direct services to individuals, such as personal assessment and coaching. In these scenarios, we process your personal data as necessary to fulfil our contractual obligations with you. Should our services incorporate psychometric evaluations or psychological testing, we will ensure that we obtain your specific consent before proceeding. This approach guarantees that we manage your personal data responsibly and in accordance with your rights and preferences.

How your personal information is collected

AGOT Global Synergies can acquire your personal information through direct submissions on our website or direct interactions with our staff. Additionally, we gather personal data through various communication methods, including email, SMS, mobile apps, social media, direct messaging, phone calls, or in-person interactions. For security, compliance, and training purposes, we may record phone and video calls. Furthermore, we obtain information from third-party sources with your consent. These sources can include recruiters, online professional networks, vendors related to pre-employment screening, job boards, social media platforms like LinkedIn, analytics providers, advertising networks, technical and payment service providers (e.g., payroll or referencing companies), publicly accessible resources like Companies House and the Electoral Register, references, tax authorities, or other governmental agencies. These entities may operate both within and outside the United Kingdom or the EU.

In our client services, the personal data we collect may include but is not limited to, names, corporate contact details, job titles, and other data relevant to the service provided. Alongside basic contact information, we also gather details about your professional role and other pertinent information supplied by your organisation. This comprehensive approach ensures that we can provide tailored and effective services to our clients while maintaining strict confidentiality and compliance with data protection regulations.

How long do we hold data for?

We retain the personal data processed by us for as long as is considered necessary for the purpose(s) for which it was collected. Where personal data is held with a view to placing applicants into job vacancies, we will hold the data for no longer than 5 years after the most recent contact with the applicant or 5 years after the termination of the most recent placement, whichever is later. There may also be occasions requiring data to be kept for longer; however, this will typically be for legal purposes.

Our role as a data processor?

When supporting some clients with parts of their recruitment process (mainly where candidates apply directly to a client and the client outsources part(s) of the recruitment process to us), AGOT Global Synergies Limited is the data processor, and our client is the data controller. Personal data that we process on behalf of our clients is stored on our secure servers and is protected by the same security measures that govern how we operate as a data controller.

Why do we process data?

Where we act as the data processor and process personal data on behalf of our clients, this is done for the following purposes:

• Assessing your skills, qualifications, and suitability for the role.

• Carrying out background and reference checks, where applicable.

• Communicating with you about the recruitment process.

• To fulfil contractual obligations towards our clients.

• Clients also require the data we process to assist them in determining whether to enter a contract of employment with you.

• To enable our clients to perform security, quality, and risk management activities.

• So that our clients can comply with any requirement of law, regulation, or a professional body of which they are a member. Our clients are subject to legal, regulatory, and professional obligations. We need to keep certain records to show how our clients comply with those obligations, and those records may contain personal data.

• To enable prospective clients to evaluate our services.

• Relationship management.

• Administration and management.

• If you accept a role with a client, then to conduct any necessary background checks and create your record in our database, we will usually also collect and consider your application, evidence of qualifications, work history, and background checks. If we require references for the role and you fail to provide us with relevant details, we cannot take your application further.

How do we use information about criminal convictions?

Subject to our contractual requirements with our client, we may collect information, on their written authority, from you about your related criminal allegations, proceedings, convictions, offences or related security measures only under the control of an official authority or when authorised by EU, UK or EU Member State law. Typically, should a client be interested in offering you a role, it may be subject to the condition that such references are satisfactory.

How does AGOT Global Synergies share your personal information?

AGOT Global Synergies may disclose your personal information if required to do so by law, court of law, or as requested by a governmental or law enforcement authority. Aside from this, AGOT Global Synergies only shares your personal information, which is a necessary part of its recruitment process. For example, AGOT Global Synergies may share your personal information with other members of AGOT Global Synergies where it is relevant to your application.

AGOT Global Synergies may also share your personal information with a selected group of third-party service providers that carry out certain recruitment-related activities on its behalf, such as background-checking agencies and companies that help AGOT Global Synergies with storing data.

AGOT Global Synergies expects the entities with which it shares your personal information (both group companies and non-affiliated third parties) to protect your information's confidentiality and security and use it only for its intended purpose. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

Transferring your Personal Information to other countries

The entities and organisations with which AGOT Global Synergies may share your personal information may be located outside of the European Economic Area (“EEA”) and the United Kingdom. AGOT Global Synergies has put in place safeguards reasonably designed to ensure your personal information remains adequately protected when transferred.

Your personal information may be transferred to the United States. The United States has not received a finding of “Adequacy” from the European Union under Article 45 of the General Data Protection Regulation (“GDPR”). Consequently, AGOT Global Synergies relies on appropriate safeguards, as set forth in GDPR Article 46, to transfer your personal information to the United States.

For more information about the appropriate safeguards set forth in GDPR Article 46, please email dataprotection@agotglobalsynergies.com.

How long do we hold data for?

When holding and processing data on behalf of our clients (where each client is the data controller and we are the data processor), we retain the personal data only for as long as our contractual obligations towards each client require. If a retention period has not been contractually specified, we will hold the data for no longer than 5 years after completing the recruitment process to which the personal data relates.

Business contacts

Personal data from our contacts, which covers both potential and prior customers and potential and prior employees, are held in our customer relationship management tool (CRM tool).

This information is entered into our systems after contact is made between a staff member of AGOT Global Synergies Limited and an individual or a business contact individual.

Why do we process data?

Where personal data on business contacts is held, it is used for several purposes, as follows:

• Promoting and developing our services
• Hosting and facilitating events
• Relationship management
• Administration and management

What data do we hold?

Personal data that may be held and processed includes (but is not limited to) name, email address, corporate contact details, job title, details of the communication between us and any other specifically relevant data.

How long do we hold data for?

We retain the personal data processed by us for as long as is considered necessary for the purpose(s) for which it was collected.

Our people

We collect personal data for our people as part of our business activities, such as administration, management, and promotion. Our staff handbook explains further how personal data is held for our staff.

Applicants

When an individual applies to work for AGOT Global Synergies Limited, personal data is collected through the application process. There are several purposes for which the personal data of applicants is collected.

• Employment: We process applicants’ personal data to assess their potential employment at AGOT Global Synergies Limited.

• Administration and management: We may also use this personal data to make informed management decisions and for administration purposes.

Personal data collected for applicants is held for as long as necessary to fulfil the purpose for which it was collected or for a maximum of one year when those purposes no longer become necessary.

Suppliers

We collect and process personal data about our suppliers, subcontractors, and associated individuals. The data is held to manage our relationship, to contract and receive services from them, and, in some cases, to provide professional services to our clients.

Why do we process data?

• Receiving goods and services. We process personal data in relation to our suppliers and their staff as necessary to receive the services.

• Providing services to our clients. Where a supplier is helping us deliver professional services to our clients, we process personal data about the individuals involved in providing the services to administer and manage our relationship with the supplier and the relevant individuals and to provide such services to our clients.

• Administering, managing, and developing our business and services. We process personal data to run our business, including:

1. Managing our relationship with suppliers

1. Developing our business and services (such as identifying client needs and improvements in service delivery).

1. Maintaining and using IT systems.

1. Hosting or facilitating the hosting of events.

1. We administer and manage our website, systems, and apps.

1. Security, quality, and risk management activities: We have security measures in place to protect our and our suppliers’ information, including personal data. These measures involve detecting, investigating, and resolving security threats. Personal data may be processed as part of our security monitoring, such as automated scans to identify harmful emails. Policies and procedures are established to monitor the quality of our services and manage risks in relation to our suppliers. As part of our supplier contracting procedures, we collect and hold personal data. We also monitor the services provided for quality purposes, which may involve processing personal data.

1. Complying with any requirement of law, regulation, or a professional body we are a member of. We are subject to legal, regulatory, and professional obligations. We need to keep certain records to show we comply with those obligations, and those records may contain personal data.

What data do we hold?

We will hold the names, contact names, and contact details of suppliers.

How long do we hold data for?

We retain the personal data we process for as long as is considered necessary for the purpose for which it was collected. Data may be held longer when law or regulation requires establishing, exercising, or defending our legal rights.

People who use our website or apps

When people visit our website or use our apps, personal data is collected both through automated tracking and interacting with various forms on the website or apps.

Personal data may be collected when individuals fill in forms on our website or apps or by corresponding with us by phone, e-mail or otherwise. This includes information provided when an individual registers to use our website or apps, subscribes to our service, or enquires.

The collection of personal data through automated tracking is achieved using cookies. A cookie is a small data file that certain websites write to your hard drive when you visit them. A cookie file can contain information such as a user ID that the website uses to track the pages you’ve visited. Still, the only personal data a cookie can contain is information which you supply yourself. A cookie can’t read personal data off your hard disk or read cookies created by other sites. Some parts of our website use cookies to track user traffic patterns. We do this to determine our website’s usefulness to our users and to see how effective our navigational structure is in helping users reach certain information.

If you prefer not to receive cookies whilst using our website, you can set your browser to warn you before accepting cookies and refuse the cookie when your browser alerts you to its presence. You can also refuse all cookies by turning them off in your browser, although you may not be able to take full advantage of our website if you do so. You may be required to accept cookies to complete specific actions on our website, including those requiring logging in. However, you do not need to have cookies turned on to use/navigate through many parts of our website.

Sharing personal data

We will only share personal data with others when we are legally permitted to do so. When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality, and security standards.

Personal data held by us may be transferred to:

• Third-party organisations that otherwise assist us in providing goods, services, or information.

• Professional Services: This may include HR, Legal, and medical advisors who may receive your data to advise on your suitability for a vacancy.

• Clients: They may receive your data to assess your suitability for a vacancy applied for.

• Law enforcement or regulatory agencies or those required by law or regulations.

• Business contacts, clients, and suppliers, where such sharing is permitted under contract or applicable law or regulation. Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, and to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.

Locations of processing

Where possible, personal data resides within the UK territory but may be transferred to and stored at a destination outside the European Economic Area (EEA).

Individual’s rights

Individuals have certain rights over their data, and data controllers are responsible for fulfilling these rights as follows:

• Individuals may request access to their data held by us as a data controller.

• Individuals may request us to rectify personal data submitted to or held by us or, where appropriate, contact us via the relevant website registration page or by amending the personal details held on relevant applications with which they registered.

• Individuals may request that we erase their data.

• Where we process personal data based on consent, individuals may withdraw their consent at any time by contacting us or clicking on the unsubscribe link in certain emails received from us.

• Individuals may have other rights to restrict or object to our processing of personal data and the right to data portability.

• Individuals may request information about, or human intervention into, any automated data processing we undertake. If you wish to exercise any of these rights, please email dataprotection@agotglobalsynergies.com.

Complaints

Should there ever be a need, although we hope this won't be the case, to express concerns or complaints about how we handle your data, we encourage you to reach out to us. Your feedback is invaluable, and we are committed to addressing any issues promptly and thoroughly. Please direct the details of your complaint via email to the following address:

dataprotection@agotglobalsynergies.com. We assure you that every complaint will be taken seriously and investigated diligently to ensure a satisfactory resolution.

You also have the right to complain to the UK data protection regulator, the Information Commissioner’s Office (“ICO”). For further information on your rights and how you may reach the relevant body to complain to the ICO, please refer to the ICO website: https://www.ico.org.uk/make-a-complaint/.

Data controller and contact information

The data controller for AGOT Global Synergies Limited is AGOT Global Synergies Limited. When supporting some clients with parts of their recruitment process (mainly where candidates apply directly to a client and the client outsources part(s) of the recruitment process to us), AGOT Global Synergies Limited is the data processor.

If you have any questions about this privacy statement or how and why we process personal data, please get in touch with us at AGOT Global Synergies Limited, 71-75 Shelton Street, Covent Garden, London WC2H 9JQ, United Kingdom.

Changes to our privacy statement

Updates to this privacy statement will appear on this website. This privacy statement was last updated on February 15, 2024.