TABLE OF CONTENTS
This privacy notice (the “Privacy Notice”) is relevant for:
-
- Visitors to Martin-Baker (as defined below) site;
- Job applicants;
- Users of our website and other individuals who submit general enquiries;
- Ejection Tie Club Members;
- Individual purchasers of our merchandise;
- Purchasers of our goods and services (the “Products”); and
- Providers of goods and services to Martin-Baker.
We only process your personal information for the following purposes:
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- Visits to Martin-Baker site;
- Recruitment and selection;
- Responding to general enquiries;
- Managing the Martin-Baker Ejection Seat Tie Club;
- Administering the purchase of Martin-Baker merchandise;
- Administering the sale of Martin-Baker Products; and
- Administering the purchase of goods and services by us from third-party suppliers.
This Privacy Notice explains what data we process, why, how it is legal and your rights.
This Privacy Notice is provided by Martin-Baker Aircraft Company Limited (“Martin-Baker” or “we” or “us”) at Lower Road, Higher Denham, Uxbridge, Middlesex, UB9 5AJ who is a “controller” for the purposes of the Data Protection Act 2018 (as amended) (the “Act”), the United Kingdom General Data Protection Regulation (“UK GDPR”) and other national laws related to data protection and subsequent amendments.
We are responsible for, and control the processing of, your personal data. This Privacy Notice applies to the personal data we process in connection with:
- · Visits to Martin-Baker site;
- · Recruitment and selection;
- · Responding to general enquiries sent to Martin-Baker;
- · Managing the Martin-Baker Ejection Seat Tie Club;
- · Administering the purchase of Martin-Baker merchandise;
- · Administering the sale of Martin-Baker Products; and
- · Administering the purchase of goods and services by Martin-Baker from third-party suppliers.
We take your privacy very seriously. We ask that you read this Privacy Notice carefully as it contains important information about our processing and your rights.
How to contact us
If you would like this Privacy Notice in another format (for example: audio, large print, braille) please contact us at the details below:
- Contact: privacy@martin-baker.co.uk
- Address: Lower Road, Higher Denham, Nr Uxbridge, Middlesex. UB9 5AJ
- Telephone number: 01895 832214
Changes to this Privacy Notice
We reserve our right to change this Privacy Notice from time to time. The latest version will be made available on our website. Your subsequent use of our website or submission of personal information to Martin-Baker will be deemed as acceptance of the latest version of our Privacy Notice.
Current version: v2 March 2021
Please familiarise yourself with the following words and phrases (used in bold) as they have particular meanings in the Data Protection Laws and are used throughout this Privacy Notice:
| TERM | DEFINITION |
|---|---|
|
Controller |
This means any person who determines the purposes for which, and the way any personal data is processed. |
|
Criminal offence data |
This means any information relating to criminal convictions and offences committed or allegedly committed. |
|
Data Protection Laws |
This means the laws which govern the handling of personal data. This includes the UK GDPR, the Act and any other national laws related to data protection and subsequent amendments. |
|
Data subject |
This means the person to whom the personal data relates. |
|
ICO |
The UK Information Commissioner’s Office which is responsible for implementing, overseeing and enforcing the Data Protection Laws. |
|
Personal data |
Any information from which a living individual can be identified. This will include for example information such as telephone numbers, names, addresses, e-mail addresses, photographs, and voice recordings. It will also include expressions of opinion and indications of intentions about data subjects (and their own expressions of opinion/intentions). It will also cover information which on its own does not identify someone, but which would identify them if put together with other information which we have or are likely to have in the future. |
|
Processing |
This covers virtually anything anyone can do with personal data, including:
|
|
Processor |
This means any person who processes the personal data on behalf of the controller. |
|
Special categories of data |
This means any information relating to:
|
We process specific categories of personal data for each service/process as explained below.
Personal information provided by you
Visits to Martin-Baker site
| PERSONAL DATA | SPECIAL CATEGORIES OF DATA/ CRIMINAL OFFENCE DATA |
|---|---|
|
We do not actively request for special categories or criminal offence data. |
Job Application with Martin-Baker
| PERSONAL DATA | SPECIAL CATEGORIES OF DATA/ CRIMINAL OFFENCE DATA |
|---|---|
|
|
Individual purchases of Martin-Baker merchandise
| PERSONAL DATA | SPECIAL CATEGORIES OF DATA/ CRIMINAL OFFENCE DATA |
|---|---|
|
We do not actively request for special categories or criminal offence data. |
General and Ejection Seat Tie Club enquiries to Martin-Baker
We always welcome people to contact us for information on our merchandise products and Ejection Tie Club.
| PERSONAL DATA | SPECIAL CATEGORIES OF DATA/ CRIMINAL OFFENCE DATA |
|---|---|
|
We do not actively request for special categories or criminal offence data. However, we may come across them if you provide them to us. |
Purchasers of our Products and providers of goods and services to Martin-Baker.
| PERSONAL DATA | SPECIAL CATEGORIES OF DATA/ CRIMINAL OFFENCE DATA |
|---|---|
|
We do not actively request for special categories or criminal offence data. |
We use your personal data for the following purposes listed in this section. We are allowed to do so on certain legal bases (see section “How is processing your data lawful” for further detail).
| PURPOSE | EXPLANATION |
|---|---|
|
Visits to Martin-Baker site |
|
|
Job application |
|
|
Individual purchases of Martin-Baker merchandise |
|
|
General enquiries |
|
|
Martin-Baker Ejection Tie Club |
|
|
Purchasers of our Products and providers of goods and services to Martin-Baker |
|
We are allowed to process your personal data and special categories of data on the following legal bases:
Visits to Martin-Baker site
Legitimate interest
We may process some personal data if doing so is in our legitimate interest, so we can host your visit to Martin-Baker. In order to do so, we have considered the impact on your interests and rights and have put in place appropriate safeguards to ensure that the intrusion on your privacy is reduced as much as possible. You have the right to object to the processing of your personal data on this ground. Please see section ‘Your Rights’ to found out how.
Legal claims
We need to process your personal data to defend or establish a legal claim (for example, claims relating to personal injury).
Job application with Martin-Baker
Legitimate interest
We may process some personal data if doing so is in our legitimate interest as an employer. In order to do so, we have considered the impact on your interests and rights and have put in place appropriate safeguards to ensure that the intrusion on your privacy is reduced as much as possible. You have the right to object to the processing of your personal data on this ground. Please see section ‘Your Rights’ to found out how.
Legal obligation
In this case, Martin-Baker’s legal obligations are:
- We may process some personal data in order to comply with our legal obligations as an employer and for the purpose of assessing your working capacity as an employee.
- We may process special categories of data, or criminal offences data necessary for the purposes of occupational health, including the assessment of your working capacity as an employee. We will process information about your health in order to assess your medical capacity to perform the role you have applied for.
- We also may process special categories of data, or criminal offences data necessary for compliance with our obligations under the law.
Public interest
We process some information obtained from the ID and criminal record check to meet our obligation to check whether there are any unspent criminal convictions which would prevent you from working in the role you have applied for. You have the right to object to the processing of your personal data on this ground. Please see section ‘Your Rights’ to found out how.
Legal claims
We may need to process special categories of data, or criminal offences data in order to exercise our legal rights and bring or defend claims.
Individual purchases of Martin-Baker merchandise
Contract
It is necessary for our performance of the contract you have agreed to enter with us to buy our merchandise. If you do not provide your personal data to us, we will not be able to carry out our obligations under the terms of the contract.
Legal claims
We need to process your personal data to defend or establish a legal claim (for example, claims relating to the sale of our merchandise under contract law).
General enquiries to Martin-Baker
Legitimate Interests
In this case, Martin-Baker’s legitimate interest is to provide information about Martin-Baker to prospective customers and to develop new business or grow existing relationships. We only use data that you provide and only use your data in order to respond to your query.
Martin-Baker Ejection Tie Club
Legitimate Interests
In this case, Martin-Baker’s legitimate interests are:
- To learn from the ejection experiences of individuals who have ejected from a Martin-Baker seat in order to develop and improve our products. Our aim is to improve the experience of ejectees and the performance of our products; and
- To keep in touch with you as a member of the Tie Club, to invite you to events, make you aware of developments in our products that might interest you, to ask for testimonials and otherwise to manage the Tie Club. You can always select not to be contacted by us for this purpose by contacting us using the details in the “How to contact us” section above.
For special categories of data, we can process your medical information on the grounds of scientific research to enable us to make improvements to our products and improve their safety features for future ejectees.
Purchasers of our Products and providers of goods and services to Martin-Baker
Contract
It is necessary for our performance of the contract you have agreed to enter with us to buy our Products or provide us with your goods and services. If you do not provide your personal data to us, we will not be able to carry out our obligations under the terms of the contract.
Legal claims
We need to process your personal data to defend or establish a legal claim (for example, claims relating to the sale of our products under contract law).
It is not our policy to use any service providers that act as our processors for the processing set out in this Privacy Notice and your information is unlikely to be sent out of the United Kingdom and the European Economic Area.
If we transfer your personal data outside the United Kingdom or European Economic Area to a country without a designated adequacy rating, Martin-Baker will ensure that the processor’s Binding Corporate Rules, Standard Contractual Clauses or ad-hoc contractual clauses stipulate that the data will be processed in accordance with the Data Protection Laws.
As part of the recruitment process at Martin-Baker we need to share your basic personal data with Agenda Screening, a provider we use for ID and criminal records checks (unspent convictions only) and SHL that provide online testing for us. Both Agenda Screening and SHL act as separate controllers of your personal data. You should review their privacy notices to find out how they process your personal data. If you have any queries or complaints about how they process your personal data, please contact them separately using the contact information provided on their website. We will also share your personal data with the police, other law enforcements or regulators where we are required by law to do so.
How we keep your personal data secure
We strive to implement appropriate technical and organisational measures in order to protect your personal data against accidental or unlawful destruction, accidental loss or alteration, unauthorised disclosure or access and any other unlawful forms of processing. We aim to ensure that the level of security and the measures adopted to protect your personal data are appropriate for the risks presented by the nature and use of your personal data. We follow recognised industry practices for protecting our IT environment and physical facilities. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information.
If you have any particular concerns about your information, please contact us (see section “How to contact us?” to find out how).
We store your personal data in accordance with our data retention policy. This policy is reviewed and updated internally to ensure we do not store your data for longer than is necessary. We also review how and where we store any data to ensure that we meet our obligation to store data securely.
We will retain your personal data and special categories of data in relation to the services for the period provided below.
| PERSONAL DATA/ SPECIAL CATEGORIES OF DATA | RETENTION PERIOD |
|---|---|
|
Visits to Martin-Baker site |
Access badge destroyed immediately after the visit. Physical and electronic records of all visitors – six months after the visitor/contractor attendance. Covid-19 Test and Trace information – twenty-one days. |
|
Job application and interview records of unsuccessful candidates |
One year after the end of the relevant recruitment exercise if your application for a role with Martin-Baker is unsuccessful or you do not accept our offer of employment. If your application for a role with us is successful and you start work as our employee/contractor, please see the Staff Privacy Notice for details of how long we will retain the data gathered during the recruitment exercise. If you apply for a new role with us when you are already our employee/contractor, this Privacy Notice applies in respect of any new information gathered during that application process, and the Staff Privacy Notice continues to apply in respect of any information we already hold by virtue of you being a current employee/contractor. |
|
Details of your enquiries and our response |
One year after enquiry completed |
|
Martin-Baker Ejection Tie Club membership details including information regarding your emergency ejection |
Indefinitely for research and development purposes. |
|
Transaction details for your purchase of our merchandise |
One year after enquiry completed. |
In addition, some of the data we hold may be subject to certain legal and regulatory obligations, which provide a minimum retention period for different types of data. The retention period varies depending on the data we hold.
As a data subject, you have the following rights under the Data Protection Laws:
-
- the right to object to processing of your personal data;
- the right of access to personal data relating to you;
- the right to correct any mistakes in your information;
- rights in relation to automated decision making (note this does not apply);
- the right to prevent your personal data being processed;
- the right to have your personal data ported to another controller; and
- the right to erasure.
These rights are explained in more detail below, but if you have any comments, concerns or complaints about the use of your personal data by us, please contact us (please refer to section “How to contact us”). We will respond to any rights that you exercise within a month of receiving your request, unless the request is particularly complex, in which case we will respond within three months. Please be aware that there are exceptions and exemptions that apply to some of the rights which we will apply in accordance with the Data Protection Laws.
Your Rights Explained
Right to object to processing of your personal data
You may object to us processing your personal data where we rely on a legitimate interest as our legal grounds for processing.
If you object to us processing your personal data we must demonstrate compelling grounds for continuing to do so. We believe we have demonstrated compelling grounds in the section headed “How is processing your personal data lawful”.
If you are applying for a role with Martin-Baker, we must process your personal data in order to carry out elements of our recruitment process. The key point to note is that without processing your data, we will not know as much about you which could affect our assessment of your suitability for a job with us.
Right to access personal data relating to you
You may ask to see what personal data we hold about you and be provided with:
-
- a copy of the personal data;
- details of the purpose for which it is being or is to be processed;
- details of the recipients or classes of recipients to whom it is or may be disclosed, including if they are overseas and what protections are used for those oversea transfers;
- the period for which it is held (or the criteria we use to determine how long it is held);
- any information available about the source of that data; and
- whether we carry out an automated decision-making, or profiling, and where we do information about the logic involved and the envisaged outcome or consequences of that decision or profiling.
To help us find the information easily, please provide us as much information as possible about the type of information you would like to see.
Right to correct any mistakes in your information
You can require us to correct any mistakes in your information which we hold free of charge. If you would like to do this, please let us know the information that is incorrect and what it should be replaced with.
Rights in relation to automated decision making (note not relevant).
We do not make any automated decisions about you so this right does not apply
Right to restrict processing of personal data
You may request that we stop processing your personal data temporarily if:
-
- you do not think that your data is accurate. We will start processing again once we have checked whether or not it is accurate;
- the processing is unlawful but you do not want us to erase your data;
- we no longer need the personal data for our processing, but you need the data to
- establish, exercise or defend legal claims; or
- you have objected to processing because you believe that your interests should
override our legitimate interests.
Right to have your personal data ported (data portability)
You may ask for an electronic copy of your personal data which we hold electronically and which we process when we have entered into a contract with you. You can also ask us to provide this directly to another party.
Right to erasure
You can ask us to erase your personal data where:
-
- you do not believe that we need your data in order to process it for the purposes set out in this Privacy Notice;
- if you had given us consent to process your data, you withdraw that consent and we cannot otherwise legally process your data;
- you object to our processing and we do not have any legitimate interests that mean we can continue to process your data; or
- your data has been processed unlawfully or have not been erased when it should have been.
What will happen if your rights are breached?
You may be entitled to compensation for damage caused by contravention of the Data Protection Laws.
Complaints to the regulator
It is important that you ensure you have read this Privacy Notice – and if you do not think that we have processed your data in accordance with this Privacy Notice – you should let us know as soon as possible. If you are not satisfied with our responses to your requests or how we manage your personal information you may complain to the ICO. Information about how to do this is available on the website at www.ico.org.uk.