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Privacy Notice concerning our
Boeing Commercial Training Solutions – Flight Training
Data Processing Activity
(Boeing Data Processing Activity ID Number: 7045)
The Boeing Company and its group of companies seek to maintain the privacy, accuracy, and
confidentiality of personal data that we collect and use.
We have established privacy and security measures
both internally and (where applicable) in our relations with third parties to safeguard
personal information in our data processing activities.
We hope that
the following questions and answers addressing privacy issues
related to our "Boeing Commercial Training Solutions – Flight Training"
data processing activity are as concise, transparent, and
intelligible as possible. We welcome
your suggestions for improvement of any of the content presented
below.
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Question |
Answer |
| What
corporate entity determines the purposes and means of processing of the personal data in this activity?
(This
is the "Controller" under the EU General Data Protection Regulation and other applicable
laws.) |
The
Boeing Company |
| Who
represents this entity with regard to privacy issues? |
The Boeing Global Privacy Office is responsible
for privacy issues related to this activity.
Contact information for the Boeing Global Privacy Office
appears below this table.
(The Boeing Global
Privacy Office will route issues to the appropriate Data
Protection Officer where applicable.)
|
| Whose
personal data is intended to be processed by this
activity? |
This
activity is intended to process the personal information
of:
-
Employees
- Customers
- Non-Boeing Individuals with BEMS IDs (consultants,
purchased services, suppliers, etc.)
- Students (over 18 years of age)
It is not intended to process the personal
information of individuals in other categories. |
| What
categories of personal data are processed by this
activity? |
Highly-Sensitive
Personally Identifiable Information:
Passport Number
Military or Geneva ID Number
Full Date of Birth
Highly Sensitive Medical Information
Sensitive
Personally Identifiable Information:
- Age
- Citizenship
- Ethnicity
- Home Address
- Job Level
- Sensitive Medical Information
- Job Performance or
Corrective Action Records
Personal Information: Airman Certificate/Pilot licence
Airline ID
Audio
Birth Certificate
Government Identification including but not limited to Pilot License
NAA Regulatory Course Completion Certificates
Pilot Medical Certificate
Video
Course Surveys
Home Address
Language Proficiency
Performance assessment ratings or narrative performance characterizations used for evaluations (no corrective action information is collected)
Photograph
Visa
Grading Sheets/ EASA CAA Regulatory course paperwork and completing certificates/ MCC Certificate/ NAA paperwork
Flight Simulator Session Recording - Images and audio from the video recording of individuals during the training session
This activity also collects the data subjects Full name, Airline employer, Business mobile telephone number, Business email address. Currency and training records - Pass or fail courses. Personal data leveraged in support of analytics includes name, BEMSID (or work ID), and student performance assessment ratings (e.g. grades) and characterizations from the training events.
|
| What
are
the purposes of
processing personal data in this activity? |
Personal data along with copies of training documents are requested from each student via Docu sign prior to the start of their course by the Boeing Flight Training Admin Dept /Boeing CPMs. As a back up to Docu sign, Boeing Guest Services at the LGW Campus can collect these training documents on the 1st day of the course then pass the documents to the Boeing Flight Training Admin Dept.
The personal information will be used to contact the student in case of an emergency, schedule changes, to confirm they are on the correct training course, and to produce the correct Flight Training Certificate.
This data will be used to contact the student in case of an emergency, for schedule changes and also to issue grade sheets.
The student data will also be shared with their airline.
Instructor licence details will be shared with customer airlines and NAAs.
To support Competency-Based Training & Assessment (CBTA) training analytics. CBTA training data collected in grading applications will be made available for analytics intended to further the objective of improving global aviation safety. The photo is used for the customers training file. The personal data will also be used to request that the student complete a course survey as required per UK Civil Aviation Authority Part Organisational Requirement for Aircrew GM1 ORA.GEN.200(c) Management System.
In the United States, United Kingdom, and Singapore, images and audio of students and possibly the instructor are recorded when initiated by the instructor. The reason for having the recording functionality, is a legitimate interest to record the students and instructor, to support reviewing the sessions to achieve the learning objectives. The protocol is for the Instructor to delete the recording at the conclusion of the Debrief. If they do not, the recorded sessions will automatically be deleted after a period of 48 hours. The recording is then available to the crew for review in order to improve their skills. However, in China, there are cameras installed inside the simulators; they are not triggered by instructors. Whenever there is any training activities in the simulators, the camera will work automatically, and record the activities inside the simulator. It is different from the recording system provided by simulator manufacturer. These cameras were installed based on the requirement from CAAC. |
| What is the legal basis of processing personal data to be able to contact the student in emergencies, schedule changes, and to support the Competency-Based Training & Assessment (CBTA) training analytics? |
Processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract.
The purpose of collecting this personal data is to be able to contact the student in case of an emergency or for schedule changes, and to support Competency-Based Training & Assessment (CBTA) training analytics. |
| What is the legal basis of processing personal data to request that the student complete a course survey? |
Processing is necessary for compliance with a legal obligation to which the controller is subject.
The personal data will also be used to request that the student complete a course survey as required per UK Civil Aviation Authority Part Organisational Requirement for Aircrew GM1 ORA.GEN.200(c) Management System. |
| What is the lawful basis for transfer of the EU data subjects personal data for Competency-Based Training & Assessment (CBTA) training analytics to the United States? |
The data subject has explicitly consented to the proposed transfer, after having been informed of the possible risks of such transfers for the data subject due to the absence of an adequacy decision and appropriate safeguards. |
| Is the
data subject (the person to whom the data relates)
required to provide personal information for this
processing activity, and what would be the possible
consequences of failing to do so? |
Provision of personal information
for this processing activity is not required.
If no personal data provided, then no training certificates can be sent to customers and therefore will have an impact on the flying pilots. No feedback would be obtained to which we are failing a requirement from the UK Civil Aviation Authority. The contract to which the data subject is a party to would not be able to be completed. No feedback would be obtained to which we are failing a requirement from the UK Civil Aviation Authority.
Flight Simulator Session Recordings - Provision of personal information for this processing activity is not required. In the United States, United Kingdom, and Singapore, the recording of the simulator sessions is optional. The tool has been provided by the simulator manufacturer in order to assist the crew in their training. The instructor teaching the crew can either decide to record the session or not. However, in China, it is a mandatory requirement from CAAC; the cameras work automatically when there is a training inside the simulators. |
| Who are
the recipients of the personal data in this activity? |
The recipients of the personal information in this activity may include -
Global Trade Control,
Boeing Employee Instructor Pilot (Non-US Person),Boeing Instructor Pilot Employee (US Person),Boeing Campus employees and contract personnel handling PII data, Boeing Flight Training Support Administration staff, Boeing Guest Services staff,
Boeing IT, Non-Boeing Instructor Pilot (Purchased Services)
Security Access Administrators, NAA, Customer Airline.
Recipients of personal data made available via training analytics will include Boeing Test & Evaluation representatives, Boeing Learning Design management and staff, Boeing Flight Training staff, Boeing Flight Deck Design and Air Crew Operations staff, BCA Management, Boeing Enterprise Safety staff, and Boeing Training & Professional Services staff.
Training analytics data disclosure to other 3rd parties, beyond those identified above, will be accommodated only when required by law or allowed by governing contract/agreement. Such disclosure shall only be made with the implicit or explicit consent of the data subject. Such 3rd parties may include, but are not limited to: Regulators / National Aviation Authorities
3rd Party Airlines Other External Organizations (e.g. IATA, ICAO, etc.)
Flight Simulator Session Recording - In the United States, United Kingdom, and Singapore, the instructor and crew that recorded the session can watch it back in the briefing room following the session but they can protect access to the files with a password chosen by them. When they initiated the recording, it triggered the creation of a password. In China, it is a separated system from the system provided by the simulator manufacturer. Boeing has direct access to it.
The video recordings will also be shared with the individual’s company (i.e. employer) and with CAAC, as required |
| In what
countries will the personal data be processed? |
The personal information involved will be used by business processes based in countries where Boeing conducts business
The pre Check-in personal data with be processed in the United Kingdom. The survey personal data will be processed in the United States.
The personal information involved in analytics will be used by business processes based in countries where Boeing conducts business or PTA (Performance & Training Advisor) users are located.
The personal data collected along with any training documents will only be stored in the United Kingdom and the survey data will be stored in the United Kingdom and the United States.
The analytics data will be stored in the United States.
Flight Simulator Session Recording - The recordings are stored on the local simulator network so they can be accessed only at the location where the simulator is placed.
The personal information will only be stored in the United States, UK, Singapore, China, depending on the location of the simulator in question.
|
| How long
will the personal data be retained by this activity? |
The personal data collected along with any training documents will be retained in accordance with Boeing requirements for a period of 10 years.
For Flight Simulator Session Recordings - the Instructor will delete the recording at the conclusion of the Debrief. If they do not, the recorded sessions will automatically be deleted after a period of 48 hours.
In the United States, United Kingdom, and Singapore, recordings are deleted within 2 days. In China, the CAAC regulation (CCAR-142) states that the training centres should maintain the recordings for at least 3 months
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What specific privacy rights may the individuals whose
personal data is processed by this activity have, and
how can they be exercised? |
Anyone may have the right to
lodge a complaint with a
supervisory authority (https://boeing.com/privacy/authorities.html).
Depending upon the jurisdiction(s)
in which you live or work, you may have the
following additional rights:
- to request access to and
rectification or erasure of personal data or
restriction of processing
- to object to processing
- to data portability
- to not be subject to a
decision based solely on automated processing
which produces legal effects concerning you or similarly affects
you
If not offered as a
self-service capability within the "Boeing Commercial Training Solutions – Flight Training"
data processing activity or otherwise addressed in
another answer above, any applicable privacy rights
may be exercised using
https://boeing.com/privacy/rightsexerciseportal. |
If you have questions or
concerns about privacy issues associated with our "Boeing Commercial Training Solutions – Flight Training"
data processing activity, you may contact the
Boeing Global Privacy Office by:
You
may use
https://boeing.com/privacy/rightsexerciseportal to exercise any
applicable privacy rights for which a self-service capability has
not been offered within the "Boeing Commercial Training Solutions – Flight Training"
data processing activity
or for which other specific instructions do not appear above.
For customers and visitors to our web sites: This notice supplements
the
Boeing Privacy and Cookie Statement.
For employees, contract labor, retirees, and subsidiary employees: This notice
supplements the
Boeing Employee Privacy Notice.
Boeing will periodically review and update
the content of this notice at its discretion.
It was last updated
2025-08-07 15:17:38
(UTC).
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