|
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
- Contract Labor
- Subsidiary Employees
- Customers
- Government Regulators
-
Non-Boeing without BEMS IDs (suppliers)
who are in the following locations:
- The United States
- China
- Singapore
- The United Kingdom (UK)
It is not intended to process the personal
information of individuals in other categories
or locations. |
| What
categories of personal data are processed by this
activity? |
Personal Information: Images and audio from the video recording of individuals during the training session. |
| What
are
the purposes of
processing personal data in this activity? |
In the United States, United Kingdom, and Singapore, images and audio of students and possibly the instructor are recorded when initiated by the instructor. These recordings are taken in order to assist with the training and improve the skills of the participants. Similar to a CCTV recording but with audio. 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 in this activity in the United States, United Kingdom, and Singapore? |
The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
Consent is given by the students (crew) being trained as the recording is initiated by the instructor. Consent can be withdrawn verbally before the recording. |
| What is the legal basis of processing personal data in this activity in China? |
Processing is necessary for compliance with a legal obligation to which the controller is subject.
Video recording has been an important way for the Civil Aviation Administration Of China (CAAC) and covered airlines to check the training quality. These recordings have become a check item in the audit checklist of some airlines. |
| If the personal information of EU data subjects is transferred to a country which is not part of the EEA, what makes the transfer lawful? |
Data of an EU data subject is not transferred to a country which is not part of the EEA.
There is no transfer of data anywhere. The personal data just remains on the local PC in the country it was recorded in. |
| 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.
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? |
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 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? |
In the United States, United Kingdom, and Singapore, recordings are deleted at the end of each day.
In China, the CAAC regulation (CCAR-142) states that the training centers should maintain the recordings for at least 3 months. |
|
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 "Flight Simulator Training Session Recording"
data processing activity or otherwise addressed in
another answer above, any applicable privacy rights
may be exercised using
https://boeing.com/privacy/rightsexerciseportal. |
