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1. Purpose

AS ”Air Baltic Corporation” (hereinafter – airBaltic) is committed to protect the privacy of personal information which it handles. This recruitment privacy policy recognizes the rights of individuals (“candidates”) applying for positions at airBaltic or any of its subsidiaries to keep their personal information private in accordance with the applicable state and territory privacy legislation.

2. airBaltic

For the purposes of this policy, unless expressly stated otherwise, references to airBaltic are references to:

• AS “Air Baltic Corporation”, registration number: 40003245752, legal address: Marupes district, Airport Riga, Tehnikas street 3, LV-1053, Latvia;
• SIA "Air Baltic Training", registration number: 40103272422, legal address: Marupes district, Airport Riga, Pilotu street 6, LV-1053, Latvia;
• AS “Aviation Crew Resources”, registration number: 40103587651, legal address: Marupes district, Airport Riga, Pilotu street 6, LV-1053, Latvia;
• SIA “Baltijas Kravu Centrs”, registration number: 40003458674, legal address: Marupes district, Airport Riga, Ziemelu iela 18, LV-2167, Latvia.

3. Collection of personal information

As a part of its recruitment process, airBaltic may collect:

• personal information that is received from individuals (including, candidates) interested in job at airBaltic, including contact information, information received through any application tools that the candidate uses, or information generated during recruitment process, for example, results of tests completed by candidate;
• education and work related information which candidate has posted on social networks and/or internet (for example, Linkedin or other);
• personal information that is provided on your behalf by another person, for example, in case employee of airBaltic refers you as a potential candidate for a vacancy. In such a case we may process information to contact you and ask whether you are interested to participate in the recruitment process for certain positions. If you do not want us to contact you, then we will delete your contact information provided by another person.

Collectively, your personal information, health information and sensitive information is referred to as “Your Information”. AirBaltic during recruitment process ask candidates to submit information which is directly relevant to the recruitment process.

AirBaltic is subject to various applicable regulatory enactments, in particular those related to aviation industry (for example, Law on Aviation, its Section 57.1 and the Regulations of the Cabinet of Ministers No. 829 provide obligation of conducting background checks and take other steps, which shall be taken before employing employees). Therefore, we may process certain information to ensure compliance with law, for example, data processing when conducting background check, information on criminal and certain administrative convictions according to the provisions of law, examination of references from previous employers and/or certifying information on education and studies.

AirBaltic will require you to provide any health information or sensitive information only when there is a valid legal ground for that (for example, for a certain type of positions health information has crucial role in evaluating eligibility for work as regulated by law and/or aviation industry standards).

In case you provide us with personal information of another person (for example, referees), please, before sharing this information make sure that you have consent from those individuals to share their information with us. We may rely that any personal data you have provided to us, is obtained in a lawful way and data subject concerned has consented on that.

4. How airBaltic uses Your Information and legal ground

Your Information will be used by airBaltic to enable airBaltic to consider you for employment and to facilitate the recruitment process. airBaltic may also use Your Information for statistical purposes, but only as anonymized data.

All data will be stored and processed by airBaltic authorized persons in order to facilitate the recruitment process. Your Information will be used for recruitment purposes, including, but not limited to contact you, to background and reference checks; evaluation for job suitability, eligibility or qualifications; recruitment or hire; verification of data and check information provided; organizing meetings and interviews, information may be processed to conclude employment contract when recruitment process has resulted in employing a candidate.

AirBaltic may also offer to organize interviews remotely using different available solutions, for example, interviews in Microsoft Teams provided by Microsoft (privacy statement on Microsoft Teams are available: commitment to privacy and security in Microsoft Teams) or also Willow platform (privacy commitments by Willow platform you may find herein: Willow privacy policy).

In the specific situations when organizing interview/meeting remotely we may offer a recording of interview/meeting in the Microsoft Teams or other similar solution used by airBaltic. Please, note that we will inform you on this before and you have rights to object recording. We will refrain from recording meeting/interview if you object.

If you do not object recording remote meeting/interview, please, note that we will delete those records together and as soon as we delete all other documentation processed within the recruitment process.

AirBaltic will ensure that your data is processed only by limited number of employees who are involved in the recruitment process. AirBaltic will not use Your Information for any other purpose (other than those mentioned in this policy) unless it has obtained your prior consent, or as required or authorised or allowed by law.

Legal ground for data processing is legitimate interest to ensure and organize recruitment process and employ employees for open vacancies, as well as some processing is based on the requirements of the applicable regulatory enactments (for example, Law on Aviation obliges airBaltic take certain steps during recruitment, for example, to conduct background check and take other steps necessary to comply with lawful obligations).

Some of processing activities are necessary for entering into and prepare the employment contract, for example: - identification of a person by asking to present valid identification document, collecting information about bank account to which salary shall be paid and other data necessary for this purpose.

There are specific processing, which is based on your consent, for example, when you apply for vacancy or if there is no active vacancy in area you are interested in, we may offer you possibility to store your data (which may vary from contact information to CV and motivation letter and other recruitment documents (if any) with us for 2 years or other term specified in the text of a particular consent to consider your candidacy for other vacancies within airBaltic and its subsidiaries. This is your free choice and only with your active consent, we will store your CV, motivation letter and other recruitment documents (if any) for the mentioned period. After this period expires, we will delete or anonymized your data unless you have provided some other new consent for additional period or we have recruited you for some positions. Additionally, based on your consent we may send you information to your contact details on open vacancies. Please, note that you may change your mind at any time.

If during period of validity of the consent you will decide to withdraw the consent by eliminating the data (CV and motivation letter and other recruitment documents (if any)) from our records, please send us free text message to careers@airbaltic.com indicating your intention to withdraw your consent and delete the data. After receiving your request and being able to identify that you are a person you declare to be, we will delete the documents from our records. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

In case we are processing special category personal data (such as health information) for assessing your eligibility for work, then please be informed that we are processing such data according to Article 09 of GDPR, paragraph 2, sub-point (b), which allows processing of such data when it is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law.

In case law obliges airBaltic to request employees to have valid COVID19 vaccination/recovery or testing certificates according to the applicable regulatory enactments, then the legal ground for the processing of such data are requirements of the applicable regulatory enactments according to the General Data Protection Regulation (EU) 679/2016, Article 9, paragraph 2, point i), which allows the processing of special category data when it is necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health or ensuring high standards of quality and safety of health care.

5. Categories of Data recipients

We have implemented various tools and services to facilitate our cooperation and the recruitment process. Therefore, we may disclose your data the categories of data recipients as mentioned below:

5.1 we may disclose your data to partners, which provide us with the following services – IT support and services and recruitment service and support providers; 5.2 we may disclose personal data to the relevant authorities in cases and under procedure provided by law;

5.2 we may disclose personal data to the relevant authorities in cases and under procedure provided by law;

5.3 we may disclose your data to the website service providers, with whom we have concluded the agreement to ensure operation of the website, where you enter your data to apply for vacancy;

5.4 we may disclose personal data in exceptional cases to consultants and lawyers;

5.5 we may approach individuals for reference purposes, our usual practice is that we ask a candidate to indicate the referees for reference purposes. In case you indicate referees, please, make sure that you have consent from such individuals on sharing their contact details with airBaltic.

Our partners are always obliged to adequately safeguard your personal information and process it in accordance with instructions stated in our agreement and law.

Please, note that if personal data is transferred out of European Union or European Economic Area, we are applying data protection measures provided under EU General Data Protection Regulation No. 679/2016 (hereinafter – GDPR) and request also from our partners to comply with such requirements, for example, Microsoft in its privacy statements (you may find it herein:Microsoft Privacy Statement) states that data transfers are protected by standard contractual clauses approved by European Commission. In its turn, data transfer to United Kingdom is protected by the adequacy decision approved by European Commission.

6. Your rights and data access

Please, be informed that you have the following rights according to the applicable regulatory enactments by addressing the request to airBaltic:

• to access your personal data (receive a copy of your personal data and request the purpose and basis of the data processing);
• to object the processing of your personal data when its based on a legitimate interest (for example, to object recording remote interview, which may be offered by airBaltic in exceptional cases. In such case you may object within communication with our recruitment specialists and in any case you may always address your request to gdpr@airBaltic.com by specifying processing against which you object);
• to withdraw consent (for example, if you have consented that airBaltic store your recruitment documents (CV, motivation letter and other recruitment documents/data, if any) for 2 years, you may change your mind at any time by addressing the request primary to careers@airbaltic.com, in any case you may always approach also data protection officer to gdpr@airBaltic.com). Take into account that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
• to data rectification (change your contact information, submit current information in case of change);
• to be forgotten and to request data to be erased (request to delete your information from our databases, in compliance with the scope determined under the applicable regulatory enactments). Please, be informed that we may continue storage of information for the establishment, exercise or defence of legal claims and in other cases provided under the applicable regulatory enactments. We will examine each request with due care and will exercise your rights to be forgotten towards information which shall be deleted according to GDPR.
• to restrict processing of personal data (you may ask us not to use certain information about you for limited period of time, for example, if you have submitted information, which for any reason is incorrect (for example, mistake in documents, in information provided to us), you may ask us not to process incorrect information until you are providing us with the correct data);
• to data portability (receive information about yourself which you have provided to us and ask to deliver such information to another controller if it is technically feasible);
• in case you have any concerns or objections or complaints on processing of personal data carried out by airBaltic, we invite you to turn to us by writing message to gdpr@airBaltic.com and we will review the issue with due care and will take steps to solve the issues as soon as possible. Nevertheless, data subjects are entitled to lodge a complaint with a supervisory authority (in the Republic of Latvia it is State Data Inspectorate of the Republic of Latvia - Datu valsts inspekcija).

Depending on the nature of information you want to access, some authentication requirements (we may ask some additional information from you) may apply to allow airBaltic to verify whether you are the person you declare to be.

7.Security and storage

AirBaltic will take steps pursuant to the applicable regulatory enactments to ensure that Your Information is protected from misuse, loss, unauthorised access, modification and disclosure.

In general, we shall store your personal data until we have fulfilled the purpose of processing.In this regard we apply the following criteria when we determine period of time for processing and storage of the data:

7.1.we process/store the data until fulfilment of the purpose;

7.2.period of time, which is necessary to ensure recruitment process and 4 (four) moth after recruitment project is closed unless no other legal ground exist for longer storage of the data (for example, consent for storing data for 2 years for other recruitment projects). The mentioned 4 months period is justified with limitation periods specified by the Labour Law and time necessary to review claim;

7.3.period of time necessary to ensure processing, which is based on your consent. If the consent is withdrawn, processing, which is based on such a consent, is terminated;

7.4.period of time specified by the applicable regulatory enactments. airBaltic is a subject of various laws and regulations, which determine strict obligations, as well as some of them determine period of time for which information shall be stored;

7.5.period of time necessary to protect lawful interests, including period of time necessary to review and resolve the dispute or claim, as well as period of time necessary to prove that appropriate processing was carried out and appropriate measures taken (including, to have proofs to present to appropriate competent authorities that airBaltic has complied with its lawful obligations).

8. Contact details

We work thoroughly to protect your personal data and ensure transparency of personal data processing activities. However, if any issues appear or you have questions about your data processing, please contact our Data Protection Officer. We will answer your questions regarding the use of your information at airBaltic. You can reach the Data Protection Officer by sending an e-mail to gdpr@airbaltic.com

In case of questions in field of recruitment process, then, please, contact airBaltic’s Head of Talent Acquisition and Development by sending e-mail to: careers@airbaltic.com).

Our activities in the field of personal data protection are monitored by State Data Inspectorate of the Republic of Latvia (Datu Valsts Inspekcija). Before you turn to them for advice or with a complaint, we encourage you to contact our Data Protection Officer (gdpr@airBaltic.com) to solve any misunderstandings as quickly as possible.

Contact us:
Data Protection Officer
AS Air Baltic Corporation
Marupe parish, Riga International Airport
Tehnikas 3, Latvia
LV-1053

9. Miscellaneous

This policy represents airBaltic policy as of March 28, 2022. AirBaltic may change this policy from time to time.

AirBaltic may act outside the policy only if any legal obligations arise under any law.