When processing your personal data for Smarter Airports’s purposes, Smarter Airports acts as a data controller.
Smarter Airports is an international organisation with legal entities in several countries. The entity responsible for the processing of your personal data (the data controller) thus depends on which entity you are working with.
Smarter Airports A/S
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Some of your personal data may be shared internally within the Smarter Airports, but only if it is necessary in order to fulfil the purpose of which we are processing your personal data. All entities in the Smarter Airports Group have entered into an Intra Group Agreement that ensures that everyone follows the same procedures when processing personal data so the same level of security is maintained throughout.
Smarter Airports only process personal data where a specific and legitimate purpose exists. Below we have listed the most relevant purposes for Smarter Airports’s processing of personal data and some of the activities associated herewith:
Applications and recruitment:
E.g. applicants applying for a job (whether solicited or non-solicited), potential candidates participating in various events (whether socially or academically), candidates contacting Smarter Airports with the purpose of hiring (whether as a regular employee or freelancer), entering and participating in Smarter Airports’s recruitment process and when participating in job interviews and/or personality tests.
E.g. when operating and managing the IT and communications systems, managing product and service development, buying various goods and items from suppliers, improving products and services, managing company assets, allocating company assets and human resources, strategic planning, project management, business continuity, compilation of audit trails and other reporting tools, maintaining records relating to manufacturing and other business activities, maintaining security of premises, budgeting, financial management and reporting, communications, managing mergers, acquisitions, and reorganisation or disposals.
E.g. when facilitating communication with employees, use of photographs in newsletters and other material distributed within Smarter Airports and to partner entities and subsidiaries, providing references, ensuring business continuity, protecting the health and safety of employees and others, safeguarding IT-infrastructure, office equipment and other property, facilitating communication in an emergency, publication of contact information and pictures on our website.
E.g. when monitoring compliance with internal policies or applicable laws, complying with legal and other requirements, such as income tax and national insurance deductions, recordkeeping and reporting obligations, conducting audits, compliance with government inspections and other requests from government or other public or regulatory authorities, responding to legal process such as subpoenas, pursuing legal rights and remedies, defending litigation and managing any internal complaints or claim and complying with internal policies and procedures.
Smarter Airports processes personal data that is provided to us by either you, our business partners or customers etc. Usually, that amounts to the processing of some of the following categories of personal data e.g.:
Sensitive personal data is defined as:
Generally, Smarter Airports does not process sensitive personal data. However, in connection with an application, we may ask for a criminal record to be provided.
We may collect personal data from the following source(s):
Smarter Airports hereby explicitly notifies that there is video surveillance at the entries of our premises.
We process personal data on the following legal grounds pursuant to the GDPR:
Consent (article 6.1.a):
E.g. when you provide Smarter Airports with the relevant personal data directly or you provide Smarter Airports with your explicit consent to obtain such personal data.
Necessary for the performance of the contract between you and Smarter Airports (article 6.1.b):
E.g. when it is necessary for Smarter Airports to comply with a contractual obligation.
Necessary for Smarter Airports to comply with a legal obligation (article 6.1.c):
E.g. when Smarter Airports must comply with laws on bookkeeping and financial reporting etc.
Necessary for the pursuit of legitimate purposes of Smarter Airports (article 6.1.f):
E.g. when Smarter Airports stores contact information in our CRM system to handle client relations.
Necessary for the purpose of carrying out obligations in the field of employment, social security and social protection (article 9.2.b):
E.g. when Smarter Airports must comply with employment laws etc.
Necessary for the establishment, exercise or defence of legal claims (article 9.2.f):
E.g. in cases where it is necessary for Smarter Airports to either establish, exercise or defence legal claims.
Smarter Airports only shares your personal data to the extent that it is necessary in order to fulfil the purposes with the processing or if required by law. In such cases, we might share your personal data with:
Certain recipients process personal data on behalf of Smarter Airports (data processors) and may only process your personal data in accordance with the instructions given by Smarter Airports. These third parties may not process your personal data for their own purposes.
To the extent that Smarter Airports disclose or transfer personal data to third parties who may use your personal data for their own purposes (joint data controllers), such disclosure or transfer will only take place if it is in accordance with applicable law or with prior consent given from you.
Smarter Airports generally refrains from transferring personal data to countries outside the EU/EEA. Should the transfer be necessary, the transfer will, however, only take place if there is a legal basis for the transfer in accordance with the GDPR as set out below:
We only store personal data for as long as it is necessary in order to fulfil the purposes of the processing, unless there are specific legal reasons, and/or a legal requirement that stipulates a longer storage period.
As such personal data obtained in connection with applications and recruitment will as a main rule be deleted after 12 months from the receiving of the candidate’s application.
As a data subject you have certain rights, which are listed and further described below. Smarter Airports takes all necessary and adequate measures to protect your personal data and ensure your rights as a data subject.
Your rights as a data subject includes the right to:
Please note that certain exceptions to the enforcement of your rights may apply e.g. if it is necessary for compliance with legal obligations and/or for the establishment, exercise or defence of a legal claim.
Exercising your rights
You may take steps to exercise your rights by contacting Smarter Airports. You can find the contact information under section 16.
Please note, that there may be other conditions or limitations on your rights as a data subject than stated above, depending on the specific circumstances.
When the processing of your personal data is based on your consent, you may withdraw your consent at any time by contacting Smarter Airports. However, please note that this does not affect the legal basis for Smarter Airports's processing of your personal data prior to the withdrawal of your consent.
If you wish to file a complaint regarding Smarter Airports’s processing of your personal data, you can always contact Smarter Airports. All complaints filed should be resolved, if, however, this is not the case, you can file a complaint to the local data protection supervisory authority.
Danish Data Protection Agency (Datatilsynet)