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Personal Data Privacy Policy

Personal Data Privacy Policy


  1. Introduction


This Personal Data Privacy Policy (“Privacy Policy”) applies to personal data which Hong Kong Aircraft Engineering Company Limited  (“HAECO”, “us” or “we”) processes about you in any form (whether electronic or written) from the start of your job application until termination of your employment, or as required by applicable law.


HAECO is committed to the policy of respecting and safeguarding the data privacy of its staff, including job applicants, current staff and ex-staff, in line with the requirements under applicable data protection laws and this Privacy Policy by collecting, holding, processing and using their employment-related personal data in a lawful and fair manner.


  1. Personal Data Collected


The term ‘personal data’ in this Privacy Policy refers to information which identifies or is capable to identify an individual. To the extent allowed by applicable law, we process the following types of personal data from time to time: individual’s personal particulars (such as name, gender, date of birth, nationality, passport or other personal identification number), contact information (such as telephone number, mailing address or email address), salary and benefits data, qualification records, performance-related data, health-related data (for determining suitability for particular job requirements at the request of the staff and for processing staff medical benefits at the request of the staff), etc.


Most of the personal data we process is information you have provided to us. In some cases, we process personal data we are able to infer about you based on other information you provide to us or on our interactions with you, or personal data about you that we receive from a third party with your knowledge.


You might provide us with special categories of personal data, meaning personal data from which we can determine or infer an individual’s racial or ethnic origin, political opinions, religious beliefs or other beliefs of a similar nature, membership of a trade union, physical or mental health or condition, sexual life, information concerning the commission or alleged commission of a criminal offence. HAECO may only collect such special categories of personal data to the extent permitted by applicable law.


  1. Purposes and Legal Bases for Processing


3.1.      These personal data will be used for specified, explicit and legitimate purposes as described in this Privacy Policy and will not be processed in a manner that is incompatible with those purposes.


To the extent allowed by applicable law, we use personal data for the following purposes:

A. Manpower planning;
B. Staff recruitment and employment;
C. Salary and benefit administration;
D. Administration of staff movement;
E. Staff training and development;
F. Performance and career management;
G. Maintaining staff’s health;
H. Staff relations and communications;
I. Detecting and preventing fraud and other illegal activities;
J. For airport security purposes; and
K. Complying with applicable laws and statutory requirements, including judicial or administrative orders regarding individual employees.


 In view of processing activity A to F, HAECO relies on the legal basis that the processing of personal data is necessary for the performance of your agreement with HAECO. In view of processing activity G to I, HAECO processes personal data for the purpose of its legitimate interests such as enabling employees to work in a healthy environment and to prevent fraud. When using personal data to serve HAECO’s legitimate interest, we will always balance your rights and interests in the protection of your personal data against HAECO’s rights and interests. In view of processing activity J to K, HAECO relies on the legal basis that the processing of personal data is necessary for the compliance with legal obligations to which HAECO is subject. HAECO will rely on the legal basis of consent when this is required by applicable law.


3.2.      It is the responsibility of every staff to provide their personal data from time to time for the above purposes. Failure of the individual to provide the required personal data may result in HAECO being unable to fulfil these purposes.


  1. Security and Accuracy of Personal Data


4.1.      HAECO takes all reasonably practicable steps to ensure that personal data, whether kept in staff files, computer systems, audio/video systems or other forms, are kept confidential and are handled by authorized persons only.


4.2.      HAECO strives to maintain the personal data collected or retained as accurate as possible. It is, however, also the responsibility of individual staff to ensure that the data they provide are accurate and notify HAECO of any changes in their personal data that may occur from time to time.


  1. Transfer of Personal Data


5.1.      HAECO may provide staff’s personal data to any authorized persons within HAECO and/or to any subsidiary/associate or jointly controlled companies for any employment-related purposes.


5.2.      HAECO may also disclose staff’s personal data to any outside parties under a duty of confidentiality to HAECO including, but not limited to, any government departments, bankers, auditors, insurance companies, actuaries, trustees, and any agents, consultants, contractors, service providers appointed by HAECO, or competent authorities for the purposes of human resources or payroll administration, or medical, housing, retirement and other benefits scheme administration or other legitimate purposes.

The transmission of personal data as described in this Privacy Policy may include overseas transfers of personal data to countries whose data protection laws are not as comprehensive as those of the countries within the EU. Where required by European law, HAECO only transfers personal data to recipients offering an adequate level of data protection. In these situations, as may be required, we make contractual arrangements to ensure that your personal data is still protected in line with European standards. You can ask us to see a copy of these contractual agreements using the contact details below.


  1. Access to and Correction of Personal Data


Staff has the right to ascertain whether HAECO holds personal data relating to them, to obtain a copy of that data, and to correct any data that is not accurate. Staff who would like to make a request for correction should fill in the prescribed form (obtainable from the Human Resources Department) and return it to the Human Resources Department. Any data access and correction request should be made in writing to the Human Resources Department. HAECO may, under certain circumstances as permitted by the applicable law, charge a reasonable fee for the processing of any data access request. Furthermore, staff has the right to enforce the right of erasure of personal data or restriction of processing, or to object to processing as well as to enforce the right to data portability by writing to us at the mailing address below or by contacting us at dpo@haeco.com. Please note that HAECO may not disclose data that you are not entitled to receive under applicable laws, or delete, rectify, or block personal data which internal policies or applicable mandatory laws oblige us to keep. Where the processing is based on consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before withdrawal.


  1. Storage of personal data


HAECO will retain your personal data for as long as we deem it necessary for the performance of your agreement with HAECO, to comply with applicable law, resolve disputes with any party and otherwise as necessary to allow us to provide employment related services, and to detect and prevent fraud or other illegal activities.


  1. Enquiries


Hong Kong Aircraft Engineering Company Limited controls the processing of personal data as described in this Privacy Policy. If you have any questions about this Privacy Policy or about the processing of your personal data, please contact us at dpo@haeco.com or write to us at the below mailing address:


The Data Protection Officer
Hong Kong Aircraft Engineering Company Limited
80 South Perimeter Road
Hong Kong International Airport
Hong Kong


You may also contact your local data protection authority.


  1. This Privacy Policy may be amended from time to time. You will be able to see when we last updated the Privacy Policy because we will include a revision date at the bottom of the document. Please review this Privacy Policy from time to time to check whether we have made any changes to the way in which we use your personal data. We will take reasonable steps to inform you of changes that will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you.


This Privacy Policy is written in English language and translated into Chinese. In the event of any inconsistency between the English version and the Chinese translated version of this Privacy Policy, the English version shall prevail.




Human Resources Department

Revision Date: 8 January 2020

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