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Privacy Policy

Belfast City Airport Data Privacy Notice

At BCA we take your privacy seriously and we are committed to protecting your personal data. We aim to be clear about how we use personal data and this privacy notice will inform you as to how we look after your personal data, what personal data we process and why. It includes the relevant requirements of the General Data Protection Regulation. It applies to your visit of our website (regardless of where you visit it from), as well as when you book to stay in our official, on site car parks or use or WiFi at BCA and when you sign up to receiving marketing communications from us. 

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice. It will give you information about:

  1. Who we are and who is responsible for your personal data
  2. Where you can contact us if you have any questions about how your personal data is processed by us 
  3. What types of personal data we process and where we get that personal data from
  4. How we use your personal data and what our legal basis for doing so is 
  5. Who we disclose your personal data to and why 
  6. Whether we transfer any of your data internationally 
  7. How we store your data securely 
  8. How long we hold your personal data for 
  9. Your rights and how you go about raising a query or concern 
  10. Data sharing agreement with Tourism NI – for free wifi sponsorship
  11. Automated Processing – Generative AI Model Trial
  12. Community Attitudes Survey Privacy Notice
  13. Glossary 

Changes to This Data Protection Notice

Like any business, our business will change over time and so will the way we use and protect your personal data. As a result, we may need to make changes to this General Data Protection Notice. These changes will not reduce your rights or the level of protection we apply to your personal information. The most up to date General Data Protection Notice will always be published on our website and we will clearly identify the changes we have made in any updates. 

1. Important information and who we are

This privacy notice aims to give you information on how BCA collects and processes your personal data through your dealings with us, including your use of this website, any data you may provide when you visit our website, any data you provide to book or  use one of our official, on-site carparks,  any data you provide when signing up to our WiFi Terms of Use and/or any data you provide when subscribing to our newsletter. 

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them. 

Controller

BCA is the controller and responsible for your personal data (collectively referred to as " BCA", "we", "us" or "our" in this privacy notice). When we refer to BCA we mean:

Belfast City Airport Limited 

Company Number:  NI16363

Registered Address: Sydenham Bypass, Belfast BT3 9JH

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. Where you can contact us if you have any questions about how your personal data is processed by us

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager on [email protected]

3. What types of personal data we process, where we get that personal data from

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). 

You may give us information about you by filling in forms on our site http://www.belfastcityairport.com/ or ("our site"), by signing up to use BCA WiFi and/or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you sign up to use BCA WiFi or when you use our site, including to search for flights, make a booking, participate in discussion boards or other social media functions, enter a competition, promotion or survey, and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, personal description, vehicle registration and photograph. 

We may need to collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you.
  • Technical Data includes internet protocol (IP) address and other technology on the devices you use to access this website. 
  • Marketing and Communications Data includes your preferences in receiving marketing from us.

We also collect, use and share Aggregated Data such as statistical data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice. 

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) unless we have your explicit consent to do so. Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time. 

How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in online or offline forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • book to use the official, on-site car parks at BCA;
  • sign up to our WiFi terms and conditions when at BCA; 
  • request marketing to be sent to you;
  • subscribe to our newsletter;
  • enter a competition, promotion or survey; or
  • give us some feedback. 
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by clicking on ‘unsubscribe links’ provided within any of our email marketing communications or by contacting [email protected]

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at [email protected] if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. 

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

(a) Identity 

(b) Contact

Performance of a contract with you

To process and deliver your booking including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity 

(b) Contact 

(c) Financial 

(d) Transaction 

(e) Marketing and Communications

 

(a) Performance of a contract with you 

(b) Necessary for our legitimate interests 

To manage our relationship with you which will include:

(a) Notify you about information relevant to your booking with us; 

(b) Notifying you about changes to our terms or privacy policy

(c) Asking you to leave a review or take a survey

(a) Identity 

(b) Contact 

(c) Profile 

(d) Marketing and Communications

(e) Financial

(a) Performance of a contract with you 

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity 

(b) Contact 

(c) Profile 

(d) Usage 

(e) Marketing and Communications

(a) Performance of a contract with you 

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)  

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity 

(b) Contact 

(c) Profile 

(d) Usage 

(e) Marketing and Communications 

(f) Technical 

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Identity 

(b) Contact 

(c) Profile 

(d) Usage 

(e) Marketing and Communications 

(f) Technical

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about services that may be of interest to you

(a) Identity 

(b) Contact 

(c) Technical 

(d) Usage 

(e) Profile 

Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional offers from us 

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). 

You will receive marketing communications from us if you have requested information from us or purchased or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing 

We will get your express opt-in consent before we share your personal data with any company outside BCA for marketing purposes. For example, when you enter competitions which we are running with third party companies, you will be asked to tick a box to confirm you wish to receive marketing communications from us as well as a second box to confirm you wish to receive marketing communications from the third party company. Where you have agreed to receive marketing material from us, we may send you carefully selected promotions on offer at BCA which may feature third party products or services but when you receive these communications from us we can assure you that we have not shared your data with the third party featured in the advertisement you receive from us. 

Opting out

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us [email protected] at any time. Marketing messages include the airport eZine communications.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website www.belfastcityairport.com  may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

Change of purpose 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose and in line with GDPR. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at [email protected]

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Who we disclose your personal data to and why

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

Category Agent/Service Provider

Details 

Law enforcement agencies

 

  • Police
  • Other law enforcement agencies

Agents/Service Providers

 

  • Solicitors (panel and third party)
  • IT Systems providers
  • Telecoms companies

Third party companies, i.e. airlines

  • When you have entered a competition we are running with a third party your personal details may be shared in the event you win the prize. 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

Where possible we will not transfer data outside of the UK, but if we host services to perform functions on this website, we will not transfer your personal data outside the European Economic Area (EEA).

7. How we store your data securely

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us at [email protected]

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. 

9. What rights you have in relation to your personal data and how you can exercise these rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights: 

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). Address: Information Commissioner's Office
3rd Floor, 14 Cromac Place, Belfast, BT7 2JB  Tel: 028 9027 8757 or 0303 123 1114 Email: [email protected].

We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance at [email protected]. When we receive a complaint from a person we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.

We will only use the personal information we collect to process the complaint and to check on the level of service we provide. 

We usually must disclose the complainant’s identity to whoever the complaint is about. This is inevitable where, for example, the accuracy of a person’s record is in dispute. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis.

We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for two years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.

Similarly, where enquiries are submitted to BCA we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide

You have the right to:

  • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. 
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at [email protected]

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. 

10. Data Sharing agreement – TOURISM NI and Belfast City Airport – Free WIFI Sponsorship

Data Sharing Agreement: George Best Belfast City Airport and Tourism NI have entered into an agreement for data sharing in exchange for branded sponsorship of the Belfast City Airport Free Wifi service provided in the Terminal. This agreement provides a discrete list of informational fields that are captured in the registration portal for access to the wifi only. These can be found below. This agreement will also provide email addresses used to register for the purposes of tracking and marketing performance for Tourism NI (TNI). 

As a result of this agreement, Tourism NI will be able to directly email your provided email with marketing information, as will George Best Belfast City Airport as normal. 

You can withdraw your consent at any time, through direct email to [email protected] to withdraw consent from GBBCA marketing, or to [email protected] to withdraw from marketing from Tourism NI (TNI). 

  1. The basic fields of data being shared as part of this agreement are limited to the following only:
    1. First Name,
    2. Last Name,
    3. Title,
    4. Age Range,
    5. Device Type,
    6. Email address used to register,
    7. The privacy policy agreed to
    8. The consent statements ticked,
    9. The dates they agreed to those consents.

11. Automated processing – Generative AI Model Trial

Purpose
BCA has partnered with Amazon Web Services (AWS) for cloud services and to enhance its business via new technologies. As part of this work, BCA is trialling a generative Ai to handle information requests to the “Contact Us” form. This will allow easier, more uniform responses to all requests made to the operations team here at Belfast City Airport. 

Scope
Currently the form data submitted will be supplied to the AWS Generative AI model. This includes the following data: 

  • Email Address
  • Phone Number

It will also submit the content of the form in plain text. 

This generative AI model will then assess against our bank of FAQ answers, and generate a response, which will be issued back via an email from BCA.

Hosting

The AWS environment is hosted here with the UK in a London Data Centre. 

Right to Object

All submitters of the form have the right to object to automated processing. To accommodate this during the purposes of the trial please email citing your subject line and the request to object to this automated processing to [email protected].  This will then ensure your data is not processed by the Generative AI model. 

Right to Erasure

After submitting your data, you have the right to request erasure. BCA will endeavour to respond to these requests within 30 days. If you wish to have your data erased from the Generative AI model then please email this request to [email protected].

12. Community attitudes survey privacy notice

Purpose: Belfast City Airport has commissioned SYSTRA Ltd (“SYSTRA”) to undertake a quantitative survey to understand how residents of Northern Ireland feel about where they live. The survey will be administered by post, with an option to complete online if preferred.

Your personal data:

The processing of personal data, including special category data, is governed by the UK General Data Protection Regulation (“GDPR”), and associated legislation including but not limited to the Data Protection Act 2018.

Belfast City Airport is Data Controller for the data collected through this research.  This means they have decided how your personal data is processed and for what purposes.

SYSTRA is the Data Processer, and are responsible for collecting, storing and processing personal data for this study. SYSTRA is Cyber Essentials (certificate number: 2d028a97-7187-4ef9-842e-f52f6639db60) and ISO20252 accredited (certificate number: 9208368).

Ayda is a sub-Processer, who will be responsible for administering the prize draw.

Scope:

The survey asks about attitudes towards factors impacting the quality of life in the residential area, current noise levels in the local environment, views about living near an airport, as well as demographic information. Demographic information includes partial postcode, gender, age, household income and household composition.  For those opting into the prize draw, name and email address will also be requested. Questions are optional and contact details will not be linked to any other responses. 

Ayda will also re-collect email address if a participant opts for a voucher or Paypal incentive, or bank details if they opt for a direct bank transfer option. This personal data will not be provided to SYSTRA. 

Why is it being collected:

To understand how residents feel about where they live.  In particular, to understand attitudes towards noise, including aircraft noise as well as noise from other sources, to monitor any changes in attitudes over the years.

We are processing the below personal data, requested within the survey, to understand residents’ views: 

  1. Demographic information to understand the profile of respondents.  
  2. Partial postcode to understand where responses are being received from across Northern Ireland. 
  3. Contact details (name and email address) to administer the optional prize draw. 

Legal basis for processing

This activity operates on the following lawful basis: Article 6(1)(f) Legitimate interest. 

However, we will also request your consent.

Usage:

Belfast City Airport have commissioned SYSTRA to collect, process and analyse the data from these surveys and have specifically highlighted the areas for processing. 

The demographic data captured within the surveys will be analysed anonymously with all other participant data to understand views towards the local environment.  SYSTRA will report the findings of the surveys to Belfast City Airport.  No individual will be made identifiable during reporting.

Anonymised data captured within the surveys will be shared only with Belfast City Airport and no other third party. 

Reports will not contain any personal data. 

Data will be stored in the EU. 

Prize Draw:

To incentivise participation in the survey, BCA will be offering a prize draw to win a first prize of £500 or ten runner- up prizes of £50.  Contact details (name and email address) for those opting into the prize draw will be used to inform winners.  

The contact details of the prize draw winners held by SYSTRA for administering the prize draw will be shared with Ayda (a sub-processor of Systra) and no other third party. 

Data will be uploaded to Ayda incentives platform

 

Data Retention Schedule: 

We keep your personal data for no longer than reasonably necessary. SYSTRA will retain data until 6th December 2024, after which it will be securely destroyed. 

Ayda will also comply with the above timeline as for administering the Prize Draw, and all personal data from this survey will be destroyed by the 6th of December 2024. 

Your rights and your personal data   

You have the following rights with respect to your personal data:

  • The right to request a copy of your personal data which SYSTRA holds about you; 
  • The right to request that SYSTRA corrects any personal data if it is found to be inaccurate or out of date;  
  • The right to withdraw your agreement to the processing at any time;
  • The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
  • The right to object to the processing of personal data; and
  • The right to lodge a complaint with the Information Commissioners Office.

Contact Details

If you would like:

  1. Any more information about the use of your data;
  2. To request to see the personal data held on you; 
  3. To exercise any other of the rights listed above:

Please contact the SYSTRA research manager, Efrosyni Theocharous, [email protected] 

You may also contact Belfast City Airport directly, regarding the processing of your data, by emailing [email protected]  

13. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at [email protected]

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

This Privacy Notice was last modified on 7th July 2024

 

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