Aberdeen International Airport Privacy Notice
How we use your information
Aberdeen International Airport Limited (known as “Aberdeen Airport”) is committed to ensuring your privacy is protected. This Privacy Notice explains how we collect information about you and how we process this information. Aberdeen Airport takes its obligations with regard to your personal information seriously.
Your personal data will be collected by Aberdeen Airport who will act as the “Data Controller”. A Data Controller determines the purposes and means of processing personal data.
Importantly, within the airport environment, other organisations may collect your personal information, for example: shops, restaurants, telecommunication providers. The personal data collected by these organisations will not be covered by this privacy notice and therefore your personal data privacy in this instance will be the responsibilities of these outlets.
The types of information Aberdeen Airport processes
The types of personal data which can be collected includes:
- National Identity (Passport Numbers)
- Telephone Numbers
- Online Identifiers (e.g. Facebook IDs.)
- 3rd Party Cookie Identifiers
- Products booked and travel schedules
- Bank or Card Details
- Flight numbers and trip purpose
- Website pages viewed and emails opened and clicked
- Details of minors or persons who are in your custody.
- Gathering visitor data to our website and e-commerce platform, which includes profiling;
Our website uses SessionCam for analysis purposes and specifically to identify any technical issues or difficulties the users of our websites are having during the customer journey. To do this, SessionCam records your mouse clicks, mouse movements and how you scroll the pages on our website. The information that we collect from web session through SessionCam does not include your personal details, financial details or any special categories of personal data. The information collected is used for internal purposes only and is used to improve the usability of our website and is stored and used only for the purposes of collecting aggregates and statistics relating to the functional performance of our websites.
The types of special categories of data collected includes:
- Biometrics for identification (e.g. photographs, CCTV images)
- Medical Information
- Personal Dietary Requirements
The purpose and legal basis of processing personal data
Aberdeen Airport will collect your personal information for specific purposes under a number of lawful methods of processing.
Aberdeen Airport will process personal information:
- for the purposes of direct marketing under opt-in consent, e.g. marketing airport destinations, holidays, products and its partners;
- gathering visitor data to our website under opt-in consent;
- for the purposes of research and surveys based upon opt-in consent;
- to provision internet services to you around the airport facilities under contract;
- for the purpose of purchasing Aberdeen Airport products or services under contract (e.g. car parking) and associated information required in the fulfilment of that transaction and for communications regarding future similar transactions with the Airport;
- for the purpose of purchases of third party services under contract. e.g. flights and wi-fi;
- to offer related information on products and services you have taken under soft-opt-in legitimate interest of the business. e.g. car parking upgrades, destinations, newsletters;
- to enable request for information, making enquiries, reports or complaints under the legitimate interest of the business;
- for publicity purposes where images are taken in places where there is no expectation of privacy. e.g. public foyer or retail spaces are under the legitimate interest of the business.
In addition, when you are transiting through Aberdeen Airport there may be further processing of personal information including, but not limited to:
- boarding card information will be collected for the purpose of access to air-side facilities under the terms of a flight contract;
- your image will be captured on CCTV, land-side and air-side and both interior and exterior to buildings for security monitoring purposes under the legitimate interest of the business;
- when making telephone calls to airport information lines, voice recording is underway to protect members of staff from malicious or abusive content;
- baggage will be scanned and images processed for the purpose of security under lawful obligations.
Where your consent has been sought, you have the right to withdraw your consent at any time.
Your personal data rights
Aberdeen Airport will respect all of your data subject rights. If we do hold information about you, we will:
- authenticate you as the data subject, or their agent;
- determine if a right can be administered;
- complete your request within 30 days; and
- communicate to you in clear and intelligible language.
These rights include, but are not limited to:
The Right of Access: at any time, you can ask for a copy of your personal information. Aberdeen Airport will respond with whether data is held or not. If data is held then a copy of the information and the required supplement notice will be offered to you.
Right of Rectification: allows you to submit changes to your records and once changes are verified, they will be amended on Aberdeen Airport records. Similarly, Aberdeen Airport will periodically request you to check your data is held accurately.
Right of Erasure: if you request your data to be erased, and there is no other lawful basis to keep your data, then it will be removed.
If you would like to exercise your data subject rights including your right of access, rectification, erasure, restriction, or objection to processing, please contact the Data Protection Officer - contact details are contained within this notice.
All personal data collected under contract or legitimate interest will be held for a period of 3 years from your last interaction with the business, or it will be removed if no other lawful method of holding your data can be determined, e.g. UK finance law.
Data collected under consent will be used until consent is withdrawn or if it is no longer useful for the purpose for which it was collected. Some data may not be removed if it involves a disproportionate effort e.g. a website image of you is held by the Google search engine.
This does not affect your rights as a data subject.
Please note: after this retention period has expired, Aberdeen Airport will be unable to reinstate the original data, offer confirmation of passage through the airport or validate a product or service you may have received, assuming the data was held in the first instance.
Failing to provide necessary personal data
Failing to provide some or all the necessary personal data may result in:
- being unable to access the air-side of the airport;
- being unable send or receive a product or service;
- not being able to access airport data services;
- not receiving related news, updates, offers or notices of events.
Sharing personal data
Aberdeen Airport will share your personal data with other organisations in order to supply products or services to you. This could include, but is not limited to, car parking, car rentals, hotels, travel companies and Wi-Fi providers.
If Aberdeen Airport shares your data on a regular basis it will perform due-diligence and hold written contracts and agreement with these organisations to legally safeguard your data.
If you have consented for us to share your data with other organisations for the purposes of direct marketing, we will keep your consent on record until it is withdrawn or the purpose of holding your data is no longer valid. On deletion of your data, Aberdeen Airport will endeavour to contact you to confirm that your information has been removed.
Transfer to international countries
Your data may be transferred internationally. If your data is transferred, Aberdeen Airport will legally safeguard your personal data by:
- transferring to the EEA countries (Members of the European Economic Area).
- transferring to an EU Adequate country, which are defined as countries outside the EU that offer adequate levels of data protection.
- transferring under “EU Model Clauses” agreement with the importing party. These are standardised contractual clauses that make specific guarantees around the transfer of personal data from EEA countries to the rest of the world.
Owing to the global nature of the internet infrastructure, the information you provide may be transferred in transit to countries outside the European Economic Area that do not have similar protections in place regarding the protection of your personal data. Where this is the case, end-to-end encryption will be employed to transmit the data securely. e.g. using industry standard data encryption (SSL or TLS) to connect to websites or using email encryption technologies.
Where Aberdeen Airport is unable to utilise legal safeguards when transferring data to a third-country, Aberdeen Airport will seek consent from you to facilitate the data transfer. This could be the case when arranging hotels and car-rentals abroad.
- Transmission: where personal data is electronically transmitted from one computing device to another over a public network an encrypted path will be used e.g. SSL. If your data is transmitted in a hard-copy format from one place to another a secure or locked method of transport will be used, suitable to the nature of the personal data.
- Storage: personal electronic records are located on servers in secure premises. If your data is required to be stored outside of the secure premises, the data will be in an encrypted format. Personal paper-based records will be stored in a locked filing cabinet in secure offices to prevent inadvertent access by unauthorised 3rd parties.
- Access: only personnel authorised by Aberdeen Airport will have access to your personal data records on a need to know basis.
- Disclosure of personal data: we do not disclose personal data unless we’re required to do so to comply with the law, under contract, have your consent, or if it is in your vital interest.
Privacy and cookies
What are cookies?
The privacy of your information is important to us and we want to keep you well informed about cookies. We shall continue to work on initiatives in relation to recent cookie legislation to ensure you have the best experience when visiting our website.
The different types of cookies we use
Aberdeen Airport use the following categories of cookies on our websites:
Strictly necessary – these cookies are essential for certain features of our websites to work e.g. when you make payments for car parking. These cookies do not record identifiable personal information and we do not need your consent to place these cookies on your device. Without these cookies some services you have asked for cannot be provided.
Performance – these cookies are used to collect anonymous information about how you use our websites. This information is used to help us improve our websites and understand how effective our adverts are. In some cases we use trusted third parties to collect this information for us but they only use the information for the purposes explained. By using our websites, you agree that we can place these types of cookies on your device.
Functionality – these cookies are used to provide services or remember settings to enhance your visit e.g. text size or other preferences. The information these cookies collect is anonymous and does not enable us to track your browsing activity on other websites. By using our websites, you agree that we can place these types of cookies on your device.
Targeting and advertising – these cookies are used by trusted third parties to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. Information contained in these cookies is anonymous and does not contain your personal information. To find out more about cookies used for targeting and advertising go to www.youronlinechoices.com and www.networkadvertising.org or contact us on our feedback page for further information about the trusted third parties we use.
If you would prefer to restrict, block or delete cookies from Aberdeen Airport and our third party advertisers, or any other website, you can use your browser to do this. Each browser is different so check the 'Help' menu of your particular browser to learn how to change your cookie preferences. If you choose to disable all cookies we cannot guarantee the performance of our websites and some features may not work as expected.
Automated decision making and profiling
The information you provided to Aberdeen Airport will be provisioned on to the Aberdeen Airport database. Aberdeen Airport systems may from time to time rely on automated decisions and perform online profiling. This does not affect your rights as a data subject.
Links to other websites
This privacy notice does not cover the links within this site linking to other websites. We encourage you to read the privacy statements on the other websites you visit.
Changes to this privacy notice
We keep our privacy notice under regular review and we will place any updates on this webpage. At the start of this privacy notice we will tell you when it was last updated.
This privacy notice does not provide exhaustive detail of all aspects of Aberdeen Airport’s collection and use of personal information, however, please contact us if you require further detail and we will be happy to provide any additional information or explanation needed.
Complaints and queries
Aberdeen Airport tries to meet the highest standards when collecting and using personal information. For this reason we take any complaints we receive about this seriously. We encourage people to bring it to our attention if they think our collection or use of personal information is unfair, misleading or inappropriate.
To make a request to Aberdeen Airport for any personal information we may hold you need to put a request in writing using the address below:
AGS Data Protection Officer
St. Andrew’s Drive,
Please reference the AGS airport concerned (Aberdeen, Glasgow, or Southampton) in your correspondence.
You have the right of redress and you are welcome to contact the Information Commissioners Office, please see: https://ico.org.uk/concerns or call the ICO on: 0303 123 1113.
Last updated: May 2018