Data Protection Notice: Cargolux’s Pilot recruitment

This Notice is intended to inform candidates who apply for a pilot position at Cargolux International Airlines S.A. Luxembourg Airport, Luxembourg (hereinafter referred to as “Cargolux” or “We/we”), and following such application, might participate in selection and training procedures (“You/you”), regarding how we process your personal data, for how long do we keep it, as well as to inform you of your rights in the quality of data subject and how you can exercise such rights.


Who is the controller of your personal data?

Cargolux will process your personal data in relation to your application and recruitment process, in the quality of data controller and in accordance with the applicable data protection legislation, especially the EU General Data Protection Regulation 2016/679 (known as “GDPR”).


What personal data do we process?

We collect and use your personal data to the extent necessary in relation to our recruitment process and to ensure that your application can be considered by the relevant Cargolux’s department(s).

In the scope of your relationship with Cargolux, we may process various types of personal information, including:

  • Identification data (such as your name, date and place of birth, nationality, ID and passport information, contact details, address, telephone, email, country, or other contact information);
  • Job application data (application form including a questionnaire, Curriculum Vitae, cover letter, previous work experience, any career gaps with supporting documents, education, training certificates, additional qualification, logbook, or other information regarding your professional qualification and experience, additional skills and abilities, professional interest, details of your right to work in the concerned country, type of employment sought, desired salary, job preferences, etc.) you provide for our consideration in the recruitment process;
  • Qualification data (e.g. level of formal qualification, licenses and medical certificates data, language skills, test and assessment results data, certificate of conduct);
  • Content data (e.g., text submissions, images, videos);
  • Results of our recruitment process, such as your performance during assessment centre, psychometric data (e.g. aptitude test results), interview, simulator screening and information provided by your referees for selection process;
  • Meta or communication data (e.g., device information, IP addresses);
  • Names and contact details of referees and knowledge of a person among our staff or management (relative or contact person).

Cargolux may also process your judicial data (e.g., criminal record certificates) and health data for the purposes of assessing your working capacity. The processing of such categories of data takes place in accordance with the applicable laws and regulations.


Why do we process your personal data (purpose and legal basis)?

We process your personal data for the following purposes:

  • To assess your skills and qualifications for the position for which you are applying.To manage the recruiting process;
  • To maintain our relationship during the recruitment process, namely, to communicate with you;
  • To verify your information, to run our internal compliance and conflict of interest checks and to conduct reference/background checks;o improve our recruitment process;
  • To defend ourselves in any legal or court proceedings;
  • To comply with applicable laws and regulations; or
  • To secure and protect our organization, IT networks and Cargolux’s information

Cargolux will only process your personal information where we have a legal basis for doing so. In the frame of the recruitment process, we process your personal data on the following basis:

As per article 6.1 b) GDPR: Taking pre-contractual measures necessary for the recruiting process, assess job applications and candidates, and to decide whether Cargolux intends to enter into an employment agreement with you;
As per article 9.2 h) GDPR: For the assessment of your working capacity pursuant to a contract with a health professional;
As per article 6.1 c) GDPR: Complying with legal obligations (namely but not limited to Commission Regulations (EU) 1178/2011, (EU) 2015/1998, (EU) 2018/1139, (EU) 2018/1042, and (EU) 2020/745 and associated implementing rules, standards, and guidance as published by EASA) and provide the required information to authorities of countries in which our operations takes place.
As per article 6.1 f) GDPR: Pursuing our legitimate interests, namely, including to manage our recruitment process, to conduct background checks to keep records of the recruitment process; to prevent conflicts of interests and confidentiality issues; to protect our interest and rights in the event of investigations; to assess and improve our recruitment processes, and/or to ensure that our company’s IT networks and information are secure.

We might process personal data of a contact person you have indicated as a point of reference. That being the case, you must ensure that the affected person was informed and has agreed to the processing of their personal data for referral purposes.


Who do we share your personal data with?

For the purposes of the recruitment process, your personal data may be shared internally, on a strict need to know basis, with: Cargolux’s selection board members, human resources department and agents involved in the recruitment process and/or training activities.

We may also communicate your personal data to:

  • Service providers/vendors that perform services on our behalf, including health professionals appointed by Cargolux;
  • Law enforcement or other government and regulatory bodies or agencies, upon request and to the extent permitted by law
  • Certain regulated professionals such as lawyers or auditors mandated by Cargolux.

Where do we transfer your personal data?

Your personal data are processed by us within the European Union and no transfer of your personal data occurs outside of the European Union/European Economic Area (EU/EEA).


How do we protect your personal data?

The processing of your personal data is carried out through IT, electronic and manual tools, with logics strictly related to the aforementioned purposes and, in any event, in compliance with the appropriate technical and organisational measures required by law to ensure a level of security that is adequate to the risk, in order to avoid unauthorised loss or access to your data.


For how long do we keep your personal data?

Unless a longer retention period is required (e.g., as necessary to defend our rights in the scope of investigations, disputes or legal claims) or permitted by law, we will retain your personal data for 2 (two) years (upon conclusion of the relevant or latest step of the selection process) and ensure that at the end of such period your personal data will be anonymized, deleted or destroyed. If required by applicable laws and regulations, or if strictly necessary in view of pursuing any of the purposes mentioned above (which might vary depending on the selection step(s) you have undergone) Cargolux may retain some limited categories of personal data for a longer period.

Note that in case you are selected for the job position you have applied for, the above categories of personal data will continue being processed as part of your employment file with Cargolux (more information will be provided to you upon the start of your employment).

Cargolux retains your personal data for no longer than necessary to fulfil the purpose for which it was collected.


What are you rights regarding your personal data?

In accordance with the applicable data protection legislation (and subject to conditions and restrictions set forth therein), you may exercise at any time the following rights in relation to your personal data

  • Right to access: which enables you to obtain from us confirmation of whether your personal data are being processed or not and, if so, obtain access to such data; considering that we process a large quantity of information, you must specify the information or processing activities to which your request relates;
  • Right to rectification: which enables you to obtain from us the correction and/or integration of any of your personal data that are incorrect and/or incomplete; and
    in certain limited cases (in which case we will analyse whether the conditions for the exercise of such rights are fulfilled, in line with GDPR):
  • Right to erasure: which enables you, in specific cases provided for by art. 17 GDPR, to obtain from us the erasure of your personal data;
    Right to restriction of processing: which enables you, in the specific cases provided for by art. 18 of the GDPR, to restrict the processing of your personal data by us;
  • Right to object: which enables you to object to the processing of your personal data when certain conditions are met;
  • Right to data portability: which enables you, in certain cases (subject, in particular, to technical feasibility) and with regard only to the data you have provided to us, to request receipt of your personal data in a structured and commonly machine-readable format.

If you have provided your consent to the processing of your personal data, you can withdraw such consent at any time, without affecting the lawfulness of processing based on consent before your withdrawal

To exercise any of these rights, you may contact us by email or by postal mail:

CARGOLUX Airlines International S.A.
Compliance Department
L-2990 Luxembourg Airport

You have the right to lodge a formal complaint with the Commission nationale pour la protection des données (CNPD).


Changes to this notice

Changes may occur in the way we process personal data. In case these changes oblige us to update this Notice, we will clearly communicate it to you through the appropriate means. The latest applicable version will always be available on our website.

Last revised on 23/08/2023