ID Centre Privacy Notice

Personal data that we hold includes:

• Name
• Gender
• Date of birth
• Country of birth
• Nationality
• National Insurance number
• Primary contact details
• Corporate contact details
• Identity document details
• Employment details
• Career history
• Qualifications
• Reference information, including all relevant communication
• Criminal record details
• Other information

On occasion we may also receive data from other UK based Airports for on-going pass management.

Heathrow is committed to collecting and using personal information responsibly, securely and fairly. The information provided to us would be used for the following purposes: -

• To check the eligibility and suitability of applicants to hold an airport ID Pass;
• To administer the airport ID pass scheme in accordance with regulatory requirements;
• To manage and record access to the security restricted areas;
• To manage and record access to the controlled areas and facilities; 
• To investigate allegations of misuse of airport ID passes and misconduct at work;
• To prevent and detect crime and for the purposes of national security; and
• To research into airport surface access opportunities

The regulatory justification for collecting and using your personal data is necessary for the performance of the Heathrow ID Pass scheme, which you contractually enter. To fulfil these purposes, we may need to disclose information to employers, our trusted third-party organisations, the Police and government agencies. They will only use the personal information provided by us for these purposes and in some instances, this may require information to be transferred overseas, but we will always ensure the disclosure is legitimate and proportionate for processing.

Please be advised, due to the security and sensitive nature of the undertakings of our critical systems and the Airport, the Heathrow ID Centre does not share procedural processes.

However, Heathrow ID pass holders do not have the authority to share their ID image in any format or on any platform, without the explicit permission of the Heathrow ID Centre. As Airport IDs should not be used in conjunction for verification or proof of ID outside of their intended purpose.

We keep personal information in line with our retention procedures, which is often a minimum of the length of employment, plus 6 years. We keep details on pass holders for no longer than is necessary. Information will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.

There will be circumstances where we may disclose your personal information without your consent, e.g. where we are required by law to disclose information, or where the information is required to prevent or detect a crime. In the case of all disclosures, we will always ensure the disclosure is legitimate and proportionate for the purpose.

We will not transfer or disclose your personal information other than: as identified in this Privacy Notice, to our trusted third party suppliers, to the police, tribunals, courts, regulators, or other authorities to assist them with their investigations or requests or for us to report security incidents or suspected or actual unlawful acts and/or as may be otherwise required by law. 

Under the General Data Protection Regulation, you have the right to:

• Access your personal data by making a subject access request, where this is justified
• Rectification of your information, where this is justified
• Data portability, where this is justified
• Erasure – where this is applicable
• Restriction of processing – where this is applicable
• Object to processing – where this is applicable

To exercise your rights, please contact the Heathrow Data Protection Officer in order to make a Subject Access Request or have any questions in relation to data protection using the following contact details:

Email: privacy@heathrow.com or by mailing:

Data Protection Officer
Heathrow Airport Limited
The Compass Centre
Nelson Road
Hounslow
Middlesex
TW6 2GW
Email:privacy@heathrow.com

A new era has begun for the UK and EU now that the Brexit transition period is over. From time to time we may process personal data from EU residents. Whenever applicable, we have appointed an EU Representative to ensure that we continuously process your personal data in compliance with applicable laws and without undermining your statutory rights.

You can contact our EU Representative at HeathrowEURepresentative@eversheds-sutherland.com and write EU Representative as subject matter. You may also contact our EU Representative per post mail at:

Eversheds Sutherland Netherlands B.V.
Attn. EU Representative Heathrow Airport
Fascinatio Boulevard 212
Floor 2A
3065 WB Rotterdam
 

Heathrow 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.

If you are not satisfied with how Heathrow has addressed your query, or if you have further concerns, you may contact the Information Commissioner’s Office which is the UK’s independent authority set up to uphold information rights in the public interest, promoting openness by public bodies and data privacy for individuals. The postal addresses for various ICO offices may be found on the ICO website. 

The ICO can be contacted via telephone on 0303 123 1113 or by using the ICO website at ico.org.uk/make-a-complaint/.

We will keep this privacy notice under regular review and we will place any updates here. At the start of this privacy notice we will tell you when it was last updated.