This privacy notice tells you what to expect when Heathrow Airport Ltd (“Heathrow”) collects personal information about you when you use the services of the Heathrow ID Pass Scheme. Heathrow is committed to protecting your personal information when you use Heathrow services. Whenever you provide such information we are legally obliged to use your information in line with all applicable laws concerning the protection of personal data, including the General Data Protection Regulation in the United Kingdom (UK GDPR) and Data Protection Act 2018.
Please click on each heading below to expand the section.
Personal data that we hold includes:
On occasion we may also receive data from other UK based Airports for on-going pass management.
Where your employer is processing your data for their own purposes and vetting your suitability to work, you will need to refer to their privacy notice.
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: -
The regulatory justification for collecting and using your personal data is necessary for the performance of the Heathrow ID Pass scheme under aviation security requirements, 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:
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
If you would like to complain about the service you received, please contact us via our online complaints form.
If you would like to make a data-privacy related complaint, please contact us at privacy@heathrow.com or our online complaints form.
Should you find our response unsatisfactory, you have the right to lodge a complaint with the supervisory authority – the Information Commission. You can find more information on the Information Commission's website at https://ico.org.uk/concerns/ regarding the complaints process.
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
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.
