How Spirit processes your Personal Data
How Spirit processes your Personal Data
Privacy Statement
26th April 2023
Welcome to Concourse, a web-based employee communication tool. By accessing this tool, you agree to provide your Personal Data to Spirit (as defined below) and that your Personal Data may be used, accessed, stored, and processed according to this Privacy Statement.
Our commitment
Spirit and all its business segments, divisions, and subsidiaries (collectively “Spirit”, “we” or “our”) are committed to conducting business in a way that complies with applicable data protection laws and regulations in every country in which Spirit operates. These laws govern the collection, storage, processing, and use of Personal Data.
What is Personal Data?
For the purposes of this Privacy Statement, Personal Data means any information about an identifiable individual (“Personal Data”).
Personal Data we collect and obtain
To facilitate Spirit’s communication with its employees, the following Personal Data will be preloaded in the system for you:-
- Name
- Spirit email
- Spirit ID
- Job title
- Organizational unit
- Division
- Work address
- Building
- Mail code
- Time zone
- Manager details
- Hire date
- Year of birth
- Last 4 digits of your government issued ID
When you first access Concourse, you should be able to use single sign on to log in. There will also be the option of setting up an account using your Spirit ID and a password. If you decide to set up an account this way, you will have to provide the following Personal Data:-
- Spirit ID
- Password
You will then be prompted to answer the following challenge questions:-
- Spirit ID
- Year of birth
- Last 4 digits of your government issued ID
While not required to enable you to use Concourse, you can choose to add or update other information such as your display name, your date of birth, preferred pronouns, and preferred language to your Concourse profile.
The Personal Data mentioned above will be saved on your Concourse account which you can access via either single sign-on or your email address and password.
Certain posts within Concourse may be set up to allow comments. If you choose to do comment on a post, your comments and your preferred name will be available to all Concourse users.
Why we collect Personal Data
We collect and use Personal Data in Concourse to:-
- facilitate employee communication at Spirit
- determine the effectiveness of communications using Concourse through anonymized, analytical reports generated by Concourse including but not limited to reports detailing of the number of accounts created, employee usage of Concourse, and the number of likes a post receives.
Legal basis for the use of your Personal Data
We process your Personal Data in Concourse based on legitimate interests
With whom we share Personal Data
Your Personal Data will be shared internally with the following:-
- The Communication team at Spirit who administers the system and sends out communications through Concourse
- Other Spirit employees who have been granted access to Concourse to send communications to employees in their part of the organization
Your Personal Data may also be shared externally with:-
- Concourse and its third-party sub-processors
- Contractors who support Spirit’s internal staff e.g., staff augmentation for a role that requires access to Concourse data or IT support that we outsource to 3rd parties
- Government agencies or third parties if relevant to an investigation or litigation
How we protect Personal Data within Spirit
Only Spirit employees or external contractors hired by Spirit, who are bound by confidentiality obligations, will be able to access your Personal Data.
Spirit has internal policies and controls in place to prevent your Personal Data from being lost, accidentally destroyed, misused, unintentionally disclosed, or accessed by individuals not covered in “With whom we share Personal Data” section above. Spirit employees are requested to comply with data protection laws and familiarize themselves with Spirit’s Information Security policies around security and acceptable use of IT systems and equipment.
International Transfers of Personal Data
We operate in the United States and in other countries in which the privacy laws may not be as comprehensive as those in your country of residence or citizenship. We transfer Personal Data of individuals located in the UK and the European Economic Area to the United States for storage and processing.
Please take note that your Personal Data will be stored in the US by Concourse.
Automated Decision-Making
Concourse will make decisions on how best to communicate with you in order to optimize your user experience considering the campaign itself, your current campaign queue, and the history of your engagement with Concourse.
How long is Personal Data retained
We are committed to ensuring that Personal Data is only retained for the length of time necessary to fulfil the purpose(s) for which it was collected or the minimum retention requirement as prescribed by applicable laws, whichever is greater.
Your rights over your Personal Data
You may have certain rights regarding your Personal Data as set forth in data privacy legislation applicable to your location. This could include the following rights to:
- access your Personal Data
- rectify the Personal Data we hold about you
- erase your Personal Data
- restrict our use of your Personal Data
- object to our use of your Personal Data
- receive your Personal Data in a usable electronic format and transmit it to a third party (right to data portability)
- lodge a complaint with your local data protection authority
If you would like to exercise any of these rights, please notify Spirit by sending us an email at: CorporatePrivacy@spiritaero.com. Following receipt of your request, a representative of Spirit will follow-up with you in a timely manner.
How to contact us
If you have any questions or suggestions about this Privacy Statement or about how we use your Personal Data, please contact our privacy team at CorporatePrivacy@spiritaero.com.
Please let us know if you are unhappy with how we use your Personal Data. Our privacy team will respond to your complaint within thirty (30) days.
Changes to this Privacy Statement
You can view this Privacy Statement at any time via Concourse.
Should we elect to change this Privacy Statement, we will post the changes here, so please check this page from time to time to ensure that you are informed of any changes.
