This privacy statement explains how we collect, store and use your personal information. The term “we” in this privacy notice refers to Airways Corporation of New Zealand Limited (“Airways”), a company registered in New Zealand with company number 331446, with registered offices at Level 2, 6Leonard Isitt Drive, Auckland, 2022, New Zealand.
Privacy laws including the New Zealand Privacy Act 2020 and the General Data Protection Regulation require us to tell you certain things about the personal information we use to provide the SureSelect service. As such, this Privacy Statement is intended to meet our obligations under Information Privacy Principle 3 of the New Zealand Privacy Act 2020, and Articles 13 and 14 of EU Regulation 2016/679 (The GDPR), and the UK GDPR as implemented by UK Data Protection Act 2018, in relation to SureSelect.
As we take our obligations under these Privacy laws seriously, we would like to explain what personal information we collect and how we use and share it. We will also explain the way we store and protect personal information, your rights in relation to that personal information and how our website processes personal information.
SureSelect test candidates
Airways provides the SureSelect service to entities (“our Clients”) that recruit candidates for air traffic controller training and employment. When you apply for a role with one of our Clients, they will share your name and email address with us so that we can contact you to arrange for candidate testing. Some Clients may also share age and gender data which will be used in line with the use of demographic data below. Our contact with you may include sending reminder emails if you have not taken the test within the expected timeframe set by our Client.
We will also assign you with a reference number so that we can distinguish you from other candidates with the same or a similar name. We do not receive any other personal information about you from our Clients.
When you take a SureSelect test, you will be given the option to provide demographic information about yourself. That information is voluntary, and your decision whether to provide that information or not will have any bearing on the SureSelect test that you take, your score or success. It will not be shared with our Client or any other party and will be used solely for the purpose of improving the development of future SureSelect tests.
We also collect information about the device that you use to take the test. This information includes device screen size, the web browser being used, and whether you’re using a desktop or mobile device. The purpose of collecting this information is to ensure that your screen will display the test properly. We also collect the device’s IP address to identify and mitigate against attempts to cheat on the test.
When you take a SureSelect test we collect your test responses which are used to generate your test score. We retain a copy of your responses and scores, and we retain them on behalf of our Client. We share your scores with them, as well as information about whether you have started and completed each test.
After you have taken a SureSelect test we will retain your contact information, test responses and scores at the direction of our Clients, for the purpose of managing re-testing, evaluating and improving test effectiveness, and identifying and mitigating against attempts to cheat on tests.
We will also make an anonymised copy of your test responses and scores for the purpose of improving the quality, effectiveness and accuracy of future tests.
We will not share your personal information with any party other than the Client to whom you have applied for testing. The only exception to this is sharing that is necessary in relation to our own legal obligations, which may include sharing with our own professional advisers, or law enforcement and regulatory bodies.
Prospective and current clients
Details about how we collect and use personal information about prospective and current clients can be found on the Airways main privacy notice.
Your personal information will be held in Australia, and will be subject to legal protections that are equivalent to the level of privacy and security protection required under the New Zealand Privacy Act, and the EU and UK General Data Protection Regulations. This level of protection is ensured through both contractual assurances with our clients and suppliers, and our compliance with all applicable privacy laws.
The period that we retain test candidates’ personal information for is determined by our Clients. We will not hold your personal information for any longer than required by our Clients, and at the conclusion of that period your personal information will be returned to them or securely destroyed.
Personal information about our Clients will be held for the duration of our contract with each Client, plus the minimum period thereafter that is necessary to meet any contractual obligations that survive the termination of the contract, and any ongoing legal risks thereafter.
We do not use automated decision making in relation to the content of the tests that you are required to complete. The type of test(s) that candidates are required to take is determined by our Client to whom you have applied for testing, and the questions that comprise each test are randomly selected for each type of test. We do not use automated decision-making in relation to your test responses or scores. Once you have completed your test our Client will use your score to determine how your application with them will be processed.
The SureSelect tests are comprised of questions that test any combination of your short-term memory, spatial and verbal reasoning, cognitive ability, behavioural traits and work preferences. Your score will be ranked against an anonymised norm group, and your score relative to the distribution of scores in that group will be provided to our Client.
Your responses to the tests and your overall scores are considered personal information about you, and in some jurisdictions the process of testing and scoring your performance against a norm group may be deemed to amount to profiling. Under the GDPR, profiling includes “any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work.”
The consequences of scoring and analysing your test performance will be determined solely by the Client to whom you have applied, and are likely to include a decision whether to progress your application for air traffic controller selection, training or employment. Any questions or complaints that you have about the use of your test scores and any related such profiling should be directed to the Client to whom you have applied.
The SureSelect tests are developed and validated by qualified professionals, including occupational psychologists, in accordance with recognised psychometric standards to ensure reliability, validity, and fairness. All candidates applying for the same role complete tests with comparable question types. Demographic data, where provided, is used solely for norm calibration and never for discriminatory purposes. Candidates may request information about how their scores were derived by contacting us at the details provided below.
We make limited use of cookie-like technologies for the purpose of ensuring that the right test is being matched with the right candidate. We do not use cookies for the purpose of tracking candidates across sessions, and we do not use them for the purpose of marketing, advertising or any similar type of activity in relation to test candidates.
For information about how we use cookies and similar tracking technologies on our website, please visit the Airways privacy notice.
If you are a SureSelect test candidate, then the fulfilment of our contractual agreement with our Clients forms the lawful basis for collecting and processing your personal information. When we anonymise your test results and scores we rely on our own legitimate business interests. These interests include accurate test scoring and future test development.
If you are a current business contact, then we collect and use personal information about you for the purpose of managing the services we provide to our Clients. The lawful basis for doing so is our legitimate business interests in maintaining effective business relationships with our Clients and suppliers, including effective contract management, operational efficiency such as invoicing, and risk management activities including compliance, legal and audit activities and any other form of internal or external reporting obligations.
When we contact existing or prospective clients for the purpose of marketing and business development the lawful basis for doing so is our legitimate business interest in promoting our products and services, customer relationship management, market research and strategy and brand awareness and reputation building.
You can ask for a copy of the personal information that we hold about you at any time. If you think that information is inaccurate then you are entitled to ask for it to be corrected. You are entitled to ask for your personal information to be deleted, or that we stop using it, and in relation to any profiling, you are entitled to object to profiling, ask that it is subject to human intervention, or challenge the outcome of the profiling.
We only use your personal information at the direction of our Clients, so any of the above requests should be directed to the Client to whom you have applied in the first instance.
Please note that any request to stop processing your personal information or to delete it may affect your application for training, recruitment, or employment with our Client, subject to their applicable processes. Any questions or concerns about this should be raised with our Client. Any concerns that are raised by you directly with us will be passed to our Client for a response.
