International Association of Machinists and Aerospace Workers, District 141
Effective Date: March 1, 2020
The purpose for gathering your personal data:
With the Pledge to Inform Campaign, we are building a voluntary national reporting system that will allow us to inform each other of potential COVID-19 outbreaks that could impact our workplaces. In all other cases, we will collect your information for the purposes of contacting you and to conduct union representation on your behalf.
What you are agreeing to:
By voluntarily participating in any IAMAW District 141 program, you agree that any personally identifying information or data can be used, accessed, recorded and broadcast by agents of IAMAW District 141 and its affiliates and all other agents or members working on its behalf. You agree to hold District 141 of the International Association of Machinists and Aerospace Workers blameless for any issues arising from the collection, broadcast, recording or any other use of your personal data, including health-related data voluntarily submitted by you to any of our agents, affiliates or members. Once you provide health-related or personal data of any kind to us for any reason, you agree to forgo any legal action, court action against District 141, its affiliates or members. You also agree not to attempt to exact any penalty whatsoever for any use of that data.
Sources of Personal Data
We collect Personal Data about you in the following ways:
When you send it to us:
/// When you provide such information directly to us, and
/// When Personal Data about you is automatically collected in connection with your use of our Services.
Other website plugins and add-ons, such as those that are used to determine which of our website pages get the most traffic, what times visitors tend to come to our site, and which browsers or devices they tend to prefer.
Personal Data We Collect
We collect and process of the following types of Personal Data about you: Personal Identifiers:
We collect personal identifiers from you and your device such as your name (optional), email address (optional), phone number (optional), a user name and password to access our sites and services, IP address, device ID, location (zip code) and other identifiers including your work area, company and days off. Note that providing your name and phone number is required for us to communicate with you. We also collect your IP address (All of the foregoing, “Personal Identifiers.”)
We process Personal Identifiers for the purposes of providing you the Services and developing, improving, promoting and running the Services. For example, we share some of these personal identifiers with Assistant General Chairs of IAMAW District 141 and possibly your employer, if it is determined that this is necessary for any reason. Any sharing of information with your employer will be done for the purposes of protecting your rights, your employment and advancing your interests and that of the union.
We may ask for your feedback and opinions and we may conduct other surveys. We may also send you information about new services or communications which we hope will be helpful to you and help you understand the actions of the overall union better.
In the event that we are collecting information intended to halt the spread of COVID-19, we may also ask for information related to your employment habits, for example the location of your work area, nearby breakrooms and restrooms, days off and other potentially identifying information. This information must be given to us voluntarily by you, and you agree that it should be broadcast, communicated and otherwise disseminated at our discretion.
Health data and other protected classification characteristics:
Through our Pledge to Inform and other programs, you may choose to submit health-related information about yourself, such as your gender identity, your age, your height, weight and information about your health, pre-existing conditions and symptoms (including your body temperature). You may also submit your COVID-19 test status and details of any treatment, whether you are a healthcare worker and your use of protective equipment, and visits to hospitals or clinics. This includes symptoms related to COVID-19, such as fever and cough. (All of the foregoing, “Health Data and Other Protected Classifications”)
We process Health Data and Other Protected Classifications for the following purposes:
- To become aware of, track, identify and/or learn about potential outbreaks of COVID-19 in the commercial aviation industry
- To track the spread of COVID-19 in commercial aviation
- To advance scientific research into the links between patient’s health and their response to infection by COVID-19
- To identify the exposure of airline workers to COVID-19
- To provide you with the Services
- In the future, we may use this data to help healthcare providers such as hospitals, companies, and others support sick individuals
- To alert our union of potential risks associated with COVID-19
Personal Data of Children
Sharing of Personal Data
Third-party processors: We use third parties to process some of your Personal Data on our behalf, for example, security and fraud prevention providers, hosting and other technology and communications providers, analytics providers, and staff augmentation and contract personnel. When we allow them access to your data, we do not permit them to use it for their own purposes. We do not consent to any knowing collection of any data related in any way to District 141, the IAMAW, or any member or agent thereof for any purposes not related to the direct mission of our union. This list is not comprehensive and is not intended to describe all possible third-party involvement with which your personal data could be shared. This list is only intended to describe a few of the potential third parties that may access some portion of your personal data.
These processors include:
- Google Cloud Platform
- Google Analytics
- Google G Suite
Research Partners and Other Third Parties:
Research Partners: The purpose of our Services is to understand and prevent the spread of COVID-19. In order to do this, we share data with people doing health research, for example, people working in:
- Health charities
- Other research institutions
We may also share your personal data with safety programs at our member airlines, such as United, American, Philippine, Spirit, and Hawaiian, their related safety programs, and other agents and representatives.
Institutions we share data with include (without limitation – examples only):
The Centers for Disease Control
The IAMAW District 141 Safety Department and any other division, agent or member of said district
Transfer: We may restructure how we provide the Services, and as part of that, your Personal Data may be transferred to one of our affiliates or to a not-for-profit organization.
Data Security and Retention
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the Internet or storing data is completely secure. We cannot guarantee the complete security of any data you share with us, and except as expressly required by law, we are not responsible for the theft, destruction, loss or inadvertent disclosure of your information or content.
We are unable today to set any particular time limit on the storage of your sensitive personal data, but we will keep it under regular review and ensure that it is not kept longer than is necessary. By way of example, we currently collect your name so that we are able to pass this on to health care professionals if it is necessary to protect your vital interests or the vital interests of another person. Once this is no longer required, we will delete all names from our records. In contrast, data about the spread of the virus is likely to be extremely valuable for researchers studying both this virus and in understanding epidemic spread for the future. We are likely, therefore, to retain this information for much longer
In some cases, we retain Personal Data for longer if doing so is necessary
We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
California Resident Rights
legal obligations, resolve disputes or is otherwise required by applicable law, rule or
to comply with our regulation. W California privacy law requires us to provide the following information, even though we do not sell your data:
You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. We will provide you with the following information, if we are able to do so without meaningful disruption to our ongoing operations:
- The categories of Personal Data that we have collected about you.
- The categories of sources from which that Personal Data was collected.
- The business or commercial purpose for collecting or selling your Personal Data.
- The categories of third parties with whom we have shared your Personal Data.
- The specific pieces of Personal Data that we have collected about you.
If we have disclosed your specific Personal Data for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipients.
You have the right to request that we delete the Personal Data that we have collected from you.
Exercising Your Rights
To exercise the rights described above, you must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate, and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify you and complete your request. You do not need an account to submit a Valid Request.
We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
You may submit a Valid Request using the following methods:
Email us at: info@IAM141.org
Personal Data Sales
We do not sell your Personal Data.
We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA
We will not discriminate against you for exercising your rights under the CCPA.
Other State Law Privacy Rights
California Resident Rights
We will not provide your Personal Data to third parties for such third parties’ direct marketing purposes;
Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support Do Not Track requests at this time. To find out more about “Do Not Track,” you can visit www.allaboutdnt.com.
Nevada Resident Rights
Nevada law requires the following wording even though we do not sell your data: If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at info@IAM141.org with the subject line “Nevada Do Not Sell Request” and providing us with your name. We do not sell your Personal Data as defined in Nevada Revised Statutes Chapter 603A.
European Union Data Subject Rights
You may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.
For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information relating to an identifiable person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage, and disclosure. District 141 and the IAMAW will be the controller of your Personal Data processed in connection with the Services.
Personal Data Use and Processing Grounds
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent and our “legitimate interests” or the legitimate interest of others, as further described below.
Legitimate Interests: Our legal basis for processing your Personal Identifiers is our legitimate interest in providing you the Services and developing, improving, marketing and running the Services.
Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection. Specifically, we process the category of Health Data and Other Protected Classifications based on your consent. Because of the tight regulatory requirements placed on us, we need your consent to process data about your health, which means that if you do not consent (or withdraw your consent), we cannot allow you to use the app. This is not meant unkindly, we are simply not able to provide you with the service without your consent.
If you wish us to stop processing Health Data and Other Protected Classifications, you may withdraw your consent at any time by emailing us at info@IAM141.org When you withdraw your consent, we will do our best to delete all Health Data and Other Protected Classifications we hold about you.
Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.
EU Data Subject Rights
Under the GDPR you have a number of important rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at info@IAM141.org. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
- Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by logging on to your account.
- Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.
- Erasure: You can request that we erase some or all of your Personal Data from our systems.
- Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
- Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
- Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
- Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the United Kingdom Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please email, call or write to our data protection officer using the contact details given below.
The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/make-a-complaint/your-personal-information- concerns/ or telephone: +44 0303 123 1113.
Transfers of Personal Data
IAMAW District Lodge 141
1771 Commerce Drive, Suite 103
Elk Grove Village, IL 60007-2139
1 (847) 640-2222
Data Protection Officer: Info@IAM141.org