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Last updated: 10th August 2023
This section of our website is designed to help you understand what we do with information about people, referred to as “personal data”.
In summary, we use personal data:
Because that is a wide range of activities, we’ve divided this privacy information into a number of different sections, reflecting the different ways you might interact with us, in order to help you get to the information you want quickly.
The data controller of your information is Gatwick Airport Limited (company number 01991018) of 5th Floor, Destinations Place, Gatwick Airport, Gatwick, West Sussex RH6 0NP, United Kingdom. If you have any questions or concerns about the information on this page, or about what we do with personal data, you should email us at dpo@gatwickairport.com, or to write to us at the above address, for the attention of the data protection officer.
What would you like to know about?
When you check-in baggage (whether via bag drop or check in desk) Gatwick Airport will allocate an identifier to your bag, and link your bag to your boarding card with that identifier. We do so to (a) ensure that your bag is loaded onto the correct aircraft; and (b) the aircraft does not take off with your bag on-board where you have not boarded the flight.
What personal data is used, and where is it obtained from?
We obtain your name, title and flight details from the barcode included on your boarding card (issued by the airline you are flying with).
We will create a record of your bag(s) and link it/them to you capturing the journey of the bag such as the scanning points, the unique baggage number, the final location it was delivered to. A scan of your baggage is also taken when you journey through security. Whilst no personal is attached to the scan, it can be indirectly identiafiable via the matching barcode attached to your boarding pass when you check your baggage in.
What is Gatwick Airport’s legal basis?
Our legal basis for ensuring your bag is loaded onto the correct aircraft is our legitimate interest of providing a service to the airline which has contracted us to do so, and in ensuring that your bag is loaded onto your flight.
Our legal basis for ensuring the aircraft does not take off with your bag on-board where you have not boarded the flight is compliance with legal obligations imposed on the airlines by the Department for Transport and Civil Aviation Authority.
Is personal data shared with anyone to achieve this purpose?
Your bag’s status/location will be shared with the airline and the airline’s contractors (such as their special assistance provider. The police may also require that this information is shared with them.
The airline already holds the other personal data, as we receive it from them via the barcode on your boarding card.
All of this personal data may be shared with the companies that operate Gatwick Airport’s baggage management system(s) so that they can perform their task, and with our IT contractors providing the technology.
How long does Gatwick Airport keep personal data for this purpose?
We keep passenger records for 30 days. After which point the personal data drops off and only the unique bag number and scanning point are left.
Facial recognition cameras are placed at the eGates before security and on reconciliation points shortly before you board a domestic flight to ensure the person boarding the plane is the same person that passed through security, and did not come directly from an international flight without passing through the UK border.
We collect two biometric images for all domestic passengers. The first is collected at the eGates as you enter security, and the second when your boarding card is scanned shortly before you board the plane.
The first image is linked to your passenger details via the barcode on your boarding card, and matched with the second image.
Where the images do not match, Gatwick Airport security staff will collect additional information to log the incident and process you manually, and in some circumstances will escalate the issue to UK Border Force.
Our legal basis is compliance with legal obligations imposed on us by UK Border Force.
Our legal basis for processing a special category of personal data (biometrics) is that the processing is in furtherance of the substantial public interest in helping to secure the border of the United Kingdom (a function conferred on us by law).
We may be required to share your information with your airline and the authorities, including UK Border Force, CAA and DfT.
All of this personal data may be shared with the companies that operate Gatwick Airport’s baggage management system(s) so that they can perform their task including, and our IT service providers.
We keep passenger records for 30 days, and biometric data for 48 hours.
We use facial recognition cameras to monitor how long it takes randomly selected passengers to pass through the immigration hall on arrival and the airport security area on departure in order to help the UK Border Force to meet its obligations immigration wait times and us to meet our legal obligations relating to security wait times.
We collect two biometric images for randomly selected passengers arriving at the immigration hall. The first image is collected upon entering the hall and the second on the immigration desk or eGate.
We collect two biometric images for randomly selected departing passengers, the first at the security eGates, and the second in the baggage reclaim area.
Our legal basis for doing this is compliance with legal obligations imposed on UK Border Force by the Home Office and on us by the Civil Aviation Authority.
Our legal basis for processing a special category of personal data (biometrics) is that the processing is in the substantial public interest (a function conferred on us by law).
Biometric images will not be shared, but aggregated statistics derived from them may be shared with UK Border Force, airlines and the Civil Aviation Authority for the purposes of performance monitoring.
We also share this personal data with our IT service providers, for instance the supplier of the biometric system.
We keep biometric data for two hours.
Gatwick Airport security personnel record the details of security related incidents, for instance someone being where they shouldn’t be or an assault, and the persons they concern.
We will collect details of any persons involved, for instance their names, characteristics and contact details – we will obtain this from the individuals concerned and or witnesses of the incident.
Details of the incident may include special categories of personal data, for instance where a crime has been committed or because a person has suffered physical or mental harm as a result.
Our legal basis is to comply with legal obligations imposed on us by the Civil Aviation Authority.
Where we process special categories of personnel data our legal basis is that the processing is in the substantial public interest (a function conferred on us by law).
Incident reports may be shared with the Civil Aviation Authority, law enforcement, security services or other public authorities.
We also share this personal data with our IT service providers, for instance our email and document storage providers.
We may also share this information on our B2B ‘Airport Community App’ which staff based onsite use to report fast time security incidents in dedicated chat groups from across the GAL campus to promote airport safety, effective working and incident response.
We will retain this personal data for 30 days.
Any information shared in the Community App will be stored for 3 months.
If we detect traces of potentially dangerous substances when you or your personal belongings are swabbed at security, Gatwick Airport security staff will ask you a number of screening questions to determine whether there is a potential threat.
We will collect your name, passport number, date of birth, nationality, flight details, contact details and the answers you give to screen questions.
This information may be shared with the Civil Aviation Authority, law enforcement, security services or other public authorities.
We will retain this personal data for up to six months.
Where you have requested assistance travelling through the airport or boarding the plane, whether from your airline or at one of the kiosks in the airport, we will collected certain personal data to allow us to provide this assistance to you.
Please note however that we provide this as a service to your airline. You should therefore read your airline’s privacy policy for more information on what personal data is processed, why and how to exercise your rights in respect of this data.
1. Gatwick Airport monitors the location of WiFi enabled devices to monitor the flow of people and to detect potential incidents.
Gatwick Airport strives not to collect personal data for this purpose. All MAC addresses (a number unique to a device) are anonymised and are not paired with other data which could reveal your identity to us.
In the unlikely event that Gatwick Airport does collect personal data, it does so on the basis of its legitimate interest in understanding the flow of people around the airport and in detecting potential incidents as soon as possible (which may be indicated by irregularities in the movement of people, for instance congregation or people moving away from an area).
MAC addresses are anonymised before sharing with anyone.
The anonymised data is retained for up to two years. Un-anonymised MAC addresses are not stored.
2. Gatwick monitors the flow of passengers through security and shares this information with (a) the police and (b) airlines and their contractors to identify if a passenger has passed through security and is likely to be able board their flight.
Every passenger scans their boarding pass when they go through the security gates at Gatwick Airport. Gatwick collects the boarding pass data (flight number, seat number and sequence number) and also the time the passenger went through security and provides it to the airlines and their contractors.
It is in Gatwick’s legitimate interests to provide this information to airlines to maintain operational efficiency. The process allows an airline to assess if their passengers have passed through security in time for them to make their way to the boarding gate.
This processing activity benefits passengers as it facilitates the decision making process behind keeping a boarding gate open to allow a passenger to board (if a passenger does have time to get from security to the boarding gate) or to close the boarding gate and prevent additional delays for the boarded passengers (if the missing passenger is too far away or has not passed through security).
This information may also be shared with the police where it is necessary for them to perform a task that is in the public interest.
Gatwick shares 1) flight number 2) sequence number, 3) seat number and 4) the time the passenger went through security with airlines and their contractors and occasionally the police. The flight number and seat number is data that the airlines and their contractors already hold for flight booking and boarding purposes. They match the data Gatwick has provided with their own data and use this information to identify which passengers have or have not yet boarded the plane.
We will retain this personal data for up to one month.
At Gatwick, we have a large number of CCTV cameras operating around the airport campus, covering staff, public and passenger areas. Including our car parks, some of which are operated by our partners Empark (known also as National Car Parks limited).
CCTV footage captures personal data in the form of moving or still images of staff, passengers, members of the public and customers. Gatwick uses CCTV and the personal data captured as part of this processing for the following purposes:
We may collect CCTV images from all the cameras around the airport. These may include static or moving images of persons as well as vehicle registration plate data (ANPR).
Occasionally these will be linked to specific individuals by name, for instance where CCTV images are downloaded in relation to a security or health and safety incident, or where we need to facilitate a data subject access access request.
Where you make an access request in relation to CCTV either as part of a Data Subject Access Request or as part of a formal request from another organisation, we will record additional information. For example, your name, contact details, address, two forms of identification including one of them photographic to prove you are the person making the request for their personal data or that you have permission to request the data on another’s behalf. If you are requesting CCTV of your vehicle, you will be required to supply proof of ownership for example a registered keeper document (V5). This will be stored on our secure data management system. If you request to view the footage on GAL premises we will also record the CCTV images you viewed and when you viewed them.
We also use Automatic Number Plate Recognition (ANPR) data from when you enter the Passenger Drop Off Scheme. You can find out more about this in the Passenger Drop Off Tab.
Our legal basis for general CCTV coverage is that we have a legitimate interest in using the system for the above purposes to protect the safety and security of the airport and its staff and passengers and to ensure operational effectiveness.
Our lawful basis for viewing and sharing CCTV for data subject access requests is in line with our legal obligation for individual rights under The Data Protection Act 2018. In the interests of national security, Gatwick will not provide footage from the following areas: any location within the security footprint, anywhere where a security process is taking place as well as the Immigration Halls and the UKBF Customs channels footprints.
In exceptional circumstances, Gatwick Airport reserves the right to deploy covert cameras for the purpose of detecting and preventing crime. This measure is taken to ensure the safety and security of all passengers, staff, and visitors within the airport premises.
CCTV images and the identify of those persons in them may be shared with the Civil Aviation Authority, law enforcement, security services or other public authorities for instance in connection with specific incidents or security reviews.
CCTV might be shared with the CAA or the Airline Operating Committee in line with our queue management and CSS reporting obligations.
Gatwick’s CCTV System is hosted within our two main data centres. Gatwick maintain all physical and virtual infrastructure via our IT and Electronics systems. This includes Cameras, cabling, storage and network equipment. External access is provided to a third party, TYCO for application support. Tyco then employ the software provider Qognify to do this.
A number of third parties also have access to the CCTV system. These are Law Enforcement Agencies such as Sussex Police, Border Force, National Crime Agency. A number of commercial third parties which have access are also DHL, British Airways, Empark and EasyJet.
We retain CCTV images for 30 days however in airport wide central search areas the retention period is 60 days, unless they are downloaded from our CCTV system within that timeframe, for instance in connection with an incident, data subject access request or to share with relevant authorities.
CCTV images downloaded from the system in connection with an incident will be retained until the investigation and any related claims have been closed. Any footage downloaded will be stored in a secure environment and only access by persons who are authorised to do so.
Personal data captured as part of the Data Subject Access Requests will be kept for a period of 2 years.
The free Wi-Fi at Gatwick Airport is operated by “Virgin Media”, and offered directly to you by them.
For more information on how Virgin Media processes personal data, please see its privacy policy, which is available by phoning 0330 660 9967.
When you book parking at a Gatwick Airport car park or book premium products online, for instance “Fast Track Security”, we will process personal data:
You can click on a link above to view more information, including what personal data we process for that purpose, our legal basis for processing it and who we share it with.
Where you book parking or a premium product, we use personal data to process and administer your booking, including: to reserve your parking/product, to send you booking confirmation, to send you service information such as expiry reminders or traffic information, to ensure your car is ready for collection (e.g. if your flight is early or late), to store your preferences for future bookings and for our internal accounting and business administration purposes.
We use your name, address, mobile phone number, email address, flight details and payment card details.
Our legal basis for processing is that this processing is necessary for us to perform our contract with you. Without this personal data, we would not be able to offering you parking or the premium products.
Is personal data shared with anyone to achieve this purpose?
Where you have booked a car parking service operated by a third party, for instance “Car & Away”, we will share your booking details with that third party so that they can perform their service.
We will also share your personal data with the third party technology providers we have engaged to operate parts of our eCommerce website and/or parking systems, but only if they need to have it in order to do their jobs for us. Examples include the companies that host our systems, our payment providers and car park operators.
We keep this personal data for six years.
When you arrive at the car park entrance, automatic number plate recognition cameras will take a picture of your car. Depending on lighting, window tinting and other conditions, that picture can incidentally include a picture of one or more of its occupants.
We use this picture to recognise your vehicle registration so we can grant you access to the car park and record the condition of your car on your arrival.
We use the same technology, for the same purposes, when you exit the car park.
We only use the photos taken by our automatic number plate recognition cameras.
To the extent we use these photos to allow you to enter and exit the car park, our legal basis is that the processing is necessary to perform our contract with you, without which we would not be able to offer you parking services.
To the extent we use these photos to record the condition of your car, our legal basis is our legitimate interest in bringing or defending legal claims.
We will share your personal data with the third party technology providers we have engaged to operate the car parks and automatic number plate recognition systems on our behalf, but only if they need to have it in order to do their jobs for us.
We may also share personal data collected by our automatic number plate recognition systems with the security services, DVLA or other relevant authorities for security purposes and detection and/or investigation of crime.
We retain the automatic number plate recognition photos for no more than six months, unless we need them in connection with a claim that has been, or we believe will be, made.
Gatwick Airport does not process personal information in relation to your shopping experience at the airport.
Where a shop within the airport scans your boarding card, they are doing so to determine whether tax is payable on the transaction, and this does not involve sharing of data by or with Gatwick Airport, as the relevant personal data is contained within the barcode itself, which is issued by your airline.
For more information on how the shops within Gatwick Airport process personal data, please see their respective privacy policies.
When you interact with our website, we may process personal data:
MyGatwick provides a convenient portal to access Gatwick Airport offers and flight notification services. When you sign up to myGatwick, we will process your personal data:
The information below explains how personal data is used to give you access to the MyGatwick members portal.
We use your name, email address and password to provide you with a myGatwick user account.
We collect this personal data directly from you.
Our legal basis is that this process is necessary for us to perform our contract with you for access to the myGatwick portal.
Without this personal data, we would not be able to provide you with access.
This personal data is shared with our IT service providers, including the company that hosts our website.
We keep this personal data until 24 months after you delete your myGatwick account (see “How does Gatwick Airport use personal data to remember you, in case you opt back in to marketing and/or newsletters at a later date?” below under “marketing and newsletters”), which you can do by contacting the Data Protection Officer using the details at the top of this page.
We will use this personal data in the same way as we use any other feedback received from the public. For more information please see “How does Gatwick Airport use personal data to manage passenger/visitor feedback?” under “customer services and community engagement” below.
The Gatwick Airport website allows you to set up email notifications about your flight.
We will use your name, email address and flight details.
We collect this information directly from you.
Our legal basis is that this process is necessary for us to perform our contract with you for provision of the flight notification service.
Without this information, we would not be able to provide this service to you.
This personal data is shared with our IT service providers, including the company that hosts our website and the company that provides us email delivery services.
We keep this personal data for one hour after your flight has landed or taken off.
The Gatwick Airport website allows anyone to log a safety incident report, although its most often used for people that work on the Gatwick Airport campus.
We will collect your name, company, incident details and any images you upload as part of the notification.
If you provide it to us, we will also use your email address, for instance to contact you for further information.
Our legal basis is that the processing is necessary in order to comply with our legal obligations in connection with security and health and safety.
We keep this personal data until the matter has been concluded.
The Gatwick Airport website allows you to reserve goods from certain shops on the airport campus for collection on your date of departure or arrival.
We will collect your name, contact details and flight details.
Our legal basis is that the processing is necessary in order to perform our contract with you for the reserve and collect service. Without this information we would not be able to provide the service to you.
Details of your order will be passed to the relevant shop.
This personal data is also shared with our IT service providers, including the company that hosts our website and our email delivery service.
We keep this personal data for 90 days after the date of collection.
Where you sign up to a newsletter via our website, we will process your personal data as set out in “How does Gatwick Airport use personal data to keep the community up-to-date on developments at the airport” under “customer services and community engagement” (for the community newsletter) or as set out in “marketing and newsletters” (for our main newsletter).
Where you enter a competition via our website, we will process your personal data as set out below.
We collect your name, email address and other contact details.
Where you enter a competition our legal basis is that the processing is necessary in order to perform our contract with you. Without this processing we would not be able to enter you into the competition.
This personal data is shared with our IT service providers, including the company that hosts our website and our email delivery service.
We will retain this personal data for 24 months after the last activity on your account (see “marketing and newsletters" section)
When you use the Gatwick Automated Chat Service (also known as Chatbot or GAIL) on WhatsApp or Apple iMessage, we will keep a record of the exchange.
When you first send a message to the service (via WhatsApp or Apple iMessage), we will obtain your telephone number. and use this to identify you and provide a response.
Our legal basis is the consent you have provided when you access the service.
We share our data with the service providers who facilitate the chat service. These will store the telephone number you provide and the conversation history for 30 days but do not share the data any further.
Gatwick will keep your telephone number and conversation history for 30 days after your last message to the service. After 30 days all personal data is deleted.
Unless you have opted-out of marketing and newsletters at the time we collected your personal data, we will use personal data to:
We use your email address to send you marketing and newsletters, and your name to address it to you.
Where provided, we may use your telephone number for marketing calls.
Our legal basis is our legitimate interest of promoting products and services available in and around Gatwick Airport.
Where we collect this personal data from you which we intend to use for sending market purposes and/or to send newsletters, we will always offer you the opportunity to opt-out of marketing.
We also allow you to unsubscribe at any point by following the instructions contained in each marketing email and newsletter we send.
We only share this personal data with our IT service providers, for instance the companies that host our marketing database and operate our email delivery system.
We will retain this personal data for 24 months after the last activity on your account (see “How does Gatwick Airport use personal data to remember you, in case you opt back in to marketing and/or newsletters at a later date?” below), but we will stop sending you marketing and newsletters when you unsubscribe.
Where you have not opted-out or unsubscribed from marketing emails and newsletters, we will use personal data to tailor marketing and newsletters to what we think you are most likely interested in.
For instance, if we know you are departing on a certain date, we might tell you about a particular promotion we have in place on that date.
This personal data may contain your personal interests, car registration number, order history, airline, flight number, flight operator, flight departure information, flight arrival information, date of flight and home address.
We collect this personal data from you during other interactions we have with you.
Our legal basis is our legitimate interest of optimising our marketing spend by showing you content that is most likely to be of interest to you, and your legitimate interest of receiving relevant marketing.
We use your name, contact details, personal interests, car registration number, order history and previous flight details, all as obtained from you during our course of dealings with you.
Our legal basis is our legitimate interest in optimising sales by remembering the details of previous recipients of marketing and/or newsletters in case they re-engage with us.
We will retain this personal data for 24 months after the last activity on your account.
We also advertise on Facebook, Instagram, and Google as well as some other online platforms. We also place adverts on other websites. We will advertise to individuals who are signed up with an online platform (such as Facebook or Google) and have consented to the relevant cookies for third party sites such as the EasyJet site . Based on what the online platform knows about them, for example, we may we may identify individuals who have booked a flight with EasyJet from London Gatwick in the last 12 months, using data from consenting third party sources. We may then serve advertisements for products and services for London Gatwick that we think may be of interest to a user via their Facebook or Instagram profile, or via relevant Google channels. These profiles are anonymised, neither us or our third party who conducts this work on our behalf, Ink Navigator see these individuals. We do not track individual responders, we only keep a tally of how many people clicked through to our webpage page and purchased a product so we understand whether our advertising is effective.
Gatwick Airport processes personal data to ensure passengers have a positive experience, and to administer community engagement projects. We use personal data to:
When you give us feedback, whether by phone, email, letter or in person, we will keep a record of it.
We will retain your name and contact details, the details of your complaint or feedback and records of what we have done about it.
Our legal basis is our legitimate interest of ensuring we take on and/or address customer feedback received, or where the matter is a complaint, to defend potential legal claims.
Where we keep records of what we have done about it that involves a financial transaction, we keep those records to comply with legal obligations imposed on us by HMRC.
We do not generally share this personal data with external recipients, but may occasionally share it with our external advisors for the purposes of obtaining advice.
We also share this personal data with our IT service providers, for instance the companies that host our website and CRM system.
We will keep this personal data for three years from the date of your complaint or feedback or, if earlier, until the matter is closed.
Gatwick Airport has an interest in keeping the community and local businesses up to date with developments at the airport.
Gatwick has a community newsletter, “Gatwick in Touch”, which it sends to subscribers quarterly.
Gatwick also runs a local supplier database where local businesses can request to be placed on the database to be contacted about upcoming work at the airport.
For the ‘Gatwick in Touch’ newsletter, we use your name, email address, postcode, telephone number, which we collect via the sign-up form on our website.
For the local supplier database Gatwick will collect the business name and personal contact name and email address, they will also collect the registered address of the company. This information is provided to Gatwick when the business requests to join the database.
Our lawful basis for the processing of your personal data in connection with ‘Gatwick in Touch’ is that you have provided your consent to receive the newsletter.
Our lawful basis for the processing of your personal data in connection with the local supplier database is you have provided your consent by requesting to be placed on the database.
For the general maintenance of the subscriber databases, we only share this personal data with our IT service providers, for instance the companies that host our market database and operate our email delivery system.
For the local supplier database, we may, depending on your wishes share your data with Tier 1 contractors who are managing large scale projects at the airport and are looking for local organisations to complete work as part of the projects.
We will retain your personal data in relation to ‘Gatwick In Touch’ for as long as you wish to receive the newsletter. You can request to be removed from the mailing list by clicking the unsubscribe button on the bottom of each newsletter.
Gatwick will retain supplier’s information on the local supplier’s database for as long as they wish to stay on there, however suppliers will be contacted every two years to see if they wish to remain on the database.
Gatwick Airport offers tours to schools and other organisations in the local area.
Before the day of the tour, Gatwick Airport requires copies of identification to be sent for each visitor, for instance passport or driving licence.
Details from your ID document will be included on your temporary security pass on the day of your visit, for instance your name and passport or driving licence number.
This will be collected via the tour organiser or directly from the individual.
Our legal basis is that this processing is necessary to comply with legal obligations imposed on us by the Civil Aviation Authority and the Department of Transport relating to security of the airport.
We share this personal data with our IT service providers, for instance the companies that host our database and operate our email delivery system
We keep this personal data for up to six months after the date of your tour.
Gatwick Airport keeps records of noise complaints it receives to respond to that complaint, for noise planning purposes and to identify and remedy regular issues (for instance that certain flights are consistently causing noise complaints).
We collect your name, contact details, location and other details regarding your noise complaint.
We obtain this personal data directly from you.
Our legal basis is that this processing is necessary to comply with legal obligations imposed on us by the Civil Aviation Authority and Department of Transport.
We may share this information with the Civil Aviation Authority and/or the Department of Transport for reporting purposes.
We may also share this personal data with our external advisors to the extent we need to in order to obtain advise from them, for instance on remediation plans.
We also share this personal data with our IT service providers, for instance the companies that host our database and operate our email delivery system.
This personal data is retained for seven years.
Gatwick Airport together with the Government and Civil Aviation Authority are working on modernising the UK airspace and engaging with the local community, airlines and other airspace users. Stakeholders will nominate a representative as the point of contact.
We collect the representative’s name, surname and contact details.
We obtain this personal data by appointment of the representative.
Our legal basis is our legitimate business interest in engaging and consulting with airspace users for the purpose of understanding how the airspace modernisation can affect and benefit all relevant stakeholders.
We may share information with the Government, Civil Aviation Authority and/or the Department of Transport in an anonymised format.
However, we may share the personal data with our agents and advisors to the extent we need to enable the agent to liaise with the nominated representative on our behalf and or to obtain advice from them.
This personal data is retained for seven years following the end of the engagement.
Where an incident occurs in or around Gatwick which does cause, or could have caused, injury to a person, we keep records of that incident in order to (a) to help us ensure that similar incidents do not happen in the future; and (b) to bring or defend legal claims.
We may collect your name, contact details, date of birth, gender, details of the incident that you were involved in and details of any injuries sustained.
Our legal basis to help us ensure that similar incidents do not re-occur is that the processing is necessary for us to comply with our legal obligations in relation to health and safety (medical records are not retained for this purpose).
Our legal basis for the purpose of bringing or defending legal claims is our legitimate interest in doing so, and where the records contain special categories of data, that the process is necessary to bring or defend legal claims.
We share this personal data with our IT service providers, for instance the suppliers of our incident tracking system, companies that host our database and operate our email delivery system.
We retain this personal data for a period of seven years.
In August 2021 Gatwick Airport announced that it intends to apply for a Development Consent Order (DCO) to obtain permission for development to increase the capacity of the airport (the Project). As part of the DCO process we will complete the following actions:
Gatwick Airport collects personal information about you when conducting its Land Referencing. Engagement Process and associated activities as part of bringing forward the Project. Gatwick Airport will use this information in line with all applicable laws concerning the protection of personal data, including the Data Protection Act 2018.
How is your personal data used?
Information obtained during the Land Referencing process will be used to carry out our legal obligations during the DCO process and to produce the required statutory documents as part of our DCO application, including the Book of Reference. The Book of Reference will be publicly available and will contain the name and address of each person or company who has an interest in any affected property and the nature of that interest, in accordance with the legal requirements of the 2008 Planning Act (as amended). The Book of Reference will not include telephone numbers or email addresses of anyone listed. We may use the details that you provide us about other interests in the property/land, such as your landlord's details, to verify and contact those interests. We will also use your information to keep you informed of the project's progress.
Gatwick will be issuing a consultation questionnaire which will be sent out to members of the public and stakeholders. When you respond to the questionnaire, you do not have to provide your personal data. However, understanding where you live in relation to the airport will help us understand your feedback. Your responses will be collated and assessed for your views relating to specific themes of concern or interest. This will then be produced into a narrative report for Gatwick and the relevant government departments to review. This will help shape the plans for the Project. We will also use the information you provide to create name badges where you attend any Engagement events and provide you with information such as meeting details and minutes of meetings that you have attended. Gatwick will also be running several telephone surgery sessions where you can discuss your views on the consultation. The questions raised in these sessions will be placed anonymously into the consultation report, however for the purpose of confirming what was said, the sessions will be recorded.
What personal data is used, and from where is it obtained?
Land Referencing
We may collect your name, trading name or organisation name, contact and address details, details of the nature of your interest in property/land, details of the use of the property/land, and details of any other interests in the land or additional information relevant to the land/property which we collect via the Land Interest Questionnaires (LIQs). We also collect information about land interest from publicly available information sources such as HM Land Registry.
Engagement Process
We may collect personal data including;
What is Gatwick Airport's legal basis?
Our legal basis for collecting and using your personal data is compliance with a legal obligation. To ensure that we can fulfil the legal requirements of the DCO process and our statutory obligations to (a) notify all parties who have a legal interest in any land that may be affected by the Project and (b) to consult with the public so that interested parties’ interests are represented in the planning process. We also have a legitimate interest’s legal basis in processing your information, for example to keep you informed of the Project's progress.
Dalcour Maclaren are working on behalf of Gatwick Airport to collate and verify information gathered for both the Land Referencing and Engagement Process. Dalcour Maclaren receive and process your personal data on our instruction and on the basis of a contractual agreement with us. They are not permitted to use your personal data for their own purposes.
In addition to Dalcour Maclaren, your personal data may be accessed by our trusted third party services providers, Newgate Consulting Limited and Traverse Limited. They will be responsible for collating the online and hard copy questionnaire responses. Traverse will be responsible for managing the online database for questionnaire responses, called Magpie. All the responses will be stored on this site and the information for the narrative report will be taken from this site. Newgate Consulting Limited will also be responsible for answering emails and queries from interested parties as well as organising telephone surgeries. Newgate Consulting may be required to share the recordings from the telephone surgeries with certain Gatwick staff if required to confirm question responses. None of these service providers will be permitted to use or share your personal data for their own purposes.
We may be required to make copies of responses to the Development Consent Order consultation available to the Secretary of State and/or the Planning Inspectorate. We will request that personal information is not placed on the public record, however, please note the Secretary of State and/or the Planning Inspectorate may use any personal information that is disclosed to them in accordance with their own privacy policies, over which we have no control. We recommend that you do not include any information in your response to the Development Consent Order that you would not want to be viewed by these third parties, or potentially to be placed on the public record.
We may also disclose your personal data to professional advisors (such as legal advisors and accountants) or auditors for the purpose of providing professional services to us.
We will retain this personal data for the duration of the DCO process and a further 10 years following granting of the DCO for the Northern Runway Project, unless otherwise required by law, so that we can continue to fulfil our legal duties and to keep relevant parties informed of the project's progress. Upon expiry of this ten year period, we will review our need to retain this information. Information made publicly available through the DCO process, including the Book of Reference, will remain available for public inspection.
We will retain this personal data for the duration of the DCO process and it will remain available for public inspection until we have completed administering our services with the Northern Runway project. Your information will be deleted once it is no longer required to support the DCO process.
Internally, Gatwick Airport only grants access to personal data to those people that need access to that data to carry out their role.
Externally, Gatwick Airport may share personal data with third parties for specific purposes, as set out in the sections above. It may also from time to time share personal data with the following categories of recipients:
Where we share personal data with service providers we will always ensure that the service provider is committed contractually to only use personal data in compliance with Gatwick Airport’s instructions and data protection law;
Gatwick Airport generally stores and processes personal data inside the European Economic Area.
However, in some circumstances its service providers may transfer personal data outside the European Economic Area.
Where they do so, Gatwick Airport requires its service providers to do so in compliance with data protection law, typically requiring them to enter into standard contractual clauses approved by the European Union as providing equivalent protection to what would be in place had the personal data remained in the European Economic Area.
We can provide more information on the non-EEA countries to which we transfer your personal data this on request.
When you apply for a role at Gatwick Airport we will use your personal data in a number of ways to process your application and provide you with a Gatwick Airport ID pass which enables you access to the Gatwick Campus upon being successful in your application.
We use personal data to:
Before a company who works on the Gatwick site is permitted to have passes issued to its personnel, we must carry out checks on that company and its signatories.
In setting you up as an authorised signatory, we use:
What is Gatwick Airport’s legal basis for this processing?
Our legal basis is that this processing is necessary to comply with a legal obligation directed upon us by the Civil Aviation Authority. The ID Centre processes are conducted in accordance and to comply with both EC300 and the DfT/CAA mandates within the Single Consolidated Direction. These mandates require a range of vetting, referencing and background checks that once successfully completed may allow the issue of an appropriate ID.
Where our processing involves the processing of special categories of personal data, our legal basis is that the processing is in the substantial public interest ( Schedule 1, part 2, section 12 (1) DPA 2018 regulatory requirements relating to unlawful acts and dishonesty).
We share this personal data with our suppliers for instance our background checking service provider and our IT service providers, including the companies that host and maintain our ID and access management systems.
We retain this data for 5 years plus 364 days past the point the pass is cancelled.
In issuing your ID card, we use:
Our legal basis is that this processing is necessary to comply with a legal obligation directed upon us by the CAA. The ID Centre processes are conducted in accordance and to comply with both EC300 and the DfT/CAA mandates within the Single Consolidated Direction. These mandates require a range of vetting, referencing and background checks that once successfully completed may allow the issue of an appropriate ID.
Where our processing involves the processing of special categories of personal data, our legal basis is that the processing is in the substantial public interest (Schedule 1, part 2, section 12 (1) DPA 2018 regulatory requirements relating to unlawful acts and dishonesty).
We share this personal data with our suppliers, and the companies that host and maintain our ID and access management systems.
We retain the personal data for 5 years plus 364 days after the pass has been cancelled.
When you enter, or attempt to enter, access restricted areas or use certain equipment, we use personal data contained in your ID pass to grant or refuse you access, and to ensure you are not in areas or operating equipment you are not entitled to be.
We may use any of the personal data associated with your ID card (see “How is personal data used to issue you with, and ensure you remain suitable to possess, a Gatwick Airport ID” above).
We share this personal data with our IT service providers, for instance the companies that host and maintain our ID and access management systems.
We retain this personal data for 5 years plus 364 days past the point the pass is cancelled.
We keep records of where your ID card is swiped on doors and to enter staff car parks to monitor trends in movement around the airport campus.
We use your name, business unit, company, employee number (obtained from your ID card), and records we generate about where and when your ID card was swiped.
Our legal basis is our legitimate interest in monitoring trends in movement around the airport campus for the purposes of identifying issues and improving the operational efficiency of the airport.
We share this personal data with our IT service providers, for instance the companies that host and maintain our ID and access management systems and our analytics service providers.
We keep records of where your ID card is swiped in order to comply with our legal obligations and to verify your location at a given time, to review conformance with the passholders contracted works, or where there is an incident or dispute.
To the extent that we are required to carry out this processing by law (restricted area access logs), our legal basis is that this processing is necessary to comply with a legal obligation imposed on us by the CAA.
We may share this personal data with your employer where they request it to verify your location at a given time, to review conformance with the passholders contracted works, or where there is an incident or dispute.
We also share this personal data with our IT service providers, for instance the companies that host and maintain our ID and access management systems and our analytics service providers.
We retain personal data for this purpose for five years plus 364 days past the point of the pass being cancelled.
Gatwick airport processes personal data to support with your application and assess your suitability for the role or number of roles at Gatwick Airport Limited.
What personal data is used and where is it obtained from?
The personal data used may vary depending on the requirements for each role however it may include your full name, address, email address, telephone number and employment history. You will provide this information when applying for the role. Right to work documents e.g. passport/visa, will need to be provided at interview stage. Bank details for payroll will be requested upon acceptance of any successful offer.
Gatwick relies on several different lawful basis’ of processing personal data for different parts of the recruitment process:
Steps to enter into a contract: needs to process your Personal Data to take steps at your request, prior to entering into a potential employment contract with you.
Legal Obligation: For certain roles, Gatwick needs to process data to ensure that it is complying with its legal obligations.
Legitimate Interest :In other cases, Gatwick Airport has a legitimate interest in processing Personal Data during and after the end of the recruitment process., including: Running the recruitment processes, responding to and defending against legal claims, maintaining and promoting equal opportunities within the workplace.
Some of the organisation’s recruitment processes are based solely on automated decision making. The automated decision-making process may result on the basis of positive discrimination (e.g. where we require a female security officer to search female passengers). In addition, as part of some of the screening of applications, we may use computer generated software to ask situational judgement questions based on the behaviours required specifically for this role, this will provide instant feedback on whether you have been successful in your application. You will be informed at the earliest opportunity if this is a requirement for the role and you are under no obligation to provide the data to the organisation; however please be aware that failure to provide the information may affect the success of your application.
Should your application progress, the organisation will collect personal data about you from third parties including information on employment background and basic criminal record checks. For some roles CTC clearance, through the Civil Aviation Authority (CAA) may also be required. Gatwick Airport Limited will only seek this information from third parties once you have been advised you have been successful and you will be informed that we are doing so. Any information shared with these third parties will be legitimate and proportionate for the purpose.
How long does Gatwick Airport keep this personal data for?
Should you not be successful in your application Gatwick Airport Limited will hold your data on file for 2 years after the end of the relevant recruitment process. If you begin an application but do not finish it, the application and profile created will remain on file for 2 years. Should you wish to remove this delete this application, you can either do this yourself within the system or by contacting dpo@gatwickairport.com.
More information is provided in the recruitment privacy notice which can be found when you begin an application for a vacancy.
For some of the roles we recruit, we use a third party to provide assistance with the recruitment process. Which uses artificial intelligence and automated decision making, by asking you a series of situational judgement questions based on behaviour specifically required for the role (via an SMS style format) and interpreting your answers, in order to create a shortlist of candidates to be considered by the recruitment team.
What personal data is used and where is it obtained?
The personal data used is captured when you submit your application and when you log on to answer the questions that are sent through to you in an SMS style format. We process the following data; email address, mobile phone number, first and last name, device ID, user ID and device type, IP and Geo lookup, Mac addresses from mobile devices, location and tracking data.
What is our lawful basis for this processing?
Our purpose in using this technology is to remove unconscious bias in Gatwick’s recruitment process in our continuing aim to create a diverse and inclusive workplace. Therefore we feel it is in our legitimate interest to invest in new technology to achieve this. Whilst we are confident in the fairness of the decision-making processes, you are entitled to have any decision made by the automated method reviewed, and should contact galrecruitment@gatwickairport.com if you wish to do so.
We use a third party called Predictive Hire to complete this work for us. Further details about how your information will be used during this process can be found at https://www.predictivehire.com/privacy-policy/.
How long is personal data kept for this purpose?
Application data is kept for a maximum of two years and Predictive Hire will also keep the data for a maximum of two years.
The law gives you certain rights in respect of the information that we hold about you. Below is a short overview of those rights.
With some exceptions designed to protect the rights of others or in respect of airport security, you have the right to a copy of the personal data that we hold about you. We may make a reasonable charge for additional copies of that data beyond the first copy, based on our administrative costs. Where the data is data that you have given to us, you have the right to receive your copy of it in a common electronic format, and to provide copies of it to other people if you wish.
You have the right to have the personal data we hold about you corrected if it is factually inaccurate. This right does not extend to matters of opinion, such as decisions which our security staff may make about your fitness to fly.
In some limited circumstances, you have the right to have personal data that we hold about you erased (the right to be forgotten”). This right is not generally available where we still have a valid legal reason to keep the data (for example, for security reasons or because we are obliged to do so by law).
You have the right to object to our processing of your personal data where we rely on “legitimate interests” as our legal basis for processing, but we may be able to continue processing if our interest outweighs your objection.
You have the right to require us to stop using your personal data to send you marketing information. If you want us to stop sending you marketing information, the quickest and most efficient way is to use the provided “unsubscribe” links in our communications (although you can contact us direct if you prefer).
You also have the right in some circumstances to request that temporary restrictions are placed on how we process your personal data, For example if you contest its accuracy or where we are processing it on the basis of our legitimate interest and you contest our assessment that our interest overrides your rights.
If we are processing your personal data on the basis of your consent, you have the right to withdraw that consent at any time, in which case we will stop that processing unless we have another legal basis on which to continue.
The easiest method of exercising your rights as set out above is to:
Please note that in order to protect your privacy, we may ask you to prove your identity before we take any steps in response to a request you have made.
Whilst we would always ask that you contact us first, you also have the right to lodge a complaint about our handling of your personal data with the Information Commissioner’s Office. You can contact them on 0303 123 1113.
To administer the Passenger Drop Off Scheme we will use some of your data to identify your vehicle in order to facilitate the scheme.
When you use the passenger drop off zone at Gatwick, you will pass through our special ANPR cameras which will capture an image in order to process the fee to be paid. These cameras will be operated by the Passenger Drop Off Scheme provider, National Car Parks (EUK) Limited (NCP).
To ensure that people do not park in dangerous positions in order to avoid the charges additional road marking, Red Route, will be implemented . These areas may also be covered by CCTV cameras which will also be operated by NCP.
We capture the Vehicle Registration Number at the time of the vehicle passing through the cameras. In order to then pay the outstanding fee, customers will provide their Full Name, Email Address, Home Address and their Credit or Debit Card details.
Those customers who are in possession of a Disability ‘ blue badge’ will be exempt from paying the fee, however they will be required to send in proof of their Blue Badge, as well as their Full Name, Telephone Number and Home Address in advance of their visit in order for their record to be updated with their fee exemption.
Staff members who are using the ‘Kiss and Fly’ route as part of their role at Gatwick will also be exempt from paying the fee. Staff will be required to provide their Full Name, Work Email Address, and Work ID number in order for their record to be updated with their fee exemption.
Gatwick will also operate a Local Commuter Scheme. This will allow a maximum of four visits to the airport a day. In order to qualify for this scheme users will have to provide evidence of their address, plus a copy of their vehicle insurance.
It is in Gatwick Airport’s legitimate interest to collect personal data to operate this scheme in order to generate revenue for the airport and share this data with NCP This will enable us to ensure that there is an accurate recording of the vehicles travelling through the location and that the customers identity is confirmed.
Our legal basis to process the Blue Badge disability pass information is A.6 GDPR Consent and A.9 GDPR Explicit Consent as the individual has opted to take part in the exemption process.
Our Legal basis to process staff and other airport employees is a legitimate interest to ensure that staff who work on the Gatwick Campus are exempted from the fee charge.
Gatwick Airport is working with NCP to manage the Passenger Drop off Scheme, Local Commuter Scheme and Red Route CCTV cameras on our behalf.
Personal data is kept for 30 days for paid records. Where the fee is not paid, records may be kept until the pursuit of unpaid fees has been resolved.
For airport employees and Local Commuter Scheme, the data will be held for as long as the participant wishes to be part of the scheme. Blue Badge information will be held until 30 days after the planned visit to the airport.
Where you book parking, or a premium service product (such as "Fast Track Security"), we use personal data to process and administer your booking, including: to reserve your parking/product, to send your booking confirmation, to send you service information such as expiry reminders or traffic information, to ensure your car is ready for collection (e.g. for Valet Parking if your flight is early or late), to store your preferences for future bookings and for our internal accounting and business administration purposes.