Here’s a Personal Information Processing Policy tailored for an aviation consulting company, compliant with international standards, including GDPR (EU), CCPA (California), and relevant aviation-specific norms. This policy is a solid starting point; however, legal counsel review is strongly recommended for implementation in specific jurisdictions.

1. Introduction:
The "Middlemist Aviation Consulting" "we", "us", or "our") is committed to protecting the personal information of our clients, partners, and stakeholders. This Personal Information Processing Policy explains how we collect, use, store, share, and protect personal data in accordance with international privacy and data protection laws, including the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), and other applicable regulations.

2. ScopeThis policy applies to all personal information processed by the Company in the course of our services, including:
  • Aviation technical consulting
  • Continuing airworthiness management (CAMO)
  • Technical audits
  • Aircraft inspections and redeliveries
  • Recruitment support for technical personnel
  • Airline certification and setup support

3. What Data We CollectWe may collect and process the following categories of personal information:
  • Identification Information: Name, company name, position/title, and nationality
  • Contact Information: Email address, telephone number, mailing address
  • Professional Data: Qualifications, certifications, resumes/CVs, employment history
  • Technical Communication: Email correspondence, project documents
  • Usage Data: Website usage, IP address, cookies, and analytics data

4. Purpose of Data CollectionWe process personal data for the following lawful purposes:
  • To provide consulting services related to aircraft maintenance, leasing, and compliance
  • To manage contracts and agreements
  • To assess and recruit technical personnel
  • To ensure compliance with aviation and data protection laws
  • To perform audits, inspections, and certification-related processes
  • To improve our services and business operations

5. Legal Basis for ProcessingWe process personal data based on:
  • The necessity to perform a contract or pre-contractual obligations
  • Legal obligations under aviation or labor laws
  • Legitimate business interests (e.g., improving services)
  • Consent (where required by law)

6. Sharing Personal DataWe may share personal data with:
  • Aviation regulatory authorities (e.g., FAA, EASA, GACA)
  • Lessors, lessees, and MRO organizations
  • Subcontractors and technical partners
  • Legal and financial advisors
  • IT and cloud service providers
All third parties are contractually obligated to maintain the confidentiality and security of your data.

7. International Data TransfersWhere data is transferred outside of the European Economic Area (EEA) or other regions with data protection laws, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) or data protection agreements.

8. Data SecurityWe implement technical and organizational measures to protect personal data, including:
  • Encrypted communications (SSL/TLS)
  • Access control and user authentication
  • Secure data storage and backup
  • Regular audits and risk assessments

9. Data RetentionWe retain personal data only as long as necessary to fulfill the purpose for which it was collected, including legal, regulatory, and contractual obligations. Data no longer required is securely deleted or anonymized.

10. Your RightsDepending on your location, you may have the following rights:
  • Right to access your personal data
  • Right to rectification of inaccurate data
  • Right to erasure ("right to be forgotten")
  • Right to restrict or object to processing
  • Right to data portability
  • Right to withdraw consent
  • Right to lodge a complaint with a data protection authority
To exercise your rights, contact us.

11. Cookies and TrackingWe use cookies and similar technologies to improve user experience on our website. Users can manage cookie preferences through their browser settings. A separate Cookie Policy is available on our website.

12. Policy UpdatesWe may update this policy from time to time to reflect changes in legal, technical, or business developments. Any updates will be posted on our website with the effective date.