Data Protection Statement for Training Participants
Please read this notice regarding the processing of your personal data, in accordance with the provisions of the European Union General Regulation 2016/679 and the Greek legislation.
This Privacy Notice sets out how we (Costamare Maritime Training Services S.A. hereafter the “Company”) may use, process, store, share and safeguard your personal information. We may get that information either from your employer or from you directly, in order to fulfill contractual obligations/to provide training courses, as detailed below.
What type of personal data we collect
Throughout our training relationship, the Company (as data controller of your personal data) may collect, process and store the following personal information about you:
1) Information required to process your enrolment application, provide training courses and issue relevant certification [name, surname, father’s name, mother’s name, gender, date of birth, place of birth, signature, passport, mobile number, rank, nationality, specialisation, seaman’s book number, photograph, date of application etc.]
2) Financial details for the issuance of relevant invoices, if payment is not effected by your employer.
3) Information about your health records (e.g. any disabilities as they appear on your seaman’s health record) is collected from your employer to the extent that it affects your performance or that it is useful to evaluate your performance during the training courses.
4) Your comments/evaluation of the training course and the trainers, your name and signature.
5) Video recording during training on bridge simulator to the extent that this is necessary to evaluate your performance in (“bridge”) simulation of real circumstances.
Why we collect your personal data (Objectives and legal basis of processing)
Any of the aforementioned data are processed in physical and electronic form for the following purposes:
1) Performance of the Company's contractual obligations i.e. enrolment, provision of training courses, evaluation of performance and issuance of relevant certificates. The legal basis for the processing is the performance of the training contract.
2) Evaluation of the company and the trainers. The legal basis for the processing is our legitimate interest to improve our business and ensure the provision of a high level of services. The video recording of the simulation exercises is performed for the evaluation of the participants in simulation of real circumstances. The legal basis for the recording is the company’s legitimate interest to provide evidence, if necessary, that evaluation has been conducted fairly and objectively.
3) Compliance with Greek laws (including taxation obligations and any other legal obligations that the Company has towards the training participants or public authorities), as well as international laws and international conventions, applicable to the maritime sector. This also includes the Company's obligation to respond in a timely and appropriate manner to financial audits and inspections and other requests for disclosure by public authorities, as well as claims and litigation management and the Company's legitimate interest in protecting the training participants and the Company’s property.
In case we need to process any additional personal data for purposes other than the ones described above, we will notify you accordingly and in advance.
Who we share this information with (Recipients of your personal data)
Potential recipients of your personal data are:
1) The Maltese Ministry of Transport only to the extent necessary for the issuance of the relevant certificates.
2) Company’s independent contractors and/or associates who receive personal data only to the extent necessary for the performance of their respective duties and/or your contract (e.g. accountants and statutory auditors, IT consultants, lawyers, private security companies, classification society).
3) Your employer who will receive copies of the certificates issued (and your evaluation) following the successful completion of the training courses.
How we protect your personal data (Storage location and period for which the personal data are stored)
All records related to training participants are stored throughout the duration of the training courses, and for such time necessary to issue the relevant certifications and for such further time as provided for by the applicable Greek and international law. They are further stored to enable the participant as well as his/her employer to obtain copies of issued certificates at later stages and to easily enrol for future courses.
In case of a dispute arising out of or in connection with the provision of the training courses, the data are held for such time necessary to lodge or defend claims and/or legal proceedings as well as for enforcement purposes.
All personal data of training participants are kept in his/her personal file (physical or electronic) and in a restricted area. The Company has taken all appropriate technical and organizational measures, according to current technological standards and applicable laws and regulations, so as to ensure that the processing of personal data is lawful, adequate and secure against any unauthorized or accidental access, disclosure, processing, erasure, modification or other unlawful use.
Your rights as data subject
You may exercise the following rights provided for in the General Data Protection Regulation at any time, by means of a written notice addressed to the Company (see "Company's contact details" below):
1) Right of access to your personal data, i.e. right to know which of your personal data are being processed, right to obtain copies of these data, as well as any other information regarding the processing.
2) Right to rectification and right to have incomplete personal data completed, (for example if you change your home address or telephone number).
3) Right to data portability, that is, the right to ask for transmission of those data to another controller that you will indicate to us. This right applies to the data where the legal basis for processing is a contract or consent (see Section 2 above).
4) Right to request data erasure (‘right to be forgotten’) and /or right to restriction of processing.
5) Right to object to the processing of your personal data.
In case you believe that your personal data are violated in any way, you have the right to lodge a complaint with the competent supervisory authority, the Personal Data Protection Authority (www.dpa.gr).
Company’s contact details:
For assistance and advice in exercising your rights, as well as for any communication regarding personal data, please contact [[email protected]].