GM1 ORO.FC.145(d)
Provision of training, checking and assessment
ED Decision 2022/014/R
CONFIDENTIALITY AND PROTECTION OF TRAINING DATA IN COMMERCIAL AIR TRANSPORT
(a) Without prejudice to applicable national legislation on the protection of individuals with regard to the processing of personal data, for the training conducted in accordance with ORO.FC.145 the operator may have a training data access and security policy (including the procedure to prevent disclosure of crew identity).
(b) If the operator decides to have such a policy, it should:
(1) be agreed by all parties involved (airline management and flight crew member representatives nominated either by the union or the flight crew themselves);
(2) be in line with the organisation’s safety policy in order to not make available or to not make use of the training data to attribute blame or liability.
(c) The training data access and security policy may include a policy for access to information only to specifically authorised persons identified by their position in order to perform their duties.
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