Privacy notice – employees

Privacy notice – employees

Lufthansa Services Thailand is committed to protecting the privacy and security of your personal data. When we collect personal data, we are obliged legally to provide you with certain information, it is called the “Right to be Informed”. That information is contained in the below Notice.

This Notice applies to all employees, temporary employee, student in internship. It basically describes how we collect and use personal data about you during and after your working relationship with us, in accordance with data protection law, including the general data protection regulation (GDPR). It does not form part of any contract of employment. We may update this notice at any time.

We encourage you to read this notice carefully, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are aware of how and why we are using such information.

If any of the information we provide to you is not clear enough, there is a contact detail for Lufthansa Services Thailand’s data protection team further down this notice. Please do not hesitate to make contact and ask for further information.

We need all the categories of your data in the list below to enable us to perform our role as employer, to enable us to comply with legal obligations, or where it is necessary to do so in the public interest.

The situations in which we will process your personal data are listed below.

  • Making a decision about your recruitment or appointment.
  • Determining the terms on which you work for us.
  • Checking you are legally entitled to work in Thailand and to provide you with the security clearance appropriate for your role.
  • Paying you and, if you are an employee, deducting tax and Social Insurance contributions.
  • Providing information about changes to your employment such as promotions, changing in working hours.
  • General administration of the contract we have entered into with you.
  • Business management and planning, including accounting and auditing Conducting performance reviews, managing performance and determining performance requirements.
  • Making decisions about salary reviews and compensation.
  • Assessing qualifications for a particular job or task, including decisions about promotions.
  • Gathering evidence and any other steps relating to possible grievance or disciplinary matters and associated hearings.
  • Making decisions about your continued employment or engagement.
  • Making arrangements for the termination of our working relationship.
  • Education, training and development requirements.
  • Dealing with legal disputes involving you, or other employees, workers and contractors including accidents at work.
  • Ascertaining your fitness to work, managing sickness absence.
  • Complying with health and safety obligations.
  • Preventing fraud.
  • Monitoring your business and personal use of our information and communication systems to ensure compliance with our IT policies.
  • Ensuring network and information security, including preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution.
  • Conducting data analytics studies to review and better understand employee retention and attrition rateEqual opportunities monitoring.

Some of the purposes will overlap and there can be several grounds which justify our use of your personal data

We directly collect personal data about you through the application and recruitment process. We may sometimes collect additional information from third parties including former employers, credit reference agencies and/or other background credit agencies.

Examples of categories of personal data which we hold:

  • Personal details such as name, surname, title etc.
  • Contact details such as telephone numbers, address and email address as well as contact details of relatives/person in case of emergency
  • Dates of birth, gender, marital status and dependents
  • Copy of Personal Identification Card, Passport
  • Bank account details, payroll records and tax status information.
  • Salary, annual leave and benefits information
  • Start date, leaving date
  • Location of employment or workplace
  • Copy of driving license
  • Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process)
  • Transcription, school and university certificate
  • Full employment records including contract, terms and conditions, job titles, work history, working hours, promotion, absences, attendances, training records and professional memberships
  • Compensation history
  • Performance and appraisal information
  • Disciplinary information
  • Photographs

We will also collect, store and use the following “special categories” of more sensitive personal information:

  • Fingerprint
  • Information about your health, including any medical condition, health and sickness records
  • Information about your race or ethnicity and religious beliefs
  • Information about criminal convictions/allegations and offences

We consider the processing of your personal data for these purposes to be necessary for:

  • The performance of our contractual obligations with you (for example, to provide you with a contract, to pay you in accordance with your contract and to administer benefit and pension entitlements) and your contractual obligations to us, and to enable both you and the University to exercise rights under our contract.
  • To comply with our legal obligations (for example, to check your entitlement to work in the Thailand, to deduct tax, to comply with health and safety laws, to enable you to take periods of leave to which you are entitled, equal opportunities monitoring) or regulatory obligations (for example, reporting to Government or governmental bodies).
  • The performance of tasks we carry out in the public interest (for example, teaching and research).
  • The legitimate interests of the company or external third parties (for example, to enable your access to external services).

We will use your particularly sensitive personal data in the following ways:

  • We will use your Fingerprint for our time attendance and payroll purpose only.
  • We will use data relating to leave of absence; this can include sickness absence or family related leave, to comply with employment and other laws.
  • We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits.
  • We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
  • We will only collect information about criminal convictions or allegations of criminal behavior where it is appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions/allegations as part of the recruitment process or if we are notified of such information directly by you in the course of you working for us.

Within the company, your data is shared with only those staff who need access to deliver and support the purposes described above.

We will share your personal data with third parties where required by law, where it is necessary administer the working relationship with you or where it is in the public interest to do so. This will, in some circumstances, involve sharing special categories of personal data and, where relevant, data about criminal convictions/allegations.

Where it is legally required or necessary (and it complies with data protection law) we may share personal data about you with:

  • Previous employers, individual referees and external peers: to obtain references
  • Thai Royal Police Department: to obtain necessary criminal records checks when required
  • Agencies and contractors where there are legitimate reasons for their receiving the information including service providers, i.e. our insurers and external legal and financial advisers.
  • Government departments and agencies where we have a statutory obligation or other legal basis to provide information i.e. Airport of Thailand (AOT), Thai Revenue Department etc.
  • Internal and external auditors i.e. PLP Auditing Office, Airline auditors etc.
  • Reference requests from banks, mortgage companies etc.

We do not share your data with external organizations for marketing their products or services. We do not sell your personal data to third parties under any circumstances, or permit third parties to sell on the data we have shared with them.

We will store your data only in Personal File (P-File), in electronic form including in Computer or/and external hard disk.

In general, we will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Therefore, the data held by us from the application process will be retained as part of your Personal File for the duration of your employment plus 6 years following the end of your employment.

Details of retention periods for different aspects of your personal data are available in our retention policy. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we will anonymize your personal data so that it can no longer be associated with you, in which case we will use such information without further notice to you. Once you have no longer working relationship with us, we will securely destroy your personal data in accordance with our data retention policy or applicable laws and regulations.

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your working relationship with us.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

  • Request access to your personal information. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing Request the transfer of your personal information to another party.​

If you have any questions, or wish to contact us and ask us to look at your rights at any time, please contact us at:


Lufthansa Services Thailand