Collection of personal data

When undertaking crewing employment payroll services, our policy is to collect only the personal data necessary for agreed purposes and as required under the relevant maritime employment laws. Throughout this data collection process and the course of the business relationship we will only ask you to provide personal data with us where it is strictly needed for us to discharge our responsibilities under the relevant employment laws and to maintain our own satisfaction of your competency in your current or proposed future role.

Personal data

Where we need to process personal data to employ crew and provide payroll and insurance services, we ask our crew members to provide the necessary information as part of the employment take on process.

The following types of personal data processed by us in relation to crew employment are usually limited to:

• personal details such as name (including prior or aliases if applicable), age, date of birth, gender, residential address;
• contact details such as email address, contact number, postal address;
• financial details such as bank account, tax status and tax reference details;
• employment history such as details of prior experience and previous employers;
• languages spoken for contact purposes; and
• education details including both academic and professional qualifications.

Lawful basis: Contractual obligation, legal obligation and legitimate interest

Special categories of personal data

The following types of special categories of personal data processed by us in relation to crew employment is usually limited to:

• medical data; and
• any requirements or restrictions arising from your national, religious or political beliefs.

Lawful basis: Explicit consent

We process the medical details such as history and current health status as part of our pre-employment checks as it is in our best interest to ensure that all crew assigned to vessels are fit and healthy.

The requirement to provide details on any requirements or restrictions that form part of your national, religious or political beliefs is not mandatory and is only processed, with your explicit consent. We only request details on this in order to ensure appropriate consideration is given to you to allow you to freely express or follow any national, religious or political requirements or restrictions whilst onboard a vessel. No other forms processing will take place in regards to this particular special category of personal data.

Personal data relating to criminal convictions and offences

As part of the recruitment process we will undertake and process personal data relating to criminal convictions and offences which include background and criminal history.

We carry out criminal records checks for the following purposes:

• to ensure an individual is eligible to work for us and potentially hold the position they are applying for;
• to establish whether an applicant has committed an unlawful act or been involved in dishonesty, malpractice or other seriously improper conduct; and
• to comply with government and public sector clearance requirements.

Lawful basis: Legal obligation and legitimate interest

These checks are carried out to ensure we comply with our legal obligation to ensure an individual is eligible to work in the country and industry and are for our own legitimate interest to ensure any potential employees have no previous convictions or committed any offences.

Next of Kin and beneficiaries

We, as part of the employment take on process, obtain the following data on individuals who you appoint as your next of kin or beneficiary/ies in the event of death in service:

Next of Kin

• personal details such as name (including prior or aliases if applicable), age, date of birth, gender, residential address; and
• contact details such as email address, contact number and postal address.

Beneficiaries

• personal details such as name (including prior or aliases if applicable), age, date of birth, gender, residential address; and
• contact details such as email address, contact number and postal address.

As detailed in the Seafarer employment contract, by providing the details of a 3rd party, you confirm that you have their authority and express permission to provide us with their personal data.

Lawful basis: Legitimate interest

This data is collected and processed by us the event you are injured or other incapacitated in the course of your employment or in the event of your death in service.

The rights of next of kin and beneficiaries

Those individuals whose data we hold under the classification of next of kin and beneficiaries have the same rights as all other individuals and for more information please see the “your individual rights and how to exercise them” section.

If you believe that we may hold your data under the classification of next of kin and beneficiaries and wish to know more, please contact the Data Protection Officer here

When and how we share personal data and who we share it with – Shipping

Personal data held in by us

Where the Döhle Group is administering or providing crew management services, all of your personal data is stored on a centralised crew management system which is owned and controlled by Döhle (IOM) Ltd. This system is accessible by all shipping and crew employment and recruitment entities within the Döhle Group, details of these companies are outlined below.

Döhle (IOM) Limited is the data controller of all of the data held on the centralised system: Mariners

Access is given to each separate Döhle Group company depending on their functions and requirements. Overall management and control is maintained by Döhle (IOM) Limited.

Legal data processing agreements govern the relationship between each entity listed above and if you want any additional information the please contact the Data Protection Officer here

Personal data sent to third parties

From time to time the Döhle Group is required to provide certain information to public authorities and companies such as:

• tax and VAT authorities;
• regulatory authorities;
• crew medical providers;
• law enforcement agencies;
• insurers;
• crew travel providers;
• ship and yacht registries; and
• customs & port authorities.

Lawful basis: Legal obligation, contractual obligations and legitimate interest

We will never provide any more than the minimum data necessary to order to satisfy the requirements of the public authority or company to enable them to discharge their obligations or provide the required services or to meet the legal requirement.

When and how we share personal data and who we share it with – Yachting

Personal data held in by us

Where the Döhle Group is administering or providing crew management services, all of your personal data is stored on a centralised crew management system which is owned and controlled by Döhle Private Clients Ltd. This system is accessible by all shipping and crew employment and recruitment entities within the Döhle Group, details of these companies are outlined below.

Döhle Private Clients Ltd is the data controller of all of the data held on the centralised system: Cello

Access is given to each separate Döhle Group company depending on their functions and requirements. Overall management and control is maintained by Döhle Private Clients Ltd.

Legal data processing agreements govern the relationship between each entity listed above and if you want any additional information the please contact the Data Protection Officer here

Personal data sent to third parties

From time to time the Döhle Group has an obligation to share information with certain public authorities and companies such as:

• tax and VAT authorities;
• regulatory authorities;
• crew medical providers;
• law enforcement agencies;
• insurers;
• crew travel providers;
• ship and yacht registries; and
• customs & port authorities.

Lawful basis: Legal obligation, contractual obligations and legitimate interest

We will never provide any more than the minimum data necessary to order to satisfy the requirements of the public authority or company to enable them to discharge their obligations or provide the required services or to meet the legal requirement.

International transfers

We may share your personal data within other companies within the Döhle Group for the purposes of crew employment, payroll, insurance purposes and for the arrangement of medical and travel services.

This may involve transferring your data outside the European Economic Area (“EEA”).

In the event we do transfer your personal data outside of the EEA, we ensure a similar degree of protection is afforded to that data as is in operation in the Isle of Man and if we undertake such a transfer then we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

If the personal data is to be transferred to a country has not been deemed adequate we will ensure that sufficient mechanisms and agreements are put into place between us and the recipient of that data, making use of specific contracts and principles approved by the European Commission which give personal data the same protection it has in Europe.

If you feel you would like more information on international transfers, Please contact the Data Protection Officer here

Data retention

To determine the appropriate retention period for personal data, we consider the minimum legal requirement nature, scale and complexity of the personal data we hold and weigh this against the potential risk of harm from unauthorised use or disclosure of your personal data.

Personal data may be held for longer periods where extended retention periods are required by law or regulation and in order to establish, exercise or defend our legal rights.

Please contact the Döhle Group Data Protection Officer if you to discuss our Data retention policy with us here