Organization data-processing agreement

Parties and scope — complete before signing

Processor: TTA s. r. o., Kvetná ulica 244/12, 930 41 Kvetoslavov, Slovakia, company ID 56573359. Controller: the organization identified in the signed training agreement. Record its legal name, address, company ID, authorized signatory and privacy contact in the schedule. This review copy is not an executed agreement.

The proposed processing covers hosting and administering assigned learning, assessments, certificates, reviewed training intervals, reports and authorized exports during the service and agreed retention period. Data subjects are learners, crew members, administrators and appointed training personnel. Data includes identity/contact details, memberships/codes, assignments/results, timestamps, certificates, signature artwork and relevant audit records. Health data and identity-document scans are not required for ordinary use and must not be uploaded without a separately assessed lawful need.

Proposed operating commitments

• TTA processes organization data on documented instructions, including any transfer instructions, and alerts the organization if an instruction appears unlawful. Legally required processing outside those instructions is notified where the law permits.
• Authorized personnel are bound by confidentiality. The agreed security annex covers role and company isolation, administrator MFA, encrypted transport, secrets, audit evidence, patching, incident handling, backup access and tested recovery.
• TTA assists the organization with rights requests, security incidents, impact assessments and regulatory consultations, considering the nature of processing and available information. Personal-data breaches are reported to the organization without undue delay, with available facts and subsequent updates.
• Subprocessors require the agreed written authorization. The signed schedule identifies their services, legal entities, processing locations and applicable transfer safeguards. Changes need notice and the agreed objection process; equivalent protection must flow down to them.
• TTA supplies evidence of compliance and cooperates with proportionate audits and competent-authority access. The contract must specify contacts and practical arrangements without frustrating regulatory access.
• At service end, TTA returns or deletes organization data as instructed, except lawful retention. The schedule states export format, handover deadline, backup expiry, protected evidence categories and final confirmation. A technical append-only record is not by itself a legal reason to keep personal data forever.

Schedule to complete together

• Approved courses, purposes, user categories and data fields; lawful bases and employee privacy notice owner; permitted integration recipients and record identifiers.
• Retention by record category, statutory basis, start of retention period, erasure/restriction procedure, archive owner and handling after employment ends.
• Hosting and email suppliers; any enabled payment/video services and their separate roles; countries and transfer mechanism where needed. No supplier is authorized merely by appearing as planned in the Privacy notice.
• Security controls actually enabled, incident contacts/escalation, recovery objectives, backup arrangements, export/exit process and agreed assistance costs. Complete and test these arrangements before real employee data is processed.

Training responsibility is separate

The organization retains control of its training programme, instructor qualifications, operational acceptance and duty compliance. TTA’s platform and data-protection obligations continue alongside that responsibility. Neither a certificate signature nor this processing agreement grants aviation approval.