What are Responsibility, Confidentiality, and Privacy in Aviation Safety Management
In aviation safety management, responsibility, confidentiality, and privacy are the triad that affect how you handle reported safety information. Whether your organization is large or small, your leadership team needs to discuss these factors and decide how to handle them.
Your organization may decide that it doesn’t need to pay particular attention to this triad, or it may draft several pieces of formal documentation and policies about them. Either way, what is important is that as an aviation service provider:
- You know where your company stands on each item;
- Your stance on the triad matches company goals; and
- Your stance on the triad is consistent with your partners and clients needs.
Here is what responsibility, transparency, and confidentiality are in aviation safety management, and how your organization should handle each one.
What is Confidentiality in Aviation Safety Management
Confidentiality in aviation Safety Management is how much personal information is included in available safety reports and other safety concerns. In other words, when reviewing safety reports/publications how much information should employees know about:
- What people were involved;
- What departments were involved;
- What teams were involved; and
- What [you fill in the blank for identifying parties] were involved.
Confidentiality is about identifying information. Who do you want or not want to be identified? Identifying information can be:
- Direct – you know what party was involved because they were named specifically
- Names of people
- Name of department
- Name of team/contractor
- Indirect – you know what party was involved based on implication
- Location information
- Equipment/aircraft/vehicle involved (consider situation where only one party has access to piece of equipment/aircraft – naming it would imply who was involved)
How to Handle Confidentiality in Aviation Safety Management
Leadership in your aviation SMS need to take a stance on confidentiality. It could be anything from:
- Leadership agreeing that they don’t care much about confidentiality; to
- Leadership drafting a formal confidentiality policy.
Either way, there are several factors that affect what stance you organization takes regarding confidential information, including:
- The size of your company;
- What type of aviation service provider you are – your confidentiality stance should be on par with your clients
- Do you work with sensitive clients?
- Do you work with government?
- Do you provide public service
- Existing Norms and safety culture in your organization;
- Company posture on safety transparency;
- Roles, responsibilities, and access to information;
- If you want information kept from auditors; and
- What personal information you are comfortable with including in safety reports.
To structure your stance on confidentiality, you need to consider these factors.
What is Transparency in Aviation Safety Management
Transparency in aviation safety management is about how much safety information access employees have. Whereas confidentiality is concerned more with privacy and identifying information, transparency is how much of types of information specific roles in your company can see.
Transparency affects things like whether or not:
- Employees can view other reports submitted in their division/department;
- Employees can view other reports submitted in their company;
- Employees can view what actions and decisions have been made on a reported concern;
- How they are notified of submitted issues;
- Who manages highly sensitive and confidential issues; and
- How involved employees are in change management.
Different Levels of Transparency
Aviation safety management systems with range from:
- Low transparency – Employees have very limited access to reported information, for example:
- Front line employees can only see issues they report
- Employees cannot see specific actions taken on issues unless management notifies them
- Strict user roles hierarchy in the SMS for view/management/access privileges
- Non-management employees have very little involvement in change management
- High transparency – employees have a lot of access to most reporting information, for example
- Front line employees can see most issues reported in their division/company
- Employees can see actions taken on reported issues
- Some user role hierarchy, either documented or an “informal” hierarchy
- Employees are notified of changes and may be able to weigh in their opinion on the changes
Your organization will likely fall somewhere in between. Often times, organizations with low transparency tend to be either:
- Handling a lot of sensitive information;
- Operating with poor safety culture; or
- Large with numerous safety roles and responsibilities.
Organizations with high transparency tend to be either:
- Small with flexible safety roles and responsibilities;
- Operating with a mature safety culture; or
- Handling routine, non-sensitive information.
It’s a very good idea to have a commitment to transparency, be that a commitment to being open and available with information or being committed to keeping reported information secure and private.
What is Safety [Information] Responsibility in Aviation Safety
Safety information responsibility in aviation safety is about:
- How is your organization taking ownership of reported safety information; and
- Who is managing safety information?
Mismanagement of safety information (i.e., irresponsibility), usually winds up with:
- Safety information not being reported;
- Safety information being lost; or
- Inconsistent safety information, such as different spreadsheets with different information.
Your organizations needs to ensure:
- All reported safety information is safe and reliable;
- Responsible mangers are being accountable for reported information; and
- Employees are reporting safety concerns.
Responsibility is everyone’s job.
How to Handle Safety Information Responsibility Safety
Some good practices your organization can adopt to ensure safety information is owned, reliable, and reported are:
- Develop a mandatory/voluntary reporting policy;
- Perform internal audits/inspections on managed issues; and
- Invest in an SMS point solution or aviation safety management software to ensure that safety information is reliable.
In short, invest in the resources (tools, documentation) and ensure that safety information is handled well.
… names match. Luckily, most airlines will correct minor spelling mistakes … promptly as possible. Some airlines do charge for the service … to fix a mistake. British Airways: BA doesn’t charge … mistake, call the Thomas Cook Airlines contact centre on 0800 916 … The post Easy mistake to make when booking a flight…
AOPA has posted online a new fact sheet about airport security to help airports that must administer a Transportation Security Administration-approved security plan stay safe while allowing general aviation pilots access to aircraft parking, ramp access, and other services.
Under TSA regulations, airports must have in place a TSA-approved Airport Security Program (ASP) when scheduled airlines operating there use aircraft with 61 or more seats. The security plan may require airport management to conduct security background checks and issue identification badges to hundreds of employees and other personnel.
Those individuals may include aircraft owners who are airport tenants. Pilots who are not locally based, however, do not have airport security credentials. At some airports, responsibility for escorting them in and out of secured areas has been delegated to fixed-base operators—some of whom have charged the visiting pilots for services they did not need.The new AOPA fact sheet, TSA Airport Access Security Requirements, can help airports “find a GA friendly outside-the-box solution that works for unique security needs of each airport.”
“It is important to understand that there are alternative methods that are less onerous and still meet TSA requirements, while being friendly to general aviation,” said Nobuyo Sakata, AOPA director of airport security.
Specifics of an airport’s security requirements are considered to be sensitive security information and are not publicly disclosed by the TSA. While that makes it difficult for airport users to weigh in on the impact of security planning on their needs, the AOPA fact sheet suggests approaches airport managers can take to develop their security plans through a combination of technology such as closed-circuit television, video surveillance systems, or one-time-use access codes; physical barriers such as gates between areas with different security levels; and other ways to leverage the airport’s physical layout in the security plan.
The new fact sheet provides information about the regulatory requirements and security levels of the different operating areas of an air-carrier-service airport. It discusses the kinds of access-control systems available and options for providing “identification media” to authorized persons.
Those persons include an airport’s GA pilots, who should be familiar with the local security protocols.
Transient pilots, however, lack locally issued ID, and “airports must implement specific procedures to control access to general aviation transient ramps,” the fact sheet notes, reminding airport managers that transient pilots “have a valid reason to be on a general aviation ramp,” and that they already carry valid credentials including their FAA pilot certificate and government-issued picture ID. In effect, transient pilots are “vetted by TSA on a daily basis.”
The fact sheet also provides helpful links to other resources on airport security questions.
AOPA also continues to promote the AOPA Airport Watch program and educate GA pilots to be vigilant and report suspicious activities, Sakata said. AOPA has also been working with the FAA on a revision to the Aeronautical Information Manual’s airport security section.