AMC1 ORO.AOC.130 Flight data monitoring – aeroplanes
“(j) The data access and security policy should restrict information access to authorised persons. When data access is required for airworthiness and maintenance purposes, a procedure should be in place to prevent disclosure of crew identity.”
Developing a just or “no blame” reporting culture is a fundamental requirement of an effective FDM process.
There is a natural reluctance of people to “incriminate” themselves and off course pilots in this regard are no different from anyone else, so if we want to have a successful FDM process the Pilot should be able to contribute to the FDM process without any fear of punishment.
The primary objective is to develop the most complete picture of all contributing and causal factors relevant to an event rather than a hunt for the “guilty” (recognising that an error or potential error has a number of pre cursors many of which are related to company process and procedures).
Once we recognise that errors are typically the result of many factors or precursor’s with a range of systemic and organisational issues impacting the outcome rather than it being the fault of a single individual.
Should the legal system of the state of the operator potentially expose the pilot to prosecution then providing for anonymity can provide a safeguard to protect the “person”.
Sometimes the process is managed with the direct involvement and support of Pilot Association or Union.
A person holding the responsibility to de-identify the data would be sometimes known as the gatekeeper.
We have two analytical opportunities proactive & reactive.
Proactive looking at data from normal ops to identify trends which may lead to an exposure and Reactive when we have an event to consider.
Once we establish adequate protections we can more on to the important task of analysing in the most appropriate way, with the possibility of pooling with other organisations de-identified data.
The important task is for the FDM program to add the highest possible value to the Organisation, we also off course need to consider the resource constraints within which we have to “manage”
Clearly, the more detailed and imaginative the analysis, the greater the value of the Flight Data Monitoring programme to the company, but equally the greater the resources required for the task
AMC1 ORO.AOC.130 Flight data monitoring – aeroplanes
Good practice on the oversight of FDM programmes
The procedure to prevent disclosure of crew identity should be written in a document, which should be signed by all parties (airline management, flight crew member representatives nominated either by the union or the flight crew themselves). This procedure should, as a minimum, define:
(a) the aim of the FDM programme;
(b) a data access and security policy that should restrict access to information to specifically authorised persons identified by their position;
(c) the method to obtain de-identified crew feedback on those occasions that require specific flight follow-up for contextual information; where such crew contact is required the authorised person(s) need not necessarily be the programme manager or safety manager, but could be a third party (broker) mutually acceptable to unions or staff and management;
(d) the data retention policy and accountability including the measures taken to ensure the security of the data;
(e) the conditions under which advisory briefing or remedial training should take place; this should always be carried out in a constructive and non-punitive manner;
(f) the conditions under which the confidentiality may be withdrawn for reasons of gross negligence or significant continuing safety concern;
(g) the participation of flight crew member representative(s) in the assessment of the data, the action and review process and the consideration of recommendations; and
(h) the policy for publishing the findings resulting from FDM.”
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