With the advancement of IT technology and the widespread use of portable devices (smartphones / tablets) in flight operations and crew support there have been initiatives to design device applications (“apps”) that are supposed to fulfil health / mental health / wellbeing monitoring as well as other related functions. These functions may include, but are not limited to:

• monitoring various physiological functions (blood pressure, heartbeat, oxygen saturation, sleep)
• inputs with regard to eating habits / calorie intake / alcohol consumption
• inputs on sleep or sleep quality
• inputs as to perceived mood / psychological state
• inputs of medical data
• guidance on eating best practices
• signposting with regard to health or mental health
• self -help or self-diagnosis function.

These apps may or may not work with smartwatch type of devices that monitor various physiological functions.

While it is understandable that new technologies entail new and innovative ways to improve current practices, these apps that deal with health or mental health / wellbeing issues raise a number of concerns on data protection, privacy as well as possible abuse by stakeholders. In our interconnected world, there are risks that sensitive personal data is unwillingly shared, spread or otherwise misused by 3rd parties.

ECA urges clear rules and guidance before such apps become widespread both in the airline pilot community and possibly with operators.

Use of digital applications

The use of digital apps by crew members¹ shall be strictly on a voluntary basis and for personal use only.

Use of such apps shall not be mandated by either licensing authorities or operators.

Refusal by crew members to use such digital applications shall not be grounds for any discrimination or disciplinary measures.

While there can be benefits provided by apps with regard to quick and cursory information about health / mental health issues, personal fatigue levels, personal eating habits or calorie intake, or personal wellbeing strategies, such apps are not standalone medical assistance and cannot replace seeking medical, psychological or other health-related advice with qualified medical personnel or seeking medical or psychological support and/or treatment.

With regard to psychological support type of applications, such apps cannot replace functioning (peer) support structures or interpersonal contacts and cannot substitute for regulatory requirements related to operator support programs.

The use of “CRM” or decision-making and similar apps cannot be substitutes for regulatory mandated CRM course, as well as classroom decision-making and leadership training by operators.


Quality of application content

To be even marginally useful, the application data output, information or other recommendations need to be based on evidence-based established science.

Apps should transparently communicate the limitations of using these apps especially in the field of health, mental health or wellbeing to the crew member and actively remind the crew member to seek adequate medical (or other) help or advice if required.


Data protection and data usage

Health / mental health / wellbeing digital applications must comply with the most stringent data protection and privacy provisions, in line with Regulation (EU) 2016/679 and national legislations.

If enabled, data collection, especially personal medical and other sensitive data must be done in a way transparent to the crew member. Biomonitoring data is deeply personal, and its collection raises serious ethical, legal, and privacy concerns. Clear boundaries must be established to ensure that such data is used strictly for supportive and safety-related purposes, and not for surveillance, punitive action, or commercial exploitation. Transparency, voluntary participation, and strict data protection protocols are essential to maintain trust and respect for individual rights.

The use of that data for analytical purposes, not limited to health analysis, must be transparent to the crew member and sharing of that data with 3rd parties must be voluntary and the app user, as provider of the data must be able to stop sharing at any moment.

Safeguards must be in place to protect the ownership rights of the data and to prevent the exploitation of this data for financial or competitive advantages, ensuring that its use remains strictly within the scope of the originally certified system.

To enhance user autonomy and trust, digital applications should support granular management of data usage.

Crew members should be able to selectively enable or disable specific features or data-sharing functionalities within the application. This flexibility ensures that those who wish to benefit from certain aspects of the software – such as fatigue tracking or dietary input – can do so without being forced to share unrelated or more sensitive data. The design must avoid an “all-or-nothing” approach to data consent, empowering crew members to make informed, modular choices about their data usage. Any data stored outside of the digital application on the crew member’s personal device shall be de-identified and encrypted.

The data remains proprietary to the crew member.

Collected data may not be shared with either regulator, licensing authority or operator unless expressly agreed to by the crew member and must be revocable at any moment by the crew member.


¹ For ease of reference, “crew member” designates the end-user that has downloaded the digital application on his/her personal or professional device and provides the personal health and other data.

While ECA acknowledges that the use of digital applications for flight crew is spreading and can be of practical use for flight crew, it cautions that:

• Use by crew members of digital applications can only be on a voluntary basis and crew members must be able to stop sharing data at any moment.
   
• Most stringent data protection and privacy provisions, in line with EU and national regulations must apply, personal data needs to remain proprietary to the crew member and must be used strictly for supportive and safety-related purposes – not for surveillance, punitive action, or commercial exploitation.
   
• Digital Applications cannot substitute for seeking medical or psychological advice or any training required by the regulations.
   
• Crew members should be aware that data protection provisions, like those related to CVR or FDR specified in Regulation 996/2010, may not apply in case of criminal proceedings as a result of an incident or accident.
   
• In case operators provide for free and voluntary programs based on the use of such apps, there should be clear and transparent agreements in place between the operator and the crew representative organisation.

August 2025