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Old 11th May 2015 | 20:24
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Intruder
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Joined: May 2000
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From: Seattle
AFAIK, there is no place for a company to use identified FOQA data under an approved FAA FOQA program: From the FAA FOQA policy statement 981202:
The FAA encourages voluntary airline collection of deidentified digital flight data recorder data to monitor line operations on a routine basis, along with the establishment of procedures for taking corrective action that analysis of such data indicates is necessary in the interest of safety.
Further guidance from HBAT 00-11 of 26 July 2000:
Data that could be employed to determine flight crewmember identity are removed from the electronic record as part of the initial event extraction process. However, air carrier FOQA programs typically do provide for a gatekeeper, who is provided with a secure means of determining identity information for a limited period of time, in order to enable follow-up inquiry with a particular flightcrew concerning a particular FOQA event, when needed for further insight into the circumstances surrounding an event. The gatekeeper is typically, though not necessarily, a member of the air carrier's bargaining unit. The concurrence of the designated air carrier pilot's bargaining unit representative is typically required in order for follow-up with an individual pilot to be initiated. Follow-up inquiries of individual crewmembers concerning FOQA events will in all cases be accomplished by a designated member of the air carrier's bargaining unit.
So, ONLY a Crewmember who is the designated member of the collective bargaining unit representing the pilots may contact a Crewmember regarding an incident flagged by FOQA.

AC 120-02 of 12 Apr 2004 further clarifies the restriction on off-premises data and identifies the role of the Gatekeeper:
This FOQA information is protected from disclosure under 49 U.S.C. 40123 and part 193. It may be released only with the written permission of the Federal Aviation Administration Associate Administrator for Regulation and Certification.
. . .

Gatekeeper. The FMT member who is primarily responsible for the security of identified data. The gatekeeper is the individual(s) who can link FOQA data to an individual flight or crewmember. The gatekeeper is normally a member of the pilot association.
. . .

Data that could be employed to determine flight crewmember identity are removed from view in the electronic record as part of the initial processing of the airborne data. However, air carrier FOQA programs typically provide for a gatekeeper, who is provided with a secure means of determining identifying information for a limited period of time, in order to enable follow-up inquiry with the specific flightcrew associated with a particular FOQA event. Such contact is usually limited to situations when further insight into the circumstances surrounding an event is needed. The gatekeeper is typically a line captain designated by the air carrier’s pilot association (if applicable). The concurrence of the gatekeeper is required in order to initiate a follow-up with an individual pilot. Follow-up inquiries with individual crewmembers concerning FOQA events will normally be accomplished by a line captain designated as a gatekeeper by the air carrier’s pilot association (if applicable).
HOWEVER,
No aircraft operator is required to have a FOQA program. No operator that conducts a FOQA program is required to obtain FAA approval of that program. However, an aircraft operator that seeks the protection available in part 13, section 13.401 from the use by the FAA of FOQA information for enforcement purposes must obtain FAA approval of its program.
so it is important that any pilot group ensure that any FOQA program the company proposes will be an "approved" program.
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