Boeing Employee Privacy Notice

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Contingent Worker Privacy Notice

 

This notice describes the privacy and data protection practices of The Boeing Company and its subsidiaries (collectively "Boeing") with respect to the processing of Personal Information about employees, former employees, contingent workers, and others (collectively "you" or "your"). Personal information is defined as any information related to, or that can be used to identify, contact, or locate an individual; any capitalization of the term "Personal Information" within this notice refers to this definition.

Please read this notice in conjunction with any other privacy notices that Boeing provides to you from time to time. In the event of any conflict between notices or disclosures required by local law and this notice, the notices or disclosures required by local law will prevail. To make it easier to navigate within this notice, we have created a table of contents outlining the specific provisions within this notice. To review a specific topic, please click on the link and it will take you to the desired section.

 

 

Who We Are

As a leading global aerospace company, Boeing develops, manufactures, and services commercial airplanes, defense products, and space systems for customers around the world. The company leverages the talents of a global supplier base to advance economic opportunity, sustainability, and community impact. Boeing's diverse team is committed to innovating for the future, leading with sustainability, and cultivating a culture based on the company's core values of safety, quality, and integrity. Boeing is incorporated in the state of Delaware in the United States. The headquarters address is 929 Long Bridge Drive, Arlington, Virginia 22202.

At Boeing, our approach to privacy begins with our enduring values. Consistent with our high ethical standards and integrity in everything we do, we are committed to privacy and the protection of your personal information through our global privacy program which enables compliance with applicable privacy laws around the world.

Governance for our privacy program relies on two key policies: PRO-98, "Personal Information Protection & Privacy" and PRO-2227, "Information Protection". Additional requirements, guidance, and related policies can be found on the Global Privacy Office Website at https://globalprivacy.web.boeing.com accessible from the Boeing Enterprise Network, or by contacting the Global Privacy Office. Your careful attention to Boeing's privacy and security practices helps maintain your privacy and the privacy of others.

 

The Types of Personal Information We Collect and Why

Boeing processes your Personal Information for a wide range of purposes relating to the employment relationship and business administration. The types of Personal Information processed, and the respective purposes of processing include but are not limited to:

 

Personal Information Category	Examples	Processing Purposes	Disclosure	Retention
Contact information and identifiers	Name, home and business addresses, telephone numbers, e-mail addresses, emergency contact information	Staffing (e.g., headcount planning, recruitment, termination, succession planning), project management, workforce communications, administration of employee enrollment and participation in activities and programs offered to eligible employees (e.g., matching donations to non-profit organizations, political action committee contributions, wellness activities)	Personal Information from this Category is shared with third parties providing services under contract to Boeing and to governmental entities in compliance with applicable law in the jurisdictions where Boeing and its partners operate.	We retain your Personal Information from this Category for as long as it is needed to fulfill its intended use and to comply with the law. The specific retention period, which varies based on information type and governing regulations, is established and effectuated in accordance with company records and information management requirements.
Sensitive Personal Information, characteristics of protected classifications, identity, and demographic information	Date of birth, marital status, social security or other national identification number, gender, gender identity, preferred language, nationality, country of birth, citizenship, age, ethnicity, race, disability status, religion, sexual orientation	Conducting background checks (as permitted by applicable laws) or conflict of interest screening and reporting; to permit authorized agencies to review and enforce equal opportunity laws; to comply with applicable laws in the jurisdictions in which we operate; and to support the Company's diversity and inclusion initiatives when permitted by applicable laws	Personal Information from this Category is shared with third parties providing services under contract to Boeing and to governmental entities in compliance with applicable law in the jurisdictions where Boeing and its partners operate.	We retain your Personal Information from this Category for as long as it is needed to fulfill its intended use and to comply with the law. The specific retention period, which varies based on information type and governing regulations, is established and effectuated in accordance with company records and information management requirements.
Employment, performance, compensation, and benefits information	Hire date, adjusted service date, BEMSID, job title, position/grade, ability to work in a particular location, export status, security clearance information, attendance, business unit, supervisor, site, union membership, objectives, projects, performance reviews and leadership ratings, salary, retirement, information about your family or dependents	Compensation, payroll, and benefit planning and administration (e.g., salary, tax withholding, tax equalization, awards, workforce planning, insurance, and pension) as permitted by applicable laws	Personal Information from this Category is shared with third parties providing services under contract to Boeing and to governmental entities in compliance with applicable law in the jurisdictions where Boeing and its partners operate.	We retain your Personal Information from this Category for as long as it is needed to fulfill its intended use and to comply with the law. The specific retention period, which varies based on information type and governing regulations, is established and effectuated in accordance with company records and information management requirements.
Education, training, certifications, non-public education information	Education level, field and institution, competency assessments, online testing, professional licenses and certifications, skills, training course completions	Performance management, workforce development, talent management, education, training, and certification	Personal Information from this Category is shared with third parties providing services under contract to Boeing and to governmental entities in compliance with applicable law in the jurisdictions where Boeing and its partners operate.	We retain your Personal Information from this Category for as long as it is needed to fulfill its intended use and to comply with the law. The specific retention period, which varies based on information type and governing regulations, is established and effectuated in accordance with company records and information management requirements.
Prior employers and employment history, professional Information	Employers in related industries, government employment, veteran status, military associations, references, letters of recommendation, resumes, job application data	Determining suitability, work shift scheduling, organizational planning and development, and workforce management	Personal Information from this Category is shared with third parties providing services under contract to Boeing and to governmental entities in compliance with applicable law in the jurisdictions where Boeing and its partners operate.	We retain your Personal Information from this Category for as long as it is needed to fulfill its intended use and to comply with the law. The specific retention period, which varies based on information type and governing regulations, is established and effectuated in accordance with company records and information management requirements.
Driving and vehicle records	Driver's license number, vehicle license plate number, insurance information	As required or expressly authorized by laws or regulations	Personal Information from this Category is shared with third parties providing services under contract to Boeing and to governmental entities in compliance with applicable law in the jurisdictions where Boeing and its partners operate.	We retain your Personal Information from this Category for as long as it is needed to fulfill its intended use and to comply with the law. The specific retention period, which varies based on information type and governing regulations, is established and effectuated in accordance with company records and information management requirements.
Financial information	Tax numbers, bank account numbers, personal or Company credit card numbers	Budget planning and administration, expense management (e.g., corporate card, expense reimbursement processing, procurement)	Personal Information from this Category is shared with third parties providing services under contract to Boeing and to governmental entities in compliance with applicable law in the jurisdictions where Boeing and its partners operate.	We retain your Personal Information from this Category for as long as it is needed to fulfill its intended use and to comply with the law. The specific retention period, which varies based on information type and governing regulations, is established and effectuated in accordance with company records and information management requirements.
Health, safety, and injury information	Work restrictions, accommodations, safety incident reports, industrial hygiene exposure and monitoring information	Safety incident and work-related injury and illness reporting, monitoring and surveillance for industrial hygiene, and purposes of occupational medicine	Personal Information from this Category is shared with third parties providing services under contract to Boeing and to governmental entities in compliance with applicable law in the jurisdictions where Boeing and its partners operate.	We retain your Personal Information from this Category for as long as it is needed to fulfill its intended use and to comply with the law. The specific retention period, which varies based on information type and governing regulations, is established and effectuated in accordance with company records and information management requirements.
Health-related information	Temperature reading, health screening responses, health-related diagnostic tests (e.g., blood pressure readings), disability information, details of sickness-related absence	To assess public and workplace health including for contact tracing when necessary, to comply with equalities legislation, for purposes of occupational medicine (e.g., to administer vaccines for international travel, assess fitness for return to work, and accommodation reviews), to assess working capacity, and to facilitate medical diagnosis	Personal Information from this Category is shared with third parties providing services under contract to Boeing and to governmental entities in compliance with applicable law in the jurisdictions where Boeing and its partners operate.	We retain your Personal Information from this Category for as long as it is needed to fulfill its intended use and to comply with the law. The specific retention period, which varies based on information type and governing regulations, is established and effectuated in accordance with company records and information management requirements.
Agreements that you enter into with the Company	Non-disclosure agreements, Code of Conduct, employment agreements, access agreements, compliance agreements	Problem resolution (e.g., internal reviews, grievances), investigations, auditing, compliance, risk management and security purposes	Personal Information from this Category is shared with third parties providing services under contract to Boeing and to governmental entities in compliance with applicable law in the jurisdictions where Boeing and its partners operate.	We retain your Personal Information from this Category for as long as it is needed to fulfill its intended use and to comply with the law. The specific retention period, which varies based on information type and governing regulations, is established and effectuated in accordance with company records and information management requirements.
Computer or facilities access and authentication information, biometrics	Identification codes, passwords, certificates, PINs, biometrics used for authentication	Authorizing, granting, administering, monitoring, and terminating access to or use of company systems, facilities, records, property, and infrastructure	Personal Information from this Category is shared with third parties providing services under contract to Boeing and to governmental entities in compliance with applicable law in the jurisdictions where Boeing and its partners operate.	We retain your Personal Information from this Category for as long as it is needed to fulfill its intended use and to comply with the law. The specific retention period, which varies based on information type and governing regulations, is established and effectuated in accordance with company records and information management requirements.
Monitoring information, internet or network information	Electronic log files from computers, phones, and mobile devices; monitoring information about your usage of the Company's network, systems, applications, and Company-provided resources (to the extent permitted by law)	Legal proceedings and government investigations, including preservation of relevant data, incident investigation	Personal Information from this Category is shared with third parties providing services under contract to Boeing and to governmental entities in compliance with applicable law in the jurisdictions where Boeing and its partners operate.	Personal Information from this Category is shared with third parties providing services under contract to Boeing and to governmental entities in compliance with applicable law in the jurisdictions where Boeing and its partners operate. We retain your Personal Information from this Category for as long as it is needed to fulfill its intended use and to comply with the law. The specific retention period, which varies based on information type and governing regulations, is established and effectuated in accordance with company records and information management requirements.
Location and geolocation data	City, county, or precise geolocation information	Managing and reporting on workforce physical security and safety, emergency, and non-emergency workforce communication, conducting business travel (e.g., reserving limousines, commercial flights, company aviation services, hotels, rental cars)	Personal Information from this Category is shared with third parties providing services under contract to Boeing and to governmental entities in compliance with applicable law in the jurisdictions where Boeing and its partners operate.	We retain your Personal Information from this Category for as long as it is needed to fulfill its intended use and to comply with the law. The specific retention period, which varies based on information type and governing regulations, is established and effectuated in accordance with company records and information management requirements.
Photographs or other visual images of you, audio and visual recordings of you	Security photos, and security camera footage, optional website and application profile photos, videos, news articles, recorded meetings	Ensuring company physical security, safety, conducting business travel (e.g., reserving limousines, commercial flights, company aviation services, hotels, rental cars), workforce personnel identification, access management; knowledge transfer, communications events	Personal Information from this Category is shared with third parties providing services under contract to Boeing and to governmental entities in compliance with applicable law in the jurisdictions where Boeing and its partners operate.	We retain your Personal Information from this Category for as long as it is needed to fulfill its intended use and to comply with the law. The specific retention period, which varies based on information type and governing regulations, is established and effectuated in accordance with company records and information management requirements.
Third-party data	Assessments, background screenings, credential information	Workforce management, performance management, workforce development, talent management, succession planning, education, training and certification	Personal Information from this Category is shared with third parties providing services under contract to Boeing and to governmental entities in compliance with applicable law in the jurisdictions where Boeing and its partners operate.	We retain your Personal Information from this Category for as long as it is needed to fulfill its intended use and to comply with the law. The specific retention period, which varies based on information type and governing regulations, is established and effectuated in accordance with company records and information management requirements.
Additional California customer records	Name, home and business addresses, telephone numbers, e-mail addresses, emergency contact information, tax numbers, bank account numbers, personal or Company credit card numbers	Staffing, workforce communications, administration of programs offered to eligible employees, recordkeeping and compliance, risk management and fraud prevention	Personal Information from this Category is shared with third parties providing services under contract to Boeing and to governmental entities in compliance with applicable law in the jurisdictions where Boeing and its partners operate.	We retain your Personal Information from this Category for as long as it is needed to fulfill its intended use and to comply with the law. The specific retention period, which varies based on information type and governing regulations, is established and effectuated in accordance with company records and information management requirements.

 

Boeing collects and processes your Personal Information for specific business purposes, including to establish, maintain, or terminate the employment relationship with you, to fulfill obligations arising from this, and for Boeing's legitimate business interests related to your employment relationship.

In other cases, such as maintaining optional benefits programs or participation in voluntary activities (e.g., wellness activities or advocacy campaigns), Boeing will notify you of your options regarding your participation and the use of your Personal Information. Boeing will not engage in any adverse actions against you should you choose not to participate in such optional uses of Personal Information. Please note that Boeing does not sell your Personal Information, share that information for the purposes of behavioral advertising, or re-identify de-identified data.

 

Further information regarding the legal basis relied upon to process your Personal Information can be found below.

 

How We Collect Your Information and Who Provides it

 

We obtain Personal Information through fair and lawful means. In many cases, we obtain your Personal Information directly from you or our interactions with you, such as when you complete an application or enter information about yourself into our systems. In other cases, we infer Personal Information through your interactions with us, such as through your use of the company's equipment, systems, and networks. Finally, some of the Personal Information we obtain may come from other sources, such as your manager, references, background checks, assessments, or vendors (with consent). Please know that we assess these activities and ensure they are permitted by law.

 

Why We can Process Your Personal Information

 

We will only collect, use, and share your Personal Information when there is an appropriate legal basis to do so. This may be because:

• You have voluntarily provided your Personal Information and have consented for us to process it. However, where the collection or processing is based on your consent, you may withdraw your consent at any time to the extent permitted by applicable law, provided that any revocation of your consent will not affect the lawfulness of any completed processing.

• Use of your Personal Information is necessary for our legitimate interests or those pursued by a third party, provided those interests are not outweighed by the related risk to individuals. The legitimate interests pursued by Boeing include but are not limited to establishing and maintaining an employment relationship with you, compliance with contractual obligation, protection of company resources and information, workplace health and safety, and conducting normal business operations.

• Use of your Personal Information is necessary to perform or enter into a contract with you.

• Processing is necessary to protect the vital interests of you or another person.

• Use of your Personal Information is necessary to comply with a legal or regulatory obligation.

Who Your Information is Shared With

 

Your Personal Information will be made available for the purposes mentioned above and access will be limited for certain business functions, including but not limited to management, human resources, accounting, security, and to third parties providing services under contract to Boeing, such as payroll processors and technology service providers.

Certain information may also be disclosed to governmental entities in compliance with applicable laws in the United States or other countries, such as to those agencies authorized to review and enforce equal opportunity laws, or for tax, insurance, labor, safety, or other purposes.

 

Personal Information may also be released to external parties as required by labor statutes or agreements, or by legal process, to our professional advisors (such as accountants, auditors, and lawyers) as well as to parties to which you authorize Boeing to release your Personal Information.

Personal Information may also be disclosed to third parties providing services under contract to Boeing (under obligation to protect the security and confidentiality of the information) who have a need to know the specific information in question to carry out their specific responsibilities and Statements of Work.

In the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock, Boeing is likely to disclose your Personal Information to associated entities and their professional advisors, subject to a requirement that such information be used only in accordance with this notice or as otherwise permitted under an applicable agreement.

 

Where Does Your Information Go

 

Your Personal Information (e.g., payroll files, benefits information, etc.) may be maintained at your place of employment and some information relating to you may be transferred to or stored and processed in the United States or another country where Boeing or its affiliates or subcontractors maintain facilities. The data protection laws in these countries are different from and could be less or more stringent than those in your country of residence, but we take steps to ensure that the data we collect under this notice is secured and processed according to the provisions of this notice and the requirements of applicable law wherever the data is located.

The primary company system of record for human resources data is in the United States and it shares Personal Information with other systems hosted by or on behalf of our company. These other systems will only process Personal Information in accordance with and as permitted by applicable laws. Boeing has put in place adequate measures, such as standard contractual clauses, to adequately protect cross-border transfers. Boeing also requires all its agents, third parties under contract, and subsidiaries to abide by applicable privacy and data protection requirements in the jurisdictions in which they operate. Boeing is responsible for the service providers who process your data on Boeing's behalf and is subject to the investigatory and enforcement powers of the Federal Trade Commission.

 

Retention and Deletion of Your Personal Information

 

We retain your Personal Information for as long as necessary to fulfill its intended use and to comply with applicable legal obligations. The required retention period varies depending on the type of information and the laws in your location. The specific retention period for business records is set forth in company retention schedules in accordance with company records and information management requirements. When no longer needed, we either anonymize or dispose of your Personal Information using Company approved standard methods, which have been developed to prevent loss, theft, misuse, or unauthorized access.

 

Automated Decision Making

 

Boeing may make certain decisions based solely on automated processing in a variety of ways (including through the use of machine learning and artificial intelligence) to support and improve business operations. Boeing does not, however, subject your Personal Information to automated decision making that produces legal or similarly significant effects. To exercise any rights and choices available, you can visit the Boeing Privacy Rights Request Portal at https://boeing.com/privacy/rightsexerciseportal.

With some job requisitions and in select jurisdictions, Boeing may deploy a tool to perform specific recruiting tasks that rely on machine learning (also referred to as artificial intelligence or AI). This tool screens internal and external candidates by generating a score based on the matched qualifications provided by the candidates and the qualifications outlined in the job requisition. Boeing recruiters use the score as a guide to further evaluate candidates. The score does not automatically result in a decision as to whether the candidate moves forward. Additionally, Boeing uses this tool to consider candidates for open job requisitions. Boeing may use these tools to compare your Personal Information against open job requisitions. If you are a match, a Boeing recruiter may contact you regarding the matched requisition. Please know that Boeing does not use your information for either of these use cases unless you opt-in.

In both scenarios, the use of the tool does not supplant human judgment. It merely helps Boeing recruiters and hiring managers expediently identify which candidates have stated that they meet the requirements of the jobs to which they applied or could apply to. Our recruiters and hiring managers always have complete discretion on which applicants they select, and what information they weight or consider. These tools do not influence any decision making. The tools simply indicate which candidates match the stated job requirements and to what extent.

If you previously opted in, but now wish to opt-out of either activity outlined above, please submit a request using the information from the Contact Us section.

 

How we Protect Your Information

 

Boeing uses appropriate administrative, technical, personnel, and physical measures to safeguard your Personal Information against loss, theft, and unauthorized use or modification. In addition, we exercise special precautions in dealing with sensitive Personal Information. The quality of your Personal Information is assured through technological and administrative controls that mitigate potentially adverse effects on personal rights or interests due to the inaccuracy or incompleteness of Personal Information.

 

Your Obligations in Connection with Personal Information

 

It is important that the Personal Information we hold about you is accurate and current. We ask that you promptly inform us when the Personal Information we hold is inaccurate or changes so appropriate corrections can be made. If you fail to provide certain information when requested we may not be able to perform the contract we have entered into with you (for example, we may not be able to pay you if you do not provide your bank details) or we may be prevented from complying with other legal obligations.

There may also be cases where you provide us with the Personal Information of others, for example in relation to pension entitlement and the provision of other benefits when you provide the details of your dependents or beneficiaries. Where this occurs, we ask that you explain to affected individuals that the Personal Information is being collected for these purposes and that you provide them with a copy of this notice, if requested.

 

Residents in Brazil

 

As a resident in Brazil, the Brazilian General Data Protection Law (Law No. 13,709/2018 or "LGPD") and its subsequent amendments apply to you. The LGPD guarantees specific privacy rights that Boeing complies with and respects. You are entitled to receive notice about the categories and types of Personal Information Boeing collects from you and how it is used, which can be found in the "Collecting and Processing Your Personal Information" section of this notice. For questions or requests related to Boeing's processing of your Personal Information you can contact the company's Brazilian Data Protection Officer, Tiago Corazolla, as described within the "Contact Us" section of this notice.

 

Residents in California

 

California law provides state residents with specific employment-related privacy rights. You are entitled to receive notice about the categories of Personal Information Boeing has collected about you in the preceding 12 months, including who provided it, for what business purposes that information has been used, how long it is retained, and to which third parties it has been disclosed. You can find this information in the "Collecting and Processing Your Personal Information" section of this notice. You have the right to request access to, correction, and deletion of your Personal Information, as well as the right to data portability. You also have the right to request that Boeing limit the use and disclosure of your sensitive Personal Information. These rights can be exercised by using the Boeing Privacy Rights Request Portal and as described within the "Contact Us" section of this notice.

Please note that Boeing does not sell your Personal Information, share it for the purposes of behavioral advertising, re-identify de-identified Personal Information, or use sensitive Personal Information to "infer characteristics" about you. Additionally, we do not offer substantive financial incentives for the collection or sale of your Personal Information, or use it for the purposes of fully automated decision making with a legal or similarly significant impact. We process sensitive Personal Information with your consent or as permitted by law. We will also not discriminate against you if you exercise your privacy rights under California law.

Upon request, this notice can be made available in alternative formats, such as large print or a paper copy. Please contact us and an alternative format will be provided to you so you can access the information in this notice.

 

Residents in Alberta or British Columbia

 

Under Alberta's Personal Information Protection Act (AB-PIPA) and British Columbia's Personal Information Protection Act (BC-PIPA), Boeing may collect, use, or disclose Personal Information without consent where the collection, use, or disclosure is reasonable for the purposes of establishing, managing, or terminating an employment relationship between Boeing and the individual. However, you are entitled to reasonable notice of the purposes for which Boeing collects, uses, and discloses your Personal Information. To fulfill this obligation, you are provided with this notice. You are entitled to request access to, or correction of, your Personal Information in our custody or control. You are also entitled to request to know who within Boeing has access to your Personal Information, and for how long that Personal Information will be kept. Where your consent is required under AB-PIPA or BC-PIPA, you are entitled to withdraw your consent previously given to us for the processing of your Personal Information, whether such consent was implicit or explicit. Please make your request by using the Boeing Privacy Rights Request Portal or as described within the "Contact Us" section of this notice.

 

Residents in Quebec

 

Quebec law provides residents with specific employment-related privacy rights related to Personal Information and sensitive Personal Information.

Boeing collects, uses, stores, discloses, and retains your Personal Information and sensitive Personal Information for the purposes identified in, and in accordance with, this notice and applicable law. Your Personal Information may be communicated to the categories of third parties referred to in this notice, which may be located outside of Quebec, for the purposes identified in this notice.

 

Identifying Technologies

 

Boeing may provide you with Boeing electronic property which may include technologies that can be used to identify, locate, or profile said Boeing electronic property, and incidentally, you, the user of such property. Such technologies may be activated or otherwise used as warranted to ensure the confidentiality, integrity, and/or availability of Boeing electronic property. When required by law, Boeing will make reasonable efforts to inform you of the use of such technologies prior to their activation.

In addition, as part of your employment, Boeing may require the use of technology that will allow you to be identified, located, or profiled (for example, to enhance workplace safety).

 

Access and Rectification Rights

 

You have a right to request access to, or correction of, your Personal Information in our custody or control. You have the right to request to know who within Boeing has access to your Personal Information, and for how long that Personal Information will be kept. Where we have relied on your consent to process Personal Information, you have the right to withdraw such consent. You may also request that Boeing stop distributing and remove any links to your Personal Information, if the availability of such information causes you an injury or violates a court order. Please make your request by using the Boeing Privacy Rights Request Portal  or as described within the "Contact Us" section of this notice.

The above-mentioned rights are subject to any applicable legal restriction, which may prevent us from fulfilling your request.

If you have any questions, requests, or complaints about our Personal Information practices, please submit your inquiry by using the Boeing Privacy Rights Request Portal or as described within the "Contact Us" section of this notice.

 

Residents in the People's Republic of China

 

The Personal Information Protection Law (PIPL) of the People's Republic of China (PRC) delineates privacy rights and requirements for mainland China. The Supplemental Notice and Consent for Employees in the PRC ("Supplemental Notice") addresses the PIPL's requirements to provide notice to, and obtain consent from, employees. To exercise your rights under the PIPL, please review the Supplemental Notice and the section below titled "Your Rights and Choices, and how to Exercise them."

 

Residents in the European Union, European Economic Area, Switzerland, Gibraltar, and UK

 

The Boeing Company is the data controller for the Personal Information within the scope of this notice. Specifically for EU, EEA, Switzerland, Gibraltar, and UK residents, whenever you see the following terms in this notice, they have the following meanings:

• "GDPR" means the European Union's ("EU") General Data Protection Regulation 2016/679 ("GDPR") and the EU GDPR as implemented into national UK legislation (the "UK GDPR"), in each case as applicable and incorporating any national laws implementing or supplementing the GDPR.

• "Processing" means any action we may take related to your Personal Information, including collection, use, disclosure, handling, storage, transmission, protection, modification, or disposal. When used in this notice, the terms "Process" and "Processed" should be read in line with this definition.

• "Sensitive Personal Information" means (i) any Personal Information defined as being one or more of the Special Categories of Personal Information under the GDPR (including any information concerning or revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic data, biometric data for the purpose of uniquely identifying an individual, data concerning health, or data concerning an individual's sex life or sexual orientation) and/or; (ii) any Personal Information relating to the commission or of criminal offences

• Personal Information retained by Boeing is Processed in accordance with the principles and requirements of GDPR. Where Boeing has determined the need to appoint a data protection officer pursuant to GDPR, this function is being carried out by a member of Boeing's Global Privacy Office who can be contacted as described in the "Contact Us" section. You have the right to request access, rectification, erasure, restriction of Processing, objection to Processing, or to data portability of your Personal Information. To exercise these rights, you can use the Boeing Privacy Rights Request Portal. Please also contact the Global Privacy Office to identify the relevant Data Protection Authority if you wish to contact them.

Cross-Border Data Transfers

 

Where we transfer your Personal Information outside of the EU/UK/Gibraltar/Switzerland, Boeing will ensure that your Personal Information receives an adequate level of protection in accordance with the requirements of the GDPR. We will only execute or allow such transfers where:

• Transfer is to a country that has been deemed by the UK Secretary of State, Gibraltar Regulatory Authority, Swiss Federal Data Protection and Information Commissioner, or the European Commission (as applicable) to provide an adequate level of protection for Personal Information;

• Boeing participates in a program approved by relevant authorities for the adequate protection of Personal Information transferred to and Processed in the United States; or

• there are appropriate contractual safeguards in place with the recipient, including standard contractual clauses approved for use by the European Commission and/or where the UK GDPR applies either the UK Addendum to the EU Standard Contractual Clauses or the International Data Transfer Agreement.

In addition, we may transfer based on limited exemptions, where adequacy or other safeguards are not present. If you require any further information about the measures we use in relation to a particular transfer outside the EU/UK/Gibraltar/Switzerland, you can request it by contacting a member of Boeing's Global Privacy Office, who can be contacted as described in the "Contact Us" section.

 

Boeing EU-U.S., UK Extension to the EU-U.S., and Swiss-U.S. Data Privacy Framework Statement

 

The Boeing Company and its U.S. subsidiaries Boeing Distribution Inc. and Boeing Digital Solutions, Inc. dba Jeppesen Sanderson (for the purposes of this section, collectively referred to as "Boeing DPF Companies") participate in the EU-U.S. Data Privacy Framework ("EU-U.S. DPF"), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework ("Swiss-U.S. DPF") (collectively, the "DPF") as set forth by the U.S. Department of Commerce. Boeing DPF Companies have certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles ("EU-U.S. DPF Principles") with regards to the processing of Personal Information received from the European Union and United Kingdom (and Gibraltar) in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Boeing DPF Companies have certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles ("Swiss-U.S. DPF Principles") with regards to the processing of Personal Information received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this Statement and the DPF Principles (collectively, the "Principles"), the Principles shall govern. To learn more about the DPF program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

Boeing DPF Companies implement these Principles with respect to the Personal Information described in this Statement and according to the stated purposes for which such Personal Information is collected, used, shared, and retained. If we transfer Personal Information to a third party, the third party's access, use, and disclosure of the Personal Information as well as any onward transfer must also comply with the DPF, and we understand that we may be liable under the DPF for any such failure to do so by the third party. Please note that Boeing DPF Companies may disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. EU, UK, and Swiss individuals have rights to access Personal Information about them, and to limit use and disclosure of their Personal Information. To exercise your rights and choices please visit the Boeing Privacy Rights Request Portal at https://boeing.com/privacy/rightsexerciseportal. If you have any questions or complaints relating to Boeing DPF Companies' handling of Personal Information received under the DPF, please contact us.

Boeing DPF Companies are subject to the investigatory and enforcement powers of the Federal Trade Commission. In compliance with the DPF, Boeing DPF Companies commit to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner's Office (ICO) and the Gibraltar Regulatory Authority (GRA) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of human resources data received in reliance on DPF in the context of the employment relationship. You may, under certain conditions, invoke binding arbitration. To learn more about these conditions and how to invoke binding arbitration, please visit https://www.dataprivacyframework.gov/framework-article/C%E2%80%93Pre-Arbitration-Requirements.

 

Processing of Sensitive Personal Information/Special Categories of Information

 

Where Boeing collects Sensitive Personal Information/Special Categories of Information, then we will only Process such information where it has an additional legal basis, including:

• For the purposes of carrying out obligations and/or exercising rights in the field of employment and social security laws;

• For health and safety purposes, the purpose of occupational medicine, to assess working capacity or for medical diagnosis or services;

• To protect the vital interests of you or another person;

• For the establishment, exercise, or defense of legal claims;

• Where Processing relates to Personal Information that has been manifestly made public by the relevant individual;

• Where Processing is necessary for reasons of substantial public interest, including for example where:

  • Processing of Personal Information relates to race or ethnicity is necessary for equalities monitoring purposes; and/or

  • Processing of Personal Information related to criminal offences is necessary to prevent or detect unlawful acts, or to enable compliance with applicable regulatory requirements;

• When you have provided your explicit consent. If Processing is based on your consent, you may withdraw your consent at any time to the extent permitted by applicable law, provided that any revocation of your consent will not affect the lawfulness of any completed Processing.

Residents in Indonesia

 

Law No. 27 of 2022 concerning Personal Data Protection (PDP Law) applies to you and provides you with specific data rights.

Boeing respects your privacy, and protects, handles, and processes your Personal Information in accordance with the PDP Law and the principles of necessity, lawfulness, fairness, and transparency.

You are entitled to:

• Receive written notice in both the national language, Bahasa Indonesia, and English regarding the collection and processing of your Personal Information, including the cross-border transfer of your Personal Information.

• Request access, correction, withdrawal, and deletion of your Personal Information. You also have the right to object to any decision-making action that is based solely on automated processing, including profiling, which has legal consequences or has a significant impact on you.

To fulfill this obligation, you are provided a Supplementary Employee Privacy Notice for Employees in Indonesia, which addresses specific requirements under the PDP Law.

When the handling of your Personal Information is based on consent rather than on any other legal basis, you will be informed of the Personal Information to be processed, and your consent will be obtained. If you withdraw consent, your withdrawal will not have an adverse effect on you or your dependents or the protection of your Personal Information. To exercise your data rights, see the "Your Rights and Choices, and how to Exercise them" section.

You can contact your Indonesia Data Protection Officer, Dwi Handayani at +(62) 815 1523 4091 or the Global Privacy Office as described in the "Contact Us" section.

 

Residents in Vietnam

 

The Vietnam Personal Data Protection Decree (Decree) applies to you and provides you with specific data rights.

Boeing respects your privacy, and protects, handles, and processes your Personal Information in accordance with the Decree and the principles of necessity, lawfulness, fairness, and transparency.

You are entitled to:

• Receive notice regarding the type of Personal Information collected, the purposes for collecting it, the individual or organizations that are allowed to process your Personal Information, and your rights and obligations. Notice will be provided in a form that can be printed or re-produced, including in electronic form or verifiable format,

• Request access, correction, deletion, or erasure of your Personal Information. You also have the right to object to or restrict the processing of your Personal Information,

• Claim damages when violation of the data protection regulations occurs with respect to the processing of your Personal Information.

To fulfill this obligation, you are provided a Supplementary Employment-related Privacy Notice and Consent for Employees in Vietnam, which address specific requirements under the Decree.

When handling of your Personal Information is based on consent rather than on a legal basis, you will be informed of the Personal Information to be processed and your express consent will be obtained. If you withdraw consent, your withdrawal will not have an adverse effect on you or the protection of your Personal Information. To exercise your data rights, see the Your Rights and Choices, and How to Exercise Them section.

You can contact your Vietnam Data Protection Officer, Emi Duong at +84942827711 or the Global Privacy Office as described in the 'Contact Us' section.

 

Your Rights and Choices, and How to Exercise Them
 

In accordance with the privacy and data protection laws where you live, you may have certain rights regarding the Personal Information Boeing maintains about you. In many cases, we will make available self-help tools to enable you to access or edit your Personal Information. In other cases, you may exercise these rights by using our Privacy Rights Request Portal at https://boeing.com/privacy/rightsexerciseportal.

 

Contact Us

 

Data Protection Officers (DPO) or Personal Information Protection Officers (PIPO) have been appointed in jurisdictions where we have an obligation to do so, and their contact information has been published.

 

If you wish to exercise your privacy rights:

• Submit your questions and requests online using the Boeing Privacy Rights Request Portal at https://boeing.com/privacy/rightsexerciseportal

If you have questions about Boeing's processing of your Personal Information or wish to file a privacy complaint, please contact the Boeing Global Privacy Office using any of the following methods:

• Call the Global Privacy Office Hotline at +1 (206) 544-2406 or toll-free from within the U.S. at +1 (877) 544-2407

• Submit your comments or questions to the Global Privacy Office e-mail account at: globalprivacy@boeing.com

• Write us at:

Boeing Global Privacy Office
Attention: Chief Privacy Officer
Mail Code 11-503
7755 East Marginal Way S.
Seattle, WA 98108
USA

 

Additionally, you also have the right to lodge a complaint with the relevant Privacy or Data Protection / Supervisory Authority where you live: https://www.boeing.com/privacy/authorities.html.
 

How we Manage Updates to This Notice

 

We ask that you check the terms of this notice for updates periodically. Boeing reserves the right to amend this notice to reflect changes in processing activities or legal requirements.

This notice was last updated and is effective as of January 3, 2025. For a previous version of this notice please submit your request to globalprivacy@boeing.com.