Question |
Answer |
What
corporate entity determines the purposes and means of processing of the personal data in this activity?
(This
is the "Controller" under the EU General Data Protection Regulation and other applicable
laws.) |
The
Boeing Company |
Who
represents this entity with regard to privacy issues? |
The Boeing Global Privacy Office is responsible
for privacy issues related to this activity.
Contact information for the Boeing Global Privacy Office
appears below this table.
(The Boeing Global
Privacy Office will route issues to the appropriate Data
Protection Officer where applicable.)
|
What
other entity may process this personal
data on behalf of
The
Boeing Company (including its fully integrated
subsidiaries around the globe)?
(This
is the "Processor" under the EU General Data Protection Regulation and other applicable
laws.) |
Bright Horizons |
Whose
personal data is intended to be processed by this
activity? |
This
activity is intended to process the personal information
of:
-
Employees
- Subsidiary Employees
- Former Employees
It is not intended to process the personal
information of individuals in other categories. |
What
categories of personal data are processed by this
activity? |
Sensitive
Personally Identifiable Information:
- Home Address
- Job Level
- Personal Email Address
- Personal Phone Number
- Termination Reason
Personal Information: Course grade or completion results and other non sensitive demographic information, including BEMS ID. Payment information related to tuition and eligible expenses, per LTP and/or ALP policy. |
What
are
the purposes of
processing personal data in this activity? |
Learning Together Program and/or Accelerated Leadership Program collects personal information from you to the extent necessary to administer the Learning Together Program and/or Accelerated Leadership Program and comply with tax and labor laws or U.S. union agreements, where applicable. The purpose of processing is to identify, communicate and report on an employee for their participation in the Learning Together Program (tuition assistance program)and/or the Accelerated Leadership Program.
Payroll deductions and/or collections may be necessary to repay Boeing for ineligible expenses, and for policy requirements not being met, as well as for taxes that may apply to my education. |
What is
the legal basis for processing personal data in this
activity? |
The
data subject has given consent to the processing of his
or her personal data for one or more specific purposes.
|
Does this activity use fully-automated processes when making significant (e.g. financial) decisions based on employees’ personal information? |
Upon review of the collections process, we didn't find that any of the decisions made met the threshold for automated decisions under governing regulations. |
How may
consent be withdrawn? |
If
not offered as a self-service capability within the "Learning Together Program (LTP) and Accelerated Leadership Progam (ALP)"
data processing activity or otherwise addressed in an
answer here, consent may be withdrawn using
https://boeing.com/privacy/rightsexerciseportal. |
Is the
data subject (the person to whom the data relates)
required to provide personal information for this
processing activity, and what would be the possible
consequences of failing to do so? |
Provision of personal information
for this processing activity is not required.
For those employees who want to participate in LTP, they must provide certain information as per LTP policy. Failure to provide the personal information could result in the employee not being able to participate in the LTP or ALP benefit. This applies to US and non-US participants. |
Who are
the recipients of the personal data in this activity? |
The recipients of the personal information in this activity include Managers, Payroll and HR. External entities that receive information include Bright Horizons and Attorney Network International for US persons. |
In what
countries will the personal data be processed? |
The personal information will be processed in all countries where Managers, HR, and Payroll are located for LTP. ALP information is for US employees only.
The personal information will only be stored in the United States.
|
How long
will the personal data be retained by this activity? |
The data will be retained for 10 years, unless otherwise required by law or regulation.
The personal information will be processed in all countries where Managers, HR, and Payroll are located for LTP. ALP information is for US employees only. |
What specific privacy rights may the individuals whose
personal data is processed by this activity have, and
how can they be exercised? |
Anyone may have the right to
lodge a complaint with a
supervisory authority (https://boeing.com/privacy/authorities.html).
Depending upon the jurisdiction(s)
in which you live or work, you may have the
following additional rights:
- to request access to and
rectification or erasure of personal data or
restriction of processing
- to object to processing
- to data portability
- to withdraw consent
- to not be subject to a
decision based solely on automated processing
which produces legal effects concerning you or similarly affects
you
If not offered as a
self-service capability within the "Learning Together Program (LTP) and Accelerated Leadership Progam (ALP)"
data processing activity or otherwise addressed in
another answer above, any applicable privacy rights
may be exercised using
https://boeing.com/privacy/rightsexerciseportal. |