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Privacy Notice concerning our
LD - Leadership Coaching with BetterUp
Data Processing Activity
(Boeing Data Processing Activity ID Number: 7663)
The Boeing Company and its group of companies seek to maintain the privacy, accuracy, and
confidentiality of personal data that we collect and use.
We have established privacy and security measures
both internally and (where applicable) in our relations with third parties to safeguard
personal information in our data processing activities.
We hope that
the following questions and answers addressing privacy issues
related to our "LD - Leadership Coaching with BetterUp"
data processing activity are as concise, transparent, and
intelligible as possible. We welcome
your suggestions for improvement of any of the content presented
below.
|
Question |
Answer |
| What
corporate entities
determine the purposes and means of processing of the personal data in this activity?
|
BetterUp Inc
and The
Boeing Company |
| Who
represents these
entities 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.
|
| What
other entity may process this personal
data on behalf of
BetterUp Inc
and 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.) |
BetterUp Inc |
| Whose
personal data is intended to be processed by this
activity? |
This
activity is intended to process the personal information
of:
-
Employees
- Subsidiary Employees
who are in the following locations:
- The United States
- Brazil
- Canada
- China
- Australia
- The European Union (EU)
- The European Economic Area (EEA)
- Hong Kong
- India
- Israel
- Japan
- Mexico
- Korea
- The Russian Federation
- Singapore
- Turkey
- The Ukraine
- The United Kingdom (UK)
-
Indonesia, Ethiopia, Netherlands, Poland, Spain, Kuwait, Malaysia, Qatar, Saudi Arabia, Thailand, Vietnam, United Arab Emirates
It is not intended to process the personal
information of individuals in other categories
or locations. |
| What
categories of personal data are processed by this
activity? |
Sensitive
Personally Identifiable Information:
- Ethnicity
- Gender
or Gender Identity
- Job Level
Personal Information: First Name, Last Name, Business E-Mail, BEMS ID, Level 2 Name (Business Unit and Enterprise Function Code), Level 3 Name, Level 4 Name, Major Function (Type of Work), Base Level (Job level in system), Work Location, Work Country, Work State. |
| What
are
the purposes of
processing personal data in this activity? |
Eligibility information is provided to BetterUp to enable access for users and to create reports about participant usage of the BetterUp services. Personal information is collected by BetterUp during coaching to provide insights on Seek, Speak & Listen behaviors. |
| Are there different legal basis for processing relied on for highly-regulated jurisdictions such as the European Economic Area? |
Boeing relies on its legitimate interest to process the data of individuals in jurisdictions such as the United States. In other jurisdictions, Boeing obtains an individuals consent prior to any data being transferred to the vendor (BetterUp.) |
| 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.
The users would not be able to be loaded into the application for usage. For HSPII/SPII data, BetterUp would be unable to provide required aggregated, de-identified data views for Boeing's Employee Listening team. |
| Who are
the recipients of the personal data in this activity? |
BetterUp receives data from individuals. Boeing receives aggregated data from BetterUp. Boeing program administration (HR, IT) will receive Name, Business Email, Job Role and Job title and usage frequency by individual from BetterUp. |
| In what
countries will the personal data be processed? |
The personal information will be used by business processes based in the United States.
The personal information will be stored only in the United States.
|
| How long
will the personal data be retained by this activity? |
BetterUp will store data for the duration of the agreement between BetterUp and Boeing and for a maximum of seven years.
Consent data through Perceptyx survey will be stored for 3 years. |
|
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 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 "LD - Leadership Coaching with BetterUp"
data processing activity or otherwise addressed in
another answer above, any applicable privacy rights
may be exercised using
https://boeing.com/privacy/rightsexerciseportal. |
If you have questions or
concerns about privacy issues associated with our "LD - Leadership Coaching with BetterUp"
data processing activity, you may contact the
Boeing Global Privacy Office by:
You
may use
https://boeing.com/privacy/rightsexerciseportal to exercise any
applicable privacy rights for which a self-service capability has
not been offered within the "LD - Leadership Coaching with BetterUp"
data processing activity
or for which other specific instructions do not appear above.
For customers and visitors to our web sites: This notice supplements
the
Boeing Privacy and Cookie Statement.
For employees, contract labor, retirees, and subsidiary employees: This notice
supplements the
Boeing Employee Privacy Notice.
Boeing will periodically review and update
the content of this notice at its discretion.
It was last updated
2024-10-29 17:20:29
(UTC).
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