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Privacy Notice concerning our
LD - Enterprise Leadership Coaching Services
Data Processing Activity
(Boeing Data Processing Activity ID Number: 8217)
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 - Enterprise Leadership Coaching Services"
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 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.) |
Third-Party Vendors
The following third-party vendors are currently included in this process:
Cambria
BetterUp
Bluepoint
TIGNUM
Skillsoft |
| Whose
personal data is intended to be processed by this
activity? |
This
activity is intended to process the personal information
of:
-
Employees
- Subsidiary 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:
Personal Information: First Name, Last Name, Business Email, Level, Title, BEMS ID, Phone Number, Work Location, Work Address, Business Unit, Organization, Enterprise Function, Supervisor Name, HRBP Name, OA Name. |
| What
are
the purposes of
processing personal data in this activity? |
Boeing provides professional 1:1 coaching service to leaders at all levels through various coaching providers. Coaching is provided by internal coaches who are also full-time Boeing employees and third-party vendors. Coaching services are available to leaders as a stand-alone service, and coaching services can be integrated into leadership development programs.
Learning & Development (L&D) would like to have access to the requested personal information in order to understand who is utilizing coaching services. This data will be shared as appropriate with colleagues across LT&D, HR and throughout the business in order to provide a well-rounded view of which leaders across different organizations are participating in coaching services. The data will help our teams gather feedback and insights from participants to evaluate the effectiveness of coaching services and improve user experience.
No other personal information and/or details obtained during any of the coaching sessions will be shared with anyone at any time, as this information is held in confidence.
Overall program success and impact data will be shared at an aggregate level with no personal identifiable information included.Boeing’s internal coaching practice obtains the required personal information of coaching clients when a leader requests coaching services, and this information is held on Boeing systems.
Third-party vendors obtain the required personal information of coaching clients, and this information is held on their own systems that have been reviewed by IT and associated security measures reviewed and approved via the IT FFU process and documentation. In certain cases, participants will be invited to complete developmental assessments that will be aggregated to provide an understanding of the effectiveness of coaching services and development changes occurring for users.
In certain jurisdictions, consent will be obtained from participants prior to their participation in this program.Both the internal Boeing coaching practice, as well as all third-party vendors, will provide Boeing with access to the names of all those who have utilized coaching services. All participants of coaching services will be entered into My Learning. Tableau Dashboards will provide views into the production, implementation, metrics, and platforms of coaching services in order for our organization and others to make data driven decisions, as well as support Learning, Talent & Development programs and strategy.
The following third-party vendors are currently included in this process: Cambria, BetterUp, Bluepoint, TIGNUM and Skillsoft. |
| What is
the legal basis for processing personal data in this
activity? |
Processing
is necessary for purposes of legitimate interests
pursued by
The Boeing Company:
|
| 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.
Failure to provide the personal information would result in the inability to report back to internal Boeing leaders on the utilization of coaching services. |
| Who are
the recipients of the personal data in this activity? |
The recipients of the personal information in this activity may include Learning, Talent & Development managers, HR managers, leaders across the business where this information would be pertinent, the Head of Coaching or Coaching focal, or internal coaches who manage the coaching practice. |
| 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 only be stored in the United States.
|
| How long
will the personal data be retained by this activity? |
The data will be retained at least during the period of employment and afterwards for a period required by labor statutes and other laws where the data subject resides. |
|
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 - Enterprise Leadership Coaching Services"
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 - Enterprise Leadership Coaching Services"
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 - Enterprise Leadership Coaching Services"
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
2025-05-30 22:42:32
(UTC).
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