|
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.) |
Credly |
| Whose
personal data is intended to be processed by this
activity? |
This
activity is intended to process the personal information
of:
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: Name, BEMSID for Boeing employees, work email address for Boeing employees |
| What
are
the purposes of
processing personal data in this activity? |
Credly is a platform that allows learning participants to receive a digital credential (such as a digital badge) showing the completion of coursework that entitles them to that credential. This activity and platform support career development and acquiring new skills and knowledge. The digital badges are lifelong and learning participants can carry with them in their career journey and be posted on social media or on career networking sites. |
| What is
the legal basis for processing personal data in this
activity? |
Processing
is necessary for the performance of a contract to which
the data subject is a party or in order to take steps at
the request of the data subject prior to entering into a
contract.
|
| Additional Privacy Notice and Information for Credly |
• Obtaining a digital badge with Credly is a voluntary activity.
• Learning participants may review the Credly Privacy Policy at https://www.credly.com/privacy which contains information regarding Credly’s privacy practices, your privacy rights, and how to contact them if you have any questions.
• The Credly platform is neither owned nor maintained by Boeing. Boeing employees as well as the general public who choose to receive a badge provided by Credly understand, agree, and acknowledge that they are using it at their own risk. |
| Credly Usage Tips |
• Badge profiles through Credly can be public or private.
• If learning participants wish to keep their profiles nonpublic/non-viewable, account settings need to be adjusted under the Privacy and Security Account settings on the user account.
• Boeing employee users may may update their account with their personal email address if they wish to keep their account after leaving employment. |
| What are the legal bases for processing in this activity? |
For data subjects that have an employment relationship with Boeing, legitimate interests of employee well-being and career development are the legal bases for processing personal information in this activity. For non-Boeing users, informed consent is received through the Privacy Notice at the front end activity that is providing the learning. Learnworlds is the current learning provider of education and has a Privacy Notice at the point of sign-up for an account. The Data Processing Agreement for Learnworlds indicates the usage of Zapier as a subprocessor that facilitates the movement of learning participant information to Credly for issuing of badges. |
| 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 required.
This activity would require the processing of personal information in order to get the digital badge. Learning participants may choose to not provide the personal data needed to issue the badge, but would not be able to receive the badge from Credly. |
| Who are
the recipients of the personal data in this activity? |
The recipients of the personal information may include select members of the Boeing Learning Development team. |
| 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 for as long as the learning participant wishes. The data subject has control over the retention of their data with Credly. If the learning participant is a Boeing employee and separates from the company, the user may still continue to use Credly by changing their profile to use their personal email address instead of their work email address to retain their digital badges. |
|
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 - Digital Credentials with Credly"
data processing activity or otherwise addressed in
another answer above, any applicable privacy rights
may be exercised using
https://boeing.com/privacy/rightsexerciseportal. |
