This Privacy Statement is effective as of June 25, 2018.
Pitney Bowes is committed to respecting the privacy of our employees. This Privacy Statement describes how the Pitney Bowes intranet site, and Human Resources portals operate, and how we collect, use, and share information.
This employee Privacy Statement applies to ourpb.com and other Pitney Bowes intranet sites, Human Resources portals and third-party partner portals that collects, and stores data and display these terms. Pitney Bowes intranet sites, and Human Resources portals that are owned and operated by Pitney Bowes and Pitney Bowes subsidiaries, collectively, “Pitney Bowes” are referred to in this statement as “Sites” and third-party partner portals that are owned and operated by our partners are referred to in this statement as “Partner Sites”. These terms do not apply to Pitney Bowes sites that do not display or link to this statement or that have their own privacy statements.
1. Collecting Personal Information from you
In order to provide you with access to certain services or data within our Sites or Partner Sites, we may require that you provide certain Personal Information (information that identifies an individual either alone or in combination with other data). Pitney Bowes also collects non-Personal Information that does not, on its own, identify an individual person. When non-Personal Information is combined with other information so that it does identify an individual person, we treat that combination as Personal Information.
We collect and maintain different types of Personal Information in respect of those individuals who seek to be, are, or were employed by us, including the Personal Information contained in:
• resumes and/or applications;
• references and interview notes;
• photographs and video;
• letters of offer and acceptance of employment;
In addition to the examples listed above, Personal Information also includes information such as:
• Contact information (including Name, Street Address, Email Address, Telephone Number)
• Username, and other information used in combination to verify identity, employee identification number
• Payroll information, banking details
• Sick pay, Paid Time Off (“PTO”), retirement accounts, pensions, insurance and other benefits information (including the gender, age, nationality and passport information for any spouse, minor children or other eligible dependents and beneficiaries)
• Date of hire, date(s) of promotions(s), work history, technical skills, educational background, professional certifications and registrations, language capabilities, and training records
• Employee stock information
• Salary history and expectations, performance appraisals, letters of appreciation and commendation, and disciplinary and grievance procedures (including monitoring compliance with and enforcing our policies)
• Acknowledgements regarding our policies, including employee handbooks, ethics and/or conflicts of interest policies and computer and other corporate resource usage policies
• Voicemails, e-mails, correspondence, documents, and other work product and communications created, stored or transmitted using our networks, applications, devices, computers or communications equipment
• Your resume or CV, cover letter, previous and/or relevant work experience or other experience, education, transcripts, or other information you provide to us in support of an application and/or the application and recruitment process
In the United States, our Partner Sites solicit and collect Sensitive Information (as required by federal, state and local governments) about you (such as details relating to racial or ethnic origin) as well as your voluntary self-identification of your disability or veteran status.
Data protection laws do not generally require Pitney Bowes to obtain your consent for the collection, use or disclosure of Personal Information for the purpose of establishing, managing or terminating your employment relationship. In addition, we may collect, use or disclose your Personal Information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.
Where your consent was required for our collection, use or disclosure of your Personal Information, you may, at any time, (subject to legal or contractual restrictions and reasonable notice), withdraw your consent. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to your Human Resources Representative.
By accessing, browsing or using our Sites or Partner Sites, you accept that Pitney Bowes may collect, disclose, store, or process your Personal Information in accordance with this Privacy Statement. You also accept the collection of data relating to your use of the Site for legitimate business and security purposes, including information concerning your identity, the pages that you have accessed, and any information provided by you to the Site, or in chat rooms or other publicly accessible forums.
2. Collecting Personal Information from Third Parties
Generally, we collect Personal Information directly from you in circumstances where you provide Personal Information (during the application or onboarding process, for example). However, in some instances, the Personal Information we collect has been inferred about you based on other information you provide us, through your interactions with us, or from third parties.
When we collect your Personal Information from third parties, it is either because you have given us express consent to do so. In this case, your consent was implied by your actions (e.g., your use of a third-party employee service made available to you by us), or because you provided consent to the third party, or the third party has an additional lawful basis, to provide your information to us.
Where permitted or required by applicable law or regulatory requirements, we may collect Personal Information about you without your knowledge or consent.
For example: when we offered you a job we may:
• have collected references from previous employers;
• obtain information about you from publicly available sources such as your LinkedIn profile or other media/job search sources;
3. Using Personal Information
Personal Information collected is used and disclosed to manage all aspects of a prospective employee or an employees’ employment relationship with Pitney Bowes, including, but not limited to the recruitment, establishment, maintenance, and termination. Examples of activities related to this include:
• marketing and/or notifications (such as SMS messages) of job or employment related opportunities
• marketing of Pitney Bowes related content or events
• conducting performance reviews and determining performance requirements;
• assessing qualifications for a particular job or task;
• compiling directories;
• determining eligibility for initial employment, including the verification of references and qualifications;
• the issuance and management of stock options and restricted stock units;
• disciplinary actions; grievance and internal investigation activities;
• career management, including the assessment of qualifications for a particular job or task;
• processing employee work-related claims (e.g., worker compensation, insurance claims);
• the provision of employee related services; and other general operations;
• to protect the safety and security of our workforce, guests, property, and assets (including controlling and facilitating access to and monitoring activity on and in our premises and activity using our computers, devices, networks, communications and other assets and resources); and
• to comply with applicable laws (e.g. health and safety, employment laws, office of foreign asset controls regulations, tax laws), including judicial or administrative orders regarding individual employees (e.g., garnishments, child support payments).
We will also use Personal Information collected and stored by us primarily to customize the content on the Sites or Partner Sites to improve your experience. Personal Information may also be used for feedback purposes, statistical analysis to improve the content of the Site, and to inform you of special offers negotiated on your behalf. Most of this information on our Sites will be accessible only to you and will not be displayed on the Site. Some of the Personal Information on our Sites may be included as part of content displayed on the intranet including names and business contact information for the purposes of providing an internal directory.
The Site will not contain any Sensitive Information about you (such as details relating to racial or ethnic origin, political opinions, religious beliefs, trade union membership, health or sex life) unless you give your express consent to the use of such information.
In the United States, our Partner Sites may contain Sensitive Information about you (as required by federal, state and local governments, such as details relating to racial or ethnic origin) as well as your voluntary self-identification of your disability or veteran status but this information will be accessible only to you and will not be displayed on the Site.
4. Retaining Personal Information
Except as otherwise permitted or required by applicable law or regulatory requirements, Pitney Bowes endeavors to retain your Personal Information only for as long as it believes is necessary to fulfill the purposes for which the Personal Information was collected (including, for the purpose of meeting any legal, accounting or other reporting requirements or obligations). We may, instead of destroying or erasing your Personal Information, make it anonymous such that it cannot be associated with or tracked back to you.
Personal Information will be stored and processed in a fair and confidential manner in the United States of America on servers owned and operated by Pitney Bowes, and will be available to Company employees worldwide.
5. Sharing Personal Information
We may share your Personal Information with employees, contractors, consultants and other parties who require such information to assist us with recruiting, establishing, managing or terminating our employment relationship with you, including: parties that provide products or services to us or on our behalf and parties that collaborate with us in the provision of products or services to you.
In some instances, such parties may also provide certain information technology and data processing services to us so that we may operate our business. We may share Personal Information with such parties both in and outside of your home jurisdiction, and as result, your Personal Information may be collected, used, processed, stored or disclosed in countries where Pitney Bowes operates, and in some cases, other countries. Personal information is only transferred by us to another country, including within the Pitney Bowes family, if this is required or permitted under the applicable privacy legislation, in particular only in as far as a reasonable level of data protection is assured in the recipient country.
When we share Personal Information with such parties we typically require that they only use or disclose such Personal Information in a manner consistent with the use and disclosure provisions of this Privacy Statement.
In addition, Personal Information may be disclosed or transferred to another party (including to another member of the Pitney Bowes family outside of your home jurisdiction) in the event of a change in ownership of, or a grant of a security interest in, all or a part of Pitney Bowes through, for example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations and required to use or disclose your Personal Information in a manner consistent with the use and disclosure provisions of this Privacy Statement, unless you consent otherwise.
Further, your Personal Information may be disclosed:
• as permitted or required by applicable law or regulatory requirements. In such a case, we will endeavor to not disclose more Personal Information than is required under the circumstances;
• to comply with valid legal processes such as search warrants, subpoenas or court orders;
• as part of Pitney Bowes’s regular reporting activities to other members of the Pitney Bowes family (including outside of your home jurisdiction);
• to protect the rights and property of Pitney Bowes;
• during emergency situations or where necessary to protect the safety of a person or group of persons;
• where the Personal Information is publicly available; or
• with your consent where such consent is required by law.
6. Protecting Personal Information
Pitney Bowes endeavors to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the Personal Information in question. These safeguards are designed to protect your Personal Information from loss and unauthorized access, copying, use, modification or disclosure.
7. Cross Border Data Transfer
Pitney Bowes Inc. and its wholly-owned U.S. subsidiaries that receives Personal Information from countries outside of the United States adhere to applicable law and regulations regarding client, partner and employee Personal Information moving across geographical and jurisdictional borders. This includes the use of data transfer agreements and model contractual clauses, where available, between our corporate entities, our partners and our clients where required.
8. EU-U.S. and Swiss-U.S. Privacy Shield Compliance
Pitney Bowes participates in and has certified its compliance with the EU-US Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the United States Department of Commerce regarding the collection, use, processing and retention of Personal Information transferred from the European Union and Switzerland to the United States.
We have certified to the Department of Commerce that we adhere to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Statement and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit www.privacyshield.gov.
Pitney Bowes is responsible for the processing of Personal Information it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Pitney Bowes complies with the Privacy Shield Principles for all onward transfers of Personal Information from the EU or Switzerland, including the onward transfer liability provisions.
With respect to Personal Information received or transferred pursuant to the Privacy Shield Framework, Pitney Bowes is subject to the regulatory enforcement powers of the United States Federal Trade
Commission. In certain situations, we may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
In compliance with the EU-U.S. and Swiss-U.S. Privacy Shield Principles, Pitney Bowes commits to resolve complaints about your privacy and our collection or use of your Personal Information. If you believe Pitney Bowes processes your Personal Information within the scope of our Privacy Shield certification, you may direct any inquiries or complaints concerning our compliance to us at the following information in the Contact Us section below.
Pitney Bowes will respond within 45 days. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact JAMS, our U.S-based third party dispute resolution provider, free of charge at https://www.jamsadr.com/eu-us-privacy-shield.
If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, you may be able to invoke binding arbitration when other dispute resolution procedures have been exhausted. Please contact or visit the Privacy Shield website at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint for more information or to file a complaint. The services of the Privacy Shield website are provided at no cost to you.
9. Your Rights
Your Rights to Access Personal Information
Where required by law, you may as it relates to your Personal Information (i) request access, (ii) and/or make corrections, (iii) request deletion, (iv) restrict or (v) object to processing, or (vi) request copies to your Personal Information that we maintain. When accessing or updating your Personal Information, we may ask you to verify your identity before we can act on your request.
Please note that we may reject requests, or limit the information we provide access to, if we determine it could risk the privacy of others or if unreasonable or repetitive, or if it would require disproportionate effort. In addition, the Personal Information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices. In the event that we cannot provide you with access to your Personal Information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
As permitted by law, we may charge a reasonable fee for providing access to Personal Information, but we do not charge for lodging a request for access.
If you want to exercise your Personal Information rights, please contact your Human Resources representative or the Data Protection Officer as described in the Contact Us section below. Please note that any such communication must be in writing using the Data Subject Access Request Form.
Your Ability to Correct Personal Information
It is important that the information contained in our records is both accurate and current. If your Personal Information happens to change during the course of your employment, please keep us
informed of such changes. In some circumstances, we may not agree with your request to change your Personal Information and will instead append an alternative text to the record in question.
If it is determined that Personal Information is inaccurate, incomplete or outdated, we will use reasonable efforts to revise it and, if necessary, use reasonable efforts to inform agents, service providers or other third parties, which were provided with inaccurate information, so records in their possession may be corrected or updated.
If you want to make changes to your Personal Information on the Sites, please go to the Employee Self-Service portal, or contact your local Human Resources representative.
If you want to make changes or delete your profile in the Partner Sites, you may do so by (i) indicating your preferences on the relevant account profile/preferences section in your account and (ii) contact firstname.lastname@example.org. Where required by law, you may request access and/or make corrections to your Personal Information that we maintain. When accessing or updating your Personal Information, we may ask you to verify your identity before we can act on your request.
10. Changes to this Privacy Statement
Pitney Bowes may change this Privacy Statement from time to time at its discretion. We will indicate at the top of the Privacy Statement when it was most recently updated. We will not use your Personal Information in ways that differ materially from this Privacy Statement without prior notice to you, and in no event will we use your Personal Information in ways prohibited by law. Your continued use of our Sites or Partner Sites indicates your consent to this Privacy Statement and any amended version of it.
11. Contact Us
If you have any questions about this Privacy Statement or concerns about how we manage your Personal Information, please contact your local Human Resources representative. We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you. If you are unsatisfied with our response, you may be entitled to make a written submission to your local data protection authority.
12. Data Protection Office
We have an appointed Data Protection Officer to oversee compliance with this Privacy Statement. The contact information for our Data Protection Office is as follows:
Global Data Protection Office
c/o Pitney Bowes Inc.
3001 Summer St
Stamford, CT USA 06926-0700
Email us @ email@example.com
Please see below for contact information for the following countries, which should be used if you have a question, comment or compliant about this Privacy Statement for your specific jurisdiction:
If you have any questions, or if you believe that we have not complied with our obligations under the Privacy Act (and, in particular, the Australian Privacy Principals), or if you believe that the Personal Information that we hold about you has been compromised in any way, please contact us as described below. We will respond to any question or complaint as soon as possible.
Global Data Protection Office
c/o Pitney Bowes Australia Pty Ltd
Level 1, 68 Waterloo Road, Macquarie Park,
NSW 2113, Australia
Email us @ firstname.lastname@example.org
Tel: +61 (0)2 9475 3500
If you are dissatisfied with our response, you may direct your complaint to the Office of the Australian Information Commissioner by email at email@example.com or by telephone on 1300 363 992.
If you have any questions or concerns about this Privacy Statement, please contact us at:
Global Data Protection Office
c/o Pitney Bowes Germany GmbH Poststr. 4-6 D-64293 Darmstadt
Email us @ firstname.lastname@example.org
If you have any questions or concerns about this Privacy Statement, please contact us at:
Global Data Protection Office
c/o Pitney Bowes Software India Pvt. Ltd.
5th Floor, Tower- B, Logix Cyber Park,
C 28-29, Sector-62, Noida – 201307
Attn: Ruchi Bhalla
Local Grievance Officer email@example.com
Global Data Protection Office @ firstname.lastname@example.org