Intelsat Corporation Safe Harbor Privacy Policy
Purpose
This privacy policy (“Policy”) contains the principles that Intelsat Corporation, including its subsidiaries and affiliates in the United States (collectively referred to as "Intelsat"), applies to Human Resource Personal Information (as defined below) relating to residents of the European Union (“EU”) (individuals in the EU are collectively referred to as "EU individuals" in this Policy).
"Personal Information" means any information that can be used directly or indirectly to identify, locate or contact a living person. If the information has been irreversibly stripped of all identifiers such that an individual cannot be identified or re-identified, it is no longer Personal Information.
"Human Resource Personal Information" (or “HRPI”) means any Personal Information pertaining to any of Intelsat’s EU individual employees, retirees, independent contractors, contractor employees or beneficiaries identified by its employees.
Scope
This Policy applies to all Intelsat employees, independent contractors and contractor employees in the United States, who, as part of their responsibilities for Intelsat, have access to any HRPI.
This Policy applies to all HRPI received by Intelsat in the United States from EU individuals, in any format including electronic, paper or verbal.
Safe Harbor Framework
The United States Department of Commerce, in consultation with the European Commission has established a safe harbor framework (“Safe Harbor”). Certifying compliance with the Safe Harbor requirements allows U.S. firms to demonstrate that they provide adequate protection for personal data pertaining to EU individuals.
Intelsat’s Privacy Standards
Commitment to the Safe Harbor Framework: Intelsat is committed to upholding the Safe Harbor framework for HRPI pertaining to residents of the EU. As part of this commitment, Intelsat adheres to the Safe Harbor principles, as further described below.
Notice: Intelsat informs EU individuals about the purpose(s) for which it collects and uses their HRPI, the types of third parties who will be given access to the information; the choices and means offered to individuals for limiting the use and disclosure of their HRPI, and how to contact Intelsat for any questions or complaints.
Consistent with the Safe Harbor principles, notice is not required in certain situations, such as when the processing of EU Personal Information is necessary to respond to a government inquiry; is required by applicable laws, court orders or government regulations; or is necessary to protect Intelsat's legal interests if providing notice would interfere with those interests.
Choice (Consent): Intelsat will provide individuals the opportunity to choose (“opt out”) whether their HRPI is (a) to be disclosed to a third party or (b) to be used for purposes incompatible with the purpose(s) for which the information was originally obtained or later authorized by the individual, except in the limited situations where a legal exception to obtaining consent applies. Where consent is obtained, Intelsat provides EU individuals with the opportunity to withdraw consent at any time (opt out).
For sensitive information, Intelsat will provide individuals an affirmative (opt in) choice if the HRPI is to be disclosed to a third party or used for purpose(s) other than those for which it was originally collected or subsequently authorized, except in the limited situations where a legal exception to obtaining consent applies.
Consent is not required from employees to collect and process their HRPI for purposes relating to their employment. However, consent is required to use an associate’s Personal Information for a non-job related purpose.
Onward Transfers: Intelsat will only transfer HRPI to a third party if that third party (a) has provided satisfactory assurances to Intelsat that it will protect the information consistent with the Safe Harbor requirements; (b) is located in the EU or a country considered "adequate" for privacy by the EU Commission, and therefore is required to comply with the EU data protection laws or substantially equivalent privacy laws; or (c) the third party has also certified to the Safe Harbor, and, accordingly, is independently responsible for complying with the Safe Harbor requirements.
Security: Intelsat takes reasonable steps to protect HRPI in its possession from loss, misuse, unauthorized access, disclosure, alteration and destruction. Data Integrity: Intelsat takes reasonable steps to ensure that HRPI is accurate, complete, current and otherwise reliable and relevant in relation to the purpose for which the information was obtained.
Access and Correction: Intelsat will permit reasonable access by EU individuals to their HRPI held by Intelsat, with the accompanying right to correct, amend, or delete the information for accuracy, if necessary, except where the burden or expense of providing access would be disproportionate to the risks to the individual's privacy in the case in question, or where the rights of persons other than the individual would be violated.
Enforcement: Intelsat has established internal mechanisms to assure compliance with the Safe Harbor Principles, recourse for individuals to whom the HRPI relate affected by non-compliance with the Safe harbor Principles, and consequences for Intelsat when the Safe Harbor Principles are not followed. Appropriate disciplinary action will be taken against individuals who violate the Policy.
Dispute Resolution
Intelsat has implemented an internal dispute resolution process for Safe Harbor complaints. Intelsat commits to cooperate and comply with the EU Data Protection Authorities for purposes of handling unresolved complaints involving HRPI.
Contact Information
For additional questions, complaints, access requests, and any other issues arising under the Safe Harbor, please write to us at:
Executive Vice President & Deputy General Counsel
Legal Department
Intelsat Corporation
3400 International Drive NW
Washington, DC 20008
