Other Covered Entities

ACCO Brands Corporation
ACCO Brands USA LLC
General Binding, LLC.

Participation

EU-U.S. Privacy Shield Framework: Active

Original Certification Date: 1/19/2017
Next Certification Due Date: 4/18/2020
Data Collected: HR, NON-HR

Swiss-U.S. Privacy Shield Framework: Active

Original Certification Date: 4/17/2019
Next Certification Due Date: 4/18/2020
Data Collected: HR, NON-HR

Purpose of Data Collection

1. Types of Personal Data Processed by ACCO Brands: Human resources data and personal data other than human resources data (a) Human resources data - Personal data relating to ACCO Brands and its international subsidiaries' staff (that is, their current and former employees, prospective employees/applicants, temporary workers, contract workers, consultants and site personnel) including: personal details; family details; educational and training details; and employment details. (b) Personal data other than human resources data - Customer Contact Data is personal data relating to ACCO Brands' current and prospective customers (including, personal data relating to business contacts at customers). Also, Supplier Contact Data is personal data relating to business contacts at ACCO Brand's current and prospective suppliers. 2. Processing Purposes: ? HR Data: To facilitate the ACCO Brands' conduct of its lawful business activities, including, but not limited to, employment activities, HR support, and employee management as needed or advisable for the operation of the ACCO Brands' businesses. ? Personal data other than human resources data: (i) To administer the relationship with a customer or supplier. (ii) To maintain existing customer relationships, facilitate the promotion of ACCO Brands' products and solutions, and identify prospective customers. (iii) To manage ACCO Brand's relationship with third party business partners and suppliers. 3. Types of Third Parties to which ACCO Brands discloses data: ? Service providers or vendors ? Potential acquirers or purchasers in relation to disposals of any of ACCO Brand's business or assets

Privacy Policy

HR Data

ACCO Brands HR Privacy Shield Statement
Description:

ACCO Brands HR Privacy Shield Statement describes our commitment to comply with the EU - US Privacy Shield Principles with respect to all Employee Personal Data that we receive from the European Economic Area. The Statement is posted on ACCO Brands' intranet site and is available for viewing by affected employees.

Effective Date: 9/28/2016

Non-HR Data

Description:

XXX

Effective Date: 1/31/2019
Description:

ACCO Brands Privacy Shield Statement describes our commitment to comply with the EU - US and Swiss-US Privacy Shield Principles with respect to all non-HR Personal Data that we receive from the European Economic Area, the United Kingdom, or Switzerland. This Statement is available on ACCO Brands public website.

Effective Date: 2/26/2019

Verification Method

Self-Assessment

Dispute Resolution

Questions or Complaints?

If you have a question or complaint regarding the covered data, please contact ACCO Brands Corp. at:

Michael Kier
Vice President, Associate General Counsel
ACCO Brands Corp.
4 Corporate Blvd.
Lake Zurich, Illinois 60047

Privacy Shield organizations must respond within 45 days of receiving a complaint.

If you have not received a timely or satisfactory response from ACCO Brands Corp. to your question or complaint, please contact the independent recourse mechanism listed below


NON-HR RECOURSE MECHANISM



Appropriate statutory body with jurisdiction to investigate any claims against ACCO Brands Corp. regarding possible unfair or deceptive practices and violations of laws or regulations covering privacy Federal Trade Commission