Organization Information:

International Business Machines Corporation
New Orchard Road
Armonk, New York - NY 10504
Phone: 202-515-5005
Fax: 202-515-5906
Contact Information:

Contact Office: Director Market Data and Analytics for on-line data
Contact Name: Kimberly A. Atherton, Program Director
Phone: 914-765-2064 Fax: 914-765-2070 Email:

Contact Office: HR Data Privacy and Security Program Manager
Contact Name: Dawn Zanfardino
Phone: 845-689-2287 Email:

Corporate Officer Information:

Corporate Officer: Harriet Pearson, Vice President, Security Counsel and Chief Privacy Officer
Phone: 202-515-2005 Fax: 202-515-5906 Email:

Safe Harbor Information:

Signed up to safe harbor 08/15/2002 01:58:48 PM
Next certification 08/15/2010
EU/EEA Countries From Which Personal Information Is Received: Austria, Belgium, Bulgaria, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, Switzerland, United Kingdom
Industry Sector: Computer & Peripherals - (CPT) Computer Software - (CSF) Computer Services - (CSV)
Personal Information Received From the EU: On-line data: IBM maintains customer records and performs analysis against its customer records in order to perform various customer services activities. Human Resources data: IBM maintains records of current, former and prospective employees to manage and maintain its employee workforce and conduct its business. Privacy Policy Effective: On August 5, 2002; for Human Resources data: June 23, 2009
Privacy Policy Effective: August 5, 2002
Location: : and internal website for Human Resources data
Regulated by: Federal Trade Commission
Privacy Programs: TRUSTe
Verification: Third Party Verification for on-line data and in-house for Human Resources data

Dispute Resolution: On-line data: TRUSTe as a third party provides independent recourse. IBM is a participant in the TRUSTe European Union Safe Harbor Web Privacy Program;Human Resources data: EU Data Protection Authorities

Personal Data Covered: On-Line data and Human Resources Data
Human Resource Data Covered: Yes

Do you agree to cooperate and comply with the European Data Protection Authorities? Yes

Certification Status: Current
Compliance Status:

Safe Harbor Overview | Safe Harbor Documents | Workbook | Safe Harbor List
Information Required for Certification | Certification Form