Purpose of this Notice

McKesson Corporation, its subsidiaries, and affiliates (together, "McKesson"), may provide its employees, business partners, consultants, independent contractors, and others acting on McKesson’s behalf (together "Worker," "Workers," "You," "Your") with computing and communications equipment, software, and digital content for Worker to use in conducting McKesson business. As part of its electronic system and communications program, McKesson has engaged Microsoft to provide Office 365 services to McKesson. The purpose of this Office 365 Privacy Notice ("Notice") is to inform Workers about McKesson’s practices regarding the collection, use, disclosure, transfer, and other processing of personal information relating to Worker in connection with the Office 365 platform.

Scope

This Office 365 Privacy Notice applies to all Workers granted access to Office 365 using a McKesson license across all McKesson entities and business units, in all locations worldwide, regardless of employment type. Third parties such as business partners, consultants, and contractors who are granted access to McKesson’s Office 365 should also be provided this Notice. This Notice is subject to change if there are changes in local law or legal requirements.

General Terms

McKesson Office 365 is a cloud-based service that provides access to Microsoft Office tools and applications, such as Outlook, Skype, InTune, Word, Excel, Access, Publisher, PowerPoint, and OneDrive. McKesson’s Office 365 will be accessible to Workers through the Internet even when not on-site at a McKesson facility. Worker may store documents and collaborate on the cloud through Office 365; some Workers may also access McKesson email services through Office 365. Access to Office 365, including remote access, is subject at all times to McKesson’s current Information Security and IT Risk Management policies policies. The description of the Office 365 offering is subject to change and dependent on Microsoft’s current Office 365 service offerings. For more information about Office 365 contact the McKesson O365 Program Office.

Per McKesson’s Acceptable Use Policy, all computing equipment, software, and information furnished to Workers are McKesson property to be used for business purposes only. By using McKesson’s systems, you understand that you have no expectation of privacy. Some jurisdictions may provide greater or different privacy protections; McKesson will follow the applicable laws, rules, and regulations of your local jurisdiction where appropriate.

Personal Information

McKesson collects three primary categories of Personal Information in connection with Office 365

  • Personal identifying information
  • Log and usage information
  • Contact Information

Personal identifying information: This information includes things such as your name, Active Directory user ID and password, and personal contact information such as your email address.

Log and usage information: This category of information relates to the activities of Worker on Office 365. McKesson may collect information, for example, about how you interact with Office 365, what date and time you log on and off, what applications you have used, what queries you submit, and any technical difficulties you encounter.

Content: This category of information encompasses all content created, uploaded, stored, maintained, or otherwise processed through Office 365.

McKesson computing facilities, including Office 365, are provided for business purposes only. Personal software and/or digital content may not be supported, backed up, or recovered by IT. Workers should have no expectation of privacy in the personal information provided to McKesson in connection with their use of Office 365. As noted above, some jurisdictions may provide greater or different privacy protections; McKesson will follow the applicable laws, rules, and regulations of the applicable jurisdiction where appropriate.

Content & Confidential Information

Workers may create, upload, store, and manage content using Office 365. Workers are expected to abide by McKesson’s Acceptable Use Policy when creating and uploading content. McKesson strives to maintain a workplace free of harassment and sensitive to the diversity of its workforce and therefore prohibits the use of McKesson computers and communications systems in ways that are offensive to others, as set forth in the McKesson Acceptable Use Policy. For example, you are prohibited from the display or transmission of sexually explicit images. Other misuse includes the use of ethnic and racial slurs.

Workers are responsible for safeguarding confidential information related to McKesson business. If you access Office 365 from non-McKesson facilities, McKesson Workers must not transmit, download, or otherwise expose or compromise McKesson confidential information when using public or otherwise non-trusted computers or devices.

Purpose and Use of Information

McKesson uses the Personal Information and other information listed above for the purpose of its normal business operations, including archiving, e-discovery, troubleshooting, and the functioning of McKesson’s data loss prevention program.

Categories of Recipients of Information

McKesson: McKesson may share Worker Personal Information and other information associated with or accessible through your Office 365 account with authorized McKesson Workers who need access for the purposes described above, including Workers from the following departments: Human Resources, Information Technology, and the General Counsel Organization. In addition, McKesson may share Worker Personal Information and other information with managers consistent with McKesson’s Worker Data Privacy Policy, such as where disclosure is necessary to comply with valid legal processes, government requests, or applicable laws, rules, and regulations; to investigate, remedy, or enforce McKesson policies; to protect the rights, property, and safety of McKesson employees, our clients, or others; and to detect and resolve any fraud or security concerns.

External Service Providers: McKesson may share Worker Personal Information and other information associated with or accessible through your Office 365 account with third party service providers, including Microsoft; information technology systems providers; consultants and professional advisors; and other service providers involved in the provision of services to McKesson and/or our employees.

Authorities: McKesson may share Worker Personal Information and other information associated with or accessible through your Office 365 account with local authorities and other parties in accordance with local regulations, or as part of internal investigations within McKesson. Worker Personal Information and other information may also be shared to respond to internal or external audit and inquiries, law enforcement requests, or where required by applicable laws, court orders, or government regulations or authorities.

Worker Personal Information and any other information on the Office 365 platform may also be disclosed in any manner consistent with the McKesson Worker Data Privacy Policy.

International Transfer of Personal Information

McKesson may transfer Worker Personal Information to providers located in the European Economic Area, in the United States, or otherwise to jurisdictions not considered to provide a level of protection equivalent to the laws of your jurisdiction. When transferring Personal Information to those recipients, McKesson will implement appropriate contractual or other measures recognized by local law, as may be required to effectuate the transfer.

Access to Personal Information

As described in the Worker Data Privacy Policy, subject to certain exceptions, some jurisdictions provide that Workers are entitled to access Personal Information held about them, have the right to have inaccurate information corrected or removed, and the right to object to the processing of their Personal Information. Please contact privacy@mckesson.com in connection with such requests.

Changes and Questions

If there are any material changes to the way McKesson collects or uses Personal Information in connection with Office 365, McKesson will notify Workers by issuing a revised Notice. If you have any questions about this Notice, please contact privacy@mckesson.com.