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     Privacy of Personal Data


     

    STATEMENT OF POLICY

    It is the policy of Eastman Kodak Company ("Kodak") to utilize Personal Data relating to its employees, customers and suppliers only for legitimate business purposes. Such information will be collected, processed, stored and transferred among Kodak locations worldwide, and among Kodak and third parties, only in a manner that is consistent with Kodak business practices and policies, and in compliance with applicable laws.

    BACKGROUND AND GUIDING PRINCIPLES

    As a global organization, Kodak must maintain certain information and exchange that information among its organizations and operations, and with third parties, worldwide. When collecting, processing, storing and transferring Personal Data, management will be responsible for ensuring that such activity is consistent with business practices and policies that are applicable to the particular type of information and consistent with applicable privacy laws. Particular attention will be given to the administration of sensitive information. Oversight of this policy is the responsibility of the Chief Privacy Officer.

    GUIDING PRINCIPLES

    The following principles will apply to the processing of Personal Data in the course of Kodak's business. Personal Data means data relating to an identified or identifiable individual where such data is maintained by Kodak either as electronic data or data held in structured filing systems and where the manner of processing creates a risk to personal privacy.

    1. Kodak will collect and use Personal Data only for legitimate business purposes. Kodak will take reasonable steps to see that such information is collected for specified and legitimate purposes, processed fairly and lawfully, maintained accurately and completely, and deleted or destroyed when no longer required.
    2. Kodak will maintain reasonable security measures to protect Personal Data against risks of unauthorized access, or improper destruction, use, modification, or disclosure.
    3. If Personal Data is made available to third parties without consent of the individual, Kodak will seek contractual or other arrangements with such third parties as to their obligations regarding the security and privacy of such information, except when such arrangements are not necessary or appropriate, as when Personal Data is made available (i) pursuant to law, regulation, court order or administrative agency request; (ii) to comply with a legal obligation; (iii) for use by law enforcement personnel; or (iv) to protect the interests of an employee.
    4. Kodak will also implement other appropriate fair information practices regarding Personal Data dealing with (i) providing individuals with appropriate notice regarding Kodak's use of such information, and (ii) providing consumers with a choice as to whether such information may be used for purposes other than for those disclosed at the time the information is collected.
    5. Kodak will conduct regular audits to ascertain that Personal Data is used and maintained consistent with this policy. Individuals may bring to the attention of management or the Chief Privacy Officer any questions or concerns regarding compliance with this policy.

    IMPLEMENTATION

    Each Kodak organization must adopt guidelines, policies or practices consistent with this policy.