Human Resources Privacy Policy
Grass Valley Safe Harbor Privacy Policy
Purpose
This Safe Harbor Privacy Policy (the "Policy") contains the principles that Grass Valley applies to Human Resource Personal Information relating to residents of the European Union (EU), Canada or Switzerland. (For simplicity purposes, individuals in the EU, Canada and Switzerland 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 considered Personal Information.

"Human Resource Personal Information" (or "HRPI") means any Personal Information pertaining to any of Grass Valley's employees (referred to herein as associates), retirees, independent contractors, contractor employees or beneficiaries identified by its associates.

Scope
This Safe Harbor Privacy Policy applies to all Grass Valley employees, independent contractors and contractor employees in the United States, who, as part of their responsibilities for Grass Valley, have access to any HRPI relating to EU individuals. This Policy applies to all HRPI received by Grass Valley 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 and the Federal Data Protection and Information Commissioner of Switzerland, has established the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework ("Safe Harbor"). Certifying compliance with the Safe Harbor requirements allows United States firms to demonstrate that they provide adequate protection for personal data pertaining to EU individuals.

Grass Valley's Privacy Standards
Commitment to the Safe Harbor Framework: Grass Valley is committed to upholding the Safe Harbor frameworks for HRPI pertaining to residents of the EU, Canada and Switzerland. As part of this commitment, Grass Valley will uphold the following Safe Harbor principles:

Notice. Grass Valley 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 Grass Valley 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: (i) necessary to respond to a government inquiry, (ii) required by applicable laws, court orders or government regulations; or (iii) is necessary to protect Grass Valley's legal interests if providing notice would interfere with those interests.

Choice (Consent). Grass Valley will process HRPI pertaining to EU individuals only for the purposes 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, Grass Valley provides EU individuals with the opportunity to withdraw consent at any time, in which case their HRPI will not be further processed. Consent is not required from associates to collect and process their Personal Information for purposes relating to their employment. However, consent is required to use an associate's Personal Information for any non-job related purpose.

Onward Transfers. Grass Valley will only transfer HRPI pertaining to EU individuals to a third party only if that third party: (i) has provided satisfactory assurances to Grass Valley that it will protect the information consistent with the Safe Harbor requirements; (ii) is located in the EU or a country considered adequate for privacy by the EU Commission which is already required to comply with the EU data protection laws or substantially equivalent privacy laws; or (iii) the third party has also self-certified to the Safe Harbor requirements and is therefore already independently responsible for complying with such requirements.

Security. Grass Valley takes reasonable steps to protect HRPI pertaining to EU individuals in its possession from loss, misuse, unauthorized access, disclosure, alteration and destruction.

Data Integrity. Grass Valley takes reasonable steps to ensure that HRPI pertaining to EU individuals is accurate, complete, current and otherwise reliable and relevant in relation to the purpose for which the information was obtained.

Access and Correction. Grass Valley will permit reasonable access by EU individuals to their own HRPI held by Grass Valley, with the accompanying right to correct the information for accuracy, except in instances where the burden or expense to Grass Valley of providing access would be disproportionate to the risks to the individual's privacy, or where the rights of persons other than the individual would be violated.
Enforcement. Grass Valley has established internal mechanisms to verify its ongoing adherence to this Policy. Appropriate disciplinary action will be taken against individuals who violate the Policy.

Dispute Resolution
Grass Valley has implemented an internal dispute resolution process for Safe Harbor complaints. For disputes that are not resolved through such process, Grass Valley agrees to submit to the jurisdiction of the EU Data Protection Authorities for unresolved disputes involving the HRPI of any individual from the EU, as well as to that of the Federal Data Protection and Information Commissioner of Switzerland for unresolved disputes involving the HRPI of any individual from Switzerland.

Contact Information
For additional information, please write to us at:

Privacy Officer - Legal Department
Grass Valley
3030 NW Aloclek Drive
Hillsboro, OR 97124
United States of America
Sales/USA +1 530 265 1000/Canada +1 514 333 1772/LATAM +1 786 845 5600/Europe +44 (0) 118 952 3400/Asia +852 2539 6987
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