Organization Information:

ITT Corporation
4 West Red Oak Lane
White Plains, New York - NY 10604
Phone: 914 641-2000
Fax: 914-646-2971
http://www.itt.com
Contact Information:

Contact Office: Human Resources Department
Contact Name: Kevin Marvel, Director E-HR
Phone: 201-760-5769 Fax: 914-696-2964 Email: kevin.marvel@itt.com

Corporate Officer Information:

Corporate Officer: Daniel S. Kelly, Asst. Secretary & Deputy General Counsel
Phone: 914-696-2152 Fax: 914-696-2971 Email: dan.kelly@itt.com

Safe Harbor Information:

Signed up to safe harbor 04/17/2008 09:51:45 AM
Next certification 04/17/2010
EU/EEA Countries From Which Personal Information Is Received: Austria, Belgium, Czech Republic, Denmark, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Netherlands, Norway, Poland, Portugal, Spain, Sweden, United Kingdom
Industry Sector: Defense Industry Equipment - (DFN) Water Resources Eqpt & Services - (WRE) Pumps Valves & Compressors - (PVC) Automotive Parts & Service Equipment - (APS)
Personal Information Received From the EU: I. INTRODUCTION.
ITT Corporation (“ITT”) strives to properly address applicable data protection and privacy legal requirements. ITT recognizes that the European Union (“EU”) has an “omnibus” data protection regime established pursuant to the European Data Protection Directive (95/46/EC) (the “Directive”). Among other things, the Directive generally restricts the transfer of personally identifiable information about ITT employees in the European Union (“EU Personal Information”) to ITT operations in the United States, unless there is “adequate protection” for such EU Personal Information when it is received in the United States. In order to address this restriction, ITT adheres to the U.S./EU Safe Harbor Privacy Principles published by the U.S. Department of Commerce (“Safe Harbor”) with respect to EU Personal Information that it receives in the United States from the EU. For more information about the Safe Harbor, please refer to the U.S. Department of Commerce website at
http://www.export.gov/safeharbor/
.

II. SCOPE.
This ITT Safe Harbor Privacy Policy (“Safe Harbor Policy”) provides the employees of ITT’s
branches, subsidiaries, and affiliates in the EU with certain important information about how ITT handles their EU Personal Information in the United States in accordance with the Safe Harbor. This Safe Harbor Policy does not apply to data about employees located outside of the EU or otherwise outside the scope of the Directive, such as employees in the United States and other non-EU jurisdictions. All employees should check with their local Human Resources Department for further information about ITT policies and procedures related to EU Personal Information.

III. EU PERSONAL INFORMATION TRANSFERS.
The types of EU Personal Information that ITT may receive in the United States include:
· Personal and family information, including name (and maiden and/or former name(s), if applicable); contact information (including home address, supplemental address, email addresses and phone number); date of birth; place of birth; marital status; language preference; gender; education history; achievement; personal history; immigration status nationality; work authorization status, and prior work history.
· Employment related information, including work contact information (telephone number and email address); job title; job description; hire date; salary; bonus; incentive awards employment history; job performance and benefits related information. ITT also may collect certain information regarding an employee’s spouse, partner, family members or other dependents for emergency contact, expatriate assignment, benefits administration or restructuring, recruiting or outplacement purposes.

IV. USES OF EU PERSONAL INFORMATION.
ITT will use and otherwise process EU Personal Information in the United States for various purposes, including:
· Workflow management, such as assigning, managing and administering projects;
· Compensation, including stock plan administration, compensation analysis and other company recognition programs;
· Job grading activities;
· Performance management;
· Organizational development and succession planning;
· Benefits and personnel administration including bonuses;
· Helpdesk and IT support services;
· Litigation evaluation, prosecution and defense;
· Compliance investigations;
· Diversity and Inclusion initiatives;
· Shareholder management;
· Restructuring;
· Emergency contacts and services.
As necessary in connection with these purposes, ITT Human Resources Department personnel and, on limited occasions, relevant business managers in the U.S. may access and otherwise process EU Personal Information in connection with their job responsibilities. ITT takes appropriate steps to ensure that such personnel are bound to duties of confidentiality with respect to EU Personal Information.

V. CHOICE AND ONWARD TRANSFER.
ITT intends to use EU Personal Information for the purposes for which such data was originally collected and does not intend to disclose EU Personal Information to any third party, except with the appropriate consent of the affected individuals or as otherwise permitted under the Safe Harbor.

VI. DATA SECURITY AND DATA INTEGRITY.

ITT maintains reasonable e security measures to safeguard EU Personal Information from loss, misuse, unauthorized access, disclosure, alteration or destruction. ITT also maintains
reasonable e procedures to help ensure that such data is reliable for its intended use, accurate, complete and current.

VII. ACCESS.
Employees have the ability to access, review and update their own EU Personal Information in accordance with applicable law. Employees should transmit requests for access to their own EU Personal Information, in writing, to the Human Resources Department and/or to the Safe Harbor Privacy Contact identified below. If a ITT employee in the EU is aware of changes or inaccuracies in his or her EU Personal Information of which ITT is not aware, the employee is responsible for informing the local Human Resources Department and/or the Safe Harbor Contact of such changes so that the EU Personal Information may be updated or corrected.
VIII. DISCLOSURES REQUIRED OR PERMITTED BY LAW.
Regardless of any other provisions in this Safe Harbor Policy, ITT may disclose or otherwise
process EU Personal Information in the context of any sale or transaction involving all or a
portion of the business, or as may be required or permitted by law and/or the Safe Harbor.

Privacy Policy Effective: March 20, 2008
Location: http://my.itt.com/portal/server
Regulated by: Federal Trade Commission
Privacy Programs: None
Verification: In-house
Dispute Resolution: ITT commits to cooperate with the data protection authorities located in the European Union or their authorized representatives. In addition, ITT Corporation's compliance group provide each employee with a means of seeking recourse elsewhere in the company for unresolved complaints at different levels within the company.
Personal Data Covered: On & Off line data to include HR 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:

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