European Safe Harbor


Delphi EU - US Data Privacy Safe Harbor Policy

Delphi, and its subsidiaries and affiliates, respect the privacy of their employees and are committed to protecting employee data maintained by the company. Due to the global nature of Delphi's business, transfers of employee Personal Data, defined below, across national boundaries may occur. As a result, Delphi and its affiliated U.S. entities ("Delphi") have adopted this Safe Harbor Data Privacy Policy ("the Privacy Policy") and adhere to the Safe Harbor Principles published by the U.S. Department of Commerce, in agreement with the European Commission, with respect to employee Personal Data transferred from the European Union to the United States of America regarding Delphi employees employed within the European Union ("EU Based Employees").

This Policy applies to all employee Personal Data received by Delphi in the United States from the European Union ("EU") in any format. For the purpose of this Policy, "Personal Data" or "Personal Information" is employee data about an identified or identifiable EU Based Employee, received by Delphi in the U.S. from the EU and recorded in any form.

NOTICE

Delphi receives employee Personal Information in connection with the management and administration of pre-employment, employment and post-employment matters. Delphi notifies EU Based Employees in the EU about the purposes for which their Personal Information is collected and used. Delphi will use the information for business operations, employee development, administration and planning, or when required in the course of judicial or administrative proceedings, subject to all nondisclosure safeguards available. Below are listed the general categories of third parties with whom Delphi may share this Personal Information. Notice to EU Based Employees will be provided before Delphi uses the information for purposes other than for which it was collected, or before it discloses the information to categories of third parties not specified in this policy.

CHOICE

Delphi gives its EU Based Employees the opportunity to opt out from allowing Delphi to disclose their Personal Information to a third party or to use it for a purpose incompatible with the purpose for which it was originally collected or authorized. To exercise this opt out, an EU Based Employee should contact his or her site Human Resources Representative.

With respect to sensitive data (for example, political or religious beliefs, union membership, health matters...), Delphi will not share such information unless specifically authorized by the individual EU Based Employee.

TRANSFER TO THIRD PARTIES

Delphi may share employee data with third parties that provide certain services to Delphi, including but not limited to outside accountants and lawyers, consultants and service providers. Prior to transferring Personal Data within the Delphi Group, Delphi will ensure that the protection and transfer of such Personal Data complies with the Safe Harbor Principles.

Delphi may transfer Personal Data to a third party acting as an agent for Delphi by having the third party enter into an agreement with Delphi in which the third party promises to provide the same level of protection as required by the Safe Harbor Principles. If the third party agent does not comply with its privacy obligations, Delphi will take commercially reasonable steps to prevent or stop the use or disclosure of Personal Data.

SECURITY

Delphi takes reasonable measures to protect Personal Information from loss, misuse, and unauthorized access, disclosure, alteration or destruction. These measures include password protection for online information systems and restricted access to Personal Data processed by the Human Resources Department.

DATA INTEGRITY

Delphi does not process Personal Information in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by the individual. Delphi will take reasonable steps to ensure that Personal Information is relevant for its intended use, accurate, complete and current.

ACCESS

Upon request, Delphi will provide EU Based Employees with reasonable access to Personal Information that it holds about them and will take reasonable steps to permit the employees to correct, amend, or delete any Personal Information which is inaccurate or incomplete.

An EU Based Employee who wants to have access to his or her Personal Information should provide a written request to his or her site Human Resources Representative.

ENFORCEMENT

Annual internal compliance reviews of the Privacy Policy will take place as part of the certification process with the U.S. Department of Commerce.

If a complaint regarding Delphi's use of Personal Information is raised by an EU Based Employee, Delphi will investigate and try to resolve any dispute. If the dispute cannot be resolved, Delphi will participate in the dispute resolution procedures of the panel established by the European Data Protection Authorities.

Any questions or concerns regarding the use or disclosure of Personal Information should be directed to the office of the Delphi's Chief Compliance Officer indicated below.

By mail:

    Delphi Chief Compliance Officer
    5725 Delphi Drive
    Troy, Michigan 48098-2815
    USA
    Facsimile: +1 248.813.2491

By email: DRIVEcompliance@delphi.com

AMENDMENT

The Delphi Privacy Policy may be amended from time to time in compliance with the requirements of the Safe Harbor Principles. Appropriate notice will be given concerning such amendments.