Towers Watson Safe Harbor Privacy Policy
(Human Resource Personal Information)
Amended December 20, 2011

Purpose

This Safe Harbor Privacy Policy contains the principles that Towers Watson Delaware Inc. (formerly known as Watson Wyatt & Co.) and Towers Watson Pennsylvania Inc. (formerly known as Towers, Perrin, Forster & Crosby, Inc.), including in each case its subsidiaries and affiliates in the United States (collectively referred to in this Policy as "Towers Watson"), apply 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 Personal Information.

"Human Resource Personal Information" (or "HRPI") means any Personal Information pertaining to any of Towers Watson'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 Towers Watson employees, independent contractors and contractor employees in the United States, who, as part of their responsibilities for Towers Watson, have access to any HRPI relating to EU individuals.

This Safe Harbor Privacy Policy (the "Policy") applies to all HRPI received by Towers Watson in the United States from EU individuals, in any format including electronic, paper or verbal.

This Policy is intended to supersede the Towers Watson Safe Harbor Privacy Policy in effect from December 15, 2008 for Towers Watson Delaware Inc. and to supplement all other data privacy and information security policies in effect for Towers Watson Delaware Inc., Towers Watson Pennsylvania Inc., or any of their respective subsidiaries and affiliates in the United States.

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.

Towers Watson’s Privacy Standards

Commitment to the Safe Harbor Framework: Towers Watson is committed to upholding the Safe Harbor frameworks for HRPI pertaining to residents of the EU, Canada and Switzerland. As part of this commitment, Towers Watson will uphold the following Safe Harbor principles.

Notice: Towers Watson 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 Towers Watson 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 necessary to respond to a government inquiry; is required by applicable laws, court orders or government regulations; or is necessary to protect Towers Watson's legal interests if providing notice would interfere with those interests. to protect Towers Watson's legal interests if providing notice would interfere with those interests.

Choice (Consent): Towers Watson 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, Towers Watson provides EU individuals with the opportunity to withdraw consent at any time ("opt-out"), 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 a non-job related purpose.

Onward Transfers: Towers Watson will only transfer HRPI pertaining to EU individuals to a third party if that third party (a) has provided satisfactory assurances to Towers Watson that it will protect the information consistent with the Safe Harbor requirements; (b) is located in the EU or a country considered "adequate" for privacy by the EU Commission, and therefore is required to comply with the EU data protection laws or substantially equivalent privacy laws; or (c) the third party has also certified to the Safe Harbor, and, accordingly, is independently responsible for complying with the Safe Harbor requirements.

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

Data Integrity: Towers Watson 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: Towers Watson will permit reasonable access by EU individuals to their HRPI held by Towers Watson, with the accompanying right to correct the information for accuracy, if necessary, except where the burden or expense of providing access would be disproportionate to the risks to the individual's privacy in the case in question, or where the rights of persons other than the individual would be violated.

Enforcement: Towers Watson 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

Towers Watson has implemented an internal dispute resolution process for Safe Harbor complaints. For disputes that are not resolved through such process, Towers Watson 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
Towers Watson
1500 Market Street
Philadelphia, Pennsylvania 19102
USA

You may also email us at: HRPISafeharbor@towerswatson.com.