DePuy Safe Harbor Privacy Policy

DePuy Orthopaedics, Inc., a member of the Johnson & Johnson Family of Companies, is strongly committed to protecting the privacy of those who entrust us with their personal information. Our employees, and all those who do business with us, trust and expect that we will protect their personal information in accordance with the promises we make. In furtherance of our commitment, DePuy Orthopaedics, Inc., has certified to the Safe Harbor Agreement between the United States and the European Union, with respect to personal data processed as part of our human resources and clinical research activities. Accordingly, DePuy Orthopaedics Inc., adheres to the Safe Harbor privacy principles and Frequently Asked Questions, as agreed to by the U.S. Department of Commerce and the European Commission.

Scope

This Safe Harbor Privacy Policy sets forth how DePuy Orthopaedics, Inc. handles personal data transferred from countries in the European Economic Area (EEA) to the United States that are collected or received in managing our workforce and in conducting clinical research activities.

Definitions

The following terms are used throughout this document and are defined here for clarification.

"Agent" means a third party that processes personal data solely on behalf of and under the instruction of DePuy Orthopaedics, Inc.

"Personal data" means any information or set of information that identifies or can reasonably be used to identify an individual. Personal data do not include information that is encoded or anonymized, or publicly available information that has not been combined with nonpublic, personal information.

"Sensitive personal data" means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, or that concerns health or sex life. Information will be treated as sensitive personal data when it is received from a third party that identifies and treats it as sensitive.

Privacy Principles

The following privacy principles apply to the collection, use and disclosure of personal data by DePuy Orthopaedics, Inc., in conducting clinical research and human resources activities.

DePuy Orthopaedics, Inc., will inform individuals about the purposes for which we collect and use personal data about them, how to contact us, the types of nonagent third parties with whom we may share personal data, and ways in which individuals may limit the use and sharing of such data. This notice will be provided when individuals are first asked to provide personal data, or as soon thereafter as is practicable.

DePuy Orthopaedics, Inc., will offer an individual the opportunity to choose (opt out) whether personal data are (a) shared with a nonagent third party or (b) used for a purpose other than that for which the data were originally collected or subsequently authorized by the individual.

For sensitive personal data, DePuy Orthopaedics, Inc., will give an individual an affirmative or explicit (opt in) choice if the information is to be disclosed to a third party or used for a purpose other than that for which it was originally collected or subsequently authorized by the individual.

DePuy Orthopaedics, Inc., will provide individuals with reasonable access to personal data about them, and they may request the correction or amendment of personal data that they demonstrate to be incorrect or incomplete.

DePuy Orthopaedics, Inc., will only transfer personal data to an agent when the agent has provided assurances that it provides at least the same level of privacy protection as is required by these privacy principles. Where we have knowledge that an agent is using or sharing personal data in a way that is contrary to these principles, DePuy Orthopaedics, Inc., will take reasonable steps to prevent or stop such processing.

DePuy Orthopaedics, Inc., will only transfer personal data to a nonagent third party when it is consistent with the notice provided to the individuals who are the subject of the data and with any consent that those individuals have given.

DePuy Orthopaedics, Inc., will only use and share personal data about individuals in a way that is consistent with the purposes for which the data were collected or subsequently authorized by those individuals. To the extent necessary for those purposes, DePuy Orthopaedics, Inc., will take reasonable steps to ensure that the data are accurate, complete and current.

DePuy Orthopaedics, Inc., will take reasonable precautions to protect personal data from loss, misuse and unauthorized access, disclosure, alteration and destruction.

DePuy Orthopaedics, Inc., has put in place mechanisms to verify our ongoing adherence to these privacy principles. We encourage individuals covered by this Policy to raise any concerns that they have about the way that we process their personal data by contacting us at the address below, and we will do our best to resolve them. We have also agreed to participate in the dispute resolution program provided by the European Data Protection Authorities Panel.

Limitation on Scope of Principles

Adherence by DePuy Orthopaedics, Inc., to these privacy principles may be limited to the extent required to meet a legal, governmental, national security or public interest obligation.

How to Contact Us

Please contact us with any questions about the way in which we use personal data. Employees and former employees of DePuy Orthopaedics, Inc., should contact us at:

Corporate Office of Privacy
Phone: (732) 524-1676
Fax: (732) 342-9819
Privacy@corus.jnj.com

All other individuals covered by this Policy should contact us at:

DePuy Orthopaedics, Inc.
700 Orthopaedic Drive
P.O. Box 988
Warsaw, IN 46581-0988
(574) 267-8143
privacy@dpyus.jnj.com

Changes to this Policy

This Policy may be amended from time to time, consistent with the requirements of the Safe Harbor. When we do amend it, we will also revise the "last updated" date at the bottom of this Policy. For material changes to this Policy, we will notify individuals by placing a notice on the following Web site: www.depuy.com.
Last Updated September 30, 2005