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FYI. I have sent them a copy of the draft policy. I think it will address
their concerns. Michelle ---------------------- Forwarded by Michelle Cash/HOU/ECT on 05/11/2000 10:44 AM --------------------------- Sherry Lessner@ENRON 05/11/2000 08:53 AM To: Jane Allen/HOU/ECT@ECT cc: Stephen D Burns/Corp/Enron@ENRON, Joe Hillings/Corp/Enron@ENRON, Chris Jones/Corp/Enron@ENRON, Tom Briggs/LON/ECT@ECT, Michelle Cash/HOU/ECT@ECT, Sharon Butcher/Corp/Enron@ENRON Subject: Re: EU-US "Safe Harbor" agreement Jane, this issue continues to be 'worked' here at Enron. In relation to a current initiative which includes a new employee directory, we are working with the business unit leaders (Cindy Olson, Steve Kean, Mark Palmer, Vision and Values Task Force) and Sharon Butcher, Kelly Higgason, and Brian Schaffer. Michelle Cash and Sharon have been involved in several discussions relating to our global data collection efforts through HR-GIS. We have a meeting scheduled next week and I will ask Sharon to include the information below in the discussion. In general, I understood Sharon and Kelly to indicated that research has been done for some locations and may have to be continuously updated. Other Enron locations have not been researched and will have to be prioritized and evaluated for research, i.e., it was recommended that we focus our efforts on locations with the higher employee populations. From: Jane Allen @ ECT 05/11/2000 07:49 AM To: Stephen D Burns/Corp/Enron@ENRON cc: Joe Hillings/Corp/Enron@ENRON, Chris Jones@ENRON, Tom Briggs/LON/ECT@ECT, Sherry Lessner/Corp/Enron@ENRON, Michelle Cash/HOU/ECT@ECT, Sharon Butcher/Corp/Enron@ENRON Subject: Re: EU-US "Safe Harbor" agreement This has been looked at by our HR IT department for many years as we have been transmitting data back and forth in our Compensation and HR systems. I am copying Sherry Lessner who at one time lead the group dealing with this issue, as well as Sharon Butcher and Michelle Cash from our legal department. Ladies, can you provide any additional information on what we are doing? Do we need additional research in this area? Thanks, Jane Stephen D Burns@ENRON 05/10/2000 07:29 PM To: Jane Allen/HOU/ECT@ECT cc: Joe Hillings/Corp/Enron@ENRON, Chris Jones, Tom Briggs/LON/ECT@ECT Subject: EU-US "Safe Harbor" agreement Jane: I participated in a lunch yesterday on Capitol Hill which discussed the recently concluded bilateral negotiations between Europe and the US on the issue of data privacy/safe harbor. I admit that I don't fully understand the issue, but in essence I'm told it's an internal EU directive passed a few years ago (not all countries within the EU have come into compliance yet, by the way) that has strict bearing on issues pertaining to the protection of the privacy of transmitted data (eg, over the internet). The EU wants to forbid transmitting certain types of data to countries that don't "adequately protect" the information. As always, the EU wants to regulate the issue, while the US prefers self-regulation. After two years of negotations, they agreed a few weeks ago that data transmitted from the EU to the US could be put in "safe harbors", which are basically approved bodies that would check the recipient's ability to protect the privacy of the information, ie, an American company receiving privelaged data from its European affiliates or offices. How does this affect Enron? A couple of other company reps said it is especially pertinent to HR issues, such as transmitting personnel information, salary, etc. from Europe back to the home office in the US. Given our large presence in London and elsewhere in Europe, does this affect us, and do you want us to track down more information? Regards, Steve Burns
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