Privacy Advisor

Dale Skivington, Chief Privacy Officer, Kodak

August 1, 2003

Dale E. Skivington is Kodak's chief privacy officer and as such has worldwide responsibility for company policies relating to consumer, employee and supplier privacy. She is also a member of the Employment and Personnel Law Legal Staff at Kodak, chaired the New York State Business Council's Labor and Human Resources committee, and also served on the New York Governor's Task Force on Independent Contractors and on the Governor's Task Force on Sexual Harassment. Prior to joining Kodak, she was in private practice litigating civil rights and personal injury matters and an assistant attorney general for the state of New York. She joined the company in 1988.

Skivington lectures on privacy and various civil rights and employment law matters, was an adjunct faculty member of the State University of New York at Brockport, and an instructor at the Cornell School of Industrial and Labor Relations. She has served as a lecturer at the Simon School at the University of Rochester, Teachers College at Columbia University, North Carolina State University's School of Management, the Equal Employment Advisory Council, Privacy and American Business, the American Corporate Counsel Association, and the International Association of Privacy Professionals.

Skivington is a graduate of the State University College at Potsdam and the Albany Law School.

POA: Describe your organization and corporate environment.

Skivington: Eastman Kodak Company is the worldwide leader in imaging technology and infoimaging. We are a global company with diverse markets, businesses, and channels. Kodak also has a strong corporate commitment to its principles, one of which is respect for the dignity of the individual. That commitment extends to protecting the privacy of the personal information of our customers, vendors, suppliers, and employees. Kodak has recognized that meeting this commitment is critical to maintaining our customers' trust in Kodak and preserving our brand, one of our most important assets. In 2000, Kodak created its first Office of the Chief Privacy Officer. That office manages a global infrastructure comprising numerous committees with more than a hundred people participating.

POA: How did your career path lead you toward the privacy profession?

Skivington: I spent the first 12 years of my career at Kodak as an attorney in the labor and employment group focusing on various civil rights issues. In 1998 I was part of a team that worked on an acquisition and spent three months in Europe working with our businesses and works council on integration. That experience presented me an opportunity to study the proposed implementation of the EU Directive on Data Privacy and how it would impact our global businesses. I realized it would have significant impact on global data transfers. In discussing the issue with the associate general counsel, and ultimately our CEO, a decision was made to create a focal point within the organization for privacy policy, direction, and implementation.

POA: What is the most challenging aspect of your current position?

Skivington: Certainly the most challenging aspect of my job is to keep pace with evolving privacy legislation and regulation. Running a global business, providing global products and services, provides significant challenges in implementation to ensure those products and services comply with the various, and often conflicting, privacy requirements, standards, and consumer expectations.

POA: What is the most satisfying part of being a privacy professional?

Skivington: The most satisfying part of being a privacy professional is to be able to work on issues which you know are important to your coworkers as well as consumers generally. Advocating their perspective within an organization that is extremely respectful of employee and consumer concerns makes my job not only satisfying but also extremely personally rewarding.

POA: What privacy issues most affect the industry your organization is in?

Skivington: There are a variety of issues that affect Kodak. As a global organization, legislation that impact transfers of data globally impacts us from an operational point of view. As a company that regularly communicates with its consumers, legislation regulating how those communications need to be managed (such as laws relating to collection of consumer information, i.e., notice and choice, outbound communication such as rules regulating e-mail) are ones that we spend a lot of time and energy addressing. In addition, as a provider of products and services to the health care industry, we devote considerable attention to products and services that assist our customers to comply with the Health Information Portability and Accountability Act.

POA: How have developments in privacy law, technology, and policy changed life within your organization?

Skivington: Since many of our products and services are managed by separate business units, but sold to the same or overlapping markets, the privacy programs have required greater coordination among our marketing organizations than has been needed previously. For example, we have standardized our privacy commitments to our consumers, used common methods and language for offering them choice about controlling their information. The marketing managers meet regularly to discuss best practices.

POA: What do you see as the biggest issues facing the privacy profession in the near and short term?

Skivington: I believe the biggest issues facing the privacy profession in the near term is the allocation of responsibilities for privacy and related issues within an organization. Coordination among the chief information officer, chief information security officer, chief marketing officer, CRM managers, and members of the associate general counsel staff is critical. Working together effectively as a team, understanding where accountability and responsibility exists for issues as they emerge is important for the profession.