1. WHAT IS THE PURPOSE AND SCOPE OF THIS DOCUMENT?
NBCUniversal is committed to the privacy and security of the personal information of its workforce. This California Workforce Privacy Notice (“Notice”) describes how we collect, use, and disclose personal information about our California workforce in the context of our working relationship with you (“workforce personal information”). For information about our information practices for applications made through our nbcunicareers.com website, please see our Candidate Privacy Statement.
This Notice applies to current and former employees and job applicants (including part-time and full-time staff, pages and interns), Production employees (including daily and weekly hires, Production Employee Payroll employees, and Run of Show payrolled employees), independent contractors, consultants, freelancers, and other workers (including those providing temporary services via third party agencies) across all NBCUniversal brands, who are residents of California. In this Notice, we will use the term “Production" to refer to film, television, digital, event, news programming and other productions.
This Notice does not form part of any employment contract or contract to provide services.
In this Notice, we will use the terms “NBCUniversal”, “we”, “us” and “our” to refer collectively to the brand that employs you, engages you or with which you are an applicant for employment, as well as the other brands under the NBCUniversal umbrella. A list of our brands can be found here. When we use the term "process” in relation to workforce personal information, we mean any action that can be taken in relation to workforce personal information, such as collection, access, storage, modification, correction, disclosure, and deletion.
It is important that you read this Notice, together with any other privacy notice that we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information. We may update this Notice at any time.
2. THE KIND OF INFORMATION WE HOLD ABOUT YOU
NBCUniversal collects, stores, and uses various types of personal information about its workforce. We collect this information through our application, recruitment, employment or engagement processes, either directly from you or (where applicable) from another person or entity, such as an employment agency or consulting firm, production service company, casting agency, recruitment or professional networking website, talent agency, management company, or other representative, background check provider, or from others who provide references on prospective workers. We will collect additional workforce personal information throughout the course of your employment or other provision of services to us.
The kind of information we hold about you depends on your role with us and may include, where applicable:
- Identification information, such as name, date and place of birth and gender.
- Contact information, such as home and business addresses, telephone numbers, and email addresses, including about your beneficiaries or emergency contacts.
- Professional or employment-related information, including:
- Financial information, such as wages, bank account details if required for direct deposit, social security number, payroll records, tax identifier and tax information.
- Business travel and expense information, such as TSA Known Traveler number, passport information and corporate credit card usage.
- Application, recruitment, new-hire, or other engagement information, such as application forms and information included in a resume; copies of identity and immigration/work authorization documents; citizenship and residence status; background screening results and references.
- Career information, such as job title, organization charts, start and end dates, work location, appraisal and performance information, time-off records, disciplinary and grievance information, and termination details.
- Internet, electronic network, and device activity information and related identifiers, such as information about your use of NBCUniversal information, communication, and collaboration systems, including user IDs, passwords, IP addresses, and audit trails of system access.
- Physical security system information, such as security camera footage and security pass entry records.
- Photographs provided by you or used for work purposes.
- Sensitive information, such as demographic information and health information (e.g. disability status, leaves of absence, health and safety incidents or accidents, medical information related to worker’s compensation claims, other medical records, and information relating to ability to perform job duties).
We may also collect the following information from individuals providing services on or working with our Productions:
- Information regarding physical characteristics collected through and/or used for the casting process, film and sound recordings made in connection with the Production, and social media handles.
3. WHAT WILL NBCUNIVERSAL DO WITH YOUR PERSONAL INFORMATION?
We process workforce personal information for our and our services providers’ business purposes, which include, where applicable:
- Workforce planning and recruitment, including assignment planning and budgeting, job advertising, interviewing, and selecting and engaging individuals to join our workforce.
- Workforce management and administration, including training administration, compensation and benefits, and performance management.
- Performance of business operations, including providing, managing, supporting, and improving information and communication systems and processes; maintaining accounts and internal directories; data administration; crisis management; processing payroll.
- Legal and regulatory requirements, including complying with legal, regulatory, and fiscal obligations; reporting to governmental agencies on employee demographics; responding to and cooperating with legal or regulatory requests and investigations; participating in due diligence activities for the sale, purchase, or reorganization of our business or a part of it; and ensuring compliance with policies, guidelines and contracts, including our contracts with those who develop, commission, finance, and insure our Productions.
- Security management, such as to ensure network and information security; to ensure Production security; to monitor and control access to company premises and locations including through the use of security cameras and physical access control systems; and to monitor your use of systems to ensure compliance with our IT policies and prevent data loss.
- Workforce updates, such as communicating with our workforce, including about updates and other changes to any of the above.
- Business reorganization, divestitures, mergers, acquisitions, establishment of joint ventures, including discussion with counterparties and professional advisors.
- Matters relating and/or incidental to the items above.
We may also process the personal information of individuals providing services on or working with our Productions for the following purposes:
- developing, producing, insuring, financing, publicizing, advertising and exploiting the Production, any derivative products thereto and any allied or ancillary rights.
We will use more sensitive personal information in the following ways:
- We will use information relating to leaves of absence, to comply with (or exercise rights under) employment and other legal or contractual obligations, for workforce planning and administration, and preparing analyses and reports.
- We will use information about your physical or mental health or disability status to help protect the health and safety of our workforce and workplace, to assess your fitness to work, to provide reasonable workplace accommodations and to monitor and manage absence, to comply with (or exercise rights under) employment and other legal or contractual obligations, and (if necessary) to protect your vital interests.
- We will use union/guild membership information to comply with (or exercise rights under) collective bargaining agreements and other legal requirements.
- We will use information that we may collect about your demographics to ensure meaningful equal opportunity and diversity and inclusion monitoring and reporting, and to comply with (or exercise rights under) employment and other legal requirements.
4. WHO IS YOUR PERSONAL INFORMATION DISCLOSED TO?
We will disclose your personal information to the following types of entities (where applicable):
(a) Within NBCUniversal and Comcast
NBCUniversal shares your personal information to people within NBCUniversal and Comcast to carry out the purposes described in this Notice. This includes, as applicable, your manager, HR representative, and personnel within NBCUniversal group functions, such as HR Operations, Payroll, Technology, Legal, and Finance. For those providing services on Productions, we may also share your information with your Production contact and those involved with NBCUniversal’s distribution of the content.
(b) Outside NBCUniversal
- Service Providers: NBCUniversal shares workforce personal information with service providers, such as compensation and benefits providers, payroll service providers, tax and other professional advisors, technology service providers, corporate card issuers, travel and expense management providers, transport and security providers, HR management and administration suppliers, consulting agencies and temporary employment agencies (in relation to consultants and third party temporary workers) and the provider of our integrity hotline, so that the relevant services can be provided.
- Production-related Disclosures: For those providing services on or working with our Productions, workforce personal information may also be shared as follows:
- Other production staff: your name, role and contact information may be listed on a call sheet which will be available to those involved in the Production in order to facilitate the efficient running of the Production.
- Service Providers: Production service providers, insurers of our Productions, casting agencies, companies providing post-production services, and external auditors.
- Industry authorities: workforce personal information may be provided to television and film authorities for reasons such as obtaining certification for financial and tax purposes. NBCUniversal also shares certain information with unions and guilds in order to comply with collective bargaining agreements and benefit trust fund obligations and/or with other industry or official bodies when applying for filming permits, visas, and/or awards.
- Co-production companies: if applicable, NBCUniversal shares workforce personal information with co-production companies, including for making casting decisions and engaging crew members.
- Event Administrators: organizers who plan and execute events such as the Olympics, and government agencies or offices of the host country.
- Licensees or other Exhibitors: workforce personal information is included in the information that NBCUniversal must provide to broadcasters, licensees or other exhibitors that have commissioned or licensed Productions. Broadcasters collect copyright and contributor information about each program that they have commissioned for operational, contractual and compliance reasons, and to allow them to pay royalties to contributors.
- Distribution, Publicity, and Marketing partners: limited workforce personal information is provided to potential and existing distribution partners in connection with the distribution of the film or show.
- Other disclosures: Generally, NBCUniversal shares workforce personal information other than as described above as follows:
- when required to do so by law, regulation, or court order;
- in response to a request for assistance by a law enforcement agency;
- to seek legal advice from NBCUniversal’s external lawyers or in connection with litigation with a third party;
- in connection with the sale, purchase, or merger of a business or the establishment of a joint venture;
- in the case of News personnel requiring access to high security locations such as the White House, identity documentation and other personal information may be shared with the relevant credential checking agency such as the FBI for security purposes; or
- to provide another entity (such as a potential or existing business counterparty or customer) with a means of contacting you in the normal course of business, for example, by providing your contact details, such as your phone number and email address.
5. HOW WE PROTECT YOUR PERSONAL INFORMATION
We maintain organizational, technical, and physical safeguards to help protect the information we collect and use. These safeguards vary depending upon a variety of factors including the sensitivity of the information we collect and use. Despite all reasonable practices, no security method is infallible.