California Workforce Privacy Notice

1. WHAT IS THE PURPOSE AND SCOPE OF THIS DOCUMENT?

NBCUniversal is committed to protecting the privacy and security of your personal information. 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 regarding recruitment, please see our Candidate Privacy Policy.  For privacy information about casting for our Productions, please see our Casting Privacy Policy.

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.

This Notice also does not address our information practices with respect to your interactions with NBCUniversal as a consumer or customer. When you interact with us as a consumer or customer, our NBCUniversal Global Privacy Policy applies. If you provide services to NBCUniversal through or in connection with another company, NBCUniversal is not responsible for the other company’s privacy practices, and you should review that company’s privacy notices carefully.

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, for example to reflect changes in our processing activities, or to meet new legal requirements.

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:

• Biographical information, such as name, date and place of birth, gender and gender identity, and the names and dates of birth of your dependents.
• 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 and compensation history, 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, details of skills, qualifications, experience and preferences (e.g., mobility), timecards, time-off records, training records, disciplinary and grievance information, HR records, termination details, volunteer activities, professional memberships.
  • Union or guild membership.
• 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, metadata, and audit trails of system access.
• Physical security system information, such as security camera footage, security pass entry records and biometric information to the extent collected for physical access control purposes.
• Photographs, to the extent provided by you or taken by us for work-related purposes.
• Social media information, such as social media handles and information on any social media profile.
• Health information such as disability status, leaves of absence, records of health and safety incidents or accidents, medical information related to worker’s compensation claims, medical reports and records, information relating to ability to perform job duties, and COVID-19 related information such as vaccination status and COVID-19 status. 
• Demographic information, such as gender, gender identity, racial or ethnic origin, sexual orientation, age or age band, military status and veteran status.
• Driver qualification information (for roles involving driving), such as Motor Vehicle Record, drug and alcohol test and violation information.

We may also hold the following information from individuals providing services on or working with our Productions:

• Biographical information, physical characteristics and audition recordings to the extent collected through and/or used for the casting process.
• Images, film and sound recordings made in connection with the Production
   

3. WHAT WILL NBCUNIVERSAL DO WITH YOUR PERSONAL INFORMATION?

We process workforce personal information for our and our service 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 where applicable, payroll processing, timekeeping, training administration, compensation and benefits, talent management, succession planning, measuring and fostering employee engagement, handling complaints, grievances and disciplinary procedures, 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; arranging business travel; processing travel and expense claims; expense management; crisis management; and workplace management.
• Legal and regulatory requirements, including complying with legal, regulatory, and fiscal obligations such as anti-bribery and corruption laws, tax, social security and legal reporting obligations; ascertaining workers’ right to work, visa and immigration status; reporting to governmental agencies on employee demographics; dealing with litigation and other proceedings and claims; 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; investigating and preventing fraud and other illegal activity; avoiding conflicts of interest; 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 (including user authentication); to detect and manage security incidents; 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; to protect our workforce and assets; to monitor your use of systems to ensure compliance with our IT policies and prevent data loss; and to manage company-owned devices. 
• Workforce updates, such as communicating with our workforce, including business updates and 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., including data analytics and management reporting.

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, distributing and exploiting the Production, any derivative products thereto and any allied or ancillary rights.

Some of the information we collect may be considered “sensitive personal information” under applicable law.  We use such information in the following ways:

• We will use your social security number for tax, payroll and benefits purposes.
• Where driving is an essential part of your role, we may request proof of a valid driver’s license to ensure that you are qualified for the role.
• 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 may 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. For example, we may collect COVID-19 related information to support our workplace health and safety protocols and comply with legal obligations.
• We will use union/guild membership information to comply with (or exercise rights under) collective bargaining agreements and other legal requirements.
• In certain locations, we may use biometric information for timekeeping and physical access control purposes.
• We will use information that we may collect about your racial/ethic origin, sexual orientation, and disability status 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 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, Finance, Environment, Health and Safety (EHS), and Business Continuity & Crisis Management (BC/CM). It also includes Comcast personnel who need to receive NBCUniversal workforce personal information to perform their roles for the above purposes, such as the Comcast Benefits Team and Comcast Global Audit. 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 and Comcast share 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, cast list or crew list which will be available to those involved in the Production on an as-needed basis in order to facilitate the efficient running of the Production.
  • Service Providers: Production service providers, insurers of our Productions, companies providing post-production services, and external auditors.
  • Industry authorities, unions: 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.
  • Viewers: If workforce personal information is included in the content of a Production and broadcast, this information will be seen by people who watch the Production or clips of it.
• 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 legitimate 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 corporate transaction discussions and arrangements;
  • 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.

6. MAINTAINING ACCURATE DATA AND EXERCISING YOUR RIGHTS

It is important that the personal information we hold about you is accurate and current. Please notify your HR representative or HR Connection ([email protected]) if the personal information you have provided to us changes during your working relationship with us.

If you are a California resident, you have the right to make certain requests regarding your personal information, or your authorized agent can make such requests on your behalf, using the HR Connection email address below. You have the right not to be discriminated against for exercising your rights. You may:

• request access to specific personal information. This enables you to be notified of the categories of personal information we collected about you and the reason we collected such information, and to have access to the specific personal information we hold about you.  Please note that there are exemptions to this right, such as where the data was generated to help ensure security or integrity, or is subject to legal privilege, or is publicly available.   
• request correction of the personal information that we hold about you. This enables you to ask us to correct incomplete or inaccurate information we hold about you.
• request deletion of your personal information. This enables you to ask us to delete or remove personal information from our records, subject to certain exceptions.  We may deny your deletion request in some circumstances. For example, we may retain your personal information if we need to use it to fulfil our obligations as your employer, meet legal requirements, fulfill reasonable internal purposes, or detect security incidents.

California law places certain obligations on businesses that “sell” personal information to third parties or “share” personal information with third parties for cross-context behavioral advertising. We do not “sell” or “share” the personal information covered by this policy and have not done so in the twelve months prior to the effective date of this policy.

Non-Production workforce: If you are not part of our Production workforce and would like to make one of the above requests, please complete the relevant form using these links: 
Current Employees
Former Employees

You can also email [email protected], or call 800-622-6432.

Production workforce: If you are part of our Production workforce and would like to make one of the above requests, please send an email to [email protected] or call 800-622-6432.

If you are employed by DreamWorks, please use this form to make your request.

We will take reasonable steps to verify your identity (and, if applicable, your agent’s authorization) before responding to a request. In doing so, we may ask you for verification information so that we can match at least two verification points with information we maintain in our files about you. If we are unable to verify you through this method, we shall have the right, but not the obligation, to request additional information from you.  If we are not able to verify your identity, we may deny your request.

7. RETAINING YOUR PERSONAL INFORMATION 

We will keep your personal information for as long as is necessary to fulfil the purposes we collected it for, including for the purpose of satisfying legal, accounting and reporting requirements.  To determine the appropriate retention period for workforce personal information, we consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the personal information, the purposes for which we process the personal information and whether we can achieve those purposes in other ways, the applicable legal requirements and our reasonable internal purposes.  For example, we will keep certain information about former employees (e.g., name, SSO, job title, work location, organizational hierarchy, dates of employment) for as long as necessary for our reasonable internal purposes of keeping this information as part of our organizational history and to confirm the facts of their employment with us.