NBCUniversal’s Privacy Principles
At NBCUniversal we take seriously our privacy obligations. We respect the privacy concerns of those that we deal with and value the relationships that we have. We know that protecting and respecting the privacy rights of everyone we work with is critical to our success. That is true irrespective of whether that information is protected by local privacy laws or not, and whether collected online or offline. Below we set out the principles which underlie our approach to privacy across all of our businesses. Of course we are committed to handling personal information in compliance with the specific provisions of applicable privacy laws worldwide where those exist.
Throughout this document:
o “personal information” means all information relating to an identifiable person (even if you don’t know that the name of that person)
o “processed” means collecting, handling, storing, sharing, using, transferring and disposing of personal information.
Our Privacy Principles
1. Integrity, Fairness & Lawfulness – Personal information will be processed fairly and lawfully
- We will only collect and use personal information where we have lawful grounds and a legitimate business reason for doing so – in general, we collect, store and use your information to provide you with a safe, smooth, efficient and customized experience on our websites. However, sometimes we need to collect and use your personal information to enable us to prevent fraud or potentially unlawful activities (including copyright infringement)
2. Purpose Limitation - Personal Information will only be used for the purposes for which it was originally collected and about which the individual was informed
- This means if we collected information for a specific purpose then we will only use it for that purpose until the individuals concerned have been informed of any new intended use and, where required, their permission obtained. Where relevant, we will provide clear information on the choices available and the means to exercise those choices.
3. Data minimisation – We will only process personal information that is adequate, relevant and not excessive
- We will use anonymous data (i.e. where no individual is identifiable) or aggregated information (i.e. summarised so as not to be identifiable to an individual) instead of personal information wherever possible
- We will not ask for more information than we need. We will make it clear which information it is mandatory for someone to provide and that which is optional.
4. Accuracy – We will ensure that the personal information we keep is up to date and accurate
- We will tell people where and how to contact us to review and update their information
- We will update our records when an individual informs us that their details have changed or are inaccurate
5. Retention – We will only keep personal information for as long as necessary for the purposes for which it was originally collected
- We will implement records retention policies for personal information
- We will ensure that personal information is securely disposed of at the end of the appropriate retention period
6. Rights of Individuals – We will observe the rights afforded to individuals under their local laws, which may include:
The right to:
- opt-out of receiving marketing communications from NBCUniversal entities
- have inaccurate information corrected
- have access to the information held about them
- prevent processing that is likely to cause damage or distress
- opt-out of information being shared with third-parties
- be informed of how automated decisions have been made
7. Security – We will ensure we have appropriate measures in place to protect personal information from accidental/unauthorised access, disclosure, theft, damage, loss, alteration etc
- train staff on their privacy obligations
- implement appropriate physical and technical security measures to protect personal information whether it is on or off-site.
- protect personal information when it is transferred from one place, or one party, to another
- vet third parties before they process any personal data on our behalf and ensure that they have equivalent mechanisms to ours to protect personal information
- limit access to personal information to those individuals who have a genuine business need to see it.
8. Information transfers – We will ensure that suitable safeguards are in place before personal information is transferred cross-border or to third parties
We will ensure that any personal information which we are responsible for will be adequately protected in the hands of a third party and/or in the country of destination when transferred across borders
9. Additional Safeguards
Whilst we will strive to protect all personal information we are responsible for there may be situations where employees or service providers fall short of our expectations or outside influences mean that we cannot meet these high standards we have set ourselves. In those situations we will:
- Take steps to investigate the issue and implement steps to mitigate any loss, damages or distress to individuals
- Notify impacted individuals where it is prudent to do so (or where required to do so by local laws, regulation or custom)
- Notify relevant regulators and authorities as required
- Take appropriate action against those responsible
- Once the issue has been resolved, ensure any remedial action is taken to prevent a recurrence of the incident
If you have any questions about our Privacy Principles please contact the NBCUniversal Chief Privacy Officer at firstname.lastname@example.org.