Warner Bros. Discovery Workforce Privacy Notice

Warner Bros. Discovery Workforce

Privacy Notice

Effective date: January 2023

1. OBJECTIVE

Warner Bros. Discovery and its broader group of affiliated companies (“Warner Bros.

Discovery”, “we”, “our” or “us”) are committed to fair data protection practices, including

when Processing information about our Workforce (as defined below).

You can learn more about Warner Bros. Discovery affiliate companies by visiting our

controller and affiliate site.

This privacy notice informs our Workforce of all possible Processing by, and on behalf of,

Warner Bros. Discovery entities of personal information pertaining to the Workforce in

connection with their employment or engagement. In the event that laws in certain

jurisdictions require different or stricter standards for the Processing of personal

information than those described in this privacy notice, relevant Warner Bros. Discovery

entities will follow such jurisdictional laws, rules or regulations.

2. DEFINITIONS

Contractors

means any non-employee working for or on behalf of Warner Bros. Discovery,

including contingent workers or contractors (whether directly or indirectly contracted),

agency workers, freelancers, consultants, secondees and individuals on work

experience/work shadowing placements.

Controllers

are the Warner Bros. Discovery entities that decide the purpose and the

manner in which any Processing of Personal Information will be carried out (a list of

Controllers can be found by visiting our controller and affiliate site). For Personnel (as

defined below), the Warner Bros. Discovery entity that employs you is always a Controller

of your Personal Information. For Contractors, the Warner Bros. Discovery entity that

engages you or the organisation that you work for, is always a Controller of your Personal

Information. For all Workforce, depending on the particular Processing activity (as

described below), there may be more than one Controller with respect to that particular

Personal Information (for example, where your Personal Information is shared with a parent

company for business planning purposes, this parent company may also be a Controller in

respect of that Processing). If you have any questions about who the Controller is for your

Personal Information, please contact us using the methods set out in section 10 below.

Personnel

means employees (regardless of classification or type and including full-time

employees, temporary employees, and interns). Solely for purposes of this privacy notice,

the definition also comprises all personnel referred to under the California Consumer

Privacy Act,

see

Cal. Civ. Code § 1798.145(m), for purposes of providing required notices.

The definition of “Personnel” under this privacy notice is not intended to be co-extensive

with the definition of “employee” or other personnel-related terms under any applicable

employment or other law.

Personal Information

means any data or information Processed by us that identifies,

relates to, describes or is capable of being associated with, or may reasonably be linked,

directly or indirectly, with an individual.

Processing, Process, Processed

refers to any action that is performed by or on behalf of

Warner Bros. Discovery on Personal Information, such as collecting, viewing, accessing,

recording, organising, analysing, storing, modifying, using, disclosing or deleting such

Personal Information and/or as otherwise defined by any applicable laws.

Sensitive Personal Information

means Personal Information that requires a high degree of

protection by law. In particular, under this privacy notice, Sensitive Personal Information

includes all information identified as a special category of personal data under the General

Data Protection Regulation (GDPR), and other applicable data protection laws, and/or

regulations. Sensitive Personal Information includes Personal Information revealing racial

or ethnic origin, political opinions, religious or philosophical beliefs, trade union

membership, genetic data and biometric data Processed for the purpose of uniquely

identifying an individual, data concerning health, sex life or sexual orientation, as well as

Personal Information relating to criminal convictions and offences or related security

measures, and in certain jurisdictions where required under applicable law, passwords and

financial information (such as bank account, or credit or debit card, or other payment

instrument details).

Workforce

includes

Contractors and

Personnel of Warner Bros. Discovery.

3. TYPE AND SOURCES OF PERSONAL INFORMATION COLLECTED AND PROCESSED

We will collect Personal Information directly from the Workforce, requested or otherwise

provided as part of your employment or engagement, including contact details, such as

address, telephone number, email address, financial information, such as bank account

details, and other identifiers, where applicable.

We may also create Personal Information as part of your employment or engagement,

such as records of your services, performance, skills and experience, salary or billing

information, and absence records.

To the extent permitted by law and where necessary to achieve the purposes of

Processing, we may collect Personal Information from other sources, including but not

limited to:

• Government organizations, health providers and benefits providers, for example

information needed to help identify which benefits have been sought or are needed

to ensure compliance with taxation laws;

• Business partners and service providers such as, companies providing training and

any other related activities, companies providing background checks, phone

companies and travel companies and agencies, to name a few. This can include

details of your training, details included in any background or vetting check and

details of your use of our service providers;

• Workforce supervisors and colleagues;

• Publicly available information that may be posted on the internet, in newspapers,

etc. where used in connection with investigations or vetting the Workforce, or

which is otherwise brought to our attention;

In the case of Contractors, we will only collect Personal Information to the extent

necessary to achieve the purposes of Processing in connection with the Contractors

engagement for or on behalf of Warner Bros. Discovery and such engagement is not

considered co-extensive with employment or other personnel-related terms under any

applicable employment or other law.

Subject to any applicable limitations under law or contract, we may process each of the

categories of personal information identified above for the following purposes:

•

Human Resources and Workforce Management

: These processes are activities

undertaken by Warner Bros. Discovery to maintain and manage a workforce.

Examples include: interviewing, recruiting and hiring; transfers, travel and/or

relocations (including immigration assistance) including family members, partners or

next of kin; recording and managing terms and conditions of employment or

engagement; conducting surveys; ensuring business continuity; arranging and

reimbursing business travel and entertainment expenses; arranging, managing and

monitoring periods of time off, including annual or sick leave and reintegration back

into the workforce; investigating and resolving conflict of interest issues; conducting

workplace investigations into compliance with applicable laws and Warner Bros.

Discovery policies; allocating, reviewing and delivering pay and other compensation;

managing careers, including reviewing and appraising performance; training,

leadership development, succession, management; managing disciplinary and

grievances procedures; providing training; administering benefits, including health

insurance plans, pensions, and family-friendly offerings; providing engagement

opportunities, including discounts, loyalty or affinity programs, and access to

sweepstakes, promotions, competitions, awards and company products and

services; complying with applicable employment and worker related legal

requirements, including anti-discrimination and health and safety requirements;

monitoring diversity and implementing diversity initiatives; communicating with the

Workforce and/or their representatives, including using personal communication

channels in emergency situations; enabling enterprise collaboration including

document sharing and storage; publishing directories; and organizing events.

•

Business Process Execution and Management

: These processes are activities

carried out in order to run the business operations of Warner Bros. Discovery.

Examples include: scheduling, recording, monitoring, evaluating and facilitating

work engaged by WBD and relevant third parties, including administration and

storage of documents; budgeting, planning and forecasting for operational and

financial purposes, including supply of products (including TV, film, video game,

publishing and other content production); project management and

headcount/resource allocation; auditing; configuring and testing new, updated or

upgraded systems, software and applications; allocating, supporting and

monitoring access to company facilities and systems; managing company assets

including approving and liaising on artwork for licensed products; tracking, collating

and analyzing global business statistics, other data elements, and licensed

business activities, including for financial purposes; and operating and maintaining

TV, theatrical, and games accounting systems.

•

Safety, Security and Business Continuity

: These processes are activities

undertaken by Warner Bros. Discovery to ensure the safety and protection of its

Workforce, resources, systems, customers and consumers, assets and

communities. Examples include: protecting occupational health and safety;

providing technical and operational security with respect to our resources, assets,

systems, information and facilities; making WBD systems and business information

and data available to relevant business divisions while being adequately protected

and supported; operating disaster recovery, back-up, business continuity and alert

systems; and authenticating an individual’s status to authorize access to WBD

resources and facilities.

•

Regulatory Compliance

: Warner Bros. Discovery operates various policies,

processes and procedures to comply with applicable laws and regulations,

including local, state, federal and international laws and regulations. Examples

include: providing whistleblower protections, where necessary to fulfill statutory

compliance obligations (such as our obligations under U.S. legislation, including the

Sarbanes-Oxley Act and/or the Foreign Corrupt Practices Act); monitoring ethical

and regulatory compliance including tracking and recording conflicts of interest;

administering and providing training in relation to regulatory and compliance issues;

and implementing and monitoring WBD policies. WBD also cooperates from time to

time as required with regulators in various jurisdictions (such as data protection

authorities, tax authorities and law enforcement or sector-specific regulators).

The foregoing purposes of Processing are not an indication that such Human Resource,

Business Resource, Safety and Security or other processes have been applied on the same

basis and/ or terms as have extended to Personnel or are intended to be co-extensive with

employment or other personnel-related terms under any applicable employment or other

law.

If Warner Bros. Discovery introduces a new process or tool that will result in the Processing

of personal information for a purpose different from the purpose for which the personal

information was collected, the WBD entity responsible for the new process or tool will, to

the extent required by applicable law, inform the Workforce of the new process or tool and

provide any required notices and/or choices.

4. LEGAL BASES FOR PERSONAL INFORMATION PROCESSING

In the UK and in countries where the General Data Protection Regulation (GDPR) applies,

we Process your Personal Information under the following legal bases:

(i) To establish and perform any contract with you, to maintain, manage or terminate any

contractual relationship and to enable you to perform any services for the purposes of

your employment or engagement, or any services you are engaged to perform, or as

necessary in connection with services or benefits you request from us, in particular:

• Administration of payroll and benefits and absence, compensation and expense

management, if applicable;

• Managing our Workforce and service providers, for example, onboarding and exit

management, recording hours of work and absence, compliance with service levels

and performance;

• Allowing you access to medical insurance, pension schemes and other benefits

offered by Warner Bros. Discovery and other providers including management of

employee transfers, travel and/or relocation (including immigration assistance), if

applicable. Some benefits may require you to provide Personal Information

concerning family members, partners or next of kin, in which case you must inform

them before providing the Personal Information to us and obtain their consent if this

is required by applicable law;

• Rights management and placement of credits, if applicable; and

• Arranging professional travel (including hotel accommodation) and relevant

insurance.

(ii) To comply with a legal obligation including for:

• Making deductions from payroll for tax and social security purposes and providing

information to tax and social security authorities as required by law, if applicable;

• Managing statutory sick pay and maternity/paternity/parental pay, if applicable;

• Engaging in mandatory employee relations engagement activities;

• Carrying out necessary checks on right to work; and

• Carrying out or obtaining occupational health and safety and necessary medical

assessments.

• For our legitimate interests, as listed below (where our interests are not overridden

by your data protection rights or your fundamental rights and freedoms), or where

you have given your consent, which may be withdrawn at any time, as may be

permitted under applicable law: Developing our Workforce – for example, training

and leadership development, succession management, award recognition, social

corporate responsibility activities, surveys and communications to the Workforce;

• Planning our business, including succession planning, reorganisation and

restructuring, office location planning, business and HR reporting and statistical

analysis of our workforce, promotional planning, pitching, applications for awards

and other professional recognition, collaborating or participating in industry

initiatives, applying for entertainment industry incentives (if applicable), attending

and organising professional or promotional events, any activities relating to disaster

recovery, back-up and daily business continuity and recording/archiving any

business operations and any documents including contracts, emails, productions or

marketing creations;

• Developing, commissioning, producing, publishing, distributing, promoting and

commercialising our productions, games and/or other audio-visual content, if

applicable;

• Storing and archiving our productions, games and/or other audio-visual content, if

applicable;

• Protecting our legitimate business interests and legal rights. This includes but is not

limited to, use in connection with legal claims, compliance, regulatory, auditing,

investigative and disciplinary purposes (including disclosure of such information in

connection with legal process or litigation, or where requested by law enforcement

or other relevant third parties) and Processing in connection with ethics and

compliance policies such as the Standards of Business Conduct and related

reporting tools;

• Managing the performance and security of our equipment, facilities, intellectual

property and electronic platforms in accordance with our policies. This includes

administering access rights, management and control of building and area access

including access logs, monitoring compliance with information security and other

Warner Bros. Discovery policies, operating CCTV and other recording software and

systems, and where permitted by local law and in accordance with relevant policies,

using Personal Information for investigations and disciplinary actions;

• Ensuring the safety and protection of our Workforce and visitors;

• Providing communication services such as email, telephone, and internet access;

• Carrying out communications and engagement activities,

including sending internal

communications to Staff (including communicating with, and alerting, Staff during a

crisis), Staff discounts, loyalty or affinity programs, and access to promotions,

competitions, and company products, managing participation in events and handling

emergency contact information;

• Publishing internal directories, charts and providing other internal communications

tools. This includes the information you provide for any internal company profile

(including your photo, if applicable and permitted under applicable law);

• As applicable, analysing and monitoring the diversity of the workforce in accordance

with applicable laws. This includes, for example, compliance with equal opportunity

employment law;

• Obtaining insurance and processing claims;

• Conducting Workforce surveys and engaging third parties to conduct Workforce

surveys; and

• Handling your Personal Information in connection with recruitment or onboarding

activities you engage in, including CV reviews, interviews, conflicts of interest,

(where permitted by law) relevant vetting and background checks and applying for

visa/work permits, if applicable.

(iii) Where you have given your consent such as:

• Providing references to third parties where you have requested;

• Carrying out certain vetting and background checks where your consent is required

by law; and

• Processing as described in any other consent we seek from you.

Where any of these purposes involves the Processing of Sensitive Personal Information,

this will only be done where this is permitted by applicable law or as necessary to comply

with applicable law, for example because you have given your explicit and freely given

consent (which may be in writing), because you have manifestly made the Personal

Information public, because we are required to carry out the Processing due to applicable

employment or health, benefit, reasonable accommodations or social security laws, or

because there is a substantial public interest in this Processing.

5. MONITORING

Where the Processing activities described above involve monitoring activities, any such

monitoring, surveillance, interception, or investigation activities would be conducted in

accordance with governance arrangements to ensure compliance with applicable laws

(where applicable laws permit such monitoring activities) and internal policies. We monitor

our network and communications systems through automated tools such as network

authentication and wireless connectivity hardware and software, anti-malware software,

website filtering and spam filtering software, security software for cloud-based

applications, access and transaction logging, and mobile device management solutions in

order to protect our Workforce and business partners. Any Personal Information gathered

may be used to:

• ensure the security of our network systems and assets, and the safety and security

of our Workforce, network and device management and support;

• network and device management and support;

• business transactions and recordkeeping;

• protection of confidential information and WBD materials;

• establish the facts and as evidence in any potential/subsequent legal, criminal, or

disciplinary proceeding/actions or violations of our corporate policies, standards,

and procedures. Monitoring may also be used for business continuity purposes,

including where particular Workforce are absent or have left the business.

A. COMMUNICATIONS MONITORING

All messages, files, data, documents, audio/video, social media posts or instant message

communications, or any other types of information transmitted to, through or from,

received or printed from, or created, stored or recorded on our network and

communications systems (included via the use of personal devices that access our network

and communication system), are business-related and are monitored or accessed by us in

accordance with applicable law and any workplace agreements (such as collective

bargaining agreements), and subject to WBD’s existing policies on access to and uses of

this data. Monitoring may include any and all use of telephones, computers, email, and

Internet. Warner Bros. Discovery reserves the right to monitor the Workforce use of WBD

technology resources to the maximum extent permitted by law, and to review, use, and

disclose any information created, stored, or transmitted on our information technology

systems for legitimate business purposes, including, without limitation, to respond to

government investigations, or as necessary in legal proceedings.

B. VIDEO AND ELECTRONIC MONITORING

Warner Bros. Discovery engages in video or electronic monitoring activities (video, still

footage or other means of electronic monitoring such as badge readers) in its workplaces

(including remote workplaces) and the Workforce understands that Warner Bros.

Discovery engages in such monitoring practices. Surveillance tools may be used in any

common areas for business purposes, including, without limitation, for safety, security

purposes and productivity related purposes. Warner Bros. Discovery engages in

workplace electronic monitoring and accesses information created, transmitted, or

stored via its network for safety, security, compliance, and productivity-related purposes.

Warner Bros. Discovery collects this information routinely and accesses it on an as-

needed basis. Warner Bros. Discovery may employ special monitoring tools or change

settings of existing monitoring tools as part of a reasonable investigation or to meet legal

obligations. Signs indicating the presence of video monitoring may be posted at

workplaces.

6. DATA RETENTION

Warner Bros. Discovery holds Personal Information only for as long as is necessary for the

purposes for which the Personal Information is Processed. This means that the retention

periods will vary according to the type of Personal Information and the reason that we have

this Personal Information.

Generally, we will hold your Personal Information for the course of your employment

relationship or engagement with us (except where applicable law only allows for a shorter

period) and for a certain period after termination of employment or engagement. We have

a detailed internal retention policy that sets out varying retention periods for different

categories of Personal Information, depending on our legal obligations and whether there

is a commercial need to retain the Personal Information. After a retention period has lapsed,

the Personal Information is securely deleted, unless, where permitted under applicable law,

it is necessary for the establishment, exercise or defence of legal claims. For further

information regarding applicable retention periods, you should contact your Controller

using the contact methods set out below.

7. TRANSFERRING, SHARING, AND DISCLOSING PERSONAL INFORMATION

Warner Bros. Discovery may share your Personal Information with third parties or within

the Warner Bros. Discovery group of companies that are located around the world and

particularly in the United States, where Warner Bros. Discovery, Inc. is based. You can learn

more about Warner Bros. Discovery affiliate companies by visiting our controller and

affiliate site. Whenever we transfer Personal Information outside of the United Kingdom,

Switzerland, European Economic Area (EEA), Mainland China or any country that restricts

data transfers, we ensure that appropriate safeguards are in place by using appropriate

data transfer mechanisms such as an adequacy decision adopted by the applicable

jurisdiction such as the EU Commission using approved Standard Contractual Clauses,

international data transfer certifications, or codes of conduct, or Binding Corporate Rules.

The Workforce may obtain further information about the transfer mechanism we rely on

when transferring their Personal Information outside the United Kingdom, Switzerland, the

EEA, or other jurisdictions that may require a transfer mechanism by contacting us at

privacy.support@wbd.com.

•

Data sharing within the Warner Bros. Discovery family of companies

All Warner Bros. Discovery entities are part of the Warner Bros. Discovery group of

companies operating internationally. All members of the group support and interact with

each other to run their businesses and to set group-wide strategy. Certain Personal

Information can be accessed by any of the Warner Bros. Discovery group of companies on

a worldwide basis (such as corporate directory information) where there is a legal basis to

do so. Other Personal Information will be Processed by your line managers, members of

your local HR team and the Legal, Compliance, Financial, and HR shared services teams

where relevant, necessary and legally permitted. Some of these Workforce and IT systems

may be located outside of your country, including in the US. All access is subject to data

security measures and internal controls established under applicable Warner Bros.

Discovery policies and is restricted to what is relevant and proportionate for the relevant

legitimate purpose.

Certain Personal Information is shared among Warner Bros. Discovery group of companies

for group reporting, legal, management and regulatory purposes, including name, employee

and ID numbers, birth date, gender, role information and salary information.

Learn more about Warner Bros. Discovery companies by visiting our controller and affiliate

site

•

Change of Control

In the event we go through a business transition such as a merger, acquisition, bankruptcy,

reorganization, or sale of all or a portion of our assets, or a diligence process in connection

with a potential business transaction, the information we collect and maintain may be

disclosed, sold, or transferred as part of that transaction. If such transfer is subject to

additional restrictions under applicable laws, we will comply with such restrictions.

•

Data sharing with third parties

We may share your information with various third parties as Warner Bros. Discovery group

of companies needs to engage with these third parties to run every aspect of its business.

Where necessary for the Processing activities set out herein, Warner Bros. Discovery

shares Personal Information with:

(i)

Third party service providers

which help Warner Bros. Discovery carry out its business

activities, for example, IT providers (resources and support), training providers,

security companies, benefits providers, payroll and other HR related service providers,

travel/events/communication companies, hotel and transport companies etc. as well

as any advisers (e.g., lawyers, accountants, auditors, etc.) and insurance companies;

(ii)

Business partners

such as event partners, co-producers, broadcasters, licensees and

distributors and awards organisers; and

(iii)

Other relevant third parties

such as journalists, professional organisations, industry

bodies, public/governmental agencies or authorities, law enforcement, emergency

contacts and services or potential purchasers of Warner Bros. Discovery or parts of its

business and the advisors of those potential purchasers.

8. SECURITY MEASURES

We aim to protect personal information by implementing and maintaining reasonable and

appropriate security, such as by using reasonable organizational, technical and physical

safeguards appropriate to the sensitivity of the personal information we hold.

You also have an obligation to help protect Warner Bros. Discovery systems and data, and

to comply with applicable policies and procedures concerning information security. If you

suspect there has been a breach of our systems, your IT credentials, or any other

circumstances that may compromise the security, integrity, confidentiality or availability

of Warner Bros. Discovery IT resources or data, you must report your concerns

immediately.

For any urgent cybersecurity matters or emergencies, contact the Security Operations

Centre at +1 (404) 827-1900 or cybersecurity@wbd.com. The SOC is here to help you

24/7/365.

9. YOUR RIGHTS AND MANDATORY PROCESSING

As provided for by applicable law, you may have the right to access your Personal

Information; to correct (or update), delete or restrict (stop any active) Processing of your

Personal Information; and to obtain the Personal Information we provide to you in a

structured, commonly used and machine-readable format and to ask us to share this

Personal Information to another controller (portability).

In addition, you may have the right to object to the Processing of your Personal Information

in some circumstances (in particular, where we don’t have to Process the Personal

Information to meet a contractual or other legal requirement). Where Warner Bros.

Discovery has asked for your consent, you have the right to withdraw your consent at any

time by contacting your Controller using the contact methods set out below.

As provided for by applicable law, you may also have the right not to be subject to certain

wholly automated decisions.

The rights set out above are not always applicable or may be limited under the GDPR or

applicable law. Under certain circumstances, Warner Bros. Discovery may not action a

request for these reasons. Warner Bros. Discovery will inform you of relevant exemptions

we rely upon when responding to any request you make.

If you are not happy with how Warner Bros. Discovery has responded to your request or

how we Process your Personal Information, you also have the right to complain to the data

protection authority where you live, work or where you believe a breach has occurred and

the right to bring an action before courts.

We will tell you where Personal Information collection is mandatory – this will include

Personal Information that is necessary to perform our contract with you, information

needed to check your right to work and to manage your performance. As permitted under

applicable law, failure to provide information may be a breach of your agreement with us

and may have disciplinary consequences. Staff are also required to report any changes to

Personal Information that is mandatory (in particular, your bank account number and any

changes in your contact details). Where Personal Information is optionally provided, for

example details of an emergency contact, there may be some adverse consequences if

you refuse to provide this.

10. CONTACTING YOUR CONTROLLER

To exercise any of the rights listed in section 9 above, or if you have any queries or

concerns about the way that Warner Bros. Discovery Processes your Personal Information

(or any questions about this privacy notice), or to contact your Controller or your

Controller’s Data Protection Officer, please email privacy.support@wbd.com. You can also

contact your local People and Culture team with your queries or concerns, but use of the

email address above will better direct your query to our Privacy team.

11. ETHICS AND COMPLIANCE CONTACT INFORMATION

Ethics and Compliance Office,

230 Park Avenue South, 12th Floor

New York, NY 10003

[email protected]

24-hour Compliance Helpline:

(800) 375-0288 OR (800) 398-6395 (calls can be made anonymously)

12. MODIFICATIONS TO THE NOTICE

Warner Bros. Discovery reserves the right to modify this privacy notice at any time. We

encourage you to periodically check back and review this notice so that you always know

our current privacy practices.

13. ACCESSIBILITY

We are committed to ensuring that our communications are accessible to individuals with

disabilities. To submit accessibility related requests or report barriers to accessibility,

please contact us at the address, phone, or email address above.

14. SUPPLEMENTARY INFORMATON FOR CALIFORNIA RESIDENTS ONLY

This supplementary information applies to all Workforce referred to under the California

Consumer Privacy Act for purposes of providing required notices.

CALIFORNIA PRIVACY RIGHTS, METRICS, AND DISCLOSURES

This California Privacy Rights, Metrics, and Disclosure section addresses legal obligations

and rights laid out in the California Consumer Privacy Act (“CCPA”) and other laws that

apply only to California residents. These obligations and rights apply only to California

residents and only to information that identifies, relates to, describes, is reasonably

capable of being associated with, or could reasonably be linked, directly or indirectly, with

California Workforce or their households (“California Information”). It does not apply to

information that has been de-identified or aggregated as provided by CCPA.

•

CCPA Metrics 

Regulations require us to provide disclosure of metrics for the previous calendar year

regarding the requests by California residents. These metrics report the number of access,

deletion and correction requests made, the number fulfilled in whole, or in part, and the

number denied. That information can be found by navigating to the CCPA Metrics Reporting

page.

•

California Information We Collected

In the year before this section was last updated, we may have collected the following

categories of California Information (each described further above under “Personal

Information Collected”):

• Address and other identifiers

• Unique and online identifiers

• Biometrics

• Categories of personal information described in California Civil Code § 1798.80

• Characteristics of protected classifications under law

• Professional or employment-related information

• Education information

• Audiovisual information

• Geolocation information

• California Sensitive Personal Information, which includes information revealing

Social Security, passport, and other government identification numbers; account

log-in and financial account numbers in combination with other information that may

provide access to an account (such as log-in credentials for our information systems

or direct deposit information); precise geolocation (such as through GPS trackers

on company vehicles); racial or ethnic origin; contents of communications for which

we are not the intended recipient (such as if an employee uses our information

systems for personal communications); information concerning health; and

biometric information processed for the purpose of uniquely identifying an individual

•

Purposes for Collecting California Information

We may have collected or used these categories of California Information for the

following business or commercial purposes:

• Performing services on behalf of the business – such as human resources and

Staff management and business process execution and management

• Helping to ensure security and integrity, such as fraud and crime prevention

• Debugging errors in networks and systems

• Internal research, analytics and development

• Developing, maintaining, provisioning or upgrading networks, services, or devices

• Auditing compliance with the CCPA and otherwise fulfilling our legal obligations

We retain California Personal Information only for as long as is necessary for the purposes

for which it was collected. This means that the retention periods will vary according to

the type of Personal Information and the reason that we have this Personal Information.

Generally, we hold California Personal Information for the course of your employment

relationship or engagement with us (except where applicable law only allows for a shorter

period) and for a certain period after termination of employment or engagement.

•

Sources of California Information

We may have obtained California Information from a variety of sources, including:

• Directly from you

• Indirectly, such as through third-party platforms

• Our affiliates

• Our joint ventures and promotional and strategic partners

• Other individuals submitting information about you – such as references and

referrals, or our service providers and business partners involved in Personnel

matters like recruitment

• Publicly available sources

•

Disclosures of California Information:

In the year before this section was last updated, we may have disclosed the following

categories of California Information to third parties:

• Address and other identifiers

• Unique and online identifiers

• Biometrics

• Categories of personal information described in California Civil Code § 1798.80

• Characteristics of protected classifications under law

• Professional or employment-related information

• Education information

• Audiovisual information

• Geolocation information

• California Sensitive Personal Information, which includes information revealing

Social Security, passport, and other government identification numbers; account

log-in and financial account numbers in combination with other information that may

provide access to an account (such as log-in credentials for our information systems

or direct deposit information); precise geolocation (such as through GPS trackers

on company vehicles); racial or ethnic origin; contents of communications for which

we are not the intended recipient (such as if an employee uses our information

systems for personal communications); information concerning health; and

biometric information processed for the purpose of uniquely identifying an individual

We may have disclosed each of these categories of California Information to the following

categories of third parties:

• Affiliates – These entities are associated with us through common ownership. For a

list of affiliates, please visit the affiliates page

https://www.warnermediaprivacy.com/policycenter/b2c/affiliateslist/#affiliates.

• Service Providers – These entities Process information on our behalf for business

purposes.

• Other third parties to the extent necessary for purposes described in the Purposes

for Collecting California Information section above, such as our agents and

representatives, successors in interest, and as reasonably necessary to meet our

legal obligations.

We may have disclosed each of these categories of California Information for the purposes

described in the Purposes for Collecting California Information section above.

•

Selling and Sharing

Warner Bros. Discovery does not “sell” or “share” California Information of the Workforce,

and has not done so in the prior 12 months. In this context, “share” means use for cross-

context behavioral advertising. We also do not have actual knowledge of selling California

Information of consumers under 16 years of age.

•

Your California Privacy Rights to Request Disclosure of Information We Collect

and Disclose About You

If you are a California resident, the CCPA grants you the right to request certain information

about our practices with respect to California Information. In particular, you can request

the following:

• The categories and specific pieces of your California Information that we’ve

collected

• The categories of sources from which we collected California Information

• The business or commercial purposes for which we collected or sold California

Information

• The categories of third parties to which we disclosed California Information

You can submit a request to us for the following additional information:

• The categories of third parties to whom we’ve sold California Information, and the

category or categories of California Information sold to each

• The categories of third parties to whom we’ve disclosed California Information, and

the category or categories of California Information disclosed to each

•

Your Right to Request the Deletion of California Information

Upon your request, we will delete the California Information we have collected about you,

except for situations when that information is necessary for us to: provide you with a

product or service that you requested; perform a contract we entered into with you;

maintain the functionality or security of our systems; comply with or exercise rights

provided by the law; or use the information internally in ways that are compatible with the

context in which you provided the information to us, or that are reasonably aligned with

your expectations based on your relationship with us.

•

Your Right to Request the Correction of California Information

Upon your request, we will correct (or provide methods for self-correction) of the California

Information we have collected about you, taking into account the nature of the California

Personal Information and the purposes of the processing, except for situations when: there

is a good-faith, reasonable, and documented belief that the request to correct is fraudulent

or abusive; where we do not hold the information that is required to be corrected; or the

request to correct has denied the same alleged inaccuracy within the past six months of

receiving the request.

•

How to Exercise Your California Rights

You may exercise your rights to request access to your California Information, deletion of

your California Information, or correction of your California Information by submitting a

request here. You can also contact us at Employee Connections at (US): 818-954-4636 or

(US Toll-Free): 888-875-4455 for additional assistance. and an agent will assist you with

submitting a request.

When you submit a request, you must provide information sufficient to verify you are the

person about whom we collected California Personal Information (or the parent or

authorized agent of that person, as explained below). We will ask you to provide an email

address which we will use to contact you to confirm the request was not fraudulently

submitted. For your security and protection, we may need to verify your identity via a phone

call. We may ask you to submit additional documentation to verify your identity but we will

only use this information for the purposes of verifying your identity for your request,

security, or fraud-prevention, and not for any other purpose. That additional information

will be deleted as soon as practical after verifying your identity.

If you are the parent of a child under 13 years of age, you may also submit a request on

behalf of your child. To do so, we will ask you to provide your email address and your child’s

email address. We will then contact you at your email address to confirm the request was

not fraudulently submitted. We will then need to verify your identity and relationship to your

child. To do so we may ask you to submit a signed and notarized form authorizing us to

proceed with the request regarding your child’s California Information. We may also ask

you to provide additional documentation to verify your identity, but we will only use this

information for the purpose of verifying your identity for your request, security, or fraud-

prevention, and not for any other purpose. That additional information will be deleted as

soon as practical after processing your request. Once we have confirmed your identity and

authority to make a request on your child’s behalf, we will start processing the request.

You may also designate an authorized agent to submit a request on your behalf. We will

contact your authorized agent to confirm the request was not fraudulently submitted. We

will then need to verify your authorized agent’s identity and that they are authorized by you

to make the request on your behalf. To do so, we may ask your authorized agent to submit

either (1) a valid and notarized power of attorney, or (2) a document of written permission

authorizing your agent to act on your behalf, signed and notarized by both you and your

agent. In the event your authorized agent is relying on a signed and notarized document of

written permission from you, we may also need to verify your identity and/or contact you

directly to confirm permission to proceed with the request. Once we have confirmed your

authorized agent’s identity and authority to make a request on your behalf, we will start

processing the request.

Your authorized agent can make a request by contacting us here or Employee Connections

at (US): 818-954-4636 or (US Toll-Free): 888-875-4455.

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Our Support for the Exercise of Your Data Rights

You have the right not to receive discriminatory treatment if you exercise any of the rights

explained in this section of the privacy notice. We are committed to providing you control

over your California Information, and we will not disadvantage you if you choose to exercise

your rights.