Live Nation Entertainment

Global Data Privacy Notice for Staff

 

Issued: May 2018

Updated: December 2022

1. Introduction

Live Nation Entertainment ("we", "us" or "our") has issued this Global Data Privacy Notice ("Notice") to describe how we handle personal information that we hold about our staff and job applicants (collectively referred to as "you"). The term "staff member" includes those who work on a non-permanent basis, including contingent workers, temporary and contract workers, independent contractors, consultants, professional advisors, secondees and interns.

We respect the privacy rights of individuals and are committed to handling personal information responsibly and in accordance with applicable law. This Notice sets out the personal information that we collect and use about you, the purposes of the processing and the rights that you have in connection with it.

If you are in any doubt regarding the applicable standards, or have any comments or questions about this Notice, please contact us at the contact details in Section 10 below.

2. Categories of personal information we collect

In the course of your employment at Live Nation Entertainment, or when making an application for employment, we may collect and use personal information about you and your dependents, beneficiaries and other individuals whose personal information has been provided to us.

The categories of personal information we may collect and use include, but are not limited to:

• Identification data – such as your name, gender, photograph, date of birth, staff member IDs.
• Contact details – such as home and business address, telephone/email addresses, emergency contact details.
• Employment details – such as past and present job title/position, office location, employment contract, performance and disciplinary records, grievance procedures, sickness/holiday records.
• Background information – such as academic/professional qualifications, education, CV/résumé, criminal records data (for vetting purposes, where permissible and in accordance with applicable law).
• National identifiers – such as national ID/passport, driver’s license, immigration/visa status, social security numbers (US only).
• Spouse & dependents information, marital status.
• Financial information – such as banking details, tax information, withholdings, salary, benefits, expenses, company allowances, stock and equity grants.
• IT information – information required to provide access to company IT systems and networks such as IP addresses, log files and login information. For further information on how IT information is processed, please see the Global Acceptable Use of Live Nation Entertainment Information Resources and Social Media Policy.
• Any other personal information you provide to us in connection with your application for employment or during your continued employment

If you are a contingent worker, the type of personal information we collect and use is limited to that needed to manage your particular work assignment with us.

Sensitive personal information includes any information that reveals your racial or ethnic origin, religious, political or philosophical beliefs, genetic data, biometric data for the purposes of unique identification, trade union membership, or information about your health/sex life ("Sensitive Personal Information"). As a general rule, we try not to collect or process any Sensitive Personal Information about you, unless authorised by law or where necessary to comply with applicable laws. However, in some circumstances, we may need to collect, or request on a voluntary disclosure basis, some Sensitive Personal Information for legitimate employment-related purposes.

Information obtained from third party sources

To the extent permitted by law we may conduct screening checks using publicly available registers, such as business-related information available on the internet, criminal record bureaus and credit reference agencies. When we perform these checks, we may receive personal information about you from these third party sources. We do not perform these checks in every case, but will do so where we consider it proportionate given the role you have applied for or are performing. If we perform these checks we will notify you and inform you as to what personal information is being collected.

3. Purposes for processing personal information

(i) Recruitment purposes

If you are applying for a role at Live Nation Entertainment, then we collect and use this personal information primarily for recruitment purposes – in particular, to determine your qualifications for employment and to reach a hiring decision. This includes assessing your skills, qualifications and background for a particular role, verifying your information, carrying our reference checks or background checks (where applicable) and to generally manage the hiring process and communicate with you about it.

If you are accepted for a role at Live Nation Entertainment, the information collected during the recruitment process will form part of your ongoing staff member record.  If you are not successful, we may still keep your application to allow us to consider you for other suitable openings with us in the future.

(ii) Employment or work-related purposes and benefits

Once you become a staff member, we collect and use this personal information for the purpose of managing our employment or working relationship with you. For example, your employment records and contract information so we can manage our employment relationship with you, your bank account and salary details so we can pay you, your equity grants for stock and benefits plans administration and details of your spouse and dependents for emergency contact and benefits purposes.

 

We collect and use our staff members' personal information through a global human resources system ("HR System"), which is a tool that helps us to administer HR and staff member compensation and benefits, and which allows staff members to manage their own personal information in some cases. We may also collect and use our staff members’ personal information via this HR System when full-time employees utilize and/or access other internal systems such as the LN Merch Store in Backstage Pass.

(iii) Our global directory

We maintain a global directory of staff members which contains your professional contact details (such as your name, location, photo, job title and contact details). This information will be available to everyone in our global group of companies to facilitate cooperation, communication and teamwork.

(iv) Other legitimate business purposes

We may also collect and use personal information when it is necessary for other legitimate purposes, such as to help us conduct our business more effectively and efficiently, including for general HR resourcing on a global level, IT security/management, accounting purposes, or financial planning. We may also collect and use your personal information to investigate violations of law or breaches of our own internal policies.

(v) Law-related purposes

We also may collect and use your personal information where we consider it necessary for complying with laws and regulations, including collecting and disclosing staff member personal information as required by law (e.g. for tax, health and safety, anti-discrimination laws), under judicial authorisation, or to exercise or defend the legal rights of our global group of companies.

4. Who we share your personal information with

We take care to allow access to personal information only to those who require such access to perform their tasks and duties, and to third parties who have a legitimate purpose for accessing it. Whenever we permit a third party to access personal information, we will implement appropriate measures to ensure the information is used in a manner consistent with this Notice and that the security and confidentiality of the information is maintained.

If we ever share your personal information in a way not described within this policy, we will first notify you and obtain your consent to this additional disclosure.

(i) Transfers to other group companies

As mentioned above, we will share your personal information with other members of our global group of companies in order to administer human resources, staff member compensation and benefits at an international level on the HR System, as well as for other legitimate business purposes such as IT services/security, tax and accounting, and general business management.

(ii) Transfers to third party service providers

In addition, we make certain personal information available to third parties who provide services to us.

We do so on a “need to know basis” and in accordance with applicable data privacy law.

For example, some personal information will be available to our third party service providers who provide us with payroll, tax and travel management services.

(iii) Transfers to other third parties

We may also disclose personal information to third parties on other lawful grounds, including:

• To comply with our legal obligations, including where necessary to abide by law, regulation or contract, or to respond to a court order, administrative or judicial process, including, but not limited to, a subpoena, government audit or search warrant;
• In response to lawful requests by public authorities (including for national security or law enforcement purposes);
• As necessary to establish, exercise or defend against potential, threatened or actual litigation;
• Where necessary to protect the vital interests of another person;
• In connection with the sale, assignment or other transfer of all or part of our business; and
• With your consent.

5. Legal basis for processing personal information (EEA staff only)

If you are a staff member in the European Economic Area (EEA), our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only where we need the personal information to perform a contract with you (i.e. to administer an employment or work relationship with us), or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect and use personal information from you or may otherwise need the personal information to protect your vital interests or those of another person. Occasionally, we may rely on your consent to collect and use your personal information.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided at Section 10 below.

6. Transfer of personal information abroad

As we operate at a global level, we may need to transfer personal information to countries other than the ones in which the information was originally collected and your personal information may be subject to the laws of the country to which it is transferred. When we export your personal information to a different country, we will take steps to ensure that such data exports comply with applicable laws, including with respect to the access of such information by the courts, law enforcement and national security authorities of that country.

When transferring information in this way, there are strict rules in place to ensure your data is still protected to a high standard. Where we do this, we will ensure that appropriate safeguards are put in place. Where your information is transferred outside of the European Economic Area, we will use one of the mechanisms listed below.

• Standard Contractual Clauses approved by the European Commission
• Binding Corporate Rules
• Binding Corporate Processor Rules

For more information, or to get a copy of the relevant documentation, please contact us using the contact details below.

7. Data retention periods

Personal information will be stored in accordance with applicable laws, as well as according to the LNE Retention and Destruction Policy and kept as long as needed to carry out the purposes described in this Notice or as otherwise required by applicable law. Generally, this means your personal information will be retained until the end or your employment or work relationship with us plus a reasonable period of time thereafter to respond to employment or work-related inquiries or to deal with any legal matters (e.g. judicial or disciplinary actions), document the proper termination of your employment or work relationship (e.g. to tax authorities), or to provide you with ongoing pensions or other benefits.

8. Your data privacy rights

Your California Privacy Rights.

Your Rights Under the CCPA.  If you are a California resident, you have specific privacy rights governed by the California Consumer Privacy Act (CCPA).  These rights include:

• Disclosure.  You have the right to request a report showing the personal information collected, shared, and sold about you.
• Deletion. You have the right to request that we delete any personal information collected from or about you.
• Do Not Sell or Share. You have the right to opt-out to the sale or sharing of your personal information with third parties.
• Correction. You have the right to request that we correct inaccurate personal information collected from or about you.
• Non-Discrimination. We shall not discriminate against you based on your exercise of any of the above rights.

You may submit a request to enact any of the above rights by clicking here to submit a request or emailing us using the contact details in Section 10 below. Please be sure to include your full name, email address, and which type of request you are making in your email. 

To verify your identity, we may collect information such as your full name and email address. This information will be compared to our existing records to verify the identity of the individual submitting the request. We may also require you to confirm your request via an automated email message before responding to your privacy rights request. Depending on the sensitivity of the information requested and the type of request, we may require additional information to verify your identity before responding.  We will respond to your request within 45 days if possible and required under the law.

You may designate an authorized agent to submit requests on your behalf. For an authorized agent to be considered verified, you must provide the authorized agent with signed, written affidavit to make such requests or a power of attorney. We may follow up with you to verify your identity before processing an agent’s request. Agents may submit requests here.  

Please note that the rights shown here relate to personal information collected or used in the context of you as a staff member or job applicant.  If you would like to exercise any of your rights in relation to personal information we collect or use about you as a consumer, such as in relation to your personal Ticketmaster account, please use the tools provided in our consumer-facing privacy policies.

Your International Privacy Rights

In addition to the above, You may exercise the rights available to you under applicable data protection laws as follows:

• If you wish to access, know, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided at Section 10 below.
• In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided at Section 10 below.
• If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries are available here.)

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

9. Updates to this Notice

This Notice may be updated periodically to reflect any necessary changes in our privacy practices. We will inform you of material changes to this Notice. We will indicate at the top of the Notice when it was most recently updated. We encourage you to check back at this website periodically in order to be aware of the most recent version of this Notice.

10. Contact details

Our Chief Privacy Officer is Hannah Foster and can be contacted at privacy@livenation.com.

The data controller of your personal information is the relevant Live Nation Entertainment entity set out in your contract with us.

Please address any questions or requests or concerns relating to this Notice to your line manager, local HR department or local Data Guru if you have one.