On the one hand, discovery statutes are construed liberally to uphold the right to discovery wherever possible. ( Emerson Electric Co. v. Superior Court (1997) 16 Cal. 4th 1101, 1107, 946 P.2d 841.) The scope of discovery is broad. the test is whether it "appears reasonably calculated to lead to the discovery of admissible evidence." ( Code Civ. Proc., 2017, subd. (a).) In particular, "discovery may be obtained of the identity and location of persons having knowledge of any discoverable matter . . . ." (Ibid.) On the other hand, the state constitutional right to privacy (Cal. Const., art. I, 1) provides a qualified, not absolute, bar to discovery. ( Britt v. Superior Court (1978) 20 Cal. 3d 844, 854-855, 143 Cal. Rptr. 695, 574 P.2d 766.) A party to an action may assert the privacy rights of third parties such as its employees. (Valley Bank of Nevada v. Superior Court (1975) 15 Cal. 3d 652, 657, 125 Cal. Rptr. 553, 542 P.2d 977.) The trial court is required to balance the right of privacy with the need for discovery. ( Harris v. Superior Court (1992) 3 Cal. App. 4th 661, 665.) As we recently explained, "the party seeking the constitutionally protected information has the burden of establishing that the information sought is directly relevant to the claims." (Tylo v. Superior Court (1997) 55 Cal. App. 4th 1379, 1387.)