Privacy Notice – Job Applicants

Personal information is data that can be used to identify or contact a single person. It does not included data which has been anonymised. There are also “special categories” of data, which are more sensitive personal data – these are provided a higher level of protection.

What Information does the Company Collect and How?

Petrolink will collect a range of information about you and this includes:

• Your name, address and contact details, including email address and telephone number;
• Details of your educational history, qualifications, skills, experience and employment history;
• Information from interviews, either face to face, by telephone or any other electronic means used for this purpose;
• Information about your current level of remuneration, including benefits entitlements;
• Information about your entitlement to work in the Isle of Man and United Kingdom; and
• Equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief.

We may collect this information in a variety of ways – such as in application forms or CVs, obtained from your passport or other identity documents, or disclosed by you during interviews or other methods of assessment.

We may also collect personal data about you from third parties, such as references supplied by former employers. We will seek information from third parties only once a job offer has been made to you.

Data will be stored in a range of different places, including on your application record, in our HR management systems and our email system.

Petrolink collects and processes your data for a number of purposes and where we have a legal basis to do so.

We may use your personal information for a number of different purposes. In each case, we must have a “legal ground” to do so. We will rely on the following legal grounds when we process your personal information:

• We have a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate’s suitability for employment, and decide to whom to offer a job. We may also need to process data from job applicants to respond to and defend against legal claims.

When processing special categories of personal information we require to have a further justification for carrying out such processing. Such justifications include (but are not limited to):

• carrying out our legal obligations as a prospective employer;
• complying with the law; and/or
• safeguarding your well-being and/or mental health.

For example, Petrolink may process information about whether or not applicants are disabled so that we can make reasonable adjustments for candidates who have a disability. Where we process other special categories or data such as information about ethnic origin, sexual orientation, health or religion or belief, this is for equal opportunities monitoring purposes. Our processing of these types of data will be carried out to ensure you or us can meet our obligations or exercise our rights under law related to employment or (only where applicable) to enable us to establish, exercise or defend legal claims.

We do not need your consent to use special categories of personal information if it is justified in line with the bases set out in the data protection laws. Where we can obtain your consent, we shall do so.

In the event of an unsuccessful application, we will not use your personal data for any purpose other than the recruitment process of which are you a part.

You are not under any statutory or contractual obligation to provide data to Petrolink during the recruitment process. However, if you do not provide the information, we may not be able to process your application.

Petrolink shares personal information only as described below:

• Third Party Service Providers
  We will not share your data with third parties, unless your application is successful and offer of employment is made. We will then share your data with former employers in order to obtain references, or third party background checking companies. We may also share your data with our group companies, for business performance and other types of monitoring and management purposes and, if you are applying for a senior management position with us, we may share your data with our investors and/or shareholders.
  Finally, we may employ other companies and individuals to perform functions on our behalf – for example to carry out pre-employment screening checks. They will have access to personal data to the extent that this is needed to perform their functions, but may not use it for other purposes. Further, they must process the personal information in accordance with this Privacy Notice and applicable data protection laws.
• Petrolink Group Companies
  We may share personal information with Petrolink’s group of companies, which means subsidiaries of Petrolink International Limited (as defined in section 220 of the Isle of Man Companies Act 2006) and personnel carrying out functions within such companies, for the purposes of the recruitment process. This may include members of the HR team, interviewers involved in the recruitment process, and managers in the business area where the vacancy exists. It should be noted that some members of the HR team, interviewers and/or managers may work in other jurisdictions.
  In the event of an unsuccessful application, we will share personal information only to the extent required in order to process your application.
• Others
  We may need to disclose your personal information if we are required by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate.
  We may also disclose information about you if we believe that such action is necessary to protect and/or defend our rights, property or personal safety and those of our users/customers or other individuals.

There may be some instances where your personal information is transferred outside of the Isle of Man or UK, such as when we transfer information to our group companies or to third party suppliers who are based in other countries or when third parties who act on our behalf transfer your personal information to countries outside of the Isle of Man/UK.

Where such a transfer takes place, we will take the appropriate safeguarding measures to ensure that your personal information is adequately protected. We will do so in a number of ways including by entering into data transfer contracts and using specific contractual provisions that have been approved by data protection authorities.

If you would like further information regarding our data transfers please contact us using the contact details provided below.

We will retain your personal information for the period necessary to fulfil the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law.

Petrolink takes the security of your data seriously. We have internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our personnel in the proper performance of their duties.

If your application for employment is unsuccessful (including when you have speculatively applied to us in response of a role which is not available), we will hold your data on file for six months. At the end of that period, your data will be destroyed or deleted (unless we need to retain it for longer to exercise or defend any legal claims).

If you application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which employee data is held will be provided to you in a separate privacy notice.

Under data protection laws you have a number of rights in relation to the personal information that we hold about you which we set out below. These rights might not apply in every circumstance. You can exercise your rights by contacting us at any time using the details set out below. We will not usually charge you in relation to a request.

Please note that although we take your rights seriously, there may be some circumstances where we cannot comply with your request such as where complying with it would mean that we couldn’t comply with our own legal or regulatory requirements. In these instances we will let you know why we cannot comply with your request.

1. The right to access your personal information
   You are entitled to a copy of the personal information we hold about you and certain details of how we use it.
   We will usually provide your personal information to you in writing unless you request otherwise. Where your request has been made electronically (e.g. by email), a copy of your personal information will be provided to you by electronic means where possible.
   Where you would like to do so, you can submit requests by email to Contracts@Petrolink.com.
2. The right to rectification
   We always take care to ensure that the information we hold about you is accurate and where necessary up to date. If you believe that there are any inaccuracies, discrepancies or gaps in the information we hold about you, you can contact us and ask us to update or amend it.
3. The right to restriction of processing
   In certain circumstances, you are entitled to ask us to stop using your personal information, for example where you think that the personal information we hold about you may be inaccurate or where you think that we no longer need to use your personal information.
4. The right to withdraw your consent
   Where we rely on your consent in order to process your personal information, you have the right to withdraw such consent to further use of your personal information.
5. The right to erasure
   This is sometimes known as the ‘right to be forgotten’. It entitles you, in certain circumstances, to request deletion of your personal information. For example, where we no longer need your personal information for the original purpose we collected it for or where you have exercised your right to withdrawn consent.
   Whilst we will assess every request, there are other factors that will need to be taken into consideration. For example we may be unable to erase your information as you have requested because we have a regulatory obligation to keep it.
6. The right to object to direct marketing
   You have a choice about whether or not you wish to receive marketing information from us and you have the right to request that we stop sending you marketing messages at any time. You can do this either by clicking on the “unsubscribe” button in an email that we send to you or by contacting us using the details set out below.
7. The right to object to processing
   In certain cases you have the right to object to our processing, This arises in relation to where we process your personal information based on our legitimate business interests. Where we do so, you can object to such processing, unless our purpose outweighs any prejudice to your privacy rights.
8. The right to data portability
   In certain circumstances, you can request that we transfer personal information that you have provided to us to a third party.
9. Rights relating to automated decision-making
   We do not carry out any automated decision making. If this changes in the future, we will provide you with an updated notice setting out our decision making process.
10. The right to make a complaint with the Regulator
    You have a right to complain to the Information Commissioner’s Office (ICO) or any other local Data Protection Regulator if you believe that we have breached data protection laws when using your personal information.

You can visit the ICO’s website at https://ico.org.uk/ for more information. Please note that lodging a complaint will not affect any other legal rights or remedies that you have.

If you have any questions or concerns about privacy of our websites or applications please contact us at Contracts@Petrolink.com with a thorough description and we will try to resolve the issue for you.

Our Privacy Notice may be updated from time to time and to comply with the data protection laws. You are encouraged to check our website frequently to see recent changes.