Available on bp forecourts from August 2019
We are bp pulse (Chargemaster Limited), a company registered in the United Kingdom (company number 06720009), whose registered offices are at Breckland, Linford Wood, Milton Keynes, United Kingdom, MK14 6GY (hereinafter: “the Company”, “bp pulse”, “we” or “us”). We are the organisation responsible for the personal data collected about you in the course of your employment at bp pulse within the meaning of applicable data protection and privacy laws.
We want to ensure you understand what personal data we collect about you, how we will use it and for what purpose. We are also required by data protection legislation to explain certain matters to you. This notice sets this out.
Personal data is all information relating to an identified or an identifiable natural person. A person is identified when the identity of a specific person can be deduced from the information itself. A person is identifiable when we can make a connection to a specific person using information available to us.
This privacy notice covers the use of personal data relating to employees, and temporary workers engaged by bp pulse. We will be the “controllers” of the personal data we collect about you.
For the avoidance of doubt, this privacy notice does not form part of your contract of employment, and we may update it at any time. If we make a material change to this privacy notice we will notify you.
During your employment with the Company, it is routine for us to collect, store and process personal data about you. We may obtain this information: directly from you; from third parties such as employment agencies; your former employer(s), background check agencies and recruitment ATSs; or, from publically available information that you post online including on social networking sites. This personal data will include your:
• personal details including your name, address, date of birth, email address, phone numbers;
• marital status;
• next of kin or emergency contact and their contact numbers;
• certain information used for equal opportunities monitoring;
• information included on your CV including references, education history and employment history;
• information on student and postgraduate loans;
• documentation relating to your right to work in the UK;
• photo ID including driving licence and passport;
• bank details;
• P45 / P46 form;
• tax codes;
• National Insurance number;
• current and previous job titles, job descriptions, pay grades, pension entitlement, hours of work, training and other terms and conditions relating to your employment with us;
• letters of concern, formal warnings and other documentation about any disciplinary proceedings;
• internal performance information including measurements against targets, formal warnings and related documentation about capability and appraisal forms;
• leave records including annual leave, family leave, sickness absence etc;
• training details;
• vehicle registration number
Please note, we provide an optional “Get Introduced to the Team” section as part of the onboarding process. You should be aware that personal data that you voluntarily include in this section, or in free text boxes, will also be processed in accordance with this privacy notice. Please bear this in mind when providing us with information about yourself via this section, or via free text boxes.
We may also collect, store and process the following “special categories” of more sensitive personal data in order to exercise rights and obligations under employment law:
· medical or health information including whether or not you have a disability;
· your race or ethnicity, religious beliefs, sexual orientation and political opinions;
· information about your health, including via a medical health questionnaire and your sickness absence records;
· certain information used for equal opportunities monitoring; and
· information on criminal offences, including through DBS checks.
We are required to inform you of the different legal bases that we rely on to legitimise our processing of your personal data. We have described these below, with respect to each of the purposes identified for processing your data:
We need to use your personal data to:
(i) administer your employment:
a. determining your recruitment and the terms and conditions of your employment;
b. administering your pay and benefits;
c. managing your holiday, sick leave and any other absences including family leave;
d. appraising and managing your performance and providing you with training;
e. dealing with disciplinary matters and any grievance raised by or involving you;
f. making decisions about your continued employment and your terms and conditions;
g. liaising with the trustees or managers of a pension arrangement operated by a group company,
your pension provider and any other provider of employee benefits; and
h. education, training and development requirements.
When processing your personal data for these purposes, we are relying on the legal basis that processing your personal data is necessary for us to carry out our contractual obligations with you.
(ii) ensure compliance with our rules and processes
a. we monitor use of our IT systems, including email, internet and intranet, Company mobile and landline phones, computers and tablets to gather evidence in respect of any potential wrongdoing; and
b. meeting the KPIs and other measures within your current position.
When processing your personal data for these purposes, we are relying on the legal basis that processing your personal data is necessary in order to further the Company’s legitimate business interest.
(iii) Ensure administration of business
a. managing and planning our business; and
b. communicating with you; and
c. working with others within the work force.
(iv) comply with our legal obligations
a. carrying out equal opportunities monitoring; and
b. ensuring you are legally entitled to work in the UK.
When processing your personal data for these purposes, we are relying on the legal basis that processing your personal data is necessary in order to comply with our legal obligations as your employer.
The Company’s relevant legitimate business interests include:
a. recruitment and succession planning;
b. organisation and distribution of work;
c. management forecasting;
d. promoting equality and diversity in the workplace;
e. ensuring health and safety in the workplace;
f. protection of Company property and property belonging to third parties;
g. maintaining an efficient employee benefits program;
h. aligning the interests of employees with those of the Company’s shareholders; and
i. maintaining a well-managed and orderly workforce and business.
Special categories of personal data (e.g. personal data revealing your race, ethnic origin, religious beliefs, or data concerning your health) require higher levels of protection. We have described the legal bases on which we process the special category personal data below, with respect to each of the purposes identified for processing your special category data, but please note the special category personal data we collect will
also sometimes be collected on the basis of it being necessary for the establishment, exercise or defence of legal claims.
(i) Race and religious belief data is held and processed for the purpose of equal opportunities monitoring.
When processing your personal data for these purposes, we are relying on the legal bases that processing your personal data is necessary: (a) in order to comply with our legal obligations as your employer; and (b) for the purposes of carrying out obligations and / or exercising specific rights of the Company or yourself related to employment.
(ii) Health information is kept to monitor the wellbeing of the work force, and also ensuring there are no trends that may show where there is further risks to health in the work environment.
When processing your personal data for these purposes, we are relying on the legal bases that processing your personal data is necessary: (a) in order to comply with our legal obligations as your employer; and (b) for the purposes of preventive or occupational medicine and for the assessment of the working capacity of employees.
(iii) Information on criminal history is collected to enable us to make recruitment and employment decisions that take the safety and wellbeing of all of our employees and customers into account.
When processing your personal data for these purposes, we are relying on the legal bases that: (a) processing your personal data is necessary in order to comply with our legal obligations as your employer; and (b) carrying out obligations and/or exercising specific rights of the Company or yourself related to employment.
Please note that the legal bases above now apply instead of any general data protection consent that is written in your employment contract.
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).
bp pulse is part of the BP Group. Given the global nature of BP’s operations, personal information may be transferred within its group internationally, subject always to BP’s Binding Corporate Rules (“BCRs”), available via the following link https://www.bp.com/content/dam/bp/country- sites/en_hu/hungary/home/documents/appendix2-part-a-bp-data-privacy-rules-public-document-13-jan- 17.pdf bp pulse is a signatory to BP’s BCRs.
We will need to share your personal data with others from time to time, including:
· our professional advisers and auditors, such as our accounting and legal advisers, where they require that information in order to provide advice to the Company (or to provide information to HM Revenue & Customs, or any other regulatory authority, on behalf of the Company);
· HM Revenue & Customs and any other regulatory authority we may be subject to for the purpose of demonstrating compliance with applicable law and regulations;
· such third parties as we reasonably consider necessary in order to prevent crime, such as the police;
· our bp pulse service providers such as our pensions brokers as well as those who provide and support our HR system; and
· prospective buyers of business assets in the event that we sell or buy any business assets.
The Company retains your personal data for no longer than is necessary for the purposes for which it is collected. When deciding the relevant retention periods, we will take into account factors including:
· legal obligation(s) under applicable law to retain data for a certain period of time;
· whether there is an on-going business need to retain the data;
· statute of limitations under applicable law(s);
· (potential) disputes; and
· guidelines issued by relevant data protection authorities.
Otherwise, we securely erase your personal data once this is no longer needed.
For more information about how long we keep your personal data for a particular purpose, you can refer to the data retention policy, by contacting firstname.lastname@example.org
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
You have certain rights in relation to your personal information as summarised here. For more information on your rights see our data protection policy and the contact details at the bottom of this notice:
· Right to be informed – you have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights; this is why we are providing you with this privacy notice;
· Right of access – you can request confirmation of the processing of your personal data, or request access to the personal information we hold about you at any time;
· Correcting your information – where we hold information about you that is inaccurate or incomplete, you have the right to ask us to rectify or complete it;
· Right to erasure – you have the right to request that we “erase” your personal data in certain circumstances, including where: the data are no longer necessary, the data has been processed unlawfully, or you object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.
· Right to restrict processing – you have the right to request that we restrict some processing of your personal data in certain circumstances, for example if you dispute the accuracy of the personal data that we hold about you or you object to our processing of your personal data for our legitimate interests;
· Right to object to processing – you can object to us processing your personal data in certain circumstances, including where we are using it for the purpose of the Company’s legitimate business interests or to enable us to perform a task in the public interest or exercise official authority;
· Right to data portability – you can request that we transfer your personal information to another party.
· Right to complain – you are able to submit a complaint to the Information Commissioner’s Office about any matter concerning your personal data, using the details below. However, we take our obligations seriously, so if you have any questions or concerns, before taking this step we encourage you to first use BP’s complaints resolution mechanism under our BCRs.
Information Commissioner’s Office Wycliffe house
Water Lane Wilmslow Cheshire SK9 5AF
Tel 0303 123 1113 www.ico.org
In general, your data will be stored in the UK. However, a number of our service providers are located outside of the UK, for example, in the United States.
In the event that we transfer your personal data to, or store your personal data in, a country outside of the UK, and where the country or territory in question does not maintain adequate data protection standards, we will take all reasonable steps to ensure that any such transfers are undertaken in accordance with applicable data protection and privacy laws and that your data is treated securely and in accordance with this privacy notice.
However, please note that where personal data is stored in another country, it may be accessible to law enforcement agencies in accordance with domestic laws.
If you have any queries or concerns about the way in which we collect or use your personal data, about this privacy notice, or if you would like to exercise one of your rights under data protection and privacy laws, please contact our Data Privacy Focus Group at email@example.com, or contact us via post at bp pulse, Breckland, Linford Wood, Milton Keynes MK14 6GY.
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