Phillips 66 Global Recruiting Privacy Statement
Last Updated: 6 September 2023
Phillips 66 is committed to protecting your privacy. This Recruiting Privacy Statement provides information regarding how we treat the personal data (also known as personal information) we collect from you and your associated rights when you apply to work for or when you are recruited by a company or companies within the Phillips 66 group of companies (“Phillips 66,” “we,” “us,” “our,” or “Company”). If we hire you, we will supply you with all additional applicable employee-related privacy policies at that time.
The term “process” (or “processes” or “processed”) refers to any action that is performed on your personal data, whether wholly or partially by automated means, such as collecting, recording, organizing, storing, modifying, using, disclosing, or deleting such data.
In addition to this Privacy Statement, other privacy statements that apply to you may contain additional information about how we process your personal data, such as when we conduct on-line video interviews, pre-employment screening, and background checks. Where applicable, such privacy statements will be communicated and made available to you separately.
What personal data does Phillips 66 collect?
Depending upon where you live, the company identified as the recruiting Phillips 66 company is called the “data controller” or “business,” and is responsible for the processing of your personal data, either solely or jointly with its affiliates within the Phillips 66 group of companies. We collect your personal data for the operational purpose of evaluating your eligibility for employment with us, and therefore, we may collect the following categories of information:
- Contact information, identifiers, and demographic information, such as your name, home or postal address, telephone number, email address, date of birth, gender identity, national insurance number, your legal right to work in the country in which you seek employment with us, emergency, or family contact information;
- Education or career-related information, such as education or institutions attended, degrees completed, employment history/experience, professional designations, associations, affiliations, references, certifications, language(s) spoken, and training;
- Video and audio recordings created during the interview process;
- Pre-employment screening and security and background check information, such as information derived from international sanctions list checks and, in some specific cases, for which we will seek your consent prior to the commencement of such screenings, credit checks, driving license checks, and/or criminal records checks.
- Security surveillance footage, such as data collected from CCTV and other surveillance technology, such as ANPR, bodycams, and dashcams in use at sites you may attend in connection with your application for employment; and
- Other information collected through your application for employment, such as your tax credit targeted group status.
We may collect and process certain categories of personal data known as sensitive personal data or special categories of personal data (depending on where you live) for the purposes explained below. These categories of data include:
- Health information, such as any disabilities where accommodations may need to be made during the interview process, pre-employment medical questionnaire answers and medical evaluations; and
- Nationality, racial and/or ethnic origin.
In the United States, in addition to these categories and as it relates to prospective employment with us, sensitive personal data also includes Social Security Numbers, state identification cards, and passport numbers. This data will only be collected and processed where required or permitted by applicable law.
You are not required to provide information we may request, but if you choose not to provide it, your employment application may not be successful.
What are the sources from which we collect personal data?
Phillips 66 collects personal data (described in the section above and including sensitive personal information or special categories of data) from you online and offline in the following ways:
- From you directly. We collect personal data that you provide to us as part of the employment application process.
- From public sources and third parties. We collect personal data about you from publicly observed data (for example, from social media websites or online activity where allowed by applicable law). We also collect data from third parties we use to assist us with pre-employment background checks and/or career application and recruiting services.
We may draw inferences from any of the categories of data described above to help us tailor our communications to you. We may also combine information we get from a third party with information we already have, and we may combine information that we have collected offline with information we collect online.
Cookies, web beacons and other tracking
Our websites may also contain web beacons, which are small, transparent image files. Web beacons allow us to count the number of users who have visited pages of our sites. We may also include web beacons in promotional email messages or newsletters in order to determine whether messages have been opened and acted upon, including whether the recipient clicked on a link in the email or forwarded the email to another person.
Here are some of the types of personal data collected when visiting our website and mobile application:
- Log data, such as your device’s IP address, browser settings, the date of your visit, and how you used the website or mobile application.
- Cookie data, which is used to record log data.
- Social media plugins, that enable you to share information with others (e.g., the Facebook “like” button) and that allows us to recognize you if you have previously visited our websites and are logged into the social media website while browsing our website.
- Device information, such as your geographic location, what operating system you are using, your device’s settings, and other unique device identifiers.
Tracking Options and “Do Not Track” Signals
For what purposes do we use your personal data?
We process personal data of applicants only as may be necessary:
- to take steps at your request prior to employment to allow us to enter into, and where applicable, to perform under an employment contract with you;
- where it is necessary to comply with a legal obligation to which the relevant Phillips 66 company is subject to ensure compliance with applicable laws and regulations;
- where it is necessary for the legitimate business interests of Phillips 66, except where such interests are outweighed by your interests or fundamental rights and freedoms; or
- with your explicit consent (if legally required).
Where processing is legally required to be based on your consent, you have the right to withdraw your consent at any time and subject to applicable local law providing otherwise. This will not affect the validity of the processing of your personal data prior to your withdrawal of consent.
We may also use your personal data in other ways as required or permitted by law, such as dispute resolution, litigation or defense of claims, or for analytical and demographic purposes where you cannot be reasonably identified because personal data is aggregated and/or in an anonymous format.
We also collect and process your personal data to comply with our legal and regulatory/government obligations related to our hiring practices; to protect your vital interests or those of another natural person if required; and/or for our legitimate business purposes, including:
- to consider your application for a posted position for which you apply or which we believe you may be eligible for and to administer the application, interview, and selection process, including communicating with you during the interview process so we can develop and maintain a skilled, professional, and productive workforce;
- to conduct background screening to verify the information you provide during the interview process and conducting background checks using publicly available information, international sanctions list checks and, in some specific cases, credit checks, driving license check, and/or criminal records checks (we will seek your consent prior to the commencement of such screening); and
- to support the health, safety, security of you, other applicants, and our employees;
- to provide a safe and respectful workplace as required by law and Phillips 66’s policies.
- to prevent illegal activity or to protect our legitimate interests such as the security and integrity of our business and assets and to safeguard your personal data.
Sensitive Personal Data/Special Categories of Data
During the pre-employment process, we may collect and process sensitive personal data (also known as special categories of personal data, depending on where you live) such as your nationality, racial and/or ethnic origin, and health-related information in our medical questionnaire for the purposes of making accommodations during the interview process; assessing your eligibility for certain positions and your fitness to work certain jobs; for the establishment, exercise or defense of legal claims; or to ensure equal employment opportunities as permitted or required by local law. We only collect and use your sensitive personal data to fulfill our business purposes related to the consideration of your employment with us, and we do not use such information to infer any other characteristics about you.
We do not sell and have not sold your personal data or transferred personal data to third parties to use for their, or our own commercial benefit.
To whom do we disclose your personal data?
The personal data we collect from and about you may be disclosed to third parties, including:
- Affiliated Phillips 66 Companies: other companies within the Phillips 66 group of companies, including to affiliates and/or subsidiaries which may be located outside of your location;
- Service Providers: third-party service providers to provide services to us or on our behalf, such as data hosting, cloud services, sending out information and communications, processing transactions, analyzing data, technical support, and other business and professional services such as provision of online interview applications and the conduct of background screening (we provide these companies with only those elements of personal data they need to provide their services to us);
- Required Disclosures: competent public authorities, government, regulatory, or fiscal agencies if we are required to do so by law or if we have a good-faith belief that we must do so to comply with the law or other legal requirements or processes, including litigation and investigations, or to protect our own or others’ rights, property, or safety; and
International transfers in global operations
We may transfer personal data to and store personal data in countries other than the country where it was collected or from where you accessed our websites or applications. Those countries may have different data privacy and protection laws than the countries from which the personal data was collected or from which you accessed our websites or applications. To the extent required by applicable law, we will take measures to protect personal data so transferred or stored. For example, we implement Standard Contractual Clauses approved by the European Commission and United Kingdom and use similar contractual obligations to comply with applicable laws of other jurisdictions including data processing agreements in the United States. By choosing to apply for employment, including use of our websites and applications, and submitting personal data to us, you consent to the transfer of such personal data outside of your country of residence.
How long do we keep your personal data?
We store personal information about you on computer systems operated by us or our service providers. As a regulated company, we keep various records that contain personal information in accordance with applicable state and federal regulations, or pursuant to contractual obligations. In general, we aim to keep personal information only for as long as necessary and only for the reason(s) we collected it. It may be necessary to keep personal information longer than our official retention periods for legal or regulatory reasons, including litigation. To support us in managing how long we hold personal information and our record management, we maintain a data retention policy which includes clear guidelines on retention and deletion.
We consider the following criteria when determining how long a particular record will be retained, including any personal information contained in that record:
- How long the record is needed to provide you with the products and services you request
- How long the record is needed to support and enhance our operational processes
- How long the record is needed to protect our rights and legal interests
- How long the record must be retained to comply with applicable laws and regulations
The same personal information about you may be included in more than one record and used for more than one purpose, each of which may be subject to different retention periods based on the factors listed above.
We use technical, administrative, and procedural measures to safeguard your personal data from unauthorized access or use. We use, and we require our service providers to use, industry standard security measures for securing and protecting personal data, which may include measures such as encrypting data in transit and at rest, as well as limiting access to personal data on a least privilege basis (i.e., giving each user access only to personal data needed to perform their specific job duties). No such measure is ever 100% effective though, so we do not guarantee that your personal data will be secure from theft, loss, or unauthorized access or use, and we make no representation as to the reasonableness, efficacy, or appropriateness of the measures we use to safeguard such data.
Our websites and applications may contain links to other websites, including those of other companies, organizations, and publications. These linked websites operate independently from our websites and applications, and we do not control and are not responsible for the content, security, or data privacy practices used by other entities. You should review the privacy statements of those linked websites to determine how they protect and use your personal data.
Our recruiting and career application websites and applications are not directed to children under 16 years of age, and we do not knowingly collect any personal data from children under 16. If we learn that we collected the personal data of a child under the age of 16, we will use reasonable efforts to delete such information from our systems promptly.
Depending upon the laws applicable where you reside, you may have certain rights associated with your personal data. You may have the right to:
- access the personal data we collected about you;
- correct inaccurate personal information;
- delete your personal data (but only where no longer required by us for a legitimate business purpose);
- restrict our processing of your personal data (limit its use);
- receive your personal data in a structured, digital form suitable for transmission to another party if technically feasible; and
- complain to your local data protection authority.
Click here if you are a resident of California in the United States.
Austrian residents or applicants may contact email@example.com. To view more details about how JET petrol stations Austria GmbH processes personal information in the course of its business operations, please review the Privacy Statement. In Austria, complaints can be addressed to the Austrian Data Protection Authority (by post to Wickenburggasse 8, 1080 Vienna or by email to firstname.lastname@example.org).
German residents or applicants may contact email@example.com. To view more details about how JET petrol stations Germany GmbH processes personal information in the course of its business operations, please review the Privacy Statement. In Germany, complaints can be addressed to the Hamburg Commissioner for Data Protection and Freedom of Information (by post to Ludwig-Erhard-Str. 22, 7th floor, 20459 Hamburg or by email to firstname.lastname@example.org).
UK residents or applicants may contact InformationManagementUK@p66.com. To view more details about how Phillips 66 Limited processes personal information in the course of its business operations, please review the Fair Processing Notice for Third Parties. In the UK, complaints can be addressed to the Information Commissioner’s Office (please visit www.ico.org.uk for further information).
Changes to this Privacy Statement
We reserve the right to amend this Privacy Statement at any time at our discretion and will review and update it as may be necessary but will do so at least annually. When we do, we will revise the effective date at the top of this Privacy Statement.
If you have questions, issues, or complaints regarding the processing of your personal data, please refer to the relevant Phillips 66 Privacy Statement in your location. Residents of all other locations may contact us at www.phillips66.com/contact.