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Phillips 66 Fair Processing Notice for Third Parties 

Last Updated: 1 November 2026

  1. This Fair Processing Notice sets out how Phillips 66 handles the Personal Data of third parties that Phillips 66 has contact with in the course of its business operations, including our current, past and prospective:
    • customers and their representatives, employees or agents;
    • suppliers and their representatives, employees or agents;
    • counterparties and their representatives, employees or agents;
    • contractors and their representatives, employees or agents;
    • officers and beneficial owners of the above;
    • visitors to our premises;
    • customers of Jet branded service stations;
    • prospective employees and apprentices, work experience students and other job applicants;
    • advisers, consultants and other professional experts; and
    • those with whom Phillips 66 works in the context of our community initiatives.

  2. The Controller of your Personal Data is the Phillips 66 legal entity that has contact with you. If you have any questions about this Fair Processing Notice or the use of your Personal Data, please contact InformationManagementUK@p66.com.

  3. Phillips 66 will collect Personal Data relating to you prior to, in the course of our business with you, and after. This Personal Data will be collected in a number of ways, including, for example, when you contact Phillips 66 by email, post, telephone or by using Phillips 66 websites or platforms operated by our service providers, through operating security policies and procedures on our premises (for example by gate access data or image data from CCTV and other surveillance technology such as Automatic Number Plate Recognition, bodycams and dashcams recorded by Phillips 66 or, where applicable, our landlord), or when you or your employer or employer’s affiliated companies otherwise have contact with Phillips 66 employees, representatives or agents during the course of Phillips 66 operating its business including where business is required to be conducted on recorded telephone lines or other electronic devices. The Personal Data Phillips 66 may collect about you will include (in certain circumstances):

    • Name (first, last, middle, previous)
    • Title
    • Work address
    • Home/Mailing address
    • Work telephone and mobile phone numbers
    • Home telephone and mobile phone numbers
    • Work email address
    • Home email address
    • Emergency contact(s) (name, address and telephone number)
    • IP address
    • Application forms (for employment)
    • Resume or curriculum vitae/career history
    • Training/Qualifications data (such as language and proficiency levels, education, degrees, certifications, etc.)
    • Professional designations, associations and affiliations
    • Compensation history (application forms for employment)
    • Job history 
    • Nationality
    • Date of Birth/age
    • Signature 
    • Gender and Gender Identity
    • References and background checks (including where applicable, results of international sanctions list checks, credit and Disclosure and Barring Service criminal convictions checks)
    • Name, location of employer business entity 
    • Position/Job title, department
    • Photographs and video images
    • Image data from surveillance technology such as CCTV, bodycams, dashcams and Automatic Number Plate Recognition footage
    • Voice/audio recordings
    • Gate log data
    • Locational data from lone worker tracking devices used on Phillips 66 premises
    • Driver’s name and further data may be derived from tracking devices such as, but not limited to, GPS used for monitoring and tracking of vehicles’ movements
    • Driver’s licence number/other details
    • Security clearances, authorizations (e.g. to access secure areas of our facilities; place orders; take/fulfill orders, etc.)
    • Ability test results
    • Data relating to health (e.g. medical, accident, health and safety, occupational health or disability records including those relating to substance abuse testing, industrial exposure monitoring, temperature checks and blood testing in connection with COVID-19) only where required or permitted by applicable laws
    • Data relating to race or ethnic origin, sexual orientation, religious or political beliefs, trade union membership and criminal background data only where required or permitted by applicable laws
    • Bank/Building Society Sort Code
    • Bank Account Number/Building Society Roll Number 
    • Bank/Building Society name and address 
    • National Insurance Number, etc. (or other personal identification as applicable)
    • Usage of Phillips 66 assets and systems
    • Access to Phillips 66 provided benefits (e.g. meal allowance)

  4. Phillips 66 may also collect Special Categories of Data relating to you, including data relating to health (e.g. medical, sickness, accident or disability records), race or ethnic origin, sexual orientation, religious or political beliefs, trade union membership and criminal background data. This data will only be processed with your explicit consent or where required or permitted by applicable laws.

  5. Phillips 66 will use the Personal Data that it collects about you for a number of purposes, including to:

    1. process any job, student placement or scholarship application you (or your representative) have submitted;
    2. carry out pre-employment/job assignment background checks, anti-money laundering and sanctions checks and otherwise comply with its legal and regulatory obligations;
    3. manage and administer the relationship or contract between you/your employer or affiliate company and Phillips 66;
    4. respond to any query that you may submit to Phillips 66 and send you relevant information on our goods and services that may be of interest to you using the contact details you have provided;
    5. support the health, safety and well-being of you and Phillips 66 employees;
    6. support Phillips 66’s assets or the environment;
    7. provide a safe and respectful premises as required by law and Phillips 66’s policies;
    8. conduct operations and to manage and protect Phillips 66 assets and systems, including Personal Data regarding network, intranet and internet usage, voice recording and image data collected via video or surveillance technology (including CCTV, ANPR, dashcams and bodycams);
    9. deliver services to employees, customers and the public;
    10. conduct ‘know your customer’ information due diligence with financial institutions, potential trading counterparties and service providers;
    11. obtain or access services (e.g. banking);
    12. allow you access to Phillips 66 premises;
    13. record your entry to and departure from Phillips 66 premises for invoicing purposes in respect of any contract between you/your employer or affiliate company and Phillips 66;
    14. allow you access to Phillips 66 facilities, systems and websites, to administer and customise such websites and Apps and as part of our efforts to keep such websites and Apps secure;
    15. prevent illegal activity or to protect our legitimate interests, as Phillips 66 consider necessary;
    16. conduct training, share knowledge and/or help improve our processes, products, systems and services; 
    17. where Processing is based on your consent, for the purpose or purposes you have consented to.

  6. For the purpose of the Data Protection Laws and Regulations, except where your consent is required and obtained or where Processing of Special Categories of Data is necessary in the context of the establishment, exercise or defence of claims; to protect the vital interests of the Data Subject or another person where the Data Subject is incapable of giving consent or for the purposes of preventative or occupational medicine, for the assessment of the working capacity of the Data Subject, medical diagnosis or the provision of treatment, for reasons of public interest in the area of public health; the legal bases on which Phillips 66 Processes Personal Data about you are that the Processing is necessary (a) for the performance of or entry into a contract to which you are party or in order to take steps at your request prior to entering into a contract; (b) for compliance with a legal obligation to which Phillips 66 is subject; (c) in order to protect your vital interests or those of another natural person; or (d) for the purposes of the legitimate interests pursued by Phillips 66 in running its business.

  7. The Personal Data that Phillips 66 collects about you may be disclosed to Recipients including:

    1. other companies in our group;
    2. contractors and service providers in the provision of services to Phillips 66;
    3. suppliers that provide business services, such as security, online job application providers and IT support (e.g. cloud service providers), banking and credit card services, or telecommunications services;
    4. professional advisors including accountants, auditors and lawyers, our insurers and brokers; 
    5. governmental and regulatory bodies, such as tax authorities.

  8. Phillips 66 will only disclose your Personal Data to Recipients where it is necessary (a) to enable the Recipient to provide services for or on behalf of or transact with Phillips 66, (b) for Phillips 66 to comply with applicable legal requirements, (c) to protect or defend the rights or property of Phillips 66, or (d) to protect the health, safety and well-being of you and Phillips 66 employees, contractors, visitors or members of the public. Some of these Recipients may Process your Personal Data in accordance with their privacy policies.

  9. Automated decision-making. The Phillips 66 recruitment process may use a system that has an element of automated decision-making, but Phillips 66 does not carry out solely automated decision-making. When you submit an application for an open role Phillips 66 has posted, the system extracts information you provide on your application regarding your qualifications to compare it to the qualifications required for the role and provides a grade and/or recommendation. This means that your application may be scored by the system based on the extracted information, and the system may suggest candidates to Phillips 66 recruitment personnel accordingly, but it does not disqualify applications. However, depending on the grade allocated to your application, Phillips 66 recruitment personnel may decide not to review your application. Ultimately, the decision on whether to progress your application will be made by a member of our recruitment team, not as a result of the automated process. 

  10. You may be entitled to request access to Personal Data Phillips 66 holds about you, or to request that your Personal Data is erased, that its Processing is restricted, or that any inaccurate Personal Data is rectified. When Processing of your Personal Data is based on consent, you have the right to withdraw your consent at any time. This will not affect the validity of the Processing prior to the withdrawal of the consent. You also have the right to object to the Processing of your Personal Data and, in some circumstances, you may have the right to receive a copy of your Personal Data in a machine-readable format. If you wish to make such a request or withdraw your consent, please contact InformationManagementUK@p66.com. 

  11. If you believe that Phillips 66 use of your Personal Data has breached its obligations under the Data Protection Laws and Regulations, and you wish to make a complaint, please contact InformationManagementUK@p66.com or write to Phillips 66 Limited, 7th Floor, 200-202 Aldersgate Street, London EC1A 4HD, for the attention of UK Data Privacy. You also have the right to complain to the Supervisory Authority (which in the UK is the Information Commission). Please visit www.ico.org.uk for further information.

  12. Phillips 66 only collects your Personal Data for the specific purposes set out at paragraph 5. Phillips 66 will not retain your Personal Data for longer than is necessary to fulfil these purposes, taking into account legal and regulatory compliance, and Phillips 66’s internal corporate retention policies.

  13. Phillips 66 centralises the management of certain Information Technology operations in the United States, and as such your Personal Data will be transferred outside of the United Kingdom. Phillips 66 has implemented safeguards to ensure that this transfer of Personal Data complies with the Data Protection Laws and Regulations, including by entering into appropriate Data Transfer Agreements. If you would like more information about the transfer of your Personal Data, please contact InformationManagementUK@p66.com.

Definitions

Controller means, as defined by the Data Protection Laws and Regulations, the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the Processing of Personal Data.

Data Protection Laws and Regulations means all laws and regulations applicable to the Processing of Personal Data, including the United Kingdom retained EU law version of the General Data Protection Regulation (EU 2016/679), the Data Protection Act 2018 (and regulations made thereunder), the Data (Use and Access) Act 2025, and the Privacy and Electronic Communications Regulations 2003 (SI 2003/2426), as they may be amended, modified or replaced from time to time.

Personal Data means any information relating to (i) an identified or identifiable natural person (“Data Subject”) that is within the scope of protection as “personal data” under the applicable Data Protection Laws and Regulations, and (ii) an identified or identifiable legal entity (where protected under applicable Data Protection Laws and Regulations).

Processing means, as defined by the Data Protection Laws and Regulations, any operation or set of operations which is performed upon Personal Data, whether or not by automatic means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Recipient means a natural or legal person, public authority, agency or another body to which Personal Data is disclosed, whether a third party or not.

Special Categories of Data means ‘special categories of personal data’ as referred to in the Data Protection Laws and Regulations, which include any Personal Data revealing a Data Subject’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, criminal background data, sex life or sexual orientation, genetic information, biometric information or health information.

Supervisory Authority means the Information Commission.