Personal information access policy

BP policy on access to personal information maintained by the company
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Effective July 1, 2010

BP respects and intends to protect employees' legitimate expectations regarding the confidentiality and privacy of personal information maintained by the company. For purposes of this policy, "employee" includes active employees, retirees and other former employees.

Personal information

Where there is law, the scope of personal data will be defined by that law. The law includes specific legislation or regulations adopted by a governmental authority and judicial and administrative decisions. Where there is no law, personal data for the purpose of this policy is defined as: data that relates to a living person who can be identified from the data or by the combination of the data and other data to which you or the company may have access. Examples of personal data include an employee's name, home address, home telephone number, medical information, job application data, race, gender and employee performance appraisals.

Release of personal information

The company will not use personal information for purposes incompatible with its stated Privacy Rules

BP does offer U.S. payroll employees including expatriates as well as former employees who left the company during 2001 or later, online and telephone access to provide third parties with employment and pay verification. To obtain information on this service, look under the Contacts tab on LifeBenefits. Other than this service, BP and its employees do not provide employment references except where necessary to comply with laws or regulations.

Employment verification/background checking for potential new hires

Individuals will be provided with appropriate and necessary notice that a background check is to be conducted and the components of the investigation. When a background check is required, consent will be obtained from the individual. Providing consent may be considered a condition of employment with BP. The information obtained through a background check will be gathered, used and disseminated in accordance with the Fair Credit Reporting Act of 1997 (FCRA) and any applicable state or federal laws for use within BP on a need-to-know basis, or as necessary with other governmental authorities.

Access to the employee file

With reasonable advance notice and in accordance with applicable state law, an employee may examine during business hours the personal information maintained by the company in an employee file specific to him or her, subject to BP's current document retention schedule. Personal information maintained prior to September 19, 2002, was subject to existing heritage company retention schedules and may no longer exit. 

Certain materials may be withheld from inspection, including:

  • Security and investigative records relating to criminal or other conduct by the employee, which could harm the company's property, operations or business, or cause the company financial liability;
  • Documents concerning staff planning for such matters as business development, expansion or closure where more than one employee would be affected;
  • Information about persons other than the employee making the request if disclosure would constitute an invasion of the other person's privacy;
  • Information related to a threatened or pending claim between the employee and the company, which may be discovered in a judicial proceeding; and
  • Any portion of a test document.

A management representative or other authorized representative will be present while an employee is examining such information. An employee may request a copy of a specific document. Reasonable and customary fees may be charged for extensive copying of documents. BP has adopted a global Access Response Procedure which outlines suggested steps followed in response to a request to view personal data held by the company. This process provides a timeline of events to ensure that valid requests are processed in line with local practices, legislation or where no local law exists. 

If an employee, upon examining his/her employee file, believes that information contained in it is inaccurate or incomplete, the employee may submit a statement of his/her position regarding the information. The employee's statement will be retained in the file as long as the information to which it pertains remains in the file. Also, if an employee believes that personal information held by the company has been used in a manner other than its intended purpose, or that inaccurate information has been used and has negatively impacted the employee, the employee can request a review of the matter and disposition by their Manager or by Human Resources.

BP rights

BP reserves the right to unilaterally amend, change, modify, delete, replace or add to the statements in this policy, at any time, with or without prior notice. BP also reserves the right to interpret the provisions of this policy, and such interpretations will be final and binding. In addition, not every situation can be anticipated in written policies, guidelines and/or procedures, and the facts surrounding any situation can require discretionary judgments by appropriate levels of management.

This policy is not intended to create, nor does it create, any express or implied contractual rights in any person. Unless he/she has entered into an express written agreement signed by an authorized company representative, each employee of BP is an "at-will" employee. Just as any at-will employee may terminate his/her employment at any time and for any reason, BP may terminate any at-will employee at any time, with or without cause, and with or without prior notice. This policy does not represent a contract, or an offer to form a contract and does not create any binding contractual commitments between an employee and BP regarding any subject, and does not alter or limit the at-will employment status of BP employees.

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