Corporate information

Petro Well Services (PWS), and associated companies (Petro Well Services Ltd and PWS Crew Ltd) (“we”/”us”/”our”) are committed to protecting the privacy and security of your personal information and this privacy notice describes how we collect and use personal information about you during prior to your working relationship with us, in accordance with the General Data Protection Regulations (GDPR).

As part of any recruitment process, PWS collects and processes personal data relating to job applicants.  We are committed to being transparent about how we collect and use that data and to meeting our data protection obligations.

This version of our Privacy Statement is live from September 2019.

What information do we collect?

Petro Well Services collects a range of information about you including:

• Personal contact details such as name, title, addresses, contact details (including email address and telephone number(s)
• Details of your qualifications, skills, experience and employment history
• Information about your current level of remuneration, including any benefits entitlements
• Whether or not you have a disability for which the Company needs to make reasonable adjustments during the recruitment process
• Information about your entitlement to work in the UK

How is your personal information collected?

Your information is collected in different ways, for example, data might be contained in application forms, CV’s, passport or other identity documents, or collected through the interviews which are held and any other forms of assessment such as online testing.

We will also collect personal data about you from third parties such as references supplied by former employers. References may be contacted prior to interview if you have given consent within the application form.

Where will we keep your personal information?

The data we collect will be stored in your application record, in  the HR systems and on other IT systems (including email).  All storage locations will adhere to our internal IT security protocols and will meet the necessary confidentiality standards.

Why we process your personal information

Petro Well Services needs to process data to take steps at your request prior to entering into a contract with you and again if we do enter into a contract with you.

Sometimes we need to process data to ensure that we are complying with legal obligations, for example, we are required to check an applicant’s eligibility to work in the UK prior to any employment starting.

We have a legitimate interest in processing personal data during the recruitment process and keeping records of that process.  By processing data from job applicants, we can manage recruitment processes, assess and confirm your suitability for employment and make decisions on job offers.  There are times when we may need to process data from job applicants in the response to and defence of any legal claims which may be brought.

We have assessed and believe that in addition to our interests, it is in third parties and your interests for us to retain your personal information in relation to any suitable future employment opportunities which you may be interested in.  If you object to us retaining your information you can object by writing to HR@pws-global.com

We will not use your data for any purpose other than the recruitment exercise for which you have applied.

Who has access to your data?

Your information will be shared for the purpose of the recruitment exercise, this includes interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to any of the data is necessary for the performance of their roles.

Your data will not be shared with any third party companies, with the exception of our outsourced HR service, until your application for employment is successful and you receive an offer of employment.  We will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks in relation to the specific role and the Disclosure and Barring Service (DBS) to obtain criminal records checks where necessary for the role.

We may transfer your personal information outside the EEA in relation to job placement opportunities.  We will only do this if:

• The transfer is to a place that is regarded by the European Commission as providing adequate protection for your Personal information; or
• we have put in place appropriate safeguards by using a contract for the transfer which contains specific data protection provisions that have been adopted by the European Commission or a relevant data protection authority, to ensure you can expect continued protection of your personal information.

Do we use automated decision making?

Our recruitment processes are not based on automated decision-making.

Data Security

Petro Well Services takes the security of your data very seriously and has 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 its employees and third party providers in the legitimate performance of their duties in relation to the recruitment process.

If you are successful in your application for employment, personal data gathered during the recruitment process will be transferred to your personal file and retained in accordance with Company policies.  You will be provided a new Employee Privacy Notice at that time.

Your rights

As a data subject, you have several rights, you can:

• Access and obtain a copy of your data on request;
• Require the organisation to change incorrect or incomplete data;
• Require the organisation to delete or stop processing your data where the data is no longer necessary for the purposes of processing;
• Object to the processing of your data where we are relying on our legitimate interests as the legal ground for processing; and
• Ask us to stop processing data for a period of data is inaccurate or there is a dispute about whether or not your interests override the Company’s legitimate grounds for processing data

If you would like to exercise any of these rights please contact HR@pws-global.com. You can also contact the HR department to request a Subject Access Request Form (SAR) if you wish to make a SAR.

If you believe that the organisation has not complied with your data protection rights, you can complain to the Information Commissioner’s Office (ICO).

We are committed to conducting our business ethically and responsibly, and as part of this commitment we fully support the abolition of, and the protection against, slavery and human trafficking which have no place in the world.

Modern slavery is an international crime affecting an estimated 40.3 million people around the world. This growing global issue transcends age, gender and ethnicities. It includes victims trafficked from overseas and vulnerable people in our communities who are forced illegally to work against their will across many different sectors such as agriculture, hospitality, construction, retail and manufacturing.

This statement outlines the steps that Petro Well Services, and all associated companies, (PWS) have taken to assess our operational actions to understand all potential modern slavery risks related to its business. This will allow us to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business, or in its supply chain.

Our organisation

PWS focuses on the provision and operation of modular drilling/workover/P&A units globally for the onshore & offshore oil & gas industry, currently employing 50 people, in the current locations:

• Norway
• United Kingdom
• Abu Dhabi

We currently have approximately 100 suppliers that provide various goods and services from the manufacture / provision of equipment to payroll support.

Our approach‍

Our business activities have been reviewed and have been considered as low risk in terms of the potential for involving the exploitation, slavery or trafficking of people.  Our code of conduct requires all employees and those working directly for the company to support our policy on standing against slavery or human trafficking.

Our supply chain carries a slightly higher potential for the exploitation of people in the manufacturing and supply processes, so within our terms and conditions documentation we stipulate that our suppliers must accept that trading with us requires them to respect human rights and stand against slavery and human trafficking.

Training‍

By providing awareness training to our personnel we will enable & educate them with the basic understanding of modern slavery & human trafficking and how we can tackle, prevent and report such issues.

Clear policy‍

We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:

• Employee code of conduct: makes clear to employees the actions and behaviours expected of them when representing PWS. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and dealing with our supply chain.
• Supplier/Procurement code of conduct: We are committed to ensuring that our suppliers meet our own high ethical standards. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour.  Where necessary, we will work with suppliers to ensure that they meet the standards of the code and improve their worker's working conditions. However, serious, and/or continuous violations of our supplier code of conduct will lead to the termination of our business relationship with them.
• Selection & Recruitment Policy: We use only specified, reputable employment agencies to source our labour. We verify the practices of any new agency we may wish to work with, before accepting any workers or placing recruitment requirements for employees from that agency. We will strive to be, as a minimum, a living wage employer, wherever we work.  We also ensure all employees have the right to work in the United Kingdom, Norway or whichever country we may be operating.

Supplier due diligence

We undertake due diligence when considering taking on new suppliers, and regularly review our existing ones. Due diligence and reviews include:

• mapping the supply chain broadly to assess product or geographical risks of modern slavery and human trafficking (ref: Global Slavery Index);
• evaluating the modern slavery and human trafficking risks of each new supplier;
• conducting supplier audits or assessments, which include focus areas for slavery and human trafficking where higher risks are identified;

Focus areas / Initiatives

We will:

• Require, as a minimum, our supply chain personnel/HR professionals to have completed awareness training on modern slavery;
• Review our supplier assessment processes and ensure it clearly captures the evaluation of modern slavery standards of suppliers before they enter the supply chain; and
• Review/Monitor our existing supply chain, and identify the risk associated with each supplier.

Management approval

This statement has been approved by our senior management team, who will review annually as a minimum.