Candidate Privacy Notice

This notice outlines:

how Flagstone Group Limited (FGL) and Flagstone International
Limited (FIL) use your personal information
how and when we share your information
how you can exercise your rights when it comes to your information

Who collects and uses your information?

Flagstone collects, processes, and stores your information in the ways outlined in this notice. FGL is registered as a data controller with the Information Commissioner’s Office (registration number ZA033774). FIL is registered as a data controller with the Jersey Office of the Information Commissioner (“JOIC”) (registration number 71026).

At times, FGL and FIL act as joint controllers of your information, especially information about FIL employees, as FGL provides back-office support to FIL.

What information do we collect and hold?

The information we may collect (directly from you or from third parties) and store includes:

your name, signature, photo, citizenship, passport/visa, drivers’
licence, national insurance number, and other government identifiers
date and place of birth, emergency contact, and gender
contact details, including your home address, telephone number, and
personal email address
job position you have applied for including job title, working time
information, work location, start date, job history, education history
and qualifications, performance, grievance and disciplinary records,
and reasons for leaving previous employment
your salary, any bonus entitlement, benefits, shares, pension plans,
tax codes, bank account details, and details of any beneficiaries for
benefits

Flagstone also processes the following sensitive information:

information on disability, for the purposes of making reasonable
adjustments at your workplace
screening records – we carry out pre-employment screening,
including criminal background checks, employment and credit
reference checks, right-to-work, and adverse media checks
race, ethnicity, religion, including information on your passport or
other citizenship and right-to-work documentation
information you’ve voluntarily provided us for the purposes of equal
opportunities and diversity initiatives
sexual orientation, marital status, and information on your marriage or
civil partnership certificate, in case we need to update your name.

How do we use your information?

We collect and use your information for several purposes, including:

determining your suitability for a role, inviting you for interview and
carrying out any pre-employment checks
drafting and entering into an employment contract with you
providing compensation, including payroll, expenses and other
applicable incentives
calculating and paying any taxes, student loans and other
government contributions, plus managing any attachment of earnings
orders, e.g. for child maintenance arrangements
providing applicable benefits, shares and other work-related
allowances, including reporting of benefit entitlements and take-up of
benefits
producing and maintaining organisational charts
carrying out workforce planning
administering mandatory training, providing IT systems and support to
enable you and others to perform your work, to enable our business to
operate and to enable us to identify and resolve IT issues and to keep
our systems secure
complying with applicable laws, regulatory (including Financial
Conduct Authority (FCA) and employment related requirements,
including health and safety, employment and immigration laws and
sanction laws
communication with you or your designated contacts in case of an
emergency

Why do we use your information?

We use your information lawfully for the purposes we’ve outlined above, where one of the following applies:

For non-sensitive information, our legal bases are:

performance of the contract of employment with you
compliance with legal obligation, especially labour and employments
law, social security and protection law, tax law, and corporate
compliance laws
the legitimate interests of Flagstone or other third parties (such as
existing or potential business partners, suppliers, customers, end-
customers, or governmental bodies and/or courts)
your consent

For sensitive information, our legal bases are:

to carry out the obligations and to exercise the specific rights of
Flagstone or you in the field of employment and social security and
social protection law as permitted
to protect the vital interests of you or another individual where you’re
physically or legally incapable of giving consent
to establish, exercise, or defend a legal claim, or whenever courts are
acting in their judicial capacity
for the assessment of the working capacity of the employee, as
permitted by local data protection law
your explicit consent
the prevention and detection of unlawful acts

Flagstone needs to process your personal information to consider your application for vacant roles and to potentially enter into a contract of employment with you. There are also statutory and other contractual requirements we’re required to comply with in relation to your prospective employment, as well as business and operational needs we must meet.

If we’re not able to carry out the processing activities we describe in this Notice, we may not be able to consider your application for employment or proceed with an employment contract. Once employed, please refer to our Employee Privacy Notice to understand how we collect, process and store the data of our employees.

Who may we share your information with?

We may transfer personal information to third parties, including outside the UK and Jersey for processing purposes such as:

communications with third parties – as necessary to fulfil our business
operations. We may transfer work contact details to existing or
potential business partners, suppliers, customers, government
officials, and other third parties.
regulators, authorities, and other third parties. We may transfer
personal information to regulators, courts, and other authorities (tax
and law enforcement authorities), independent external advisors (for
example, auditors), insurance providers, pensions and benefits
providers, and investigations teams (both internal and external).
acquiring entities. If the business may be sold or transferred in whole
or in part (or if we contemplate a sale), we may transfer your personal
information to the new employer or potential new employer as part of
the transfer itself, or as part of an initial review for such transfer (for
example, due diligence). This is subject to any rights provided by
applicable law, including jurisdictions where the new employer or
potential new employer are located.
data processors. To only process personal information in line with our
written contract. The data processors may be involved in workforce
administration, IT system support, payroll and compensation, training,
compliance, and other activities.

Where do we keep your information?

We store your information in the UK/Jersey where possible. In some circumstances, your information may be located elsewhere, which may include a country that does not have the same level of data protection as the UK or Jersey. We’ll always take measures to ensure we’re protecting your information as required by law.

How long do we keep your information?

We only keep your personal information for as long as necessary. We may, for example, keep your personal information for a reasonable time after you’ve ended your employment to ensure we have the records we need in the event of a dispute or regulatory investigation. Or, to comply with any ongoing contractual obligations.

We also may need to keep personal information to comply with requests from regulators. In the event that we keep your personal information, that period will be determined by applicable local law.

Our records retention policy states that for job applicants, we retain personal data for no more than 6 months after we’ve informed the candidate they have been unsuccessful, or have not accepted an offer of employment.

Your rights

You have rights when it comes to your personal information, and there are several requests you can make to exercise these rights.

The right to be informed how we're using your information

You have rights when it comes to your personal information, and there are several requests you can make to exercise these rights.

The right to access your information

You can ask us for a copy of any information we hold on you.

The right to rectify your information

You have the right to ask us to correct information you feel is inaccurate, incomplete, or both.

The right to restrict how we use your information

In some cases, you have the right to restrict us from processing or deleting your information. There are some things we need to use your information for – for example, to help protect you from fraud, and to fulfil legal and contractual obligations. This may mean we’re unable to restrict how we use your information.

The right to object to how we use your information

In some cases, you have the right to object to the way we process your information. There are some situations where we will not stop processing your information despite your objection – for example, to meet legal or regulatory obligations, or so we can continue to fulfil our contract with you.

The right to erasure

In some cases, you have the right to have your information erased. We may not be able to agree to your request if it affects our ability to meet our regulatory obligations, or so we can continue to fulfil our contract with you.

The right to data portability

You have the right to ask us to transfer a copy of some of your information to you or to a new data controller – for example, another employer. This applies when you’ve shared your information with us, it’s been collected with your consent, or where collecting it was necessary for the agreement between us.

The right to human intervention

You have the right not to be subject to a decision that's based solely on automated processing, if the decision affects your legal rights (for example, if we automatically reject your application for a Flagstone account). However, we do not make automated decisions right now, so this isn't applicable.

The right to withdraw your consent

Where we’re relying on your consent to process any of your information, you have a right to withdraw that consent at any time.

Exercising your rights

If you wish to exercise any of these rights, please contact our Data Protection Officer (DPO) at data.protection@flagstoneim.com. The DPO will fulfil your request within one month (UK) or four weeks (Jersey). We may extend this deadline by up to a further two months (UK) or eight weeks (Jersey).

Complaints

If you’re concerned with how we've handled your information, please contact our Data Protection Officer at data.protection@flagstoneim.com.

You also have the right to complain to the Information Commissioner’s Office (UK): ico.org.uk

Jersey Office of the Information Commissioner: jerseyoic.org

Updated February 2024