Privacy Notice for Job Applicants

Pillar Capital Management Limited (the “Company”, “we” or “us”) is committed to handling your personal information responsibly. This Privacy Notice describes how we may use, collect, hold, and disclose Personal Information, as defined below, about Applicants or Consultants (as defined below). The Company may use, collect, transfer, and store Personal Information in accordance with service agreements covering its role as insurance manager, investment manager, and as a related party to its affiliates.

This Privacy Notice is intended to provide individuals with clear and easily accessible information about our practices and policies with respect to Personal Information and is intended to comply with the requirements of the Personal Information Protection Act 2016 of Bermuda (“PIPA”). The Board of Directors of Pillar Capital Management Limited has adopted policies and procedures relating to the use, collection, storage, transfer and protection of non-public Personal Information of the current and former job applicants and individual contractors of Pillar Capital Management Limited (each referred to herein as an “Applicant” or “Consultant”). Pillar Capital Management Limited’s Privacy Policy is set out below.

We have always been, and we remain, committed to maintaining the confidentiality, integrity and security of our Applicants’ and Consultants’ Personal Information. It is our policy to respect the privacy of our Applicants and Consultants and to protect the Personal Information entrusted to us. This Privacy Notice describes the standards we follow for handling your Personal Information.

Definitions

  • “Personal Information” means any information about an identified or identifiable natural person.
  • “Use” or “using”, in relation to Personal Information, means carrying out any operation on Personal Information, including, but not limited to: collecting, holding, organizing, altering, transferring, disclosing, combining, blocking, erasing or destroying it.
  • “Sensitive Personal Information” means any Personal Information relating to an individual’s place of origin, race, colour, national or ethnic origin, sex, sexual orientation, sexual life, marital status, physical or mental disability, physical or mental health, family status, religious beliefs, political opinions, trade union membership, biometric information or genetic information.

 

Information We Collect

We collect the following types of Personal Information, including Sensitive Personal Information, about Applicants and Consultants:

  • Information provided by you as part of the employment application process or due diligence, as applicable. This category may include your name, address, tax identification number, social security number (if applicable), age, marital status, number of dependents, details of financial status including asset holdings, directorships and/or officer appointments, assets, debts, income, employment and salary history, beneficiary information and personal bank account information.
  • Information obtained from others, such as consumer credit reporting agencies and screening software.
  • Information used, collected, stored and transmitted as a result of a Pillar employee’s use of computer systems, company data, computing resources, internet resources, mobile devices, cloud workloads, and physical computers used to conduct the Company business.
  • Correspondence between us and you (written, telephonic or electronic).

 

How we use your Personal Information and Sensitive Personal Information

We use or may use your Personal Information: (i) with your consent; (ii) except for Sensitive Personal Information, where our use is within your reasonable expectation and not prejudicial to your rights; (iii) where it is necessary in the context of a potential employment relationship with us; (iv) to perform a contract with you and/or to prepare to enter into a contract with you; (v) where it is publicly available and will be used for a purpose that is consistent with the purpose of its public availability; and/or (vi) where it is necessary in order for us to comply with a provision of law that authorizes or requires such use.

Your Personal Information will generally be used and collected for the following purposes:

  • Assessing and evaluating your suitability for any current or prospective role within the organization;
  • Administrative and human resources-related matters within our organization;
  • Facilitating our compliance with any laws, agreements, guidance, government and/or industry surveys, and regulations which may be applicable to us; and
  • Verifying your identity and the accuracy of your personal details and other information provided.

Non-public Personal Information consists of information about you and can include information concerning your name, address, social security number, proof of identity and address, and information about your marital status and level of income and/or assets. We may also use your Personal Information which you have permitted to be made available to the public or which is legally obtained through government records or information that is legally required to be made public. We will keep your Personal Information no longer than is necessary for the purpose of its use, including in accordance with any statutory or regulatory requirements and our record retention policies. A limited and reasonable amount of information may be kept for archiving purposes. Your Personal Information will be used by us in a lawful and fair manner and adequate, relevant and not in excess of the purposes for which it has been collected or used.

Sensitive Personal Information that we use, collect, store, and transfer from you is limited to information you provide regarding your place of origin, race, color, national or ethnic origin, sex, sexual orientation, marital status, physical or mental disability, physical or mental health, family status, religious beliefs, biometric information or genetic information. Your Sensitive Personal Information will generally be used and collected for the following purposes, and we may disclose your Sensitive Personal Information to unaffiliated third parties where necessary for the following purposes:

  • Verifying your identity and the accuracy of your personal details and other information provided;
  • Completing police and other background checks;
  • Applying for or renewing a work permit, if required;
  • Verifying your continued rights to live and work in Bermuda;
  • Fulfilling contractual obligations relating to the provision of health and pension benefits; and
  • Facilitating our compliance with any laws, agreements, guidance, government and/or industry surveys, and regulations which may be applicable to us.

 

Information We Disclose

We will not disclose any of your Personal Information except to our affiliates, such as our affiliated Funds, investment advisers and general partners, and to third parties, such as our benefits administrator and providers, attorneys, and other parties as the need may arise further to the employer-employee (or Company-consultant) relationship. When sharing information with third parties, we remain responsible for ensuring that the Personal Information is used in accordance with applicable law.

We may disclose all of the Personal Information and Sensitive Personal Information described above to the types of third parties listed above under one or more of these circumstances:

  • As Authorized and with Consent – if you request/ consent to or authorize the disclosure of the Personal Information;
  • Use relating to your potential employment or consulting relationship with the Company – if the use of the Personal Information is necessary as part of the recruitment, vetting, or on-boarding process of an Applicant or Consultant.
  • Verifying your identity and the accuracy of your personal details and other information provided;
  • Completing regulatory required screenings for sanctions and negative news;
  • Facilitating our compliance with any laws, agreements, guidance, government and/or industry surveys, and regulations which may be applicable to us;
  • Legal and regulatory compliance such as AML/ATF/Sanctions laws and regulations, CDD/KYC requirements, and tax laws and regulations such as the Common Reporting Standard (CRS) and Foreign Account Tax Compliance Act (FATCA);
  • Use is necessary in the context of your present (or past) employment relationship with the Company;
  • Performing services necessary to operate and act as an employer or to complete a transaction in furtherance of our obligations under the Statement of Employment.

 

Protecting Your Information

We strictly limit access to the Personal Information we have about you to those who need to know such information in order for us to successfully recruit, train, and retain individuals. In addition, we maintain appropriate physical, electronic and procedural safeguards to protect your personal information.

Any party that receives your Personal Information pursuant to the foregoing will be authorized to use it only for the services required and as allowed by applicable law or regulation and will not be permitted to share or use this Personal Information for any other purpose. To protect this Personal Information, we permit access only by authorized employees who need access to that information to perform their jobs. To protect your Personal Information from unauthorized access, use, destruction, modification, disclosure and other misuse, we use proportional security measures and safeguards against such risks that comply with applicable law. These measures and safeguards include computer safeguards and secured files and buildings and are subject to review and reassessment. In the event of a breach leading to the unlawful destruction or unauthorized use of or access to Personal Information which is likely to adversely affect an individual we will, without undue delay, notify the Privacy Commissioner and any individual affected by the breach.

Your Rights in relation to your Personal Information

In the course of business, the Company will use, collect, record, store, adapt, transfer, and otherwise process information by which Applicant or Consultants may be directly or indirectly identified in compliance with PIPA. The Company is an organization within the meaning of PIPA and undertakes to use and hold certain Personal Information, including Sensitive Personal Information, provided by Applicants or Consultants (whether current or former) in accordance with PIPA. As applicable to Applicants or Consultants (whether current or former), Sensitive Personal Information may include information about the individual’s place of origin, nationality, ethnicity, sex, and marital status as contained in the employment-related forms and supporting documents provided by such individual.

Under PIPA, you have the right to request a copy or summary of the information that we hold about you. If you would like a copy of some or all of your Personal Information, please contact Ms. Tara Railton, Privacy Officer, at HR@pilllar-capital.com or via phone at 1 441-278-8560. We shall retain your Personal Information for as long as necessary under applicable laws that require us to retain your Personal Information, such as data retention rules.

You may submit a written request to access your Personal Information or request information on the purposes for which such information is being held by us, who has access to such information, and details of the circumstances in which your Personal Information may be disclosed to other parties. Please contact the Privacy Officer to request the Personal Information Request form.

You may also request that: (i) we correct an error or omission in any of your Personal Information held by us; (ii) we cease, or not to begin, using your Personal Information for the purposes of advertising, marketing or public relations, or where the use of your Personal Information is causing or is likely to cause substantial damage or distress to you or another individual; and/or, (iii) we erase or destroy Personal Information about you where that Personal Information is no longer relevant for the purposes of its use (subject to applicable legal requirements relating to required data retention periods and requirements for backup storage of data); and/or (iv) you would like to withdraw your consent to our use of your information. Any such requests should be sent via email to the Privacy Officer.