Privacy Notice for Job Applicants and Consultants.

Pillar Capital Management Limited (the “Company”) is committed to handling your personal information responsibly. We are providing this Privacy Notice to you so that you will know what kinds of personal information we use and collect about you and the circumstances in which that information may be disclosed to third parties.  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.

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 job applicants and prospective individual contractors of Pillar Capital Management Limited (each referred to herein as an “Applicant” or “Consultant”).

Information We Collect

We collect non-public “personal information”, including “sensitive personal information”, each as defined in Bermuda’s Personal Information Protection Act 2016 (“PIPA”), about Applicants and Consultants from the following sources:

  • 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, 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).

Information We Disclose
For Applicants and Consultants, your personal information will generally be used and collected for the following purposes, and we may disclose your personal information to unaffiliated third parties where necessary 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.

Sensitive personal information that we use, collect, store, and transfer from you is limited to information you provide regarding your place of origin, race, colour, 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 work permit, if required;
  • Verifying your rights to live and work in Bermuda; and
  • Facilitating our compliance with any laws, agreements, guidance, government and/or industry surveys, and regulations which may be applicable to us.

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. 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.

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

Your Rights

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 trailton [at] pillar-capital [dot] com or via phone at 1 441-278-8564.  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.

Applicants / Consultants: With your application and continued pursuit of employment or a service provider relationship with us, you are consenting to Pillar’s use, collection, and disclosure of your personal information and sensitive personal information in the manner described herein. Such consent will remain valid until such time it is withdrawn by you in writing. You may withdraw your consent for the Company to use all or a portion of your personal information or sensitive personal information at any time, noting however that withdrawal of such consent may not prevent the Company’s continued use of your information pursuant to Bermuda law which authorizes or requires such use, and may result in the Company no longer considering your application for employment or to provide services to us.

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; (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.