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The Enstar Group of Companies controlled by Enstar Group ltd, (“Enstar”, "we", "us" “the Company” or "our") is committed to protecting the privacy of our employees and contractors. We will ensure that the information you submit to us, or which we collect, via various channels, through written correspondence (including e-mail), or through any of our offices globally, is only used for the purposes set out in this notice.

Through this Employee Privacy Notice (“this Notice”) we aim to inform you about the types of personal data we collect from employees and contractors, the purposes for which we use the data and the ways in which the data is handled. We also aim to satisfy the obligation of local laws relevant to our offices’ locations.

For the purpose of this Notice, the Data Controller of personal data is Enstar and our contact details are set out in the ‘Contact Us’ section at the end of this Notice. The Company has registered office locations in Australia, Bermuda, Continental Europe, the United Kingdom, and the USA.

The Company collects and processes personal data relating to its employees and contractors to manage the employment relationship. The Company is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations. We will never rent, sell, your data or share your data unnecessarily.

What information does Enstar collect?

Enstar collects and processes a range of information about you. This includes:

  • Identifier and records information such as your name, address and contact details, including email, and telephone number, date of birth
  • Online identifiers if you browse to our websites such as IP Address, Browsing History, Interaction with the Internet, Cookies, and Geolocation information
  • The terms and conditions of your employment
  • Details of your qualifications, skills, experience and employment history, including start and end dates, with previous employers and with the Company and any other information you chose to supply us on your CV or during the application process
  • Information about your remuneration, including entitlement to benefits such as pensions or insurance cover
  • Details of your bank account, and social security/national insurance number (or equivalent)
  • Information about your marital status, next of kin, dependants and emergency contacts;
  • Information about your nationality and entitlement to work in your respective location
  • Background checks that may contain information about criminal records should that be relevant
  • Details of your schedule (days of work and working hours) and attendance at work
  • Details of periods of leave taken by you, including holiday, sickness absence, family leave and sabbaticals, and the reasons for the leave
  • Details of any disciplinary or grievance procedures in which you have been involved, including any warnings issued to you and related correspondence
  • Assessments of your performance, including appraisals, performance reviews and ratings, training you have participated in, performance improvement plans and related correspondence
  • Information about medical or health conditions, including whether or not you have a disability for which Enstar needs to make reasonable adjustments
  • We may also collect equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health, and religion or belief
  • CCTV footage captured while safeguarding people and property
  • Biometric data such as facial images that may have been supplied in online profiles or for the purpose of accessing company devices
  • Fingerprints used for device access control

The Company collects this information in a variety of ways. For example, data is collected through application forms, CVs or resumes; obtained from your passport or other identity documents such as your driving licence; from forms completed by you at the start of or during employment (such as benefit nomination forms); from correspondence with you; or through interviews, meetings or other assessments.

In some cases, Enstar collects personal data about you from third parties, such as references supplied by former employers, information from employment background check providers, information from credit reference agencies and information from criminal records checks permitted by law.

Data is stored in a range of different places, including in your personnel file, in the Company's HR management systems and in other IT systems (including the Company's e-mail system).

Why does Enstar process personal data?

Enstar needs to process data to enter into an employment contract with you and to meet its obligations under your employment contract. For example, it needs to process your data to provide you with an employment contract, to pay you in accordance with your employment contract and to administer benefit, pension and insurance entitlements.

In some cases, Enstar needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check an employee's entitlement to work in that country, to deduct tax, to comply with health and safety laws and to enable employees to take periods of leave to which they are entitled.

In other cases, Enstar has a legitimate interest in processing personal data before, during and after the end of the employment relationship. Processing employee data allows Enstar to:

  • Run recruitment and promotion processes
  • Maintain accurate and up-to-date employment records and contact details (including details of who to contact in the event of an emergency), and records of employee contractual and statutory rights
  • Operate and keep a record of disciplinary and grievance processes, to ensure acceptable conduct within the workplace
  • Operate and keep a record of employee performance and related processes, to plan for career development, and for succession planning and workforce management purposes
  • Operate and keep a record of absence and absence management procedures, to allow effective workforce management and ensure that employees are receiving the pay or other benefits to which they are entitled
  • Obtain occupational health advice, to ensure that it complies with duties in relation to individuals with disabilities, meet its obligations under health and safety law, and ensure that employees are receiving the pay or other benefits to which they are entitled
  • Operate and keep a record of other types of leave (including maternity, paternity, adoption, parental and shared parental leave), to allow effective workforce management, to ensure that Enstar complies with duties in relation to leave entitlement, and to ensure that employees are receiving the pay or other benefits to which they are entitled
  • Ensure effective general HR and business administration
  • Provide references on request for current or former employees
  • Respond to and defend against legal claims
  • Maintain and promote equality in the workplace
  • Operate CCTV for employee security; and
  • Register username information, name, biometric data, or business e-mail for access to applications and software to assist the operation of the business.

Where Enstar relies on legitimate interests as a reason for processing data, it has considered whether or not those interests are overridden by the rights and freedoms of employees or workers and has concluded that they are not.

Some special categories of personal data, such as information about health or medical conditions, is processed to carry out employment law obligations (such as those in relation to employees with disabilities and for health and safety purposes).

Where Enstar processes other special categories of personal data, such as information about ethnic origin, sexual orientation, religion or belief, this is done for the purposes of equal opportunities monitoring. Data that Enstar uses for these purposes is anonymised or is collected with the express consent of employees, which can be withdrawn at any time. Employees are entirely free to decide whether or not to provide such data and there are no consequences of failing to do so.


The Company will only use your personal data for the purpose for which it was collected unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will advise you of this and explain the legal basis which allows us to do so.

You should be aware that we may process your personal data without your knowledge or consent where this is required or permitted by law.

Who has access to data?

Your information will be shared internally, including with members of the HR and recruitment team (including payroll), your line manager, managers in the business area in which you work and IT staff if access to the data is necessary for performance of their roles.

Enstar shares your data with third parties in order to obtain pre-employment references from other employers, obtain employment background checks from third-party providers and obtain necessary criminal records checks. The Company may also share your data with third parties in the context of a sale of some or all of its business. In those circumstances, the data will be subject to confidentiality arrangements.

Enstar also shares your data with third parties that process data on its behalf, in connection with payroll, the provision of benefits and the provision of occupational health services or software companies used in the operation of our business. A list of third parties is available upon request. Please contact your Line Manager to obtain this information.

As a global business, your data may be transferred to companies in our Group on a need-to-know basis. When Personal Data for residents of the UK or EEA is transferred outside the UK or EEA, it will be on the basis of a declaration of adequacy or relevant safeguards being in place, such as EU Model Clauses or an International Data Transfer agreement.

How does Enstar protect data?

The Company takes the security of your data seriously. The Company has internal policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by its employees in the performance of their duties. Further information can be found in the business’s Data Protection Policy.

Where Enstar engages third parties to process personal data on its behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

For how long does Enstar keep your data?

Enstar will hold your personal data in corporate HR systems for the duration of your employment and for seven years afterwards. Paper and digital records will be reviewed annually and records for people who exited the company more than seven years prior will be securely destroyed. The periods for which your data is held after the end of employment maybe be subject to local statutory variations.

What if you do not provide personal data?

You have some obligations under your employment contract to provide Enstar with data. In particular, you are required to report absences from work and may be required to provide information about disciplinary or other matters under the implied duty of good faith. You may also have to provide Enstar with data in order to exercise your statutory rights, such as in relation to statutory leave entitlements. Failing to provide the data may mean that you are unable to exercise your statutory rights.

Certain information, such as contact details, your right to work in your country and payment details, need to be provided to enable Enstar to enter a contract of employment with you. If you do not provide other information, this will hinder the Company's ability to efficiently administer the rights and obligations arising from the employment relationship.

Automated decision-making

Employment decisions are not based solely on automated decision-making.

Your rights

As a data subject employed by Enstar, you have a number of rights. You can:

  • Access and obtain a copy of your data on request (known as a “data subject access request”)
  • Require the Company to change incorrect or incomplete data
  • Request erasure of your personal information. This enables you to ask the Company to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing
  • Object to the processing of your data where the Company is relying on its legitimate interests as the legal ground for processing
  • Ask the Company to suspend the processing of your personal data for a period if data is inaccurate or there is a dispute about its accuracy or the reason for processing it, and you have
  • The right not to be discriminated against for submitting a data subject request.

If you would like to exercise any of these rights, please contact our Data Protection Officer at [email protected].

If you believe that Enstar has not complied with your data protection rights, you can contact our Chief People Officer; our Data Protection Officer [email protected]; or you can complain to your local regulator.

Further Information on Data Protection and Personal Privacy

If you have any enquiries or if you would like to contact us about our processing of your personal information, including to exercise your rights as outlined above, please contact using the details in the Contact Us Section below.

Contact Us

When you contact us, we may ask you to verify your identity if you are requiring a data subject rights request.

Email: [email protected]

Last Review date: 09/02/2023

Document Owner and Approval

The Data Protection Officer is the owner of this document and is responsible for ensuring that this procedure is reviewed in line with the review requirements of local data protection laws and group standards.