Skip to main content
Discuss

Standard 03

Privacy & Data Protection

How personal data is collected, used, retained, transferred, and protected across every engagement — governed against the applicable privacy law per jurisdiction and role.

Precise institutional architecture

Core statement

Flow Group Ventures structures relevant engagements around the commercial, privacy, employment, marketing, technology, contractual, and data requirements applicable to the client, service, and jurisdiction. Where an engagement requires licensed, regulated, or jurisdiction-specific advice, Flow Group Ventures may coordinate with qualified local professionals or require the client to obtain appropriate advice.

Scope of this standard

Privacy and data protection covers personal-data handling across every engagement — including candidates in recruitment work, customer data in growth work, and employee data in transformation work.

How we apply it in practice

The operating controls used across engagements. Every control is calibrated to the applicable jurisdiction and role.

  • Data minimisation and purpose limitation
  • Role-based access to personal data
  • Retention controls per data category
  • Cross-border transfer basis documented per jurisdiction
  • Vendor and subprocessor review before onboarding
  • Data subject request handling routed through a documented channel

Governance lifecycle

Every engagement moves through a documented five-stage governance lifecycle.

  • Identify — the applicable commercial, privacy, employment, marketing, and technology considerations.
  • Assess — the jurisdictions, roles, data, and risk profile in scope.
  • Structure — engagement classification, contracts, and controls.
  • Review — periodic review across the engagement lifecycle.
  • Monitor — ongoing monitoring against outcomes, incidents, and change.

Operating principles

The principles applied across every engagement, calibrated to the jurisdictions and roles involved.

  • Applicable-law assessment
  • Jurisdiction-sensitive contracting
  • Data minimisation
  • Role-based access
  • Appropriate consent management
  • Vendor review
  • Subprocessor review
  • Recruitment privacy
  • Human review of consequential outputs
  • Anti-discrimination standards
  • Documented escalation
  • Access controls
  • Data retention controls
  • Local professional involvement where required
  • Region-aware marketing practices
  • Appropriate employment-classification review

Potentially relevant frameworks

The frameworks below may be relevant depending on the client, jurisdiction, and data involved. We do not claim certification under any of them unless separately published.

  • GDPR (EU)
  • UK GDPR
  • Brazil LGPD
  • CCPA / CPRA (California)
  • Canadian privacy requirements (PIPEDA and provincial)
  • Applicable electronic-communications laws
  • Applicable employment regulations
  • Applicable anti-discrimination requirements

What this page does not claim

This page describes the operating standards and controls the group applies. It does not claim, and should not be read to imply, universal compliance or certification against any specific framework.

  • We do not claim compliance with every law in every country.
  • We do not claim to be 'fully compliant worldwide' or 'legally approved globally'.
  • We do not claim certification under GDPR, HIPAA, SOC 2, ISO, or equivalent frameworks unless an independent certification is separately published on this page.
  • We do not claim guaranteed compliance outcomes.

Contact the Group

One relationship. Senior operators. Delivered through the Flow ecosystem.

Next step

Contact the Group

Proceed