Castle Cornet, St Peter Port, Guernsey
Security and hosting

Built in Guernsey. Your client data stays here.

Flarion is written and run in St Peter Port by Islands AI. Everything on this page describes the product as it runs today.

HostingSure's Tier III data centre in Guernsey, with a copy held in Jersey.
EncryptionTLS on every connection. Application data and its backups encrypted at rest.
BackupsEncrypted nightly backups, held off the production machine.
AccessRoles enforced on the server for every request, never only in the browser.
AuditEvery view of a file, a document or a record logged with who, when and where.
Sub-processorsEach one named below, with what it receives and for what purpose.
The facts

Where it runs, who can see what, and how long it is kept.

HostingProduction runs in Sure's Tier III data centre in Guernsey, with Sure's nightly backup and a copy held in Jersey.
RegulationGFSC Handbook mapped rule by rule; JFSC Handbook mapping scheduled. Evidence built for an inspection, not a sales deck.
IdentityDocument authenticity, liveness and face match through Didit or ComplyCube, chosen per firm. Images held in your firm's own store, never on a shared provider account.
ScreeningA consolidated sanctions and PEP dataset of more than 200 sources, including the UN, EU, UK and OFAC lists. Weekly rescreening of the whole book included.
AccessRoles enforced server side, decisions recorded with reason, reviewer and time, append only, every view logged and watermarked document views.
CompanyIslands AI Ltd, 2 Market Street, St Peter Port. Guernsey company 74458.
In more detail

The controls behind those six answers.

EncryptionIn transit, every connection is TLS. At rest, the application data and its backups are encrypted.
BackupsEncrypted nightly backups, held off the production machine. Sure backs up the production machine every night in Guernsey and holds a copy in Jersey; Flarion writes its own encrypted archive each night as well, and each night's backup writes a heartbeat the firm can see.
Screening decisionsEvery decision on a screening hit carries the reviewer, the reason and the time, and is append only: a decision is never edited, it is superseded by a later one.
ViewsEvery view of a client file, a document and a record is logged with who, when, from which device and where. Document views inside an inspection link are watermarked, visibly and invisibly, so a leaked page can be traced to the link it came from.
Identity imagesThe document and face images from a verification are captured into the firm's own store in Guernsey at decision time and served only inside Flarion, with every view logged.
RetentionThe provider's copy of identity data is erased on a schedule against the retention limit the firm sets (twelve months if it sets none). The firm's own record that a check was run, and what it returned, is kept for the six years Fiduciary Rule 2.6.4(1) requires.
Data subject rightsThe firm is the controller; Flarion is its processor. Access, correction, restriction and erasure requests go to the firm and Flarion carries them out on its instruction. One erasure path serves the MLRO's button and the nightly agent, so the answer does not depend on who pressed it.
Support accessWhen Islands AI looks at a firm's account to fix something, it does so as a view with a reason, read only unless the firm has allowed edits, that ends by itself after thirty minutes unless the firm sets another limit. Every view is recorded, append only, on our log and on the firm's own activity trail.
IncidentsSecurity incidents and vulnerability reports: info@flarion.ai, or 07781 146227. The founder answers. Our contact for security researchers is at /.well-known/security.txt.
AI

AI runs in London, and only in London.

Every AI feature runs on Amazon Bedrock in London (eu-west-2), on a London-only model with no cross-region routing, and nothing sent is used to train a model. The AI reads and drafts; a person decides. Meeting audio is deleted once it is transcribed unless the firm chooses to keep it. Board papers are never sent to a model, and nor are a board meeting's minutes unless the firm switches that on.

What it is used forWhat it does and what it receives
Adverse mediaReads web search results about a screened name and says which are about that person and adverse. Receives the name, the firm's keywords and each result's title, snippet and source.
Document readingReads the details off an identity document a client uploads, or a staff training certificate, and offers them into the form to be checked. Receives the image.
Review memoDrafts the periodic review memo for an officer to correct and sign. Receives the structure's name, type, jurisdiction and rating, its people and their roles, and the review's own facts.
Meeting briefRewords the brief the product has already written before a meeting with a client. Receives those facts; never the disclosures register, never staff documents.
Email summariesOne line per email thread with a client's people. Receives those threads from the mailboxes of staff who have switched it on, while the firm allows it.
Training coursesDrafts a staff course from the firm's own manual or policy. Receives the text of that document.
Draft minutesDrafts the minutes of a recorded meeting from its transcript. For a client company's board meeting, only if the firm switches that on.
Spreadsheet importSuggests where the columns of a business development spreadsheet belong, if the firm switches it on. Receives the sheet names and column headings only.
Sub-processors

Who else touches the data, and what each receives.

Each acts on Flarion's instructions, for the purpose named and no other, and none of it is used to train a model.

ProviderWhat it is for and what it receives
Identity verification: Didit, or ComplyCube where the firm uses it insteadDocument authenticity, liveness and face match. Receives the document images and face capture for the check, and the name and date of birth to compare them against.
Sanctions and PEP data: OpenSanctionsList matching against the consolidated dataset. Receives the name and, where held, the date of birth and nationality of the person or entity screened.
Adverse media search: SerperWeb search about the person or entity screened. Receives the name and the firm's own keywords, nothing else. Serper is operated from the United States.
AI: Amazon Bedrock, LondonThe AI uses listed above, in London (eu-west-2) on a London-only model. Each call receives only the material for that one task, and nothing is used to train a model.
Speech to text: Amazon Transcribe, LondonTurns a recorded meeting into text, in London (eu-west-2), when the firm records a meeting with the agreement of the people in it. Receives the audio.
Address lookup: LoqateThe Find address box on the onboarding form, where the firm switches it on. Receives what the client types into that box and the country chosen, nothing else.
Email delivery: ResendInvitations, reminders and digests. Receives the recipient's address and the message. No documents are ever attached.
Network and content delivery: CloudflareCarries traffic between the browser and Flarion. Handles everything in transit, including the visitor's IP address; stores no client data.
Hosting: Sure, GuernseyRuns the application and its database, which is where client data is stored, in Sure's Tier III data centre in Guernsey, with the backup copy held in Jersey.
Meeting booking: Cal.comThe calendar on the demo page of this website, which loads only when a visitor asks for it. Receives the name, email address and any note of someone booking a call. It touches no client data and is not part of the product.
IP location lookup: on our own serverPerformed against MaxMind databases held on the server. Receives nothing: no address leaves the machine.

The data processing agreement, which carries the same list, is available on request.

Evidence, not assertions

Read the controls

Everything on this page describes how the product behaves today, and every line of it is something you can put to us in your own review. Where a control is not built, the page says so rather than implying it.

Regulation

GFSC Handbook mapped

Rule by rule; JFSC Handbook mapping scheduled. Regulators do not approve software; the evidence Flarion keeps is built for an inspection, not a sales deck.

Vendor review

The Due Diligence Pack

Company and ownership details, this hosting overview, the data flow including AI processing, the sub-processor list, data processing terms and a continuity summary, sent within two working days. Request it and take Flarion through your own process.

FAQ

Questions about security and hosting

Is Flarion approved by the GFSC or JFSC?

No software is. Regulators do not approve or endorse vendors, and a vendor implying otherwise should worry you. Flarion is built around the GFSC Handbook and your own policies and procedures determine your compliance. The Due Diligence Pack supports your internal assessment and any notification your process requires.

Where is our data held?

In Guernsey. Production runs in Sure's Tier III data centre in Guernsey, with Sure's nightly backup and a copy held in Jersey. Client documents, identity images and screening decisions are all held there. The providers above receive only what the table says, for the task named.

How does the AI handle our client data?

Every AI feature runs on Amazon Bedrock in London (eu-west-2), on a London-only model, and nothing sent is used to train a model. Each call receives only what its task needs, the eight uses are listed above, and a person checks every result: the AI reads and drafts, and decides nothing. Meeting audio is deleted once it is transcribed unless the firm chooses to keep it. Board papers are never sent to a model, and nor are a board meeting's minutes unless the firm switches that on.

What assurance material can we have for our vendor review?

The Due Diligence Pack, sent within two working days: company and ownership, the hosting and security overview, the data flows including every use of AI, the sub-processor list with what each receives, our processing terms and a continuity summary. The data processing agreement is available on request. Send your own questionnaire with the request and we will complete it in your format.

Can we run Flarion on our own hardware?

Not today. There is one production environment, in Sure's data centre in Guernsey, run by Islands AI. A firm that needs its own deployment should talk to us about it rather than assume it: it is a conversation, not a switch.

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Bring your security questionnaire to the demo. The answers are the ones on this page.

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