Custom flow actions in Salesforce cannot conditionally bypass FLS and sharing enforcement based on the parent flow context. All custom actions, whether public or private, must implement proper CRUD, field-level security (FLS), and record-level (with sharing) access checks to comply with security standards. Bypassing these enforcement mechanisms is not allowed.
However, there are conflicting perspectives on this topic. Some guidance suggests that custom Apex actions can conditionally bypass FLS and sharing checks when called from a Flow running in system context, but this should be done cautiously and only in specific scenarios where necessary, such as implementing secure guidelines for Guest Users or handling objects with custom security policies. It's important to document these exceptions and ensure that sensitive fields are excluded from queries and not exposed to the UI or client-side logic.
If you need further clarification on this topic, consider opening a case with Salesforce Support for definitive guidance.
For implementation details on enforcing security in Apex, see [Apex Security and Sharing](https://developer.salesforce.com/docs/atlas.en-us.apexcode.meta/apexcode/apex_security_sharing_chapter.htm).