Suppliers (including subcontractors and individuals associated with our suppliers and subcontractors)

Collection​ ​of​ ​personal​ data

We collect and process personal data about our suppliers (including subcontractors and individuals associated with our suppliers and subcontractors) in order to manage the relationship, contract, to receive services from our suppliers and, where relevant, to provide professional services to our clients.

Use​ ​of​ ​personal​ data

We use personal data for the following purposes:

Receiving services

We process personal data in relation to our suppliers and their staff as necessary to receive the services. For example, where a supplier is providing us with facilities management or other outsourced services, we will process personal data about those individuals that are providing services to us.

Providing professional services to clients

Where a supplier is helping us to deliver professional services to our clients, we process personal data about the individuals involved in providing the services in order to administer and manage our relationship with the supplier and the relevant individuals and to provide such services to our clients (for example, where our supplier is providing people to work with us as part of a PwC team providing professional services to our clients).

Administering, managing and developing our businesses and services

We process personal data in order to run our business, including:

• managing our relationship with suppliers;
• developing our businesses and services (such as identifying client needs and improvements in service delivery);
• maintaining and using IT systems;
• hosting or facilitating the hosting of events; and
• administering and managing our website and systems and applications.

Security, quality and risk management activities

We have security measures in place to protect our and our clients’ information (including personal data), which involve detecting, investigating and resolving security threats.  Personal data may be processed as part of the security monitoring that we undertake; for example, automated scans to identify harmful emails.  

We have policies and procedures in place to monitor the quality of our services and manage risks in relation to our suppliers.  We collect and hold personal data as part of our supplier contracting procedures.  We monitor the services provided for quality purposes, which may involve processing personal data.

Providing information about us and our range of services

Unless we are asked not to, we use business contact details to provide information that we think will be of interest about us and our services.  For example, industry updates and insights, other services that may be relevant and invites to events.

Complying with any requirement of law, regulation or a professional body of which we  are a member

As with any provider of professional services, we are subject to legal, regulatory and professional obligations.  We need to keep certain records to demonstrate that our services are provided in compliance with those obligations and those records may contain personal data.

Legal basis of the processing

If the processing of personal data referred to in this section is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary to be recipient of the service, the processing is based on contractual lawful basis.

If the processing of data is necessary for complying with a legal obligation such as complying with tax law obligations or necessity to evidence and document professional services received, the processing will be based on the lawful basis.

If personal data are processed for the other purposes specified above we will rely on the legitimate interest basis (such as receiving services, providing services, administration, managing and developing our business, security, quality and risk management activities)  or the consent, if we asked the data subject for the consent.

Data retention

We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation).   

Personal data may be held for longer periods where extended retention periods are required by law or regulation and in order to establish, exercise or defend our legal rights.