Privacy Statement
Introduction
PwC is strongly committed to protecting personal data. This privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights. It applies to personal data provided to us, both by individuals themselves or by others. We may use personal data provided to us for any of the purposes described in this privacy statement or as otherwise stated at the point of collection.
“PwC” (and “we”, “us”, or “our”) refers to PricewaterhouseCoopers LLC, the limited liability company registered in the Isle of Man under registration no. 000934L and with its registration address at Sixty Circular Road, Douglas, Isle of Man, IM1 1SA that: (1) is a contracting party for the purposes of providing or receiving services, (2) posted a position for which you are applying, or (3) you have a role or relationship with. Each member firm in the PwC network is a separate legal entity and a separate controller for personal data. For further details, please see www.pwc.com/structure.
Personal data is any information relating to an identified or identifiable living person. When “you” or “your” are used in this statement, we are referring to the relevant individual who is the subject of the personal data. PwC processes personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose may differ.
When collecting and using personal data, our policy is to be transparent about why and how we process personal data. To find out more about our specific processing activities, please go to the relevant sections of this statement.
Quick access
Our processing activities
To find out more please go to the sections of this statement that are relevant to you.
We provide external users access to various applications controlled by us. Such applications will contain their own privacy statements explaining why and how personal data is collected and processed by those applications. We encourage individuals using our applications to refer to the privacy statements available on those applications.
Security
We take the security of all the data we hold very seriously. We have a framework of policies, procedures and training in place covering data protection, confidentiality and security and regularly review the appropriateness of the measures we have in place to keep the data we hold secure.
When and how we share personal data and locations of processing and service providers, such as IT services, used by us
We will only share personal data with others when we are legally permitted to do so. When we share data with others, we put contractual arrangements and security mechanisms in place as appropriate to protect the data and to comply with our data protection, confidentiality and security standards.
We are part of a global network of firms and in common with other professional service providers, we use third parties located in other countries to help us run our business. As a result, personal data may be transferred outside the countries where we and our clients are located. This includes to countries outside the European Union and to countries that do not have laws that provide specific protection for personal data. We have taken steps to ensure all personal data is provided with adequate protection and that all transfers of personal data outside the Isle of Man are done lawfully. Where we transfer personal data outside of the EU and the Isle of Man to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the EU requirements for the transfer of personal data outside the EU, such as the European Commission approved standard contractual clauses.
Personal data held by us may be transferred to:
Other PwC member firms
For details of our member firm locations, please click here.
We may share personal data with other PwC member firms where necessary for administrative purposes, to provide professional services to our clients (for example when providing services involving advice from PwC member firms in different countries), and to develop new PwC technologies and services across the PwC network of member firms.
We store personal data on our or other PwC member firm servers in the European Union. IT support and services are provided by PwC’s IT Services company.
Our business contacts are visible to and used by other PwC member firms to learn more about a contact, client or opportunity they have an interest in (please see the Business contacts section of this privacy statement for more information about our processing of this type of data).
Third party organisations that provide applications/functionality, data processing or IT services to us
We use third parties to support us in providing our services and to help provide, run and manage our internal IT systems. For example, providers of information technology, cloud based software as a service, identity management, website hosting and management, data analysis, data back-up, security and storage services. The servers are located in secure data centres around the world, and personal data may be stored in any one of them. Further details of these providers are set out below.
| Name | Role | Address |
Adobe Inc |
Document and Video Management |
345 Park Avenue, San Jose, CA, 95110-2704 |
| Altirnao Inc | Records Management | Ten Rockefeller Plaza, Suite 1001, New York, NY 10020 |
| Confirmation | Digital information management platform | Capital Confirmation, Inc. 214 Centerview Drive #100 Brentwood, Tennessee 37027 |
| Digital Guardian Inc. | Endpoint USB blocking and data leakage prevention |
11095 Viking Drive Suite 100. Eden Prairie, MN |
| Doxbond (IOM) Limited | Document Storage & Destruction | Unit 37 Snugborough Trading Estate, Braddan, Isle of Man, IM4 4LH |
Google Ireland Limited |
Business applications (such as email, virtual meetings, documents and calendar) | Gordon House, Barrow Street, Dublin 4, Dublin, D04 E5W5 Data centres located in a number of locations around the world (EU, Chile, Singapore, Taiwan, USA) |
| IBM United Kingdom Limited | Software and cloud services |
Hursley Park Road, Hursley, Winchester, SO21 2JN, United Kingdom |
Introhive Services, Inc |
Customer relationship management |
3250 NE 1st Ave, Miami, Florida 33137, USA |
| LinkedIn Ireland | Advertising and digital marketing |
LinkedIn Ireland, Wilton Place, Wilton Plaza, Dublin, Ireland |
| Manx Telecom | Communications services |
Isle of Man Business Park, Cooil Road, Braddan, IM99 1HX |
| Microsoft Limited | Azure cloud services, Business applications (such as email, virtual meetings, documents and calendar) |
Microsoft Campus, Thames Valley Park, Reading, Berkshire, RG6 1WG, UK |
| Salesforce | Customer relationship management system |
Salesforce.com EMEA, Village 9, Floor 26 Salesforce Tower, 110 Bishopsgate, London, EC2N 4AY, UK Salesforce.com |
ServiceNow |
Risk and process management system |
2225 Lawson Lane, Santa Clara, CA, 95054 |
| Vuture by Marigold | Marketing Communications |
10 Lower Thames St, London EC3R 6EN, UK |
Third party organisations that otherwise assist us in providing goods, services or information
On certain client engagements, we may engage or otherwise work with other providers to help us provide professional services to our clients.Our clients
Where we need to process personal data to provide professional services to our clients, we may share personal data in our deliverables (such as the reports we create).
- Insurers and professional advisers
Personal data may be shared with our advisers as necessary in connection with the products and services they have been engaged to provide.
- Law enforcement, other government and regulatory agencies and other third parties as required by, and in accordance with, applicable law or regulation
Occasionally, we may receive requests from third parties with authority to require and compel disclosure of personal data (for example to check that we are complying with applicable law and regulation, to investigate an alleged crime, or to establish, exercise or defend legal claims). We will only comply with such disclosure requests for personal data where we are permitted to do so in accordance with applicable law or regulation.
Changes to this privacy statement
We recognise that transparency is an ongoing responsibility, so we keep this privacy statement under regular review.
This privacy statement was last updated on 14 December 2023.
Data controller and contact information
We are generally the data controller for the personal data we process when providing professional services. However, we may provide some limited services, such as payroll services, as a data processor (in which case our client is the data controller). If you have any questions about this privacy statement or how and why we process personal data, please contact us at:
Data Protection Officer, PricewaterhouseCoopers LLC, Sixty Circular Road, Douglas, IM1 1SA
Email: IOM_DPO@pwc.com
Individuals’ rights and how to exercise them
Individuals have certain rights over their personal data. Individuals’ rights include the rights:
of access;
to rectification;
to erasure;
to restriction of processing;
to object to processing;
to data portability;
to withdraw consent at any time (where processing is based on consent); and
and the right to lodge a complaint with the supervisory authority.
Please see further information about these rights, when they are available and how to exercise them below.
Your right of access to personal data
You have the right to obtain confirmation of whether we process personal data about you, to receive a copy of your personal data held by us as a controller, and to obtain information about how and why we process your personal data (similar to the information provided in this privacy statement). This right may be exercised by emailing us at IOM_DPO@pwc.com. We aim to respond to any requests for information promptly, and in any event within the legally required time limits.
Your right to rectification / amendment of personal data
You have the right to request for your personal data to be amended or rectified where it is inaccurate (for example, if you change your name or address), and to have any incomplete personal data completed.
To update personal data submitted to us, you may email us at IOM_DPO@pwc.com or, where appropriate, contact us via the relevant website registration page or directly amend the personal details held on relevant websites or applications with which you registered. When practically possible, once we are informed that any personal data processed by us is no longer accurate, we will make updates as appropriate based on your updated information.
Your right to erasure
You have the right to request deletion of your personal data in certain circumstances:
the personal data are no longer necessary in relation to the purposes for which they were collected and processed;
our legal basis for processing is consent, you withdraw that consent and we have no other lawful basis for the processing of your personal data (this will only apply in very limited circumstances);
our legal basis for processing is that the processing is necessary for legitimate interests pursued by us or a third party, you object to our processing and we do not have overriding legitimate grounds;
you object to our processing for direct marketing purposes;
your personal data have been unlawfully processed; or
your personal data must be erased to comply with a legal obligation to which we are subject.
To request deletion of your personal data, please email us at IOM_DPO@pwc.com.
Your right to restrict processing
You have the right to restrict our processing of your personal data in the following cases:
for a period enabling us to verify the accuracy of your personal data where you have contested the accuracy of the personal data;
your personal data have been unlawfully processed and you request restriction of processing instead of deletion;
your personal data are no longer necessary in relation to the purposes for which they were collected and processed but the personal data are required by you to establish, exercise or defend legal claims; or
for a period enabling us to verify whether the legitimate grounds relied on by us override your interests where you have objected to processing based on it being necessary for the pursuit of a legitimate interest identified by us.
To restrict our processing of your personal data, please email us at IOM_DPO@pwc.com.
Your right to object to processing
You have the right to object to our processing of your personal data in the following cases:
our legal basis for processing is that the processing is necessary for our legitimate interests or those of a third party; or
our processing is for direct marketing purposes.
To object to our processing of your personal data, please email us at IOM_DPO@pwc.com.
Your right to data portability
Where our legal basis for processing your personal data is either consent or performance of a contract, you have a right to receive personal data provided by you to us and to have this sent to another organisation (by us where technically feasible).
To exercise your right to data portability, please email us at IOM_DPO@pwc.com.
Your right to withdraw consent
Where we process personal data using only your consent, you have a right to withdraw this consent at any time. Note that we do not generally process personal data based on consent (as we usually rely on another legal basis) and so the right to withdraw consent may not be applicable. However, if you wish to exercise the right to withdraw your consent please email us at IOM_DPO@pwc.com.
To opt out of direct marketing and to stop receiving an email from a PwC marketing list, please click on the unsubscribe link in the relevant email.
The relevant “Use of personal data” sections of this privacy statement explain our processing of personal data using the legal basis of consent.
Complaints
We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please email the details of your complaint to IOM_DPO@pwc.com. We will look into and respond to any complaints we receive.
You also have the right to lodge a complaint with the supervisory authority in your country of residence, place of work or the country in which an alleged infringement of data protection law has occurred within the EU. The Information Commissioner ("IC") is the Isle of Man data protection regulator/supervisory authority. For further information on your rights and how to complain to the IC, please refer to the IC website.
