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. The personal data is generally business card data and will include name, employer name, phone, email and other business contact details and the communications with us.
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.
Legal grounds: Legitimate interests
This processing of personal data by us is necessary for the purposes of the legitimate interests pursued by us in receiving services.
- 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).
Legal grounds: Legitimate interests
This processing of personal data by us is necessary for the purposes of the legitimate interests pursued by us in providing professional services and our client in receiving professional services as part of running their organisation.
- Administering, managing and developing our businesses and services
We may 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.
Legal grounds: Legitimate interests
This processing is necessary for the purposes of the legitimate interests pursued by us to administer, manage and develop our business and services.
- 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.
Legal grounds: Legitimate interests
This processing is necessary for the purposes of the legitimate interests pursued by us to ensure network and information security, manage risks to our business and check the quality of the services.
- 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.
Legal grounds: Consent
We have been given explicit consent from client and prospective client business contacts to process their personal data for the purpose of sending them marketing communications.
- 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 grounds: Legal obligation or legitimate interests
This processing is necessary for us to comply with a legal obligation; for example, when conducting supplier due diligence checks and, where we do not have a legal obligation, we have a legitimate interest in processing personal data as necessary to meet our regulatory or professional obligations.
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 will be retained about our contacts at our suppliers for as long as it is necessary for the purposes set out above (e.g. for as long as we have, or need to keep a record of, a relationship with a contact, which is for the duration of our relationship with a contact or their organisation) and then deleted in line with our deletion and retention policies.
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.
When and how we share personal data and locations of processing
Further details about the processors (such as IT service providers) used by PwC and locations of processing are provided here. We may use other organisations to help us deliver our services as agreed with our client on an engagement-specific basis.
