Corporate Administration Services contacts
This section of our privacy statement describes why and how we collect and use personal data in connection with the provision of corporate administration services.
Collection of personal data
Our policy is to collect only the personal data necessary for agreed purposes and we ask our clients only to share personal data with us where it is strictly needed for those purposes.
Where we need to process personal data to provide Corporate Administration Services, we ask our clients to provide the necessary information to the data subjects concerned regarding its use.
We collect and use contact details for our clients in order to manage and maintain our relationship with those individuals.
In order to be able to provide corporate administration services, we are required to process many categories of personal data, including:
- Personal details (e.g. name, date of birth/death, country of birth, passport number, gender, marital status/certificate, country of residence, occupation);
- Contact details (e.g. email address, contact number, residential address);
- Financial details (e.g. salary, payroll details and other financial-related details such as bank details, income, investments and other financial interests, benefits, national insurance number, tax status);
- Engagement details (e.g. references, evidence of asset ownership, screening, high profile information, tax/legal advice, qualifications/professional memberships); and
- Administrative details (e.g. file notes, board minutes, Letter of Wishes, financial statements).
For certain services or activities, we may process special categories of personal data (such as in performing know your client checks, which involve us processing government identification documents that may contain biometric data or data revealing racial or ethnic origin).
Generally, we collect personal data from our clients or from a third party acting on the instructions of the relevant client.
Use of personal data
We use personal data primarily to allow us to perform contracts with clients that you are associated with and/ or where we need to comply with a legal obligation such as fiduciary or regulatory obligation. The purposes for using personal data include:
- Providing corporate administration services
- Administering, managing and developing our businesses and services
- Security, quality and risk management activities
- Complying with any requirement of law, regulation or a professional body of which we are a member
Providing corporate administration services
In order to provide the following full lifecycle corporate administration services we are required to process personal data, including:
- Acting as a company, partnership or foundation formation agent;
- Acting or fulfilling the function of or arranging for another person to act as or fulfil the function of a partner of a partnership;
- Acting or arranging for another person to act as secretary, alternate, assistant or deputy secretary of a company or as secretary of a limited liability partnership;
- Providing a registered office or business address for a company, partnership or a foundation;
- Providing an accommodation, correspondence or administrative address for a company, a partnership or a foundation or for any other person;
- Providing analysis for management purposes and statutory returns; and
- Performing the calculation and analysis of payroll, billing, credit control and other data relating to the company’s finances and the transfer of such data for use by financial personnel and other appropriate independent third parties.
Legal grounds: Legitimate interests, legal obligation, public interest or consent.
The 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. In some cases, we have a legal obligation to provide the services in a certain way. Where we process special categories of personal data, we may rely on a relevant public interest condition or consent.
Administering, managing and developing our businesses and services
We process personal data in order to run our business, including:
- managing our relationship with clients;
- 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.
Unless we are asked not to, we may use client 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: 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 PwC 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 monitor the services provided to clients for quality purposes, which may involve processing personal data stored on the relevant client file. We have policies and procedures in place to monitor the quality of our services and manage risks in relation to client engagements.
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 our services.
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.
We collect and hold personal data as part of our client engagement and acceptance procedures. As part of those procedures we carry out searches using publicly available sources (such as internet searches and sanctions lists) to identify politically exposed persons and heightened risk individuals and organisations and check that there are no issues that would prevent us from working with a particular client (such as sanctions, criminal convictions (including in respect of company directors), conduct or other reputational issues).
Legal grounds: Legal obligation or legitimate interests
This processing is necessary for us to comply with a legal obligation; for example, when conducting customer due diligence checks to comply with anti-money laundering regulations 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.
When and how we share personal data and locations of processing
In addition to the general information about when and how we might share personal data and locations of processing, personal data processed by us in connection with our corporate administration services may be transferred to:
Third party organisations that provide managed services to us
We use the services of a third party organisation as part of our corporate administration services offering. Please see further details below:
| Name |
PwC service entity |
Role | Address |
|---|---|---|---|
| PraxisIFM Trust Limited |
PricewaterhouseCoopers Services (Jersey) Limited | Regulated fiduciary services provider acting as Manager of the service entity | Charter Place, 23/27 Seaton Place St Helier, Jersey, JE1 1JY |
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.
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).
In the absence of specific legal, regulatory or contractual requirements, our baseline retention period for records and other documentary evidence created in the provision of services is 10 years in line with current legislation.
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.
Individuals’ rights
Individuals have certain rights over their personal data and controllers are responsible for fulfilling these rights. Individual’s rights may include the right of access to personal data, to rectification of personal data, to erasure of personal data/right to be forgotten, to restrict processing of personal data, to object to processing of personal data, to data portability, the right to withdraw consent at any time (where processing is based on consent) and the right to lodge a complaint with a supervisory authority.
These rights may be exercised by emailing us at ci.dataprotection@je.pwc.com. We aim to respond to any requests for information promptly, and in any event within the legally required time limits. The request should contain sufficient information to verify your identity and provide sufficient information to locate the data about which you are exercising your right.
