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 CI LLP (the limited partnership registered in England under registration no. OC309347 and with its registration address at 1 Embankment Place, London, WC2N 6RH and principal place of business is 37 Esplanade, St Helier, Jersey, JE1 4XA) and its subsidiaries 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.

When and how we share personal data and locations of processing

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 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 EU are done lawfully. Where we transfer personal data outside of the EU 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. The European Commission approved standard contractual clauses are available here.

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 and to provide professional services to our clients (e.g. when providing services involving advice from PwC member firms in different territories).
  • We store personal data on our or other PwC member firm servers in the EU, and the USA. IT support and services are provided by PwC India and 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 providers, identity management, website hosting and management, data analysis, data back-up, security and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them.
• 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 helps 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)
• Auditors, insurers and professional advisers
  Our auditors are Crowe Clark Whitehill LLP St. Bridge’s House, 10 Salisbury Square, London, EC4Y 8EH. We have a number of business insurance policies in place and we may need to share personal data with the insurer, for example, in the event of a claim. We use other professional advisers, for example, law firms, as necessary to establish, exercise or defend our legal rights and obtain advice in connection with the running of our business. Personal data may be shared with these advisers as necessary in connection with the products and services they have been engaged to provide.
• Law enforcement or other government and regulatory agencies or to 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 obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation. Details of our regulators can be found in the following links for Guernsey or Jersey.

Data controller and contact information

We are generally controllers for the personal data we process, however, we may provide some services, such as payroll services, as a processor (in which case our client is the controller). If you have any questions about this privacy statement or how and why we process personal data, please contact us at:

Risk Management Partner
PricewaterhouseCoopers CI LLP
37 Esplanade
St Helier
Jersey JE1 4XA

Email

Your right of access to personal data

You have the right to obtain confirmation as to whether we process personal data about you, receive a copy of your personal data held by us as a controller and obtain certain other 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 bci_data_protection@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 erasure / right to be forgotten

• You have the right to obtain deletion of your personal data in the following cases:
• the personal data are no longer necessary in relation to the purposes for which they were collected and processed;
• our legal grounds for processing is consent, you withdraw consent and we have no other lawful basis for the processing;
• our legal grounds 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 bci_data_protection@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 grounds for processing is that the processing is necessary for a legitimate interest pursued by us or a third party; or
• our processing is for direct marketing purposes.

To object to our processing of your personal data, please email us at bci_data_protection@pwc.com.

Your right to withdraw consent

Where we process personal data based on consent, individuals have a right to withdraw consent at any time. We do not generally process personal data based on consent (as we can usually rely on another legal basis). Where we rely on your consent for our processing of your personal data, to withdraw your consent please email us at bci_marketing@pwc.com or, to stop receiving an email from a PwC marketing list, please click on the unsubscribe link in the relevant email. Please see the relevant “Use of personal data” sections of this privacy statement for further details about our processing of personal data based on consent.