PwC's Privacy Commitment

Collection of personal data

Our policy is to collect only the personal data necessary for agreed purposes and we ask our clients to only share personal data where it is strictly needed for those purposes.

Where we need to process personal data to provide professional services, we ask our clients to provide the necessary information to the data subjects regarding its use. Our clients may use relevant sections of this privacy statement or refer data subjects to this privacy statement if they consider it appropriate to do so.

Generally, we collect personal data from our clients or from third parties acting on the instructions of the relevant client.

Use of personal data

We use personal data for the following purposes:

Providing professional services

We provide a diverse range of professional services. Some of our services require us to process personal data in order to provide advice and deliverables. For example, we will review payroll data as part of an audit and we often need to use personal data to provide global mobility and pensions services.

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.
  
• 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 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. 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).

Providing our clients with information about us and our range of services

Unless we are asked not to, we 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.  

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 are continually looking for ways to help our clients and improve our business and services. Where agreed with our clients, we may use information that we receive in the course of providing professional services for other lawful purposes, including analysis to better understand a particular issue, industry or sector, provide insights back to our clients, to improve our business, service delivery and offerings and to develop new PwC technologies and offerings. To the extent that the information we receive in the course of providing professional services contains personal data, we will de-identify the data prior to using the information for these purposes.

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.

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 where it is strictly needed for those purposes.

Where we need to process personal data to provide our services, we ask our clients to provide the necessary information to other data subjects concerned, such as family members, regarding its use.

Given the diversity of the services we provide to personal clients, we process many categories of personal data, including as appropriate for the services we are providing:

• Contact details;
• Business activities;
• Family information;
• Income, taxation  and other financial-related details; and
• Investments and other financial interests.

For certain services or activities, and when required by law or with an individual's consent, we may also collect special categories of personal data. Examples of special categories include race or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; physical or mental health; genetic data; biometric data; sexual life or sexual orientation; and, criminal records.

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 for the following purposes:

Providing professional services

We provide a diverse range of professional services. Some of our services require us to process personal data in order to provide advice and deliverables. For example, we need to use personal data to provide individual tax advice, immigration services or pensions advice.

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.
  
• 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 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.  We collect and hold personal data as part of our client engagement and acceptance procedures.  As part of our client and engagement acceptance, 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).

Providing our clients with information about us and our range of services

With consent or otherwise in accordance with applicable law, we use client 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.

We are continually looking for ways to help our clients and improve our business and services. Where agreed with our clients, we may use information that we receive in the course of providing professional services for other lawful purposes, including analysis to better understand a particular issue, industry or sector, provide insights back to our clients, to improve our business, service delivery and offerings and to develop new PwC technologies and offerings. To the extent that the information that we receive in the course of providing professional services contains personal data, we will de-identify the data prior to using the information for these purposes.

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.

We provide external users access to various applications managed 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.

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 where it is strictly needed for those purposes.

Where we need to process personal data to provide our 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. Please see the 'Business contacts' section of this privacy statement for more information about our processing of this type of data.

Given the diversity of the services we provide to clients, we process many categories of personal data, including:

• Contact details;
• Business activities;
• Information about management and employees;
• Payroll and other financial-related details; and
• Investments and other financial interests.

Generally, we collect personal data from our clients or from a third party acting on the instructions of the relevant client. For some of our services, for example, when undertaking a due diligence review of an acquisition target on behalf of a client, we may obtain personal data from that target’s management and employees or from a third party acting on the instructions of the target.

Use of personal data

We use personal data for the following purposes:

Providing professional services

 We provide a diverse range of professional services. Some of our services require us to process personal data in order to provide advice and deliverables. For example, we will review payroll data as part of an audit and we often need to use personal data to provide global mobility and pensions services.

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.
  
•  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 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. We collect and hold personal data as part of our client engagement and acceptance procedures. As part of our client and engagement acceptance, 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).  

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 are continually looking for ways to help our clients and improve our business and services. Where agreed with our clients, we may use information that we receive in the course of providing professional services for other lawful purposes, including analysis to better understand a particular issue, industry or sector, provide insights back to our clients, to improve our business, service delivery and offerings and to develop new PwC technologies and offerings. To the extent that the information that we receive in the course of providing professional services contains personal data, we will remove the personal data prior to using the information for these purposes.

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.

We collect personal data when an individual gets in touch with us with a question, complaint, comment or feedback (such as name, contact details and contents of the communication). In these cases, the individual is in control of the personal data shared with us and we will only use the data for the purpose of responding to the communication.

We collect personal data concerning our own personnel as part of the operations, administration, management and promotion of our business activities. Partners and staff should refer to the Staff Handbook for information on why and how personal data is collected and processed.

When applying online for a role at PwC via the PwC careers website, applicants should refer to the information made available when applying for a job for details about why and how personal data is collected and processed.

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.
  
• 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.

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.

We have security measures in place at our offices, including CCTV and building access controls.

There are signs in our office showing that CCTV is in operation. The images captured are securely stored and only accessed on a need to know basis (e.g. to look into an incident). CCTV recordings are typically automatically overwritten after a short period of time unless an issue is identified that requires investigation (such as a theft).

We require visitors to our offices to sign in at reception and keep a record of visitors for a short period of time. Our visitor records are securely stored and only accessible on a need to know basis (e.g. to look into an incident).

We also process personal data of individuals who attend events and/or participate in surveys organised by us for the purposes of such attendance and/or participation of the individual in the said event and/or survey.

Collection of personal data

Visitors to our websites are generally in control of the personal data shared with us.  We may capture limited personal data automatically via the use of cookies on our website.  Please see the section on Cookies below for more information.

We receive personal data, such as name, title, company address, email address, and telephone and fax numbers, from website visitors; for example when an individual subscribes to updates from us.

Visitors are also able to send an email to us through the website. Their messages will contain the user’s screen name and email address, as well as any additional information the user may wish to include in the message.   

We ask that you do not provide sensitive information (such as race or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; physical or mental health; genetic data; biometric data; sexual life or sexual orientation; and, criminal records) to us when using our website; if you choose to provide sensitive information to us for any reason, the act of doing so constitutes your explicit consent for us to collect and use that information in the ways described in this privacy statement or as described at the point where you choose to disclose this information.

Cookies

We use small text files called ‘cookies’ which are placed on your hard drives to assist in personalising and enriching your browsing experience by displaying content that is more likely to be relevant and of interest to you. The use of cookies is now standard operating procedure for most websites. However if you are uncomfortable with the use of cookies, most browsers now permit users to opt-out of receiving them. You need to accept cookies in order register on our website. You may find other functionality in the website impaired if you disable cookies. After termination of the visit to our site, you can always delete the cookie from your system if you wish.

Use of personal data

When a visitor provides personal data to us, we will use it for the purposes for which it was provided to us as stated at point of collection (or as obvious from the context of the collection). Typically, personal data is collected to:

• Register for certain areas of the site.
• Subscribe to updates.
• Enquire for further information.
• Distribute requested reference materials.
• Submit curriculum vitae.
• Monitor and enforce compliance with our terms and conditions for use of our website.
• Administer and manage our website, including confirming and authenticating identity and preventing unauthorised access to restricted areas, premium content or other services limited to registered users.
  
• Aggregate data for website analytics and improvements.

Unless we are asked not to, we may also use your data to contact you with information about PwC’s business, services and events, and other information which may be of interest to you.  Should visitors subsequently choose to unsubscribe from mailing lists or any registrations, we will provide instructions on the appropriate webpage, in our communication to the individual, or the individual may contact us by email to data.protection@mt.pwc.com.

Our websites do not collect or compile personal data for the dissemination or sale to outside parties for consumer marketing purposes or host mailings on behalf of third parties. If there is an instance where such information may be shared with a party that is not a PwC member firm, the visitor will be asked for their consent beforehand.

Data retention

Personal data collected via our websites will be retained by us for as long as it is necessary (e.g. for as long as we have a relationship with the relevant individual).