PwC Malta's Privacy Statement

Collection of personal data

Where we need to process personal data as a data controller 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.

Use of personal data

We use personal data for the following purposes: 

(1) 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. We usually receive your personal data from our client. In this case, the personal data shall be generally processed on the basis of Article 6 (1)(f) of the GDPR, as there is a legitimate interest for PwC to provide the service commissioned in the letter of engagement with our corporate client. Accordingly, the same applies when preparing a proposal for the provision of services. To the extent that the necessary information is not provided, PwC will not be able to provide the agreed service.

(2) Administering, managing and developing our businesses and services

We may further process personal data on the basis of Article 6 (1)(f) of the GDPR, as there is a legitimate interest for us 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.
• Providing our clients with information about us and our range of services (for example, industry updates and insights, invites to events).
• Hosting or facilitating the hosting of events.
• Managing our security, quality and risk management activities (such as doing automated scans to identify harmful emails, and carrying out searches using publicly available sources to identify heightened risk individuals and organisations).
• Administering and managing our website and systems and applications.

(3) 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 required by tax, corporate and professional laws to keep certain records to demonstrate that our services are provided in compliance with those obligations. Such personal data is generally processed on the basis of Article 6 (1)(c) of the GDPR as PwC is subject to the above-mentioned statutory 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).  

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

PwC also provides professional services to natural persons, i.e. personal clients. Where we need to process personal data to provide our services, we ask our personal clients to provide the necessary information to other data subjects concerned, such as family members, regarding its use, wherever this might be necessary.

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. 
• Investments and other financial interests.
• For specific services or activities, generally with an individual's consent on the basis of Article 9 (2)(a) of the GDPR, we will 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. 
• In limited circumstances, we also process criminal records (depending on the nature of the services requested). We will only process such information when authorised by law. 

Use of personal data

We use personal data for the following purposes:

(1) 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. In such instances, the personal data is typically processed on the basis of Article 6 (1)(b) of the GDPR, as we have a contractual agreement (the letter of engagement) with the personal client. To the extent that the necessary information is not provided, PwC will not be able to provide the agreed service.W

(2) Administering, managing and developing our businesses and services

We may further process personal data on the basis of Article 6 (1)(f) of the GDPR, as there is a legitimate interest for us 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.
• Providing our clients with information about us and our range of services (for example, industry updates and insights, invites to events).
• Hosting or facilitating the hosting of events.
• Managing our security, quality and risk management activities (such as doing automated scans to identify harmful emails, and carrying out searches using publicly available sources to identify heightened risk individuals and organisations).
• Administering and managing our website and systems and applications.

(3) 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 required by tax, corporate and professional laws to keep certain records to demonstrate that our services are provided in compliance with those obligations. Such personal data is generally processed on the basis of Article 6 (1)(c) of the GDPR as PwC is subject to the above-mentioned statutory 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).  

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

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 of data subjects in order to perform our services, and to manage and maintain our relationship with our client. 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.

Use of personal data

We use personal data for the following purposes:

(1)   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. As stated above, we receive your personal data from our client or from a relevant third-party. In this case, the personal data shall generally be processed on the basis of Article 6 (1)(f) of the GDPR, as there is a legitimate interest for PwC to provide the service commissioned in the letter of engagement with our client. To the extent that the necessary information is not provided, PwC will not be able to provide the agreed service.

(2)   Administering, managing and developing our businesses and services

We may further process personal data on the basis of Article 6 (1)(f) of the GDPR, as there is a legitimate interest for PwC to run its 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.
• Managing our security, quality and risk management activities (such as doing automated scans to identify harmful emails, and carrying out searches using publicly available sources to identify heightened risk individuals and organisations).
• Administering and managing our website and systems and applications.

(3)   Complying with any requirement of law, regulation, judicial decision or a professional body of which we are a member

As with any provider of professional services, we are required by tax, corporate and professional laws to keep certain records to demonstrate that our services are provided in compliance with those obligations.Such personal data is generally processed on the basis of Article 6 (1)(c) of the GDPR as PwC is subject to the above-mentioned statutory 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). 

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. The processing of personal data in this instance is generally carried out on the basis of Article 6 (1)(f) of the GDPR, as we have a legitimate interest in responding to the individual.

We collect personal data concerning our own personnel as part of the operations, administration, management and promotion of our business activities. Principals 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. We shall be the data controller for the personal information you submit via Workday and your questions, complaints, or exercise of any of your rights should be directed to PwC as explained herein. 

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, to 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:

(1) 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. Personal data in this instance is typically processed on the basis of Article 6 (1)(f) of the GDPR, as there is a legitimate interest for PwC to manage the related risk and quality of the services received.

(2) Providing professional services to clients

Where a supplier is helping us to deliver professional services to our clients, we generally process personal data about the individuals involved in providing the services on the basis of Article 6 (1)(f) of the GDPR, as we have a legitimate interest 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).

(3) Administering, managing and developing our businesses and services

We may further process personal data on the basis of Article 6 (1)(f) of the GDPR, as PwC has a legitimate interest to run its 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.
• Providing information about us and our range of services (for example, industry updates and insights, invites to events).
• Hosting or facilitating the hosting of events.
• Managing our security, quality and risk management activities in relation to suppliers (such as doing automated scans to identify harmful emails, and carrying out searches using publicly available sources to identify heightened risk individuals and organisations).
  
• Administering and managing our website and systems and applications.
  

(4) 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 required by tax, corporate and professional laws to keep certain records to demonstrate that our services are provided in compliance with those obligations. Such personal data is typically processed on the basis of Article 6 (1)(c) of the GDPR as PwC is subject to the above-mentioned statutory 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 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.

PwC is legally required to obtain and process personal data about prospective and current clients, their ultimate beneficial owners and client representatives under the Prevention of Money Laundering Act (Chapter 373 of the Laws of Malta); the Prevention of Money Laundering and Funding of Terrorism Regulations (S.L. 373.01 of the Laws of Malta); and other related legislation.

The collection of personal data for these purposes is typically on the basis of Article 6 (1)(c) of the GDPR, in accordance with the legal obligation mentioned above. Furthermore, where we process personal data which qualifies as a special category of personal data in this context (for example, data related to political opinions), the processing is carried out on the basis of Article 9 (2)(g) of the GDPR, namely, in order to carry a task in the public interest on the basis of the applicable legislation.

Use of personal data

Personal data obtained in the context of AML/CFT is processed by PwC for the purposes of the prevention, detection or investigation of potential money laundering and terrorist financing. In line with our legal obligations, we apply the following measures:

• Client Due Diligence (CDD) for new and existing clients, their ultimate beneficial owners and client representatives.
  
• A risk-based approach for prospective clients, as part of PwC’s AML/CFT framework.

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 AML/CFT 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.

Visitors in this section refer to any person other than Partners and staff which are physically present on our premises, including attendees of events hosted by us.

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 90 days unless an issue is identified that requires investigation (such as a theft). We generally process CCTV footage on the basis of Article 6 (1)(f) of the GDPR, since we have a legitimate interest to protect the property against burglary, theft or vandalism and to prevent and detect any unlawful conduct. We do not share CCTV footage with any third party to the exception of law enforcement authorities in the course of official investigations.

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). Where visitors are attending an event and/or participate in surveys organised by us, PwC generally processes their personal data on the basis of Article 6 (1)(f) of the GDPR, since we have a legitimate interest in registering their attendance and/or participation.

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. Please refer to our Subscribers section for more information on the applicable purposes and legal bases.

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 to 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. For further information on how we use cookies, we encourage you to access our Cookie Policy.

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 for the below purposes on the basis of Article 6 (1)(f) of the GDPR, as we have a legitimate interest to run our business:

• 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 mt_privacy@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) and as outlined in our Cookie Policy.

Collection of personal data

We collect personal data, such as name, title, company address, and email address for the purpose of adding you to our subscription list. 

The collection of personal data for these purposes is generally on the basis of Article 6 (1)(a) of the GDPR, that is, upon collection of your lawful consent, and Article 6 (1)(f) of the GDPR, in cases where we have an existing relationship with you and we think that certain communications might be of interest to you.

You have the right to withdraw your consent at any time by emailing us at mt_privacy@pwc.com or, to stop receiving an email from a PwC marketing list, please click on the unsubscribe link in the relevant email received from us.

Use of personal data

We process personal data in the context of our marketing campaigns for the following purposes:

• Sending alerts and updates concerning PwC’s products and services.
  
• Sending newsletters, thought leadership, and other PwC publications which might be of interest to you.
• Sending of notifications related to events organised by PwC and invitations to such events.
• Offering PwC’s products and services.

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 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.