Privacy statement
Introduction
We (“PwC”, “us”, or “our”) are strongly committed to protecting personal data. This transparency notice describes why and how we collect and use personal data and provides information about individuals’ rights. We may use personal data provided to us for any of the purposes described in this transparency notice or as otherwise stated at the point of collection.
Personal data is any information relating to an identified or identifiable living person. 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.
Security
We take the security of all the data we hold very seriously. We adhere to internationally recognised security standards and our information security management system relating to client confidential data is independently certified as complying with the requirements of ISO/IEC 27001: 2013. We have a framework of policies, procedures and training in place covering data protection, confidentiality and security and regularly review the appropriateness of the measures we have in place to keep the data we hold secure.
Our processing activities
To find out more please go to the sections of this statement that are relevant to you.
- Business contacts
- Individuals associated with our corporate clients
- Personal clients
- Individuals who use our applications
- Individuals whose personal data we obtain in connection with providing services to our clients
- Others who get in touch with us
- Recruitment applicants
- Suppliers (including subcontractors and individuals associated with our suppliers and subcontractors)
- Visitors to our offices
- Visitors to our website
Business contacts
Collection of personal data
PwC processes personal data about contacts (existing and potential PwC clients and/or individuals associated with them) using a customer relationship management systems (the “PwC CRM”).
The collection of personal data about contacts and the addition of that personal data to the PwC CRM is initiated by a PwC user and will include name, employer name, contact title, phone, email and other business contact details. In addition, the PwC CRM may collect data from PwC email (sender name, recipient name, date and time) and calendar (organiser name, participant name, date and time of event) systems concerning interactions between PwC users and contacts or third parties.
Use of personal data
Personal data relating to business contacts may be visible to and used by PwC users to learn more about an account, client or opportunity they have an interest in, and may be used for the following purposes:
- Developing our businesses and services
- Providing information to you about us and our range of services
- Making personal data available to PwC employees for performing services and for offering new services
- Identifying clients with similar needs
- Performing analytics such as on market trends, relationships maps or sales opportunities.
In addition, the PwC CRM uses an algorithm to evaluate the strength of interactions between a PwC user and a contact. This ranking is primarily based on interaction frequency, duration, recency and response time.
Legal basis for processing
We will process our business contacts’ personal data based on our legitimate business interests or the consent, if the data subject has been requested to express one. We have an interest in marketing our services or providing communications which we think will be of interest to recipients.
Data retention
Personal data will be retained on the PwC CRM 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 business contact).
Individuals associated with our corporate clients
Collection of personal data
Our policy is to collect only the personal data necessary for specified 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.
The personal data may include name, employer name, contact title, phone, email and other business contact details.
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; and
- 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. - 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 basis for processing
In case we are subject to a legal obligation, by which processing of personal data is required, such as the fulfillment of tax obligations or evidencing or documenting professional services provided, the processing of personal data of the individuals associated with our corporate clients is based on the legal obligation (lawful basis).
We may also process the personal data of individuals associated with our corporate clients based on our legitimate business interests (such as providing services to data subject’s employer ) or the consent, if the data subject has been requested to express one.
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 does not exceed 10 years.
Personal clients
Collection of personal data
Our policy is to collect only the personal data necessary for specified 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.
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 an individual with tax, social security advice or immigration 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; and
- 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. - Providing our clients with information about us and our range of services
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.
Legal basis for processing
If the processing of personal data referred to in this section is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of service, the processing is based on contractual lawful basis. If the processing of data is necessary for complying with a legal obligation such as complying with tax law obligations or necessity to evidence and document professional services provided, the processing will be based on the legal obligation. If personal data are processed for the other purposes specified above we will rely on the legitimate interest basis or the consent, if we asked the data subject for the consent.
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 does not exceed 10 years.
Individuals who use our applications
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.
Individuals whose personal data we obtain in connection with providing services to our clients
Collection of personal data
Our policy is to collect only the personal data necessary for specified 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; and
- 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. - 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 basis for the processing
If the processing of data, which we obtain in connection with providing services to our clients, is necessary for complying with a legal obligation, such as tax law regulations or necessity to document and evidence professional services provided, the processing will be based on the legal obligation. If the aforementioned personal data is processed for the other purposes specified in this section we will rely on the legitimate interest basis (e.g. providing our services) or the consent, if we asked the data subject for the consent.
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 does not exceed 10 years.
Others who get in touch with us
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 and handling the matter as appropriate. The personal data referred above may include name, employer name, contact title, phone, email and other business contact details.
Legal basis of the processing
If personal data are processed for the other purposes specified above we will rely on the legitimate interest basis or the consent, if we asked the data subject for the consent.
Data retention
We retain the personal data referred to in this section for as long as is considered necessary for the purpose for which it was collected.
Recruitment applicants
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.
For more detail about our recruitment processes, please visit our career page.
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.
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; and
- 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.
Legal basis of the processing
If the processing of personal data referred to in this section is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary to be recipient of the service, the processing is based on contractual lawful basis. If the processing of data is necessary for complying with a legal obligation such as complying with tax law obligations or necessity to evidence and document professional services received, the processing will be based on the lawful basis. If personal data are processed for the other purposes specified above we will rely on the legitimate interest basis (such as receiving services, providing services, administration, managing and developing our business, security, quality and risk management activities) or the consent, if we asked the data subject for the consent.
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.
Visitors to our offices
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 we 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 will rely on the legitimate interest basis (assuring security at our offices).
Visitors to our website
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.
You can find out more details regarding our use of cookies on our Cookies page.
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; and
- 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 pwc.ukraine@ua.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.
Legal basis for the processing
We will process personal data of visitors to our website based on our legitimate business interests or the consent, if the data subject has been requested to express one. For example, we have an interest in making sure our marketing is relevant for specified individuals, so we may process personal data to send our marketing that is tailored to the interests of a data subject.
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).
Legal basis for processing
Legal bases for each processing activity are specified in the relevant sections above. When we process personal information for our legitimate interests, we make sure to consider and balance any potential impact on a data subject (both positive and negative), and the data subject’s rights under data protection laws. Our legitimate business interests do not automatically override interests of the data subjects - we will not process personal data for activities where our interests are overridden by the impact on the data subject (unless we have the consent or are otherwise required or permitted to by law).
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 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.
In respect of personal data being regulated by EU legislation please note that: cross border transfers may include countries outside the European Economic Area ("EEA") 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 EEA are done lawfully. Where we transfer personal data outside of the EEA 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 EEA, 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). Our business contacts are visible to and used by PwC users from 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
Auditors and other professional advisers
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.
Changes to this privacy statement
We recognise that transparency is an ongoing responsibility so we will keep this privacy statement under regular review.
This privacy statement was last updated on 21 May 2018.
Data controller and contact information
The data controller is PwC Ukraine or such PwC member firm, listed under this link, that is a contracting party for the purposes of providing or receiving services or the entity you have contacted.
If you have any questions about this privacy statement or how and why we process personal data, please contact us at:
75 Zhylyanska St.
01032, Kyiv, Ukraine
Email: ua_pwc@pwc.com
Phone: +380 44 354 0404
Individuals’ rights and how to exercise them
Individuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights. Where we decide how and why personal data is processed, we are a data controller and include further information about the rights that individuals have and how to exercise them below.
Access to personal data
You have a right of access to personal data held by us as a data controller. This right may be exercised by emailing us at ua_pwc@pwc.com.
Amendment of personal data
To update personal data submitted to us, you may email us at ua_pwc@pwc.com or, where appropriate, contact us via the relevant website registration page or by amending the personal details held on relevant applications with which you registered.
When practically possible, once we are informed that any personal data processed by us is no longer accurate, we will make corrections (where appropriate) based on your updated information.
Withdrawal of 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). To withdraw consent to our processing of your personal data please email us at ua_pwc@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.
Right to restrict or object to our processing of personal data
You have the right to restrict or object to the processing of your personal information at any time, on reasonable grounds relating to your particular situation, unless the processing is required by law.
In such case, we will no longer process or restrict the processing of the personal data, unless we can demonstrate compelling legitimate grounds for the processing or for the establishment, exercise or defence of legal claims.
Other data subject rights
This transparency notice is intended to provide information about what personal data we collect about you and how it is used. As well as rights of access, amendment and restriction or objection to processing referred to above, individuals may have other rights in relation to the personal data we hold, such as a right to erasure/deletion and the right to data portability.
If you wish to exercise any of these rights, please send an email to ua_pwc@pwc.com.
Complaints
We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to ua_pwc@pwc.com. We will look into and respond to any complaints we receive.
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