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.
We use personal data for the following purposes:
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 need to use personal data to provide global mobility and pensions 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.
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).
Unless we are asked not to, we use client business contact details to provide them 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.
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 anonymize the data prior to using the information for these purposes.
We retain the personal data processed by us for as long as it is considered necessary for the purposes for which it was collected, and/or the respect of any legal or regulatory obligation, and/or the establishment, defense or exercise of legal claims, and/or the respect of obligations resulting from PwC network standards.