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 LLP, the limited partnership registered in England under registration no. OC303525 and with its registration address at 1 Embankment Place, London, WC2N 6RH, and such other PwC member firm in the UK and their 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. (Please note this privacy statement does not cover the activities of Embankment Place Primary Healthcare Ltd (“the Clinic”), which is not included within the definition of “PwC”, “we”, “us”, and “our”).

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.

Our Privacy Information Management System relating to the processing of client personal information is independently certified as complying with the requirements of ISO/IEC 27701: 2019.

To find out more about our specific processing activities, please go to the relevant sections of this statement.

We provide external users access to various applications controlled 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.

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.

When and how we share personal data and locations of processing and service providers, such as IT services, used by PwC UK

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 United Kingdom. We will do so only where we have a lawful basis, for example to recipients: (i) in countries which provide an adequate level of protection for personal data; or (ii) if adequacy is not available, under agreements which meet UK and/or European Commission Decision 2021/914 requirements for those transfers, as appropriate.

Personal data held by us may be transferred to:

• Other PwC member firms
  • Details of our territory member firm locations
  • Details of our other member firm locations
  • We may share personal data with other PwC member firms where necessary for administrative purposes, to provide professional services to our clients (for example when providing services involving advice from PwC member firms in different countries ), and to develop new PwC technologies and services across the PwC network of member firms.
  • We use other PwC member firms as IT service providers for the operation, maintenance and care of the IT systems and applications used by us.
  • We store personal data on other PwC member firm servers in the EU, Singapore and the USA.
  • 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, identity management, website hosting and management, data analysis, data back-up, security and storage services. The servers are located in secure data centres around the world, and personal data may be stored in any one of them. Further details of these providers are set out below.
  

• 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 help 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 (further details) 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 legal claims 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 to us.
  
• Law enforcement, other government and regulatory agencies and 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 require and compel disclosure of personal data (for example to check that we are complying with applicable law and regulation, to investigate an alleged crime, or to establish, exercise or defend legal claims). We will only comply with such disclosure requests for personal data where we are permitted to do so in accordance with applicable law or regulation. See details of our regulators.
• Charity and fundraising partners
  We share personal data with The PwC Foundation (registered charity number 1144124) to administer charitable payments. Your personal data will be shared with The PwC Foundation where you have donated to a PwC JustGiving page to enable us to appropriately record the amount of money collected, from whom and the intended charity.
• Sales, mergers, acquisitions and disposals
  Other organisations in connection with an actual or potential sale, transfer, disposal, merger or restructure of a part of our business or as part of an acquisition or merger with another business.

Changes to this privacy statement

We recognise that transparency is an ongoing responsibility so we keep this privacy statement under regular review.

This privacy statement was last updated on 01 May 2024.

Data controller and contact information

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

Data Protection Officer
PricewaterhouseCoopers LLP
1 Embankment Place
London
WC2N 6RH

Email: UK_privacy_information_management@pwc.com

From time to time, PwC processes certain personal data in the course of offering goods or services or monitoring citizens in the European Economic Area (EEA). With effect from 1 January 2021, PwC has appointed PwC Ireland as its European representative. PwC Ireland can be contacted at ie_pwc_data_protection@pwc.com in relation to PwC's processing in Europe.

Individuals’ rights and how to exercise them

Individuals have certain rights over their personal data. Individuals’ rights include the rights:

• of access,
  
• to rectification,
  
• to erasure,
  
• to restriction of processing,
  
• to object to processing to data portability,
  
• to withdraw consent at any time (where processing is based on consent).

Please see further information about these rights, when they are available and how to exercise them below.

Your right of access to personal data

You have the right to obtain confirmation of whether we process personal data about you, to receive a copy of your personal data held by us as a controller, and to obtain 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 UK_privacy_information_management@pwc.com.

Your right to rectification / amendment of personal data

You have the right to request for your personal data to be amended or rectified where it is inaccurate (for example, if you change your name or address), and to have any incomplete personal data completed.

To update personal data submitted to us, you may email us at UK_privacy_information_management@pwc.com or, where appropriate, contact us via the relevant website registration page or directly amend the personal details held on relevant websites or 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 updates as appropriate based on your updated information.

Your right to erasure

You have the right to request deletion of your personal data in certain circumstances:

• the personal data are no longer necessary in relation to the purposes for which they were collected and processed;
  
• our legal basis for processing is consent, you withdraw that consent and we have no other lawful basis for the processing of your personal data (this will only apply in very limited circumstances);
  
• our legal basis 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 UK_privacy_information_management@pwc.com.

Your right to restrict processing

You have the right to restrict our processing of your personal data in the following cases:

• for a period enabling us to verify the accuracy of your personal data where you have contested the accuracy of the personal data;
  
• your personal data have been unlawfully processed and you request restriction of processing instead of deletion;
  
• your personal data are no longer necessary in relation to the purposes for which they were collected and processed but the personal data are required by you to establish, exercise or defend legal claims; or
  
• for a period enabling us to verify whether the legitimate grounds relied on by us override your interests where you have objected to processing based on it being necessary for the pursuit of a legitimate interest identified by us.

To restrict our processing of your personal data, please email us at UK_privacy_information_management@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 basis for processing is that the processing is necessary for our legitimate interests or those of a third party; or
  
• our processing is for direct marketing purposes.

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

Your right to data portability

Where our legal basis for processing your personal data is either consent or performance of a contract, you have a right to receive personal data provided by you to us and to have this sent to another organisation (by us where technically feasible)

To exercise your right to data portability, please email us at UK_privacy_information_management@pwc.com.

Your right to withdraw consent

Where we process personal data using only your consent, you have a right to withdraw this consent at any time. Note that we do not generally process personal data based on consent (as we usually rely on another legal basis) and so the right to withdraw consent may not be applicable. However, if you wish to exercise the right to withdraw your consent please email us at UK_privacy_information_management@pwc.com

To opt out of direct marketing and to stop receiving an email from a PwC marketing list, please click on the unsubscribe link in the relevant email.

The relevant “Use of personal data” sections of this privacy statement explain our processing of personal data using the legal basis of consent.

Automated decision making

Automated decision making is the process of making a decision based on solely automated means without any human involvement, which may involve profiling. You can ask us to review any decisions made about you that produce legal effects concerning you, or similarly significantly affect you, which are made solely based on automated processing. If you wish us to review a decision, you can do so by contacting UK_privacy_information_management@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 email the details of your complaint to UK_privacy_information_management@pwc.com. We will look into and respond to any complaints we receive.

You also have the right to complain to the Information Commissioner's Office (“ICO”) in the UK (as the UK’s data protection regulator). For further information, please visit the ICO’s website.