Collection of personal data
Our policy is to collect only the personal data necessary for agreed purposes. We ask our clients to only share personal data with us 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.
The categories of personal data processed by us in relation to the services we provide are
- Personal details (name, age/date of birth, gender, marital status, country of residence);
- Contact details (email address, contact number, postal address);
- Financial details (salary and other income and investments, benefits, tax status and other tax information, including tax code); and
- Job details (role, grade, professional experience and performance information).
For certain services or activities, we may process special categories of personal data. When performing our know your client checks and providing immigration and tax services, we are required to process government identification documents that may contain biometric data or data revealing racial or ethnic origin. Such processing may be necessary during the course of an audit engagement for a client organisation in the health sector.
We collect personal data from our clients directly, or sometimes from third parties, when providing our professional services to the relevant client.
Use of personal data
We process personal data for the following purposes:
- Providing our professional services
We provide a diverse range of professional services (click here for information on our 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 when providing our audit services and we normally have to process personal data to provide global mobility, tax and pensions services to our clients.
Legal grounds: Legitimate interests, legal obligation, public interest or consent
This processing is necessary for the purposes of our legitimate interests in providing professional services to our clients, and those of our clients in receiving our professional services in the course of their business activities. In some circumstances, we have a legal obligation to provide the services in a certain way (for example when providing statutory audit services to our clients). Where we are required to process special categories of personal data, we do so on the grounds of a relevant public interest condition or consent.
- Administering, managing and developing our businesses and services
We may process personal data in order to run our business, including:
- managing our relationship with clients and prospective 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.
- Performing analytics for reporting and statistical purposes
Legal grounds: Legitimate interests
This processing is necessary for the purposes of the legitimate interests pursued by us to administer, manage and develop our business and services.
- 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 assurance purposes, which may involve processing personal data stored on the relevant client file.
- We collect and hold personal data as part of our client engagement and acceptance procedures. We carry out searches using publicly available sources (such as internet searches and checking against sanctions lists) to identify politically exposed persons and heightened risk individuals and organisations, and to check that we are not prohibited from providing our services (for example due to sanctions, criminal convictions (including in respect of company directors), conduct or other reputational issues).
Legal grounds: Legal obligation or Legitimate interests
This processing is necessary to enable us to comply with our legal obligations or for the purposes of our legitimate interests in ensuring network and information security, managing risks to our business and checking the quality of our services. Where it is necessary to process special categories of personal data or criminal offence data, we do so for reasons of substantial public interest
- Providing our clients and prospective clients with information about us and our professional services business contact details to inform our clients and relevant others about our professional services. Further information is available under 'Business Contacts'.
Legal grounds: Legitimate interests
This processing is necessary for the purposes of our legitimate interests promoting and growing our business and our range of professional services
- 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 are required to keep certain records to demonstrate that our services satisfy those obligations and these may contain personal data.
Legal grounds: Legal obligation or legitimate interests
This processing is necessary for us to comply with a legal obligation; for example, when conducting customer due diligence checks to comply with anti-money laundering regulations and, where we do not have a legal obligation to conduct such processing, we have a legitimate interest to meet our regulatory or professional obligations.
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 standard retention period is 7 years.
Personal data may be held for longer periods where extended retention periods are required by law or regulation and/or where this may be needed to establish, exercise or defend our legal rights.
When and how we share personal data and locations of processing
Further details about the processors (such as IT service providers) used by PwC and locations of processing are provided here (see ‘When and how we share personal data and locations of processing’). We may use other organisations to help us deliver our services as agreed with our client on an engagement-specific basis.