Collection of personal data
Our policy is to collect only the personal data necessary for agreed purposes and we ask our clients only to share personal data with us 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 (click here for information on our services), we process many categories of personal data, including:
- Personal details (e.g. name, age/date of birth, gender, marital status, country of residence);
- Contact details (e.g. email address, contact number, postal address);
- Financial details (e.g. salary, payroll details and other financial-related details such as income, investments and other financial interests, benefits, tax status); and
- Job details (e.g. role, grade, experience, performance information and other information about management and employees).
For certain services or activities, we may process special categories of personal data (such as in performing know your client checks and providing immigration and tax services, which involve us processing government identification documents that may contain biometric data or data revealing racial or ethnic origin or as part of an audit of an organisation in the health sector).
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 (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 as part of an audit and we often need to use personal data to provide global mobility and pensions services.
Legal grounds: Legitimate interests, legal obligation, public interest or consent
This processing of personal data by us is necessary for the purposes of the legitimate interests pursued by us in providing professional services and our client in receiving professional services as part of running their organisation and, in some cases, we have a legal obligation to provide the services in a certain way (e.g. statutory audit). Where we process special categories of personal data, we rely on 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;
- 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.
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 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 our client and engagement acceptance, 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).
Legal grounds: Legitimate interests
This processing is necessary for the purposes of the legitimate interests pursued by us to ensure network and information security, manage risks to our business and check the quality of our 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 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 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, we have a legitimate interest in processing personal data as necessary to meet our regulatory or professional obligations.
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 that we receive in the course of providing professional services contains personal data, we will remove the personal data prior to using the information for these purposes.
Legal grounds: Legitimate interests
We have a legitimate interest in de-identifying data to help our clients, to improve our business, service delivery and offerings and to develop new PwC technologies and offerings, including by performing benchmarking and analysis.
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 7 years.
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.
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. We may use other organisations to help us deliver our services as agreed with our client on an engagement-specific basis.