This privacy statement describes why and how PricewaterhouseCoopers LLP (“PwC”, “we”, “us”, or “our”) collects and uses personal data in connection with Tax Information Space (“application”) and provides information about your rights as a user of the application (“you”, “user” or “individual”).
Personal data is any information relating to an identified or identifiable living person. This privacy statement applies to personal data provided to us, both by you or by others and any personal data created in connection with your use of the application. 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.
When collecting and using personal data, our policy is to be transparent about why and how we process personal data. To find out more about our specific processing activities in connection with the application, please go to the relevant sections of this statement.
We adhere to internationally recognised security standards. Data is encrypted at rest and in transit within the application. 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.
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 26 April 2019.
The data controller is 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 that is a contracting party for the purposes of providing services using the application.
If you have any questions about this privacy statement or how and why we process personal data, please contact us at:
Data Protection Officer
1 Embankment Place
Our policy is to collect only the personal data necessary for agreed purposes and we ask our clients to only share personal data with us where it is strictly needed for those purposes.
We will collect personal data in connection with the application as described below.
The application uses “cookies”. A cookie is a small text file which is placed on your device (e.g. computer, tablet, or phone) when you visit a website that helps the site remember information about you and your preferences.
For details of the cookies used on the application (and the purpose of use) please click here.
We use personal data for the following purposes:
Our services require us to process personal data in order to provide advice and deliverables. For example, using personal data and reviewing payroll data as part of our personal tax compliance work. The information provided by you on the portal will be processed and analysed in line with the scope of work we have agreed with you. We will input this data into other technology systems that we use, to produce your tax return.
Legal grounds: Performance of a contract, legitimate interests, legal obligation, public interest or consent
This processing is necessary for the performance of the engagement letter (contract) to which our personal client (the data subject) is a party and, where we process personal data about other individuals (such as family members) in order to provide our services, this processing is necessary for the purposes of the legitimate interests pursued by us in providing professional services and our client in receiving professional services. In some cases, we have a legal obligation to provide the services in a certain way.
We may process personal data in order to run our business, including:
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.
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).
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.
Unless we are asked not to, we use client and prospective client 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.
Legal grounds: Legitimate interests
This processing is necessary for the purposes of the legitimate interests pursued by us to promote our business and services.
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, Financial Reporting Oversight Role 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 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 12 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.
You have certain rights over your personal data. Data controllers are responsible for fulfilling these rights. Where we decide how and why personal data is processed, we are a data controller.
Individuals’ rights are the right of access to personal data, to rectification of personal data, to erasure of personal data / right to be forgotten, to restrict processing of personal data, to object to processing of personal data, to data portability, the right to withdraw consent at any time (where processing is based on consent) and the right to lodge a complaint with a supervisory authority.
Please see further information about these rights and how to exercise them below.
You have the right to obtain confirmation as to whether we process personal data about you, receive a copy of your personal data held by us as a data controller and obtain certain other information about how and why we process your personal data (similar to the information provided in this privacy statement).
You may exercise this right by emailing us at using the link below. We will aim to respond to any requests for information promptly, and in any event within the legally required time limits.
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 incomplete personal data completed.
To update personal data submitted to us, please email us using the linke below or, contact your local PwC team. 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.
You have the right to obtain deletion of your personal data in the following cases:
To request deletion of your personal data, please email us using the link below.
You have the right to restrict our processing of your personal data in the following cases:
To restrict our processing of your personal data, please email us using the link below.
You have the right to object to our processing of your personal data in the following cases:
To object to our processing of your personal data, please email us using the link below.
You have a right to receive your personal data provided to us and have the right to send the data to another organisation (or ask us to do so if technically feasible) where our lawful basis for processing the personal data is consent or necessity for the performance of our contract with you and the processing is carried out by automated means.
To exercise your right to data portability, please email us using the link below.
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). Where we rely on consent for processing, to withdraw your consent please contact your local PwC team or email us using the link below. Please see the “Use of personal data” section of this privacy statement for further details about any processing of personal data based on consent.
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 using the link below. We will look into and respond to any complaints we receive.
You also have the right to lodge a complaint with the supervisory authority in your country of residence, place of work or the country in which an alleged infringement of data protection law has occurred within the EU. The Information Commissioner's Office (“ICO”) is the UK data protection regulator/supervisory authority. For further information on your rights and how to complain to the ICO, please refer to the ICO website.