Tax Information Space privacy statement

Introduction

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.

Security

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.

Changes to this privacy statement

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.

Data controller and contact information

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
PricewaterhouseCoopers LLP
1 Embankment Place
London
WC2N 6RH

Collection of personal data

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.

Personal data that may be provided directly by you:

  • Personal details (e.g. name, title, age/date of birth, gender, country of residence, unique taxpayer reference number, national insurance number, government identification documents);
  • Contact details (e.g. email address, contact number, postal address, fax number);
  • Financial details (e.g. salary and other income and investments, bank details, benefits, tax status);
  • Company/job details (e.g. company name, company address, role, grade); and
  • Responses to memorable security questions (to enable a password reset).

Personal data inferred or derived from your use of the application:

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.

Use​ ​of​ ​personal​ data

We use personal data for the following purposes:

Providing professional services

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.

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; 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 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.

Providing our clients and prospective clients with information about us and our range of 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.

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, 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.

When and how we share personal data and locations of processing

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 countries where we and our clients are located. This includes to countries outside the European Union and to countries that do not have laws that provide specific protection for personal data.  We have taken steps to ensure all personal data is provided with adequate protection and that all transfers of personal data outside the EU are done lawfully. Where we transfer personal data outside of the EU to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the EU requirements for the transfer of personal data outside the EU, such as the European Commission approved standard contractual clauses. The European Commission approved standard contractual clauses are available here.

Personal data held by us may be transferred to:

Other PwC member firms

For details of our member firm locations, please click here.

We may share personal data with other PwC member firms where necessary for administrative purposes and to provide professional services to our clients (e.g. when providing services involving advice from PwC member firms in different territories). Or to other PwC member firms that support us in the delivery of our services.

We store personal data on our or other PwC member firm servers in the EU, Singapore and the USA.  IT support and services are provided by PwC India and PwC’s IT Services company.

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 the pwc.co.uk 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 providers, identity management, website hosting and management, data analysis, data back-up, security and storage services.  The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them. Information about the providers used across PwC is available here.

The key third party providers specifically providing services to us in respect if this application are:

Name

Role

Address

Microsoft Azure

Hosting of the application

Microsoft Campus, Thames Valley Park, Reading, RG6 1WG, UK


Wolters Kluwer UK Limited

Provider of the application platform

145 London Road, Kingston upon Thames, Surrey KT2 6SR, UK

Please contact us for further details of the third party organisations that provide applications/functionality, data processing or IT services in relation to the application.

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 helps 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 are available here) 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 our legal rights 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.

Law enforcement or other government and regulatory agencies or to 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 obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights.  We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation. Details of our regulators are available here.

Data retention

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.
 

Individuals’ rights and how to exercise them

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.

Right of access

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.

Right to rectification

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.

The right to erasure / right to be forgotten

You have the right to obtain deletion of your personal data in the following cases:

  • the personal data are no longer necessary in relation to the purposes for which they were collected and processed;
  • our lawful basis for processing is consent, you withdraw consent and we have no other lawful basis for the processing;
  • our lawful basis for processing is that the processing is necessary for a legitimate interest pursued by us, 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; and
  • 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 using the link below.

The 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 the 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;
  • the 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; and
  • 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 using the link below.

The right to object to processing

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

  • our lawful basis for processing is that the processing is necessary for a legitimate interest pursued by us; and
  • our processing for direct marketing purposes.

To object to our processing of your personal data, please email us using the link below.

Right to data portability

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.

Right to withdraw consent or stop receiving marketing

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.

Complaints

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.

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