PwC Singapore's privacy policy

This privacy policy was last updated on 14 November 2023

This privacy policy applies to PricewaterhouseCoopers firms which are established in Singapore (“PwC” or “we”). This policy governs the collection, use and disclosure of personal data submitted to PwC including through pwc.com/sg or through the Singapore pages of pwc.com, and explains how we collect and handle personal data of individuals and comply with the requirements of the Personal Data Protection Act 2012 of Singapore (“PDPA”) and its regulation(s). In this policy, “personal data” shall have the meaning ascribed to it in the PDPA.

As a member of the PwC network, PwC shall also comply with the requirements of the PwC network requirements which comply with the requirements of the EU General Data Protection Regulations (GDPR) and UK GDPR where it applies to a processing activity including EEA personal data and UK personal data.

For the avoidance of doubt, nothing herein shall require PwC to act in breach of applicable Singapore laws.

If you have any further questions in relation to our data protection handling practices, please contact our Data Protection Officer by submitting a request here.

PwC's commitment to personal data is set out below.

Collection of Personal Data

General

We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for any other purpose which has not been notified to you (except where permitted or authorised by law).

By interacting with us, using our website, submitting information to us, or engaging our services, you agree and consent to PwC, as well as our service providers and third parties appointed by us on your behalf collecting, using and disclosing your personal data in the manner set forth in this policy. If you provide us with any personal data relating to a third party, by submitting such personal data to us, you also represent to us and must ensure that you have notified the third party of the terms of this policy and obtained his consent thereto.

Recruitment Process

As part of our recruitment process, we collect necessary personal data about you to consider you for employment with our firm. During the course of the recruitment and selection process, we may request further information about you to assess your suitability for positions with our firm. In doing so, we only collect personal data that is necessary for recruitment decisions. The procedures used by the firm to gather further information about you might include:

  • selection interviews;
  • assessment centres;
  • written skills tests;
  • referee reports;
  • security vetting; and,
  • necessary pre-employment activities.

In some cases, pre-employment checking may be necessary. Failure to provide requested information may influence the processing and outcome of your application.

Use of Personal Data

We may collect and use personal data for the following purposes:

  • to provide our services
  • to respond to the individual’s request or for the purposes for which it was provided to us as stated at the time of the collection (or as is obvious from the context of collection)
  • to maintain contact with clients and other contacts
  • to keep clients and other contacts informed of the services we offer, industry developments, service offerings, seminars and other events we are holding, that may be of interest to them
  • order publications
  • to organise any relevant promotional activities such as, but not limited to, seminars, firm events and news alerts on publications
  • to send you communications from time to time, for example, to advise you of technical updates or ask you to participate in surveys or quizzes which may be of interest to you
  • to verify the individual’s identity
  • to respond to, handle, and process queries, requests, applications, complaints, and feedback from the individual
  • to comply with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority
  • managing your relationship with us
  • for general management and reporting purposes, such as invoicing and account management
  • managing your application(s) for employment, evaluating you for open positions throughout the PwC network, and managing your candidate profile;
  • evaluating your suitability for employment with PwC (including for example providing your personal data to third parties to conduct background checks);
  • sending you email notifications and other announcements, requesting additional information, or otherwise contacting you about your candidacy;
  • conducting statistical analyses and reports including for example, demographic analyses of candidates, reports on PwC recruitment activities, and analyses of candidate sourcing channels;
  • transfer and disclosure to third parties as described below;
  • any other recruitment-related purposes for which you provided the information to PwC
  • for purposes related to the employment of our personnel and providing internal services to our personnel
  • registering for events, conferences or premium online services
  • all other purposes related to our business
  • for any other incidental business purposes related to or in connection with the above.

Any individual may choose to unsubscribe from mailing lists, registrations, or elect not to receive further marketing information from us by submitting a request to sg_events@pwc.com, or if we have contacted such individual by email, such individual may use the unsubscribe function in that email to notify us. In general, we shall seek to process such request within ten (10) business days of receiving it.

Disclosure of Personal Data

We may disclose personal data to other PwC firms within the PwC global network (PwC Network Firms), where it is necessary (i) to meet the purpose for which such individual has submitted the information; or (ii) to enable such individual to be provided with information at a later date which may be of relevance and interest to such individual based on the nature and purpose of such individual’s voluntary requests. For a list of where the PwC Network Firms are located, you may refer to PwC office locations.

We do not disclose personal data to third parties except when permitted or required by law, when we have the individual’s consent or deemed consent or in cases where we have engaged third parties such as data intermediaries or subcontractors specifically to assist with our firm’s activities. Any such third parties whom we engage will be bound contractually to keep all information confidential. We may also transfer all data in our possession to a successor-in-interest to our business or assets.

International Transfers of Personal Data

If we process your personal data, your personal data may be transferred to and stored outside of the country where you are located. This includes countries outside of Singapore, EEA, UK and countries that may not provide the same level of data protection as your home country.

Any transfers of personal data to a territory outside of EEA or UK will only be made:

  • to a recipient located in a country which provides an adequate level of protection for your personal data; and/or
  • subject to appropriate safeguards which cover the EU GDPR or UK GDPR requirements.

Any transfers of personal data to a territory outside of Singapore will be made in accordance with the PDPA and we will take steps to ensure a standard of protection to personal data so transferred that is comparable to the protection under the PDPA.

Privacy on our websites and applications

This Policy also applies to any personal data we collect via our websites. Cookies may be used on some pages of our websites. “Cookies” are small text files placed on your hard drive that assist us in providing a more customised website experience. Cookies are now used as a standard by many websites to improve users’ navigational experience. If individuals are concerned about cookies, most browsers permit individuals to decline cookies. In most cases, a visitor may refuse a cookie and still fully navigate our websites, however other functionality in the site may be impaired. After termination of the visit to our site, you can always delete the cookie from your system if you wish. If you require more information on the type and use of cookies by PwC, refer to our Cookies Information page.

Whenever a registered member visits our website, they may be required to identify themselves in order to gain entry. This data is logged by PwC primarily to measure website performance and in assisting to resolve any website technical difficulties.

Because we want visitors’ website experience to be as informative and resourceful as possible, we may provide a number of links to third party websites. We assume no responsibility for the information practices of these third-party websites that visitors are able to access through ours. When a visitor to our website links to these third-party websites, our privacy practices no longer apply. We encourage you to review each website’s privacy policy before disclosing any data.

Access to and Correction of Personal Data

If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data (including your personal data in relation to your job application, or contact information submitted for a PwC event), or (b) a correction request to correct or update any of your personal data which we hold about you (including your personal data in

relation to your job application, or contact information submitted for a PwC event), you may submit your request to our Data Protection Officer here.

We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

Withdrawal of Consent

The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request to our Data Protection Officer here.

Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it. We will cease (and cause any of our data intermediaries and agents to cease) collecting, using or disclosing the personal data unless it is required or authorised under applicable laws.

Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described above.

Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

Accuracy of Personal Data

We generally rely on personal data provided by you (or your authorised representative). We will make a reasonable effort to ensure that personal data collected by us or on our

behalf is accurate and complete. In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer here.

Security and Protection of Personal Data

We have implemented generally accepted standards of technology and operational security to protect the personal data in our possession or under our control and to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. All PwC personnel follow a network-wide security policy. Only authorised PwC personnel are provided access to personal data and these personnel have agreed to ensure confidentiality of the personal data.

You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

Retention of Personal Data

General

We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

Site Visitor’s Contact Information

Some of the information we receive is not retained. For example, contact information about visitors (such as information generated though registration for access to areas on the site) will be kept as long as the information is required to completely service the contact request or until a user request that we delete that information. Mailing list information, discussion posts and email are kept for only the period of time considered reasonable to facilitate the visitor's requests.

Recruitment

Where it relates to job applications and recruitment, as PwC must process your personal data in order to consider you for a position as part of the recruitment process, if you revoke your consent, PwC may need to terminate your application. PwC may retain certain information related to your application for a reasonable but limited period to meet applicable legal or records retention requirements. In the event of an unsuccessful application, we will retain your personal data for future recruitment purposes. If applicable, when there are vacancies in our associate firms (whether locally or overseas) during that period we may transfer your application to them for consideration of employment. Personal data will be kept for only as long as it is reasonably necessary for the purposes as described above.

Data Protection Officer

If you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, you may contact our Data Protection Officer, See Hong Pek, by submitting a request here.

Modifications

This Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

PwC reserves the right to modify or amend this policy from time to time without any prior notice. You may determine if any such modification has taken place by referring to the date on which this policy was last updated.

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