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 individuals who are the subject of the data.
Given the diversity of the services we provide, 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, we may process special categories of personal data (such as in performing 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 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. 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.
- Administering, managing and developing our businesses and services
- managing our relationship with clients;
- developing our businesses and services (such as identifying client needs and improvements in service delivery);
- administering and managing IT systems, websites and applications; and
- hosting or facilitating the hosting of events
- 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).
- 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.
- Improving and developing our services
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 de-identify the data prior to using the information for these purposes.
We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected. 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.