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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.
Where we need to process personal data to provide professional services, we ask our clients to provide the necessary information to the data subjects regarding its use. Our clients may use relevant sections of this privacy statement or refer data subjects to this privacy statement if they consider it appropriate to do so.
The categories of personal data processed by us in relation to the services we provide are generally:
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 third parties when providing services to the relevant client.
We use personal data for the following purposes:
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.
This processing is necessary for the purposes of the legitimate interests pursued by us to administer, manage and develop our business and services.
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.
We have been given explicit consent from client and prospective client business contacts to process their personal data for the purpose of sending them marketing communications.
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 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 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.
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.