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 data subjects concerned regarding its use.
We collect and use contact details for our clients in order to manage and maintain our relationship with those individuals. Please see the Business contacts section of this privacy statement for more information about our processing of this type of data.
Given the diversity of the services we provide to clients (click here for information on our services), we process many categories of personal data, including:
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 a third party acting on the instructions of the relevant 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.
We use personal data for the following purposes:
Legal grounds: Legitimate interests, legal obligation, public interest or consent
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.
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 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 that we receive in the course of providing professional services contains personal data, we will remove the personal 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.