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Our policy is to collect only the personal data necessary for agreed purposes and we ask our clients only to share personal data 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 other data subjects concerned, such as family members, regarding its use.
Given the diversity of the services we provide to personal clients (click here for information on our services), we process many categories of personal data, including as appropriate for the services we are providing:
For certain services or activities, and when permitted by law (e.g. under a public interest condition) or with an individual's consent, we may also collect special categories of personal data. Examples of special categories include race or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; physical or mental health; genetic data; biometric data; sexual life or sexual orientation; and, criminal records.
Generally, we collect personal data from our clients or from a third party acting on the instructions of the relevant client.
We use personal data for the following purposes:
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 and 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 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 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.