Individuals whose personal information we obtain in connection with providing professional services to our clients
Collection of personal information
Our policy is to collect only the personal information necessary for agreed purposes. Where our clients provide us with personal information in connection with our provision of professional services, we will process that information in accordance with our agreement with the client, and we may act as the client’s entrusted party. Our clients are expected to share necessary information in compliance with applicable data protection law and regulations.
Given the diversity of the services we provide, the categories of personal information we process may include:
- Contact details (e.g. email address, contact number, postal address);
- Personal details (e.g. name, age or date of birth, gender, marital status, country of residence);
- Financial details (e.g. 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 and/or sensitive personal information (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 information 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 information from that target’s management and employees or from a third party acting on the instructions of the target.
Use of personal information
We may use personal information for the following purposes:
Providing professional services
We provide a diverse range of professional services. Some of our services require us to process personal information in order to provide advice and deliverables. For example, we will review financial data as part of an audit and we often need to use personal information to provide tax and consulting services.
Administering, managing and developing our businesses and services
This includes:
- 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.
Performing our pre-engagement acceptance checks
This may include conflicts, anti-money laundering or other professional or regulatory related checks. We collect and hold personal information as part of our client engagement and acceptance procedures. As part of those procedures 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).
Security, quality and risk management activities
We have security measures in place to protect our and our clients’ information (including personal information), which involve detecting, investigating and resolving security threats. Personal information 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 information 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.
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 information.
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.
Data retention
We retain the personal information processed by us for as long as is considered necessary for the purpose for which it was collected. Personal information may be held for longer periods where extended retention periods are required by law or regulation or in order to establish, exercise or defend our legal rights.
