Privacy Policy

This privacy statement describes why and how PricewaterhouseCoopers LLP (“PwC”, “we”, “us”, or “our”) collects and uses personal data in connection with PwC Suite, which includes Family Office and Global VAT Online (“application”) and provides information about your rights as a user of the application (“you”, “user” or “individual”).  

We adhere to internationally recognised security standards.  Our information security management system relating to client confidential data is independently certified as complying with the requirements of ISO/IEC 27001: 2013.  We have a framework of policies, procedures and training in place covering data protection, confidentiality and security and regularly review the appropriateness of the measures we have in place to keep the data we hold secure.

We recognise that transparency is an ongoing responsibility so we will keep this privacy statement under regular review.

This privacy statement was last updated on 20 January 2021.

Data controller and contact information

The data controller is PricewaterhouseCoopers LLP (the limited partnership registered in England under registration no. OC303525 and with its registration address at 1 Embankment Place, London, WC2N 6RH).

If you have any questions about this privacy statement or how and why we process personal data, please contact us at:

Data Protection Officer

PricewaterhouseCoopers LLP

1 Embankment Place

London

WC2N 6RH

Email: UK_privacy_information_management@pwc.com

We will collect personal data in connection with the application as described below.

Personal data provided directly by you:

• We collect personal data that is specifically and voluntarily provided by you, such as your name, company address, email address, telephone number, marketing preferences and login information to allow you to register for certain areas of the site, to respond to enquiries for further information, distribute requested reference materials to you.
• You are able to email us through the website. Your message will contain your screen name and email address, as well as any additional information you may wish to include in the message.
• We may collect other personal data provided directly by you in order to provide our services (such as financial and business information).
  
  

If you decide to register and obtain the service via the application, you will be asked to provide certain information as part of the registration process. You do not have to fill in the "optional" boxes - and if you don't, it will not prevent us from providing the services or responding to your enquiry but it is always helpful for us to receive this optional data as it may enable us to better understand your business needs. You must fill in the "mandatory" boxes marked * as otherwise it may prevent us from providing the services or responding to your enquiry.

Personal data inferred or derived from your use of the application:

• We use small text files called ‘cookies’ which are placed on your hard drives to assist in providing a more customised website experience. The use of cookies is now standard operating procedure for most websites. However if you are uncomfortable with the use of cookies, most browsers now permit users to opt-out of receiving them. In that case you will be unable to use this registration process and may find other functionality in the site impaired. After termination of the visit to our site, you can always delete the cookie from your system if you wish.  Please see the cookies information sectionfor further details. 

Unless otherwise stated above, our lawful basis for the processing of personal data in connection with the application is the legitimate interests pursued by us in making the application available, providing connected professional services and developing our business.

We use personal data for the following purposes:

• to provide the application (and enable you to securely log in to the application), to provide you with relevant information and respond to enquiries and to provide services

We use personal data to enable you to securely log in to the application, to provide information that we think will be of interest about us and our services (e.g. industry updates and insights, other services that may be relevant and invites to events) and respond to enquiries) and to provide services as follows

• to  provide services to you which may be further described in service-specific privacy statements provided to you
• to administer, manage and develop our businesses and services
  
  

We may process personal data in order to run our business, including:

• managing our relationship with clients and prospective clients;
• developing our businesses and services (such as identifying client needs and improvements in service delivery);
• maintaining and using IT systems;
• hosting or facilitating the hosting of events; and
• administering and managing our systems and applications.

•  security, quality and risk management

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).  

• to monitor the performance of the application, how it is being used and to make improvements and to troubleshoot any issues with the application
• 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.  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 will only share personal data with others when we are legally permitted to do so.  When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards.

We share personal data processed in connection with the application as follows:

• Other PwC member firms

• We share personal data processed in connection with the application with other PwC member firms for  administrative purposes and to provide advice from PwC member firms in different territories. Our business contacts are visible to and used by PwC users from other PwC member firms to learn more about a contact, client or opportunity they have an interest in.  Please see our website privacy statement for further information.  
• For details of our member firm locations, please click here.
• We have the European Commission approved standard contractual clauses in place with the other PwC member firms to provide appropriate safeguards for personal data transferred outside of the EU.  The standard contractual clauses are available here.

• Third party organisations that provide applications/functionality, data processing or IT services to us

We are part of a global network of firms and in common with other professional service providers, we use third parties to help us run our business and these third parties may be located in other countries.  Further details about the processors (such as IT service providers) used by PwC and locations of processing are provided here.  

Where the locations of processing are outside of the EU, we have the European Commission approved standard contractual clauses in place to provide appropriate safeguards for personal data transferred outside of the EU.  The standard contractual clauses are available here.

• Third party organisations that otherwise assist us in providing goods, services or information

We may use other organisations to help us deliver our services as agreed with our client on an engagement-specific basis.

Where the locations of processing are outside of the EU, we have the European Commission approved standard contractual clauses in place to provide appropriate safeguards for personal data transferred outside of the EU.  The standard contractual clauses are available here.

• Auditors and other professional advisers
• Law enforcement or other government and regulatory agencies or to other third parties as required by, and in accordance with, applicable law or regulation

Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights.  We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.

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.

You have certain rights over your personal data.  Data controllers are responsible for fulfilling these rights.  Where we decide how and why personal data is processed, we are a data controller.

Individuals’ rights are the right of access to personal data, to rectification of personal data, to erasure of personal data / right to be forgotten, to restrict processing of personal data, to object to processing of personal data, to data portability, the right to withdraw consent at any time (where processing is based on consent) and the right to lodge a complaint with a supervisory authority.

Please see further information about these rights and how to exercise them below.

You have the right to obtain confirmation as to whether we process personal data about you, receive a copy of your personal data held by us as a data controller and obtain certain other information about how and why we process your personal data (similar to the information provided in this privacy statement).  

You may exercise this right by emailing us at UK_privacy_information_management@pwc.com. We will aim to respond to any requests for information promptly, and in any event within the legally required time limits.