Collection of personal information
PwC collects, holds and processes personal information from clients, suppliers, employees, contractors and other individuals. We collect and hold this information when it is necessary for business purposes.
The main types of personal information PwC collects, holds and processes relate to the contact details and organisational roles of our clients, suppliers and other business contacts. Typically, this information includes names, addresses, telephone numbers, e-mail addresses and job titles. In the course of providing professional services to our clients, we may collect and hold more detailed personal information (for instance financial details if we are engaged to perform financial services, or credit information).
We generally do not intend to collect and we ask you not to submit any special categories of personal information. Special categories of personal information include race or ethnic origin; political opinions or political affiliations; religious or philosophical beliefs; trade union membership; physical or mental health; genetic data; biometric data that uniquely identifies someone; sexual life or sexual orientation; and criminal records.
We collect most information directly from individuals when we deal with them. The personal information we collect may be provided in forms filled out by individuals, face to face meetings, email messages, telephone conversations, when you use our websites or our social media, or by third parties. If you contact us, we may keep a record of that contact.
Because of the nature of our business, it is generally impracticable for us to deal with individuals on an anonymous basis or through the use of a pseudonym, although sometimes this is possible (for example, when seeking staff or client feedback generally).
Our legal grounds for processing your personal data
We rely on one or more of the following processing conditions:
- our legitimate interests in the effective delivery of information and services to you and in the effective and lawful operation of our businesses and the legitimate interests of our clients in receiving professional services from us as part of running their organisation (provided these do not interfere with your fundamental rights);
- our legitimate interests in developing and improving our businesses, services and offerings and in developing new PwC technologies and offerings (provided these do not interfere with your fundamental rights);
- our legitimate interests in maintaining the security of our and our client’s data and in ensuring the quality of our services;
- to satisfy any requirement of law, regulation or professional body of which we are a member (for example, for some of our services, we have a legal obligation to provide the service in a certain way);
- to perform our obligations under a contractual relationship with you; or
- where no other processing condition is available, if you have agreed to us processing your personal information for the relevant purpose.
Why we process personal information
The primary purposes for which we collect, hold and process personal information are:
- to provide professional services to our clients: we provide a diverse range of services to our clients. Some of our services require us to collect and process personal data in order to provide advice and deliverables. For example, we will review payroll data as part of an audit and we often need to use personal data to provide global mobility, tax and pension services;
- to respond to an individual's request;
- to maintain contact with clients;
- administering, managing and developing our business and services: This includes:
- managing our relationship with clients and prospective clients;
- developing our business and services (such as identifying client needs and improvements in service delivery);
- analysing and evaluating the strength of interactions between PwC and a contact;
- performing analytics, including producing metrics for PwC leadership, such as trends, relationship maps, sales intelligence and progress against account business goals;
- administering and managing IT systems, websites and applications; and
- hosting or facilitating the hosting of events.
- providing our clients and prospective clients with information about us and our range of services : we use client and prospective client business contact details to provide information that we think will be of interest about us and our services in accordance with any permissions required by law. This includes industry updates and insights, other services that may be relevant and invites to events;
- for general management and reporting purposes, such as invoicing and account management;
- for recruitment purposes;
- for purposes related to the employment of our personnel and providing internal services to our staff;
- receiving services: we process personal data in relation to our suppliers and their staff as necessary to receive the services they are contracted to provide;
- security, quality and risk management activities: we have security measures in place to protect our and our client’s 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 in place policies and procedures 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 those client engagement and acceptance 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 reputation issues);
- complying with any requirements 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; and
- other purposes related to our business.
We may keep a record of your Personal Information, correspondence or comments in a file specific to you. We will utilize, disclose or retain your Personal Information for as long as necessary to fulfill the purposes for which that Personal Information was collected and as permitted or required by law.
If you choose not to provide us with personal information, we may be unable to do such things.
We may collect, hold and use personal information about individuals to market our services, including by email. However, individuals always have the opportunity to elect not to receive further marketing information from us by writing to the Privacy Officer at email@example.com. Please allow 20 working days for your request to be processed.
Alternatively, if we have contacted you by email, you may use the unsubscribe function in that email to notify us that you do not want to receive further marketing information from us by email.
If we collect, hold or use personal information in ways other than as stated in this policy, we will ensure we do so pursuant to the requirements of the Privacy Act.
Employee records are not generally subject to the Privacy Act and therefore this policy may not apply to the handling of information about employees by PwC. For information about our practices relating to employee information, please contact us directly.
Disclosure of personal information
PwC does not routinely disclose personal information to other organisations unless:
- use or disclosure is permitted by this policy;
- we believe it is necessary to provide you with a product or service which you have requested (or, in the case of a partner, employee or contractor of PwC, it is necessary for maintaining or related to your role at PwC);
- to protect the rights, property or personal safety of any member of the public or a customer of PwC or the interests of PwC;
- some or all of the assets or operations of PwC are or may be transferred to another party as part of the sale of some or all of PwC' business;
- you give your consent; or
- such disclosure is otherwise required or permitted by law, regulation, rule or professional standard. This would potentially involve disclosure as necessary to law enforcement, regulatory and other government agencies and to professional bodies.
We may also disclose personal information under the following circumstances:
- with professional advisers, for example, law firms, as necessary to establish, exercise or defend our legal rights and obtain advice in connection with the running of our business. Personal data may be shared with these advisers as necessary in connection with the services they have been engaged to provide;
- when explicitly requested by you;
- when required to deliver publications or reference materials requested by you;
- when required to facilitate conferences or events hosted by a third party;
We may also share non-personal, de-identified and aggregated information for research or promotional purposes. Except as set out in this policy, we do not sell to or trade personal information with third parties.
PwC uses a range of service providers to help us maximise the quality and efficiency of our services and our business operations (including internal business requirements, such as recruitment and human capital requirements). We may transfer or disclose the personal data we collect to third party contractors, subcontractors, and/or their subsidiaries and affiliates. This means that individuals and organisations outside of PwC will sometimes have access to personal information held by PwC and may collect or use it from or on behalf of PwC. This may include, but is not limited to, independent contractors and consultants, travel service providers, mail houses, off-site security storage providers, information technology providers, event managers, credit managers, debt collecting agencies, providers of identity management, website hosting and management, data analysis, data backup, security and cloud storage services. The third party providers may use their own third party subcontractors that have access to personal data (subprocessors). It is our policy to use only service providers and third party providers that are bound to maintain appropriate levels of security and confidentiality, to process personal information only as instructed by PwC and in accordance with our privacy guidelines and not to keep, use or disclose personal information we provide to them for any unauthorised purposes. We also require the flow of those same obligations down to their sub-processors. If PwC' staff obtain products or services offered by a third party pursuant to an agreement or arrangement between that third party and PwC, such as a credit card provider, we may provide your personal information to that third party, including information that relates to your use of such services.
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 as appropriate to protect the data and to comply with our data protection, confidentiality and security standards.
We retain personal data processed by us for as long as is necessary for the purpose for which it was collected. Personal data may be held longer periods where extended retention periods are required by law or regulation and as necessary in order to defend our legal rights.
Transfer of information outside New Zealand
In addition to disclosures permitted under this policy, we may disclose your personal information to other PwC firms within the PwC global network.
For a list of where the PwC firms are located, see PwC member firm locations
We may share personal data with other PwC member firms where necessary for administrative purposes and to provide professional services to our clients (e.g. when providing services involving advice from PwC member firms in different territories).
PwC and other PwC firms with which we exchange information may also use overseas facilities or contractors to process or back-up our information or to provide certain services to us. These PwC firms, service providers and contractors may not be New Zealand entities or regulated by the Privacy Act, and may not be subject to privacy laws that provide the same level of protection as New Zealand’s. You consent to the disclosure of your personal information to such PwC firms, service providers and contractors on this basis.
However, any such transfer of information does not change any of our commitments to safeguard your privacy and the information remains subject to existing confidentiality obligations.
Storage of information in cloud systems
PwC may store personal information within services provided by offshore cloud service providers (CSP).
Privacy on our Web Sites and Applications
This policy also applies to any personal information we collect via our websites, including pwc.co.nz, and applications including mobile applications. In addition to personal information you provide to us directly (such as where you make a request or complete a registration form).
In order to properly manage our websites and applications, we may log certain statistics about the users of the facilities, for example the users' domains and browser types. None of this information specifically identifies an individual and it is used solely to ensure that our websites and applications provide the best possible navigational experience for users.
Cookies and web beacons are used on some PwC websites.
A web beacon is a clear picture file used to keep track of your navigation through a website. Along with cookies, web beacons help us gain an understanding of how users of PwC websites navigate through and process the content contained in those websites. On occasion PwC will advertise on third party websites. As part of the tracking process for advertising campaigns we may at times use web beacons to count visitors who have come to the PwC websites after being exposed to PwC advertising on a third party site.
We do not use this technology to access your personal information.
If you have registered an account with us, you will be identified by a user name and password when you log into our website or applications. The information we collect about members' use of our websites may be used for measuring use and performance and in assisting to resolve any technical difficulties.
Security of Personal Information
Depending on the purpose for which we have collected personal information (for example, registration for a PwC event or a request for particular information or material), we may store some of the information electronically in PwC' customer relationship management system. Some or all of this personal information may be available to partners and authorised staff of PwC for use in accordance with this policy.
PwC will endeavour to take all reasonable steps to keep secure any information which we hold about you, whether electronically or in hard-copy, and to keep this information accurate and up to date. We also require our employees and data processors to respect the confidentiality of any personal information held by PwC.
PwC aims to achieve industry best practice in the security of personal information which it holds. It is our policy not to retain personal information once there is no longer a legal or business need for us to do so.
We take the security of all the data we hold very seriously. We adhere to internationally recognised security standards and 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.
Access to Information
We will provide access to personal information upon request by an individual, except in the limited circumstances in which it is permitted for us to withhold this information (for instance, where granting access would infringe another person’s privacy).
When you make a request to access personal information, we will require you to provide some form of identification (such as driver’s licence or passport) so we can verify that you are the person to whom the information relates. In some cases we may also request an administrative fee to cover the cost of access.
If at any time you want to know what personal information we hold about you, you may contact us by email the Privacy Officer at firstname.lastname@example.org.
Residents in the European Economic Area
If you are a resident in the European Economic Area, you have the following rights in relation to your personal information (where applicable):
- Access. You have the right to request a copy of the personal information we are processing about you. For your own privacy and security, at our discretion we may require you to prove your identity before providing the requested information.
- Rectification. You have the right to have incomplete or inaccurate personal information that we process about you rectified.
- Deletion. You have the right to request that we delete personal information that we process about you, except we are not obliged to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.
- Restriction. You have the right to restrict our processing of your personal information where you believe such data to be inaccurate; our processing is unlawful; or that we no longer need to process such data for a particular purpose unless we are not able to delete the data due to a legal or other obligation or because you do not wish for us to delete it.
- Portability. You have the right to obtain personal information we hold about you, in a structured, electronic format, and to transmit such data to another data controller, where this is (a) personal information which you have provided to us, and (b) if we are processing that data on the basis of your consent or to perform a contract with you.
- Objection. Where the legal justification for our processing of your personal information is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate grounds for the processing
Withdrawing Consent. If you have consented to our processing of your personal information, you have the right to withdraw your consent at any time, free of charge. This includes cases where you wish to opt out from marketing messages that you receive from us.
To make a request to exercise any of these rights in relation to your personal information, please email, call or write to us using the contact information listed below in the “Introduction” and “Correction and Concerns” sections.
Data controller and contact information
We are generally controllers for the personal data we process, however, we may provide some services, such as payroll services, as a processor (in which case our client is the controller). If you have any questions about this privacy statement or how and why we process personal data, please contact us at:
Privacy Officer: email at email@example.com.
Corrections and Concerns
If you believe that information we hold about you is incorrect or out of date, or if you have concerns about how we are handling your personal information, please contact us and we will try to resolve those concerns.
If you wish to have your personal information deleted, please let us know and we will take reasonable steps to delete it (unless we need to keep it for legal, or internal risk management reasons, or compliance with our professional obligations).
Effect of Policy
PwC operates in a dynamic business environment and we aim to review this policy annually to keep it current.
The amended policy will apply between us whether or not we have given you specific notice of any change.