This privacy statement describes why and how PricewaterhouseCoopers LLP ('PwC', 'we', 'us', or 'our') collects and uses personal data in connection with the Inform web site with the URL www.inform.pwc.com or such other URL as may replace it from time to time ('application') and provides information about your rights as a user of the application ('you', 'user' or 'individual').
Personal data is any information relating to an identified or identifiable living person. This privacy statement applies to personal data provided to us, both by you or by others and any personal data created in connection with your use of the application. We may use personal data provided to us for any of the purposes described in this privacy statement or as otherwise stated at the point of collection.
When collecting and using personal data, our policy is to be transparent about why and how we process personal data. To find out more about our specific processing activities in connection with the application, please go to the relevant sections of this statement.
When you use this application and in the course of our providing services to you, we may collect personal data either (i) directly where you are asked to provide data (for example, name, e-mail address and mailing address); or (ii) indirectly (for example, via cookies and other technical means to monitor your use of the application; or from third parties who provide us with information about you). Please see the section on Collection of personal data below for further details.
We take the confidentiality and security of personal data collected via this web site very seriously and have implemented generally accepted standards of technology and operational security in order to protect the personal data collected via this web site, but the nature of the Internet is of course such that the data may flow over networks without appropriate security measures and may be accessed and used by unauthorised persons.
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.
Changes to this privacy statement
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 June 2018.
Data controller and contact information
The data controllers are PricewaterhouseCoopers LLP (the limited partnership registered in England under registration no. OC303525 and with its registration address at 1 Embankment Place, London, WC2N 6RH) and PricewaterhouseCoopers LLP (the US firm of the PricewaterhouseCoopers network of firms) and other PwC member firms with an Inform territory branch (details of which are available by visiting inform.pwc.com or on request by emailing email@example.com).
If you have any questions about this privacy statement or how and why we process personal data, please contact us at:
Data Protection Officer
1 Embankment Place
Phone: 020 7803 3700
Collection of personal data
We will collect personal data in connection with the application as described below.
If you decide to register and obtain services or information via this application (or if a legal entity which you represent has already registered and you log in to the application), you may be asked to fill in certain boxes. You do not have to fill in the 'optional' boxes – and if you don't, it will not prevent us from registering you with the web site, 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 registering you with the application or processing your order or enquiry. We will only ever collect, process, use and disclose such data, whether optional or not, in accordance with this privacy statement.
Personal data provided directly by you:
- Job title
- Company name
- Parent company (i.e. Official legal parent entity name)
- Zip/postal code
- External auditor
Information sent by a web server to a browser is commonly referred to as a cookie. A cookie can then be accessed by that same server the next time the user goes on to the application. A cookie can hold a variety of information, including the number of times the user has accessed the site, registration information, and the number of times a user has seen a particular advertisement on the site. The 'help' function on most browsers will have information on how to prevent your computer accepting cookies, how to find out if you have received a cookie and how to disable them completely, if this is what you want to do. Personal data inferred or derived from your use of the application using cookies and other technologies:
Use of personal data
- Date/time terms & conditions accepted
- Date/time last logged in
- Number of times logged in: this month/over last 12 months/since registration
We use personal data for the following purposes:
- Providing the application and services to you
This processing is necessary for the performance of our contract with the you (e.g. to provide the application) or, where we do not have a direct contract with you, 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.
- Administering, managing and developing our businesses and services
We may process personal data in order to run our business, including:
This processing is necessary for the purposes of the legitimate interests pursued by us to administer, manage and develop our business and services.
- To administer and manage the application
- To update our records and databases
- To improve the personalisation of our services to you and maintain an 'e-profile' about you or a third party about whom you have supplied us with data (for example, your employer)
- To send you newsletters and other relevant information via email
As part of the Inform service, we send fortnightly email newsletters. You can unsubscribe from the newsletters at any time by clicking on the unsubscribe link in the newsletter, emailing firstname.lastname@example.org or updating your profile (if applicable). We may contact you from time to time to inform you of other PwC features, services and products and/or send you related information which may be of interest to you, but only if you don't object to us doing this. You can deselect this option when you register with Inform by removing the tick(s) from the checkbox(es) under the section ‘Please select territory newsletters you are interested in:’
This processing is necessary for the purposes of the legitimate interests pursued by us to promote our business and services.
When and how we share personal data and locations of processing
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
- Because of the nature of the service provided by this web site and the international nature of PricewaterhouseCoopers' activities, personal data may, subject to applicable law, be transferred internationally throughout the world-wide PwC member firms (details of which are available on request by emailing email@example.com where necessary for the purposes described in the ‘Use of personal data’ section above. This may mean that personal data is transferred to countries which do not have laws or regulations that protect personal data, such as the United States of America, where the application may be hosted or where a mirrored server may be kept. The data will only be disclosed to relevant PwC personnel (that is, partners and staff whose job it is to process your enquiries and orders or otherwise to administer the web site, and those individuals involved in the provision of products and services) and they will only process the data for the purposes identified in this privacy statement.
- We store personal data on our or other PwC member firm servers in the EU, Singapore and the USA. IT support and services are provided by PwC India and PwC’s IT Services company.
- 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. We share personal data processed in connection with the application as follows:
- Interactive 1 Limited, to provide website hosting, development, support and maintenance services, Mutual House, 70 Conduit Street, London W1S 2GF
- 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.
- 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 personal data processed in connection with the application as follows:
- Data needed to maintain your subscription is held as long as your company’s subscription remains active, and for two months after expiry so as to retain your personalisation settings should you decide to reactivate your subscription.
- We keep sufficient data to identify previous free trials to confirm eligibility for future free trials.
Individuals’ rights and how to exercise them
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.
Right of access
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 firstname.lastname@example.org. We will aim to respond to any requests for information promptly, and in any event within the legally required time limits.
Right to rectification
You have the right to request for your personal data to be amended or rectified where it is inaccurate (for example, if you change your name or address) and to have incomplete personal data completed.
To update personal data submitted to us, please email us at email@example.com. You may be able to update some of the data we hold about you (such as your registration data and newsletter preferences) directly yourself, by clicking 'My Inform > My profile' from the home page. When practically possible, once we are informed that any personal data processed by us is no longer accurate, we will make updates, as appropriate, based on your updated information.
The right to erasure/right to be forgotten
You have the right to obtain deletion of your personal data in the following cases:
- the personal data are no longer necessary in relation to the purposes for which they were collected and processed;
- our lawful basis for processing is consent, you withdraw consent and we have no other lawful basis for the processing;
- our lawful basis for processing is that the processing is necessary for a legitimate interest pursued by us, you object to our processing and we do not have overriding legitimate grounds;
- you object to our processing for direct marketing purposes;
- your personal data have been unlawfully processed; and
- your personal data must be erased to comply with a legal obligation to which we are subject.
To request deletion of your personal data, please email us at firstname.lastname@example.org.
The right to restrict processing
You have the right to restrict our processing of your personal data in the following cases:
- for a period enabling us to verify the accuracy of the personal data where you have contested the accuracy of the personal data
- your personal data have been unlawfully processed and you request restriction of processing instead of deletion;
- the personal data are no longer necessary in relation to the purposes for which they were collected and processed but the personal data are required by you to establish, exercise or defend legal claims; and
- for a period enabling us to verify whether the legitimate grounds relied on by us override your interests (where you have objected to processing based on it being necessary for the pursuit of a legitimate interest identified by us).
To restrict our processing of your personal data, please email us at email@example.com.
The right to object to processing
You have the right to object to our processing of your personal data in the following cases:
- our lawful basis for processing is that the processing is necessary for a legitimate interest pursued by us; and
- our processing for direct marketing purposes.
To object to our processing of your personal data, please email us at firstname.lastname@example.org.
Right to data portability
You have a right to receive your personal data provided to us and have the right to send the data to another organisation (or ask us to do so if technically feasible) where our lawful basis for processing the personal data is consent or necessity for the performance of our contract with you and the processing is carried out by automated means.
To exercise your right to data portability, please email us at email@example.com.
Right to withdraw consent
Where we process personal data based on consent, individuals have a right to withdraw consent at any time. We do not generally process personal data based on consent (as we can usually rely on another legal basis). Where we rely on consent for processing, to withdraw your consent please email us at firstname.lastname@example.org or, to stop receiving an email from a PwC marketing list, please click on the unsubscribe link in the relevant email received from us. Please see the 'Use of personal data' section of this privacy statement for further details about our processing of personal data based on consent.
We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to email@example.com. We will look into and respond to any complaints we receive.
You also have the right to lodge a complaint with the supervisory authority in your country of residence, place of work or the country in which an alleged infringement of data protection law has occurred within the EU. The Information Commissioner's Office ('ICO') is the UK data protection regulator/supervisory authority. For further information on your rights and how to complain to the ICO, please refer to the ICO website.