PwC's privacy commitment

PwC Gibraltar Website Privacy Commitment/Privacy Statement

Introduction

PwC Gibraltar is strongly committed to protecting personal data.  This privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights.  It applies to personal data provided to us, both by individuals themselves or by others.  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.

“PwC Gibraltar” (and “we, “us”, or “our”) refers to PricewaterhouseCoopers Limited, the limited liability company registered in Gibraltar with registration number 94799 and principal place of business and registration address at 327 Main Street, Gibraltar, GX11 1AA that: (1) is a contracting party for the purposes of providing or receiving services, (2) posted a position for which you are applying, or (3) you have a role or relationship with. Each member firm in the PWC network is a separate legal entity and a separate controller for personal data. For further details, please see www.pwc.com/structure.

Personal data is any information relating to an identified or identifiable living person.  When “you” or “your” are used in this statement, we are referring to the relevant individual who is the subject of the personal data. PwC Gibraltar processes personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose may differ.

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, please go to the relevant sections of this statement.

 

Security

We take the security of all the data we hold very seriously.  We adhere to internationally recognised security standards and 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.

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 are part of a global network of firms and in common with other professional service providers, we use third parties located in other countries to help us run our business.  As a result, personal data may be transferred outside of Gibraltar. We will do so only where we have a lawful basis, for example to recipients: (i) in countries which provide an adequate level of protection for personal data; or (ii) if adequacy is not available, under agreements which meet Gibraltar and / or European Commission requirements for those transfers, as appropriate. 

Personal data held by us may be transferred to:

·        Other PwC member firms

Details of our 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) and to develop new PwC technologies and services across the PwC network of member firms. 

We may store personal data on other PwC member firm servers in the EU and the USA.

 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 the Business contacts section of this privacy statement for more information about our processing of this type of data).

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

We use third parties to support us in providing our services and to help provide, run and manage our internal IT systems.  For example, providers of information technology, cloud based software as a service providers, identity management, website hosting and management, data analysis, data back-up, security and storage services.  The servers  are located in secure data centres around the world, and personal data may be stored in any one of them. Further details of these providers are set out below.

Name

Role

Address

Adobe Inc

Document and Video Management including Frame.io

345 Park Avenue San Jose, CA 95110-2704

Digital Guardian Inc.

Endpoint USB blocking and data leakage prevention

860 Winter Street, Suite 3, Waltham, MA 02451 USA

Microsoft Limited

Azure cloud services and software applications

Microsoft Campus, Thames Valley Park, Reading, RG6 1WG, UK

Salesforce

Customer relationship management system

Salesforce.com EMEA, Village 9, Floor 26 Salesforce Tower, 110 Bishopsgate, London, EC2N 4AY, UK

ServiceNow

Risk and process management system

2225 Lawson Lane, Santa Clara, CA, 95054

Onesys

Sage Coretime business application, online timesheet and project management software 

Systems House, Main Street, Little Ouseburn, York, YO26 9TD

EasyPay

Payroll and HR business application

Rock IT Limited,

World Trade Center, Unit 1.02,

6 Bayside Road,

Gibraltar GX11 1AA

DocuSign

Electronic signature software

100 Liverpool St

London

EC2M 2RH

United Kingdom

+44 203 714 4800

DataSnipper

Intelligent Audit Platform within Excel

Weteringschans 94, 1017 XS Amsterdam, Netherlands

Alteryx

Analytics Automation Platform

186 City Road, London, Greater London EC1V 2NT, GB

Gibtelecom

Telecommunications provider

15/21 John Mackintosh Square, Gibraltar, GX11 1AA

Google Ireland Limited

Business applications (such as email, virtual meetings, documents and calendar)

Gordon House, Barrow Street, Dublin 4, Dublin, D04 E5W5

Data centres located in a number of locations around the world (EU, Chile, Singapore, Taiwan, USA)

GibFibre

Internet and TV Services

Unit 5 Waterport Terraces Gibraltar, N Mole Rd, Gibraltar GX11 1AA

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

On certain client engagements, we may engage or otherwise work with other providers to help us provide professional services to our clients.

·        Insurers and other professional advisers

We have a number of business insurance policies in place and we may need to share personal data with the insurer, for example, in the event of a claim. We use other professional advisers, for example, law firms, as necessary to establish, exercise or defend legal claims 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 products and services they have been engaged to provide to us.

·        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 fulfill requests for personal data where we are permitted to do so in accordance with applicable law or regulation.

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 4 May 2023.

Data controller and contact information

The data controller is PwC Gibraltar and such other PwC member firm that is a contracting party for the purposes of providing or receiving services.

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

Data Protection Officer
PwC Gibraltar
327 Main Street
Gibraltar
GX11 1AA

Email: gi_data.protection@pwc.com
Phone: +350 20073520

Individuals’ rights and how to exercise them

Individuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights.  Where we decide how and why personal data is processed, we are a data controller and include further information about the rights that individuals have and how to exercise them below.

Access to personal data

You have a right of access to personal data held by us as a data controller.  This right may be exercised by emailing us at gi_data.protection@pwc.com. We may charge for a request for access in accordance with applicable law.  We will aim to respond to any requests for information promptly, and in any event within the legally required time limits.

Amendment of personal data

To update personal data submitted to us, you may email us at gi_data.protection@pwc.com or, where appropriate, contact us via the relevant website registration page or by amending the personal details held on relevant applications with which you registered.

When practically possible, once we are informed that any personal data processed by us is no longer accurate, we will make corrections (where appropriate) based on your updated information.

Withdrawal of 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).  To withdraw consent to our processing of your personal data please email us at gi_data.protection@pwc.com, to stop receiving an email from a PwC marketing list please click on the unsubscribe link in the relevant email received from us.

Other data subject rights

This privacy statement is intended to provide information about what personal data we collect about you and how it is used.  As well as rights of access and amendment referred to above, individuals may have other rights in relation to the personal data we hold, such as a right to erasure/deletion, to restrict or object to our processing of personal data and the right to data portability.

If you wish to exercise any of these rights, please send an email to gi_data.protection@pwc.com.

Complaints

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 gi_data.protection@pwc.com. We will look into and respond to any complaints we receive. You also have the right to lodge a complaint with the Gibraltar Regulatory Authority (“GRA”) (the Gibraltar data protection regulator).

 

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