Privacy Statement

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PwC is the brand under which the legally separate member firms of PricewaterhouseCoopers International Limited operate and provide professional services. Together, these firms form the PwC network. Please see www.pwc.com/structure for further details.

In this Privacy Statement, ‘PwC’, ‘we’ or ‘us’ refers to PricewaterhouseCoopers AG, which is a separate legal entity. The PwC network and each of the individual PwC firms are strongly committed to protecting personal data. As part of this commitment to privacy, PwC regularly reviews its data protection practices to comply with applicable laws, industry standards and best practices. 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. Please note that this Privacy Statement serves as a general overview and data subjects are informed specifically about their rights and the use of their data at the point of collection.

Personal data are any information relating to an identified or identifiable living person. PwC processes personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure and retention periods may differ for each of these purposes.

Security

Information Security is a high priority for the PricewaterhouseCoopers (PwC) network. PwC member firms are accountable to their people, clients, suppliers and other stakeholders to protect information that is entrusted to them. The PwC Information Security Policy (ISP) outlines the minimum security requirements with which every member firm must comply.

The PwC ISP has been developed to safeguard the confidentiality, integrity and availability of the information and technology assets used by the PwC member firms. The PwC ISP is aligned with the industry standard ISO/IEC 27002:2013 Information technology – Security techniques – Code of practice for information security controls.

Third parties

We shall 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.

The transfer of personal data may be possible to:

  • Other PwC member firms
    - For details of our member firm locations, please click here. 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). Our business contacts are visible to and used by PwC users from other PwC member firms to learn more about a contact, a client or an opportunity in which they have an interest.
    - In addition, PwC uses its own Service Delivery Centres (SDC), which operate within the PwC network to support other PwC firms in the administrative organisation and processing of customer orders and mandates. This includes, for example, the preparation and review of invoices, layout and design, editing, translation services and other services relating to client orders and mandates.
    - The PwC member firms have concluded an internal data protection agreement that provides for the transfer of personal data from EU/EEA countries to other companies in compliance with the EU standard contract clauses of the EU Commission. The EU standard contractual clauses are available here.
  • 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 in Switzerland and abroad. PwC shall take appropriate precautions to maintain confidentiality and to protect data.
  • Third party organisations that otherwise assist us in providing goods, services or information
  • Auditors and other professional advisers
  • Law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable laws or regulations
  • 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 laws and regulations, to investigate an alleged crime or to establish, exercise or defend legal rights. We shall only fulfil requests for personal data where we are permitted to do so in accordance with applicable laws or regulations.

Data controller and contact information

The data controller in accordance with art. 4 (7) GDPR is PricewaterhouseCoopers AG (CHE-106.839.438) and such other PwC member firms that are contracting parties for the purposes of providing or receiving services.

We have appointed a Data Protection Officer in accordance with art. 37 GDPR. If you have any questions about this Privacy Statement or about how and why we process personal data, please contact our Data Protection Officer at:

Data Protection Officer
PricewaterhouseCoopers AG
Birchstrasse 160
8050 Zurich
Email: swiss.data.privacy@ch.pwc.com
Phone: +41 (0) 58 792 00 00

Modifications to this Privacy Statement

PwC reserves the right to modify or amend this Privacy Statement at any time by publishing an updated version here. The current version of the statement shall be accessible on this website. This Privacy Statement was last updated on 30 May 2018.

Individual’s rights

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 swiss.data.privacy@ch.pwc.com. We may charge for a request for access in accordance with applicable law. We aim to respond to any requests for information promptly and, in any event, within the legally required time limit (currently 30 days).

Amendment of personal data

To update personal data submitted to us, you may email us at swiss.data.privacy@ch.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 feasible in practice, once we are informed that any personal data processed by us is no longer accurate, we shall make appropriate corrections 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 swiss.data.privacy@ch.pwc.com or, to stop receiving an email from a PwC marketing list, please click on the ‘unsubscribe’ link in the email you received from us.

Erasure/deletion of personal data

You have the right to request that PwC deletes your personal data if there is a legally relevant reason. To request the deletion of your personal data, please send an email to swiss.data.privacy@ch.pwc.com together with the reasons why you wish us to delete the data. We shall inform you of the outcome of your request.

Right to lodge a complaint with a supervisory authority

In accordance with art. 77 GDPR, you have the right of appeal to a data protection supervisory authority if you believe that the processing of your personal data violates data protection law.

Other data subject rights

As well as the rights referred to above, individuals may have other rights in relation to the personal data we hold, such as the right to restrict or object to our processing of personal data and the right to data portability. If you wish to exercise these rights, please send an email to swiss.data.privacy@ch.pwc.com.

Stakeholders

In the following sections, we take a detailed look at the stakeholder groups from which we process personal data as part of their use of this website or other internet-based channels. Please note that other stakeholders whose personal data are processed (e.g. visitors to our office premises, partners and staff, suppliers) are informed of the use of their data and all other legally required information at the point of collection. To find out more, please go to the section(s) of this Privacy Statement applicable to you.

Corporate clients (and individuals associated with our corporate clients)

We only collect the personal data necessary for agreed purposes and we ask our clients to share personal data with us only if it is necessary for those purposes. Where we need to process personal data to provide professional services, we ask our clients to provide the data subjects with the necessary information regarding its use. Our clients may use relevant sections of this Privacy Statement or refer data subjects to this Privacy Statement if they consider it appropriate to do so.

Given the diversity of the services that we provide to clients, we process many categories of personal data, including:

  • contact details;
  • business activities;
  • information about management and employees;
  • payroll and other financial- and tax-related details;
  • internal processes and procedures;
  • corporate IT systems such as SAP; and
  • investments and other financial interests.

For payroll and immigration services, and with the individual’s consent, we may also process special categories of personal data. Examples of special categories include religious beliefs, physical or mental health, sexual life or sexual orientation, excerpts from the debt register and criminal records. In such cases, the person concerned is informed about the purpose of data processing and asked for his/her consent individually.

Generally, we collect personal data from our clients or from a third party acting on the instructions of the relevant client. Only the persons performing the processing activities have access to these personal data. In this way, the data are treated as highly confidential within PwC.

Purposes of processing personal data

Initiating and fulfilling contracts

PwC processes personal data to carry out pre-contractual measures (such as preparing an offer, conducting internal pre-contractual compliance checks or creating a contract) and to provide the contractually agreed services, including the administrative execution and billing of the order. The legal basis for the processing is art. 6 (1) lit. b GDPR. In this context, the contact data are processed in particular, such as name, address, telephone number and email address.

PwC uses IT systems in which personal data are stored and managed for the processing of order enquiries and orders.

No automated decision-making or profiling is undertaken.

The length of time that personal data are retained is determined by the data processing described below for the purpose of file management, documentation and archiving.

If the data subject has not contracted PwC as a person, we usually receive the contact details from the employer, i.e. our client. In this case, the personal data shall be processed on the basis of art. 6 (1) lit. f GDPR, as there is a legitimate interest in processing. On the basis of a contract with our client, PwC is subject to an obligation to provide the service for which it is commissioned. In order to be able to provide this service, it is necessary to process the data of the contact persons and persons with responsibility at the client. This constitutes a legitimate interest of PwC in the processing of these data. Accordingly, the same applies when preparing a proposal for the provision of services.

Please note that, in accordance with PwC’s General Terms and Conditions of Business, the client is obliged to cooperate in providing PwC with all documents and information necessary for the execution of the contract. If and to the extent that the necessary information is not provided, PwC will not or only to a limited extent be able to process the client’s order and provide the agreed service.

Administering, managing and developing our businesses and services

PwC is legally obliged to keep records properly and to document its mandates and orders extensively. These files and the documentation must also be kept and stored after completion of an order or mandate for retention periods specified by law. In addition, PwC is subject to further statutory documentation and storage obligations, which are based, among other things, on tax, accounting or commercial and corporate law requirements for companies.

The documents to be recorded, the results of the work and the associated client-related correspondence also contain personal data, so that these are also part of file management and archiving.

The record keeping, documentation and archiving of client documents at PwC is performed electronically in the IT systems of PwC and, in some cases, in the form of paper files.

This processing is carried out on the basis of art. 6 (1) lit. c GDPR. With its file management, documentation and archiving, PwC fulfils the legal obligations of professional law, tax law and commercial and corporate law, among others.

Security, quality and risk management activities

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 in 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 those procedures, we carry out searches using publicly available sources (e.g. the internet and sanctions lists) to identify politically exposed persons and individuals and organisations involving heightened risk. Such searches are used to check 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 – or conduct or other reputational issues).

Providing our clients with information about us and our range of services

PwC also uses contact data (in particular, name, address, email address) to obtain customer feedback or to provide the client with information on other PwC offers, services or events.

This processing is carried out on the basis of a legitimate interest of PwC in accordance with art. 6 (1) lit. f GDPR. There is a legitimate economic interest in informing PwC's customers and clients about offers and events of our own in order to establish and maintain a long-term customer relationship.

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.

Management of business contacts

If PwC has received contact data within the framework of a business event held by PwC or others, within the framework of a business appointment (e.g. by exchanging business cards) or within the framework of an order, we also use these contact data (in particular, name, address, email address) to maintain our business contacts. For this purpose, we transfer the contact data into the customer relationship management (CRM) systems used by us.

This processing is carried out on the basis of a legitimate interest of PwC in accordance with art. 6 (1) lit. f GDPR. PwC has a legitimate economic interest in maintaining contacts established in the course of business transactions beyond the initial contact and in using them to establish a business relationship and to remain in contact with those affected for this purpose.

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, to provide insights 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 data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable laws or regulations).  

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 12 years.

Personal clients

If a natural person is a customer of PwC, other personal data are processed within the scope of order processing, insofar as this is required for the provision of the service agreed with the client. For this purpose, we shall process, in particular, bank data and payment data, as well as further information on personal, professional and financial circumstances, where applicable, insofar as these play a role in the fulfilment of the order by PwC and the client provides us with this information in accordance with the order concluded with PwC.

The processing of such personal data by PwC is carried out on the legal basis of art. 6 (1) lit. b GDPR, as the data processing is necessary for the fulfilment of the contract concluded between the client and PwC.

Given the diversity of the services that we provide to clients, we process many categories of personal data, including:

  • contact details;
  • business activities;
  • family information;
  • income and other financial related details; and
  • investments and other financial interests.

For payroll and immigration services, and with the individual’s consent, we may also process special categories of personal data. Examples of special categories include religious beliefs, physical or mental health, sexual life or sexual orientation, excerpts from the debt register and criminal records. In such cases, the person concerned is informed about the purpose of data processing and asked for his/her consent individually.

Generally, we collect personal data from our clients or from a third party acting on the instructions of the relevant client. Only the persons performing the processing activities have access to these personal data. In this way, the data are treated as highly confidential within PwC.

Purposes of processing personal data

We only collect the personal data necessary for agreed purposes and we ask our clients to share personal data with us only if it is necessary for those purposes. Where we need to process personal data to provide professional services, we ask our clients to provide the data subjects with the necessary information regarding its use.

Providing professional services

We provide a diverse range of professional services (click here for information on our services). Some of our services require us to process personal data in order to provide advice and deliverables. For example, we need to use personal data to provide individual tax advice, immigration services or pension advice.

Administering, managing and developing our businesses and services

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

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

Security, quality and risk management activities

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 in 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 those procedures, we carry out searches using publicly available sources (e.g. the internet and sanctions lists) to identify politically exposed persons and individuals and organisations involving heightened risk. Such searches are used to check 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 – or conduct or other reputational issues).

Providing our clients with information about us and our range of services

With or without consent, in accordance with applicable law, we use client contact details to provide clients information that we believe to be of interest about us and our services; for example, industry updates and insights, other services that may be relevant and invitations to events.

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.

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, to provide insights to our clients, to improve our business, service delivery and offerings and to develop new PwC technologies and offerings. To the extent that the information we receive in the course of providing professional services contains personal data, we shall de-identify the data prior to using the information for these purposes.

Data retention

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 laws or regulations).  

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 12 years.

Individuals who use our applications

We provide external users access to various applications managed by us. Such applications shall include their own Privacy Statements explaining why and how personal data are collected and processed by those applications, or in the absence of a particular Privacy Statement refer to this present Privacy Statement. We encourage individuals using our applications to refer to the Privacy Statements issued on those applications.

Event app

Some events are enabled and supported by the PwC Events and Community app (‘Event app’) developed for iOS, Android and HTML5 mobile devices to provide a superior event experience and convenient interaction between the participants and PwC. By registering for these events, you explicitly allow PwC Switzerland to upload to the Event app your basic participant information (first name, last name, company, email address). Your email address is required to log in to the Event app but it will be neither visible to nor shared with the other participants. The Event app is developed and provided by DoubleDutch, Inc. All data are securely stored in a private cloud in the UK hosted by Rackspace Ltd. and managed by DoubleDutch, Inc. The applicable data privacy policy from DoubleDutch is available at https://doubledutch.me/privacy/. By submitting your email address and clicking the checkbox above, you agree to this. Should you have any questions concerning the Event app, please contact Event App Support (eventappsupport@ch.pwc.com).

Others who get in touch with us

We collect personal data (such as name, contact details and contents of the communication) when an individual gets in touch with us with a question, complaint, comment or feedback. In these cases, the individual is in control of the personal data shared with us and we shall only use the data for the purpose of responding to the communication.

Recruitment applicants

When applying online for a position at PwC via the PwC careers website, applicants should refer to the information provided when applying for a job for details on why and how personal data are collected and processed. If you should enter in an employment relationship with us, contractual agreements will regulate our use of your personal data.

For more details about our recruitment processes, please visit our careers page.

Other visitors to our website

The data controller collecting the data provided by a visitor to this website is the PwC firm in the visitor’s country or another PwC firm to which the visitor has submitted his/her data. Personal data collected by a PwC firm may be transferred to other PwC firms in connection with the purpose for which the visitor has submitted the information. By submitting data on this website, a visitor provides explicit consent to the use of the data in accordance with this Privacy Statement, including the cross-border transmission of data collected on the website in order to fulfil the voluntarily submitted request.

Data collection

We collect only personally identifiable information provided specifically and voluntarily by visitors to this website. PwC receives limited identifiable information (such as name, title, company address, email address, telephone and fax numbers) from website visitors. Typically, identifying information is collected in order to:

  • register for certain areas of the site;
  • subscribe to updates;
  • inquire after further information;
  • distribute requested reference materials;
  • submit resumes;
  • monitor and enforce compliance with the terms and conditions for the use of our website;
  • administer and manage our website, including confirming and authenticating identity and preventing unauthorised access to restricted areas, premium content or other services limited to registered users; and
  • aggregate data for website analytics and improvements.

Although most publications are provided as downloads, visitors may also have the opportunity to purchase PwC publications online (by calling toll free numbers) or by faxing order forms to our fulfilment centres. We collect order information and a customer’s credit card information, where applicable, in order to facilitate shipment and payment of the publication.

Visitors are also able to send emails via the site. Their messages will contain the user’s screen name and email address, as well as any additional information the user may wish to include in the message. Because we use the website as a recruiting tool, a visit to the website may also result in the user sending a resume to an individual within PwC.

PwC’s intention is not to seek any sensitive information through our website unless legally required for recruiting purposes. Sensitive information includes a number of types of data relating to race or ethnic origin, political opinions, religious or other similar beliefs, trade union membership, physical or mental health, sexual life or criminal records. We suggest that you do not provide sensitive information of this nature. If you do wish to provide sensitive information for any reason, PwC assumes your explicit consent to use that information in the ways described in this Privacy Statement or as described at the point where you choose to disclose this information.

Unless we are asked not to, we may also use your data to contact you with information about PwC’s business, services and events, and other information that may be of interest to you. Should visitors subsequently choose to unsubscribe from mailing lists or revoke their registration, we provide instructions on the related webpage or in our communication to the individual, or the individual may contact us by email at swiss.data.privacy@ch.pwc.com.

Purposes of processing personal data

When a visitor provides personal information to us, we use it in connection with the purposes for which it was provided to us, as stated at the point of collection (or as obvious from the context of its collection). A user may choose to provide personal information in the context of the following, among others:

  • Ordering publications
  • Submitting resumes or work history information
  • Participating in ‘join our mailing list’ initiatives
  • Participating in bulletin boards, discussion or message forums
  • Contacting us for further information
  • Filling out quick surveys, quizzes or benchmarking surveys
  • Registering for events and conferences
  • Registering for premium online services

The data are not shared with other entities in the network for secondary or unrelated purposes, or shared with a third party other than as described in this Privacy Statement or otherwise disclosed at the point of collection. If there is an instance where such information may be shared, the visitor shall be asked for permission beforehand.

PwC makes every practical effort to avoid excessive or irrelevant collection of data. If a visitor believes the site has collected excessive information, we encourage the visitor to contact us at swiss.data.privacy@ch.pwc.com to raise any concerns.

Except for the mailing list initiative described above, where visitors explicitly choose to receive specific PwC marketing or other materials, PwC shall not use personal data collected from our websites to facilitate unsolicited marketing activities.

Cookies and log files

Cookies may be used on some pages of our site. Cookies are small text files placed on your hard drive that assist us in providing a more customised website experience. For example, a cookie can be used to store registration information in an area of the site so that a user does not need to re-enter it on subsequent visits to that area. It is PwC’s policy to use cookies to make navigation of our websites easier for visitors and to facilitate efficient registration procedures. Site statistics are compiled by third parties and therefore your IP address will be passed to third parties for statistical reporting only.

If you are concerned about cookies, most browsers permit individuals to decline them. In most cases, a visitor may refuse a cookie and still be able to navigate our websites; however, other functionality on the site may be impaired. After ending a visit to our site, users can delete the cookie from their systems if they so wish.

To manage our website properly, we may anonymously log information on our operational systems and identify categories of visitors by aspects such as domains and browser types. These statistics are reported in aggregate to our webmasters. This is to ensure that our website presents the best web experience for visitors and is an effective information resource.

Full details on the cookies used on our website can be found on the cookies information page.

Data retention

Some of the information we receive is not retained. For example, usually we do not keep mail addresses for white papers. Contact information about visitors (such as information generated though registration for access to areas on the site) shall be kept as long as the information is required to service the contact request or until a user requests that we delete that information. Mailing list information, discussion posts and emails are kept for only the period of time considered reasonable to facilitate the visitor’s requests. Resumes are disposed of when they are no longer under consideration or are considered out-of-date by our Human Capital departments.

When PwC retains personally identifiable information, PwC assumes responsibility for keeping an accurate record of the information once a visitor has submitted and verified the data. PwC does not assume responsibility for verifying the ongoing accuracy of the content of personal information. When feasible in practice, if PwC is informed that any personal data collected through a website are no longer accurate, PwC shall make appropriate corrections based on the updated information provided by the authenticated visitor.

User updates of information should be handled by going back through the registration process. Inquiries about the accuracy of identifying information previously submitted to PwC through its websites, or requests to have outdated information removed, should be directed to swiss.data.privacy@ch.pwc.com. PwC is committed to providing reasonable and practical access to visitors to allow them the opportunity to identify and correct any inaccuracies. When requested and practical, PwC shall delete identifying information from current operational systems.

Third party links

In several places, pwc.ch may link to other websites that do not operate under the privacy practices of pwc.ch. If visitors follow links to other websites, PwC’s privacy practices no longer apply. We encourage visitors to review each site’s Privacy Statement before disclosing any personally identifiable information.

Choices

As policy, visitors are not required to register to gain access to the areas of PwC websites. In certain cases, as a visitor’s PwC website experience expands, we may require in the future that a visitor register in order to obtain a user ID and password for authentication and secure access to a transaction or to certain confidential business or proprietary information services on premium websites.

Personally identifiable information provided to PwC through its websites is provided voluntarily by visitors. Should visitors subsequently choose to unsubscribe from mailing lists or revoke their registration, we provide instructions on the related webpage or in our communication to the individual, or the individual may contact us by email at swiss.data.privacy@ch.pwc.com.

Children

PwC understands the importance of protecting children’s privacy, especially in an online environment. Our website is not intentionally designed for or directed at children 16 years of age or younger. It is PwC’s practice never knowingly to collect or maintain information about anyone under the age of 16.

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