Client engagement
Client relationship management
- Purpose
- Data subject
- Categories of personal data
- Legal basis for processing
- Source
- Period of retention
- Recipients
Purpose
The purpose is to manage the engagements with our clients (including create client and job accounts, provide consultancy services, invoice and carry out quality assurance and control), administer, manage and develop our business and services, operate and maintain our IT systems and process data for statistical purposes.
Data subject
The client, its owners and contacts, if any.
Categories of personal data
PwC processes non-sensitive personal data, including names, addresses, telephone numbers and e-mail addresses of our clients and their owners, and names, job titles, telephone numbers and e-mail addresses of the clients’ contacts.
Legal basis for processing
The processing of personal data is necessary in order for us to perform the agreement with the client or implement measures at the client's request prior to the conclusion of the agreement, see Article 6(1)(b) of the General Data Protection Regulation.
Furthermore, processing is necessary in order for us to pursue our legitimate interest in managing the client cooperation, administering, managing and developing our business and services, e.g. identifying client needs and improvements in service delivery, operating and maintaining IT systems made available to or used as part of our servicing of the client, as well as hosting, administering and managing our website, systems and applications and processing data for statistical purposes, see Article 6(1)(f) of the said Regulation.
Source
The client, its owners and contacts, if any.
Period of retention
PwC retains personal data for ten years, counted from the end of the calendar year of the last job/engagement, unless special circumstances require shorter or longer periods of storage.
Contacts are deleted as soon as possible after PwC becomes aware that such contacts are no longer employed with the client.
Recipients
PwC discloses personal data to the PwC network and professional advisers, including accountants and public authorities, in the event that PwC is required to do so. Besides this, PwC does not disclose information to third parties, but we engage data processors, including IT suppliers, to whom we make personal data available. PwC enters into data processing agreements with all data processors to ensure appropriate security.
Client due diligence procedures
- Purpose
- Data subject
- Categories of personal data
- Legal basis for processing
- Source
- Period of retention
- Recipients
Purpose
The purpose is to ensure the completion of anti-money laundering procedures.
Data subject
Actual owners or daily management of the client.
Categories of personal data
PwC processes the personal data included in identity documents, such as passports or driving licences, including civil registration numbers. PwC stores copies of such documents.
Legal basis for processing
PwC is subject to the provisions of the Danish Act on Measures to Prevent Money Laundering and Financing of Terrorism (hvidvaskloven). PwC processes personal data in accordance with the customer identification procedures of the said Act, see sections 11-21, in particular section 11(1)(i), which must be performed to comply with a legal obligation to which PwC is subject, see Article 6(1)(c) and Article 87 of the General Data Protection Regulation and section 11(2)(1) of the Danish Act on the Processing of Personal Data.
Disclosure by PwC is based on the principle of legitimate interest laid down by Article 6(1)(f) of the General Data Protection Regulation, according to which disclosure is necessary to ensure that subcontractors assisting PwC in providing services comply with national anti-money laundering legislation.
In addition, the disclosure is a natural element of the ordinary operation of enterprises etc. of the type in question and the disclosure is of decisive importance for unique identification of the data subject, see Article 87 of the General Data Protection Regulation and section 11(2)(3) of the Danish Act on the Processing of Personal Data.
Source
The client, its owners or daily management.
Period of retention
PwC stores personal data for five years, counted from the end of the calendar year in which the engagement with the client terminates or the individual transaction is executed, unless special circumstances requires a longer period of storage.
Recipients
PwC may be ordered to disclose personal data to public authorities. Where a suspicion of money laundering or terrorist financing cannot be rebutted, PwC is obligated to report and pass on the information to the Danish State Prosecutor for Serious Economic and International Crime and any other supervisory authority under section 26 of the Danish Act on Measures to Prevent Money Laundering and Financing of Terrorism.
To the extent that PwC engages another PwC firm as subcontractor, PwC may disclose anti-money laundering documentation in order for such foreign PwC firm to comply with its legal obligations.
In addition, we engage data processors, including IT suppliers, to whom we make personal data available. PwC enters into data processing agreements with all data processors to ensure appropriate security.
