Business contacts 

Collection​ ​of​ ​personal​ data 

PwC processes personal data about contacts (existing and potential PwC clients and/or individuals associated with them) using a customer relationship management system (the “PwC CRM”). 

The collection of personal data about contacts and the addition of that personal data to the PwC CRM is initiated by a PwC user and will include name, employer name, contact title, phone, email and other business contact details. In addition, the PwC CRM collects data from PwC’s email (sender name, recipient name, date and time) and calendar (organiser name, participant name, date and time of event) systems concerning interactions between PwC users and contacts or third parties. 

Use​ ​of​ ​personal​ data 

Personal data relating to business contacts is visible to and used by authorised PwC users to learn more about an account, client or opportunity they have an interest in. The personal data in this case is generally processed on the basis of Article 6 (1)(f) GDPR, as there is a legitimate interest for us in: 

• Administering, managing and developing our businesses and services. 

• Providing information about us and our range of services. 

• Making contact information available to PwC users. 

• Identifying clients/contacts with similar needs. 

• Describing the nature of a contact’s relationship with PwC. 

Performing analytics, including producing metrics for PwC leadership, such as on trends, relationship maps, sales intelligence and progress against account business goals. 

PwC member firms do not sell or otherwise release personal data contained in the PwC CRM to third parties for the purpose of allowing them to market their products and services without consent from the data subjects themselves to do so. 

Data retention 

Personal data will be retained on the PwC CRM for as long as it is necessary for the purposes set out above (i.e. for as long as we have, or need to keep a record of, a relationship with a business contact). 

Personal clients 

Collection of personal data 

PwC also provides professional services to natural persons, i.e. personal clients. As a result of the services that PwC provides, we process several categories of personal data, including as appropriate for the services we are providing: 

• Name and surname; 

• Contact details; 

• Website log-in details; 

• Billing information; 

• Course details (including but not limited to attendance and certificates); 

• Ancillary documentation related to the course (including but not limited to booking sheets and Get Qualified declarations). 

• Audiovisual data (recorded learning sessions) 

For specific services or activities, generally with an individual’s consent on the basis of Article 9 (2)(a) of the GDPR, we will also collect special categories of personal data. Examples of special categories include race or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; physical or mental health; genetic data; biometric data; sexual life or sexual orientation.  

Use of personal data 

We use personal data for the following purposes:  

 (1) Providing professional services  

We provide a range of professional services including but not limited to training, learning consulting and LMS services. Some of our services require us to process personal data in order to deliver the relevant services. For example, we need to use personal data to be able to enroll, collect payment for, and manage an individual’s participation in a particular course offered by PwC. We also use audiovisual recordings of training sessions which may capture a student’s image, voice, name, and interactions during the session, for the purposes of delivering the purchased course package, including enabling students to access recorded lectures on demand, supporting learning continuity, quality assurance, and academic administration. In such instances, the personal data is typically processed on the basis of Article 6 (1)(b) of the GDPR, as we have a contractual agreement (the terms of business) with the personal client. Inversely, such personal data is processed on the basis of Article 6(1)(f) of the GDPR, as we have a legitimate interest in delivering and maintaining high-quality training services, including providing the learning materials to students on demand.

To the extent that the necessary information is not provided, PwC will not be able to provide the agreed service. 

(2) Administering, managing and developing our businesses and services 

We may further process personal data on the basis of Article 6 (1)(f) of the GDPR, as there is a legitimate interest for us to run our business, including: 

• Managing our relationship with clients. 

• Developing our businesses and services (such as identifying client needs and improvements in service delivery). 

• Maintaining and using IT systems. 

• Providing our clients with information about us and our range of services (for example, industry updates and insights, invites to events). 

• Hosting or facilitating the hosting of events. 

• Recording of lectures and other educational sessions / events for the purposes of supporting learning continuity, quality assurance, and academic administration.

• Managing our security, quality and risk management activities (such as doing automated scans to identify harmful emails, and carrying out searches using publicly available sources to identify heightened risk individuals and organisations). 

• Administering and managing our website and systems and applications. 

(3) 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 may be required by applicable laws and regulations to keep certain records to demonstrate that our services are provided in compliance with those obligations. Such personal data is generally processed on the basis of Article 6 (1)(c) of the GDPR as PwC is subject to the above-mentioned statutory obligations. 

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 law or regulation).

Student academic records will be archived and kept readily available for 40 years from completion of the relevant course or part thereof. Audiovisual recordings will be retained for the duration of the course availability plus six (6) months following the conclusion of the relevant course cycle, or until the course content is materially updated or retired, whichever is earlier, unless a longer retention period is required for quality assurance, regulatory compliance, or dispute resolution purposes. In the absence of specific legal, regulatory or contractual requirements, however, our baseline retention period for records and other documentary evidence created in the provision of services is 10 years.

Individuals whose personal data we obtain in connection with providing services to our clients 

Collection of personal data 

Where we need to process personal data to provide our services, we ask our clients to provide the necessary information to the data subjects concerned regarding its use. 

We collect and use contact details of data subjects in order to perform our services, and to manage and maintain our relationship with our client. Please see the ‘Business contacts’ section of this privacy statement for more information about our processing of this type of data. 

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

• Name and surname. 

• Contact details. 

• Website log-in details. 

• Billing information. 

• Course details (including but not limited to attendance and certificates). 

Use of personal data 

We use personal data for the following purposes: 

(1)   Providing professional services 

We provide a range of professional services including but not limited to training, consulting and LMS services. Some of our services require us to process personal data in order to deliver the relevant services. For example, we need to use personal data to be able to enroll and manage an individual’s participation in a particular course offered by PwC. As stated above, we receive your personal data from our client or from a relevant third-party. In this case, the personal data shall generally be processed on the basis of Article 6 (1)(f) of the GDPR, as there is a legitimate interest for PwC to provide the service commissioned in the terms of business with our client. To the extent that the necessary information is not provided, PwC will not be able to provide the agreed service. 

(2)   Administering, managing and developing our businesses and services 

We may further process personal data on the basis of Article 6 (1)(f) of the GDPR, as there is a legitimate interest for PwC to run its business, including: 

• Managing our relationship with clients. 

• Developing our businesses and services (such as identifying client needs and improvements in service delivery). 

• Maintaining and using IT systems. 

• Hosting or facilitating the hosting of events. 

• Managing our security, quality and risk management activities (such as doing automated scans to identify harmful emails, and carrying out searches using publicly available sources to identify heightened risk individuals and organisations). 

• Administering and managing our website and systems and applications. 

(3)   Complying with any requirement of law, regulation, judicial decision or a professional body of which we are a member 

As with any provider of professional services, we may be required by applicable laws and regulations to keep certain records to demonstrate that our services are provided in compliance with those obligations. Such personal data is generally processed on the basis of Article 6 (1)(c) of the GDPR as PwC is subject to the above-mentioned statutory obligations. 

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 law or regulation).  

Student academic records will be archived and kept readily available for 40 years from completion of the relevant course or part thereof. In the absence of specific legal, regulatory or contractual requirements, however, our baseline retention period for records and other documentary evidence created in the provision of services is 10 years. 

Others who get in touch with us 

We collect personal data when an individual gets in touch with us with a question, complaint, comment or feedback (such as name, contact details and contents of the communication). In these cases, the individual is in control of the personal data shared with us and we will only use the data for the purpose of responding to the communication, unless instructed otherwise by the said individual. The processing of personal data in this instance is generally carried out on the basis of Article 6 (1)(f) of the GDPR, as we have a legitimate interest in responding to the individual. 

Principals and staff 

We collect personal data concerning our own personnel as part of the operations, administration, management and promotion of our activities. Principals and staff should refer to the Staff Handbook of PricewaterhouseCoopers Malta (“PwC Malta”) for information on why and how personal data is collected and processed. 

Suppliers (including subcontractors and individuals associated with our suppliers and subcontractors) 

Collection​ ​of​ ​personal​ data 

We collect and process personal data about our suppliers (including subcontractors and individuals associated with our suppliers and subcontractors) in order to manage the relationship, to contract, to receive services from our suppliers and, where relevant, to provide professional services to our clients. In the context of delivering training services, PwC may collect or otherwise process audiovisual data relating to lecturers, trainers or subject matter experts, including video and audio recordings of training sessions. Such recordings may include data such as the image, voice, name and interactions of the concerned individual.  

Use​ ​of​ ​personal​ data 

We use personal data for the following purposes: 

(1) Receiving services 

We process personal data in relation to our suppliers and their staff as necessary to receive the services. For example, where a supplier is providing us with facilities management or other outsourced services, we will process personal data about those individuals that are providing services to us. Personal data in this instance is typically processed on the basis of Article 6 (1)(f) of the GDPR, as there is a legitimate interest for PwC to manage the related risk and quality of the services received.  

(2) Providing professional services to clients 

Where a supplier is helping us to deliver professional services to our clients, we generally process personal data about the individuals involved in providing the services on the basis of Article 6 (1)(f) of the GDPR, as we have a legitimate interest to administer and manage our relationship with the supplier and the relevant individuals and to provide such services to our clients (for example, where our supplier is providing people to work with us as part of a PwC team providing professional services to our clients). For example, the processing of audiovisual data is carried out for the purposes of delivering, administering and improving training courses, including making recorded sessions available to enrolled students, on the basis of Article 6(1)(f) of the GDPR, as PwC has a legitimate interest in delivering and maintaining high quality training services, subject to appropriate safeguards. 

(3) Administering, managing and developing our businesses and services 

We may further process personal data on the basis of Article 6 (1)(f) of the GDPR, as PwC has a legitimate interest to run its business, including: 

• Managing our relationship with suppliers. 

• Developing our businesses and services (such as identifying client needs and improvements in service delivery). 

• Maintaining and using IT systems. 

• Providing information about us and our range of services (for example, industry updates and insights, invites to events). 

• Hosting or facilitating the hosting of events. 

• Managing our security, quality and risk management activities in relation to suppliers (such as doing automated scans to identify harmful emails, and carrying out searches using publicly available sources to identify heightened risk individuals and organisations). 

• Administering and managing our website and systems and applications. 

(4) 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 may be required by applicable laws and regulations to keep certain records to demonstrate that our services are provided in compliance with those obligations. Such personal data is generally processed on the basis of Article 6 (1)(c) of the GDPR as PwC is subject to the above-mentioned statutory obligations.   

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 law or regulation).

Audiovisual recordings will be retained for the duration of the course availability plus six (6) months following the conclusion of the relevant course cycle, or until the course content is materially updated or retired, whichever is earlier, unless a longer retention period is required for quality assurance, regulatory compliance, or dispute resolution purposes. 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 10 years.

Visitors to our offices 

Visitors in this section refer to any person other than Partners and staff which are physically present on our premises, including attendees of events hosted by us. 

We have security measures in place at our offices, including CCTV and building access controls. Security measures and all personal data collected in the exercise thereof are controlled and retained by PwC Malta.  

There are signs in our office showing that CCTV is in operation. The images captured are securely stored and only accessed on a need-to-know basis (e.g. to look into an incident). CCTV recordings are typically automatically overwritten after 90 days unless an issue is identified that requires investigation (such as a theft). PwC Malta generally processes CCTV footage on the basis of Article 6 (1)(f) of the GDPR, since we have a legitimate interest to protect the property against burglary, theft or vandalism and to prevent and detect any unlawful conduct. We or PwC Malta do not share CCTV footage with any third party to the exception of law enforcement authorities in the course of official investigations. Please refer to the PwC Malta Privacy Statement for more information. 

Visitors to our website 

Collection of personal data 

Visitors to our websites are generally in control of the personal data shared with us. We may capture limited personal data automatically via the use of cookies on our website. Please see the section on Cookies below for more information. 

We receive personal data, such as first and last name, job title, email address, and telephone number, from website visitors; for example when an individual subscribes to updates from us. Visitors are also able to send an email to us through the website. Please refer to our Subscribers section for more information on the applicable purposes and legal bases. 

We ask that you do not provide sensitive information (such as race or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; physical or mental health; genetic data; biometric data; sexual life or sexual orientation; and, criminal records) to us when using our website; if you choose to provide sensitive information to us for any reason, the act of doing so shall constitute your explicit consent for us to collect and use that information in the ways described in this privacy statement or as described at the point where you choose to disclose this information. 

Cookies 

We use small text files called ‘cookies’ which are placed on your hard drives to assist in personalising and enriching your browsing experience by displaying content that is more likely to be relevant and of interest to you. The use of cookies is now standard operating procedure for most websites. However, if you are uncomfortable with the use of cookies, most browsers now permit users to opt-out of receiving them. You need to accept cookies in order to register on our website. You may find other functionality in the website impaired if you disable cookies. After termination of the visit to our site, you can always delete the cookie from your system if you wish. For further information on how we use cookies, we encourage you to access PwC’s Cookie Policy. 

Use of personal data 

When a visitor provides personal data to us, we will use it for the purposes for which it was provided to us as stated at point of collection (or as obvious from the context of the collection). Typically, personal data is collected for the below purposes on the basis of Article 6 (1)(f) of the GDPR, as we have a legitimate interest to run our business: 

• Register for certain areas of the site. 

• Subscribe to updates. 

• Enquire for further information. 

• Distribute requested reference materials. 

• Monitor and enforce compliance with our terms and conditions for 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. 

• Aggregate data for website analytics and improvements.

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 which may be of interest to you.  Should visitors subsequently choose to unsubscribe from mailing lists or any registrations, we will provide instructions on the appropriate webpage, in our communication to the individual, or the individual may contact us by email to mt_privacy@pwc.com. 

Our website does not collect or compile personal data for the dissemination or sale to outside parties for consumer marketing purposes or host mailings on behalf of third parties. If there is an instance where such information may be shared with a party that is not a PwC member firm, the visitor will be asked for their consent beforehand. 

Data retention 

Personal data collected via our websites will be retained by us for as long as it is necessary (e.g. for as long as we have a relationship with the relevant individual) and as outlined in our Cookie Policy.  

Subscribers of our newsletters and other marketing materials 

Collection of personal data 

We collect personal data, such as first and last name, job title, company name, contact number and email address for the purpose of adding you to our subscription list.  

The collection of personal data for these purposes is generally on the basis of Article 6 (1)(a) of the GDPR, that is, upon collection of your lawful consent, and Article 6 (1)(f) of the GDPR, in cases where we have an existing relationship with you and we think that certain communications might be of interest to you. 

You have the right to withdraw your consent at any time by emailing us at mt_privacy@pwc.com or, to stop receiving an email from a PwC marketing list, please click on the unsubscribe link in the relevant email received from us. 

Use of personal data 

We process personal data in the context of our marketing campaigns for the following purposes: 

• Sending alerts and updates concerning PwC’s products and services. 

• Sending newsletters, thought leadership, and other PwC publications which might be of interest to you. 

• Sending of notifications related to events organised by PwC and invitations to such events. 

• Offering PwC’s products and services. 

 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 legislation). 

In the absence of specific legal, regulatory or contractual requirements, however, our baseline retention period for records and other documentary evidence created in the provision of services is 10 years. 

Security 

Security remains a high priority for PwC, and we remain accountable to our clients, suppliers, visitors and other stakeholders and the information we are entrusted with. 

Our offices make use of security measures including CCTV surveillance and building access controls, generally on the basis of Article 6(1)(f) of the GDPR, as PwC has a legitimate interest to protect the property against burglary, theft or vandalism and to prevent and detect any unlawful conduct whilst also safeguarding our employees and visitors to our offices. There are signs throughout our premises showing that CCTV is in operation whereby PwC Malta acts as the exclusive controller of the data collected. The images captured are securely stored and only accessed internally on a need to know basis (e.g. to look into an incident). CCTV recordings are typically automatically overwritten after 90 days unless an issue is identified that requires investigation (such as a theft). In such an event, we may be required to process and transfer the data collected in order to cooperate with law enforcement authorities whether local or foreign, as the case may be. 

Furthermore, all personal data is processed in accordance with PwC Malta’s internal information security procedures, which provide a baseline security level for all PwC firms.  All PwC staff who process personal data are required to follow the provisions of such procedures and are bound by confidentiality obligations. Various technical and organisational measures are set out throughout PwC, including the use of data loss prevention, web filtering, transport layer security, incident response procedures and full disk encryption. For more information, please refer to the PwC Global Information Security Statement. 

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 the countries where we and our clients are located. This includes countries outside the European Union (“EU”) and European Economic Area (“EEA”) and to countries that do not have laws that provide specific protection for personal data. We have taken steps to ensure all personal data is provided with adequate protection and that all transfers of personal data outside the EU are done lawfully in such a manner that the same level of protection provided to personal data under the GDPR is ascertained. Where we transfer personal data outside of the EU to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the EU requirements for the transfer of personal data outside the EU, such as the European Commission approved standard contractual clauses. The European Commission approved standard contractual clauses are available here. 

Personal data held by us may be transferred to: 

Third party accredited academic bodies. We may share your personal data with third parties whose courses we either resell or otherwise assist or support the delivery thereof to you, including but not limited to the National Commission for Further and Higher Education (NCFHE). These third parties are carefully selected and are required to comply with applicable data protection laws to ensure your data is handled securely and responsibly. 

• 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 powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them

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

• Auditors and other professional advisors 

• Third parties as described above under a written contract which imposes obligations consistent with those contained herein

• 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.

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 mt_privacy@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 (currently one month which may be extended to two months). We shall inform you of any such extension within one month of receipt of the request, together with the reasons for the delay.

Amendment of personal data 

To update personal data submitted to us, you may email us at mt_privacy@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 mt_privacy@pwc.com or, 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 mt_privacy@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 mt_privacy@pwc.com. We will look into and respond to any complaints we receive.

You also have the right to lodge a complaint with the Office of the Information and Data Protection Commissioner (the Malta data protection supervisory authority).