1. Introduction

The PricewaterhouseCoopers Survey site (the “Site”) is designed by PricewaterhouseCoopers LLP, the limited liability partnership registered in England under registration no. OC303525 and with its registered address at 1 Embankment Place, London WC2N 6RH, (“PwC”, “us”, “our”, or “we”) for the conduct of surveys on behalf of our clients.

PwC will, generally, process any personal data provided in response to the Survey as a controller.

Where agreed with our client, we may de-identify and use information that we receive for other lawful purposes, including analysis to better understand a particular issue, industry or sector, provide insights back to our clients, to improve our business, service delivery and offerings and to develop new PwC technologies and offerings. PwC is a controller when de-identifying personal data for these purposes.

PwC is fully committed to keeping survey information private and secure. This privacy statement has been developed to help survey participants understand what information PwC will collect and how it will be used and provides information about individuals’ rights.

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.

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

Data Protection Officer
PricewaterhouseCoopers LLP
1 Embankment Place
London
WC2N 6RH

 
2. Security

We take the security of all the data we hold very seriously. We adhere to internationally recognised security standards and our information security management system relating to client confidential data is independently certified as complying with the requirements of ISO/IEC 27001: 2013. The Site uses secure socket layer (SSL) technology to encrypt survey responses submitted through the Site. 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.
 
The Site requires site administrators and certain users to maintain both a user ID and password. It is the responsibility of the relevant user and site administrator to protect the password and not share it with others, including co-workers. Please contact your PwC Research support contact (as stated in the survey or survey invite) immediately if your user ID and/or password are compromised.

3. Collection of data
 
Personal data is any information relating to an identified or identifiable living person. Survey participants are generally in control of the data shared with us.
 
We may capture limited data automatically as follows:
  • "Cookies" are small text files placed on your hard drive that assist us in providing a better Site. The Site uses cookies to store information for anonymous/generic link surveys only and further information about any cookies we use is provided in the cookie policy at the start of the survey. The Site does not use any third party cookies or web beacons.
  • Information about the device used to complete the survey (IP address and domain), browser and operating system. This data is collected and aggregated in order to properly manage the Site and identify categories of visitors by items such as domains and browser types. These statistics are reported in the aggregate to our PwC webmasters. This is to ensure that the Site presents the best web experience for you and is an effective resource.

We may obtain limited personal data (such as your name and contact details) from our client.

All other personal data is voluntarily provided by survey participants in response to the survey questions, including the survey participant’s contact details and answers to the survey questions on the Site. The information that survey participants provide in response to the survey questions will be treated in the strictest confidence.

4. Use of data

Data submitted through the Site will only be used for the purpose of the relevant survey and, where agreed with our clients, for other lawful purposes once de-identified.

Typically, personal data may be used for the following legitimate interests:

  • To carry out research using a survey (as engaged by our client)
  • To analyse and compile the survey responses to produce aggregate data on the survey results.
  • To create a report with the aggregated results of the survey and publish or share the report with our client.  The report will not contain data that is attributable to any individual person. 
  • To monitor the performance of the Site and collect activity statistics in aggregate in relation to the Site to assist in maintaining the performance of the Site and to help enhance operating effectiveness. 
  • To aggregate survey results from a number of surveys to produce overall statistics and benchmarks. This information will not be correlated with data about individuals and it will not be possible to identify any individual from the aggregated and anonymised results.
  • To validate the contact details of the participant for future contact.
  • To store on online dashboards built for the purposes of sharing data with PwC teams or client teams in relation to the surveys we conduct and authorise access to such data using PwC’s identity and access management system.
5. Data Retention

Survey data is kept for as long as the information is required to operate the relevant survey for the client organisation and to provide the full scope of the services required by the client organisation. Any personal details/contact lists (such as name or e-mail address) provided for the relevant survey will be deleted after a period of 12 months.
 
6. 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 to countries outside the European Union 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. 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:

  • 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).
    Where we use PwC’s identity and access management system to authorise users to access data via an online dashboard, depending on the user’s location, the user will be authenticated by a data centre in the EU, Hong Kong or the USA.
  • 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. After completing a survey, you may be linked to a website provided by one of our third party suppliers. 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. The hosting of the Site is provided by an outsourced third party web hosting organisation under our direction and control and the personal data is hosted in the EU and if requested by our client, in the USA.

    The hosting of the Site is provided by an outsourced third party web hosting organisation, under our direction and control and subject to all appropriate technical and organisational security requirements.
  • Third party organisations that otherwise assist us in providing goods, services or information
    We use third parties to support us in providing our services such as Focus Groups, Online Panel Providers and Field agencies. For example, recruiting individuals on behalf of PwC for focus groups/depth interviews, field data collection and online panel access. All Third parties have been reviewed and approved by PwC in providing goods, services and information.
  • 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.
7. Individuals’ rights and how to exercise them

Individuals have certain rights over their personal data and controllers are responsible for fulfilling these rights.

Individuals’ rights may include 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, when they are available and how to exercise them below.

Your right of access to personal data
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 controller and obtain certain other information about how and why we process your personal data (similar to the information provided in this privacy statement). This right may be exercised by emailing us at data.protection.office@uk.pwc.com. We aim to respond to any requests for information promptly, and in any event within the legally required time limits.

Your right to rectification / amendment of personal data

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, you may email us at data.protection.office@uk.pwc.com or, where appropriate, contact us via the relevant website registration page or directly amend the personal details held on relevant websites or 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 updates as appropriate based on your updated information.

Your 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 legal grounds for processing is consent, you withdraw consent and we have no other lawful basis for the processing;
  • our legal grounds for processing is that the processing is necessary for legitimate interests pursued by us or a third party, 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; or
  • 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 data.protection.office@uk.pwc.com.

Your 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 your 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;
  • your 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; or
  • 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 data.protection.office@uk.pwc.com.
 
Your right to object to processing
You have the right to object to our processing of your personal data in the following cases:
  • our legal grounds for processing is that the processing is necessary for a legitimate interest pursued by us or a third party; or
  • our processing is for direct marketing purposes.
To object to our processing of your personal data, please email us at data.protection.office@uk.pwc.com.
 
Your right to data portability
You have a right to receive your personal data provided by you 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 data.protection.office@uk.pwc.com.
 
Your 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 your consent for our processing of your personal data, to withdraw your consent please email us at data.protection.office@uk.pwc.com or, to stop receiving an email from a PwC marketing list, please click on the unsubscribe link in the relevant email. Please see the relevant “Use of personal data” sections of this privacy statement for further details about our processing of personal data based on consent.

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 data.protection.office@uk.pwc.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.
 
8. Changes to this privacy statement

We recognise that transparency is an ongoing responsibility so we will keep this privacy statement under regular review. No change will compromise the privacy or security of any Survey information.

This privacy statement was last updated on 30 July 2018.
If you have any technical questions or concerns, please contact via e-mail: elaine.m.mcginty@uk.pwc.com
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