Collection of personal data

Our policy is to collect only the personal data necessary for agreed purposes and we ask our clients only to share personal data where it is strictly needed for those purposes.

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

We collect and use contact details for our clients in order to establish a legal contract between us and manage and maintain our relationship with those individuals.

In accordance with various regulatory laws and codes of practice, we are required to acquire and hold comprehensive personal data including personal financial data and source of wealth. We do not require, however, any 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) for any purpose.

We process many categories of personal data, including, but not restricted to):

• Contact details;
• Business activities and Source of Wealth;
• Investments and other financial interests.

As a norm, we collect personal data from our clients direct or from a third party acting on the instructions of the relevant client.

Use of personal data

We use personal data for the following purposes:

• Providing professional services
  We provide a range of trust, pension, company administration and life insurance products and services.
• Administering, managing and developing our businesses and services
  We process personal data in order 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;
  – hosting or facilitating the hosting of events; and
  – administering and managing our website and 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 on 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 our client and engagement acceptance, we carry out searches using publicly available sources (such as internet searches and sanctions lists) to identify politically exposed persons and heightened risk individuals and organisations and check that 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), conduct or other reputational issues).
• 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, provide insights back 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 that we receive in the course of providing professional services contains personal data, we will remove the personal data prior to using the information for these purposes.

 

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).

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 8 years.