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Online Privacy Statement

PwC Luxembourg is the largest professional services firm in Luxembourg. It strives to build trust in providing audit, tax and advisory services in ways that protect privacy of its clients, people, and others with whom it does business through the design of its products and robust information security safeguards. PwC Luxembourg aspires to promote transparency through education initiatives, privacy principles and guidelines, and appropriate opportunities for choice, access, and correction with respect to personal data of the data subjects.

This privacy statement defines how PwC Luxembourg, acting as data controller, may process information relating to identified or identifiable natural candidate (called “data subjects”) collected from time to time (directly or indirectly, on a compulsory or voluntary manner, manually or otherwise) from the data subjects themselves as well as from third parties and/or from publicly available sources where applicable.

Why does PwC Luxembourg process personal data?

PwC Luxembourg may process personal data for the following purposes:

  • To monitore its recruitment process, including assessment and vetting, potential contact and job offer issuance (for PwC Luxembourg or for one of its clients), organisation of meetings and drafting of employment contract…;
  • To organise events, including workshops and reporting and statistics;
  • To provide the data subjects with information about PwC Luxembourg and its range of services;
  • To facilitate compliance with its legal, regulatory, professional and/or contractual obligations;
  • To maintain and protect its buildings, equipment, IT infrastructure and data (including access management and authentification, security and performance monitoring…);
  • To manage risks and litigations;
  • To process the data subjects’ requests; and/or
  • To manage its websites.

The purposes above are based on at least one of the following legal basis:

  • the processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
  • the processing is necessary for compliance with a legal obligation to which PwC Luxembourg is subject;
  • the processing is necessary for the purposes of the legitimate interests pursued by PwC Luxembourg or by a third party (such as the protection of PwC Luxembourg asset, the understanding of its clients’s needs and expectations or the fulfillment of the PwC Luxembourg’s purpose or social interest). Especially, PricewaterhouseCoopers, in its quality of “expert comptable” and “cabinet de révision agréé”, has the duty to demonstrate its professional ethic, integrity, objectivity, competence, due care and professional independence. In this context, and to the extent legally permitted, PwC Luxembourg emphases the fact that it carries out legitimate verifications regarding candidates. Such background checks may cover reputational vetting, consistency of the curriculum vitae, relevance of professional expertise (including by cpntacting the former employer), confirmation of academic and professional qualifications… and may also include the consideration of criminal records; and/or
  • the data subject has given consent to the processing for one or more specific purposes.

What personal data does PwC Luxembourg process?

Depending on, and when necessary for, the purposes above, PwC Luxembourg may process the following categories of personal data:

  • Identification data (e.g. name, surname, alias…);
  • Professional data (e.g. position, company…);
  • Administrative data (e.g. identity documents, birthdate, gender, language …);
  • Relational data (e.g. relation history, attendance sheets…);
  • Environmental data (e.g. characteristics, habits, social media information…);
  • Financial data (e.g. tax data, transactional data...);
  • Numeric data (e.g. logs, IP address…); and
  • Biometric data (e.g. picture, sound, video…).

In the initial stages of the recruitment process, PwC Luxembourg does not plan to collect specific categories of personal data such as racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data or criminal records. Therefore, each candidate is invited to avoid providing PwC Luxembourg with such categories of information to support his/her application. Should the candidate do so this will constitute a formal consent on his/her incidental processing under the conditions set in this Privacy Statement.

Does PwC Luxembourg share personal data to third parties?

Depending on the purposes above, and besides the data subjects themselves, PwC Luxembourg may share the personal data to the following categories of recipients:

  • subcontractors, business partners and experts;
  • clients and potentials clients;
  • processors and sub-processors such as IT suppliers (including systems administrators, cloud services providers, hosting providers, etc…);
  • other PwC entities;
  • PwC Luxembourg’s external counsels, agents or auditors;
  • entities or individuals that have a relationship with the data subjects (employers, relatives, counsels, business or potential business partners, etc…); and/or
  • supervisory bodies or public authorities.

Does PwC Luxembourg transfer personal data outside the European Union?

PwC Luxembourg shall not transfer any personal data outside the European Union otherwise that:

  • to countries which provide an adequate level of protection for personal data as decided by the European Commission or;
  • to recipients under a suitable agreement which contains the legal requirements for such transfer. Copy of the applicable safeguards may be requested to the Data Protection Officer of PwC Luxembourg.

How long does PwC Luxembourg keep the personal data?

The personal data will be kept in a form which permits identification of the data subjects for no longer than is necessary for each purpose for which they have been collected, without prejudice to automatic IT back-ups and PwC Luxembourg’s legal and regulatory archiving obligations.

What are your rights and obligation as data subject?

By applying, you:

  • confirm that the information provided is true and accurate;
  • acknowledge that any misrepresentation, omission of any required field or false statement may be cause for rejection of your application or later dismissal; and
  • clearly understand all aspects of the processing of your personal data as specified in this Privacy Statement and on the background checks as defined above.

To the extent permitted by the laws, you may have the right, to:

  • request access to and rectification or the erasure of your personal data or restriction of processing;
  • object the processing of your personal data; as well as
  • data portability.

Should the processing be exclusively based on your consent, you shall have the right to withdraw it at any time, without affecting the lawfulness of the processing based on your consent before such withdrawal.
To exercise the rights listed above, you are invited to send an email demonstrating your identity and specifying the right you want to exercise to the Data Protection Office of PwC Luxembourg.
Please note that you shall also have the right to lodge a complaint with the competent supervisory authority, the lead supervisory authority competent for personal data processed by PwC Luxembourg being the Commission Nationale de Protection des Données (CNPD).

Who are the data controllers?

For the purpose of this notice PwC Luxembourg means PricewaterhouseCoopers on its behalf and on the behalf of PwC Tax Information Reporting, PricewaterhouseCoopers Training Administration Service Centre and PricewaterhouseCoopers Academy S.à r.l.

PricewaterhouseCoopers
A Luxembourg société coopérative
2 rue Gerhard Mercator, B.P. 1443, L-1014 Luxembourg
T : +352 494848 1, www.pwc.lu

PwC Tax Information Reporting
A Luxembourg société à responsabilité limitée
2, rue Gerhard Mercator, B.P. 1443, L-1014 Luxembourg
T : +352 494848 1, www.pwc.lu/TIR

PricewaterhouseCoopers Academy S.à r.l.
A Luxembourg société à responsabilité limitée
2 rue Gerhard Mercator, B.P. 1443, L-1014 Luxembourg
T : +352 494848-4040, www.pwcacademy.lu

How to contact the PwC Luxembourg’s Data Protection Officer?

PwC Luxembourg has appointed a Data Protection Officer who can be contacted at the following address: www.pwc.lu/dataprotection-contact.

Update

In order to comply with the applicable laws and to reflect adequately the way PwC Luxembourg processes the personal data, this privacy statement shall be updated from time to time.

Contacts

PwC Luxembourg

Tel: +352 49 48 48 1
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