Corporate clients (and individuals associated with our corporate clients)

Collecting personal data

Since PwC Turkey’s “Personal Data Protection and Processing Policy” stipulates that only the personal data required for the purposes agreed upon with the client will be collected, PwC Turkey requests that clients only share the personal data required for these purposes.

If clients share personal data of their employees, contractors, clients or other persons with PwC Turkey so that PwC Turkey can provide professional services, they should carry out all legal requirements including, but not limited to, informing the relevant persons of the purpose and scope of the data processing activities PwC Turkey carries out and the foreseen disclosure of personal information and obtaining the consent of these relevant persons. Clients can direct this privacy statement to relevant people for them to refer.

Personal data categories that can be processed in relation to the services provided:

communication

entity

location

risk management

transaction security

legal transaction

finance

client transactions

physical location security

marketing

work experience

association membership

foundation membership

union membership

medical information

 

 

 

visual or auditory recordings

 

 

 

 

other

Using personal data

PwC Turkey processes personal data for the purposes below:

1. Providing professional services

PwC Turkey provides a wide variety of professional services. For more information about our services, please click here.

To provide advisory services and prepared deliverables it may be necessary to process personal data. For instance, we examine payroll data as part of an audit process, and we use personal data to provide global mobility, tax and pensions services.

The personal data processed within the each legal grounds stated below:

  • execution of a contract,
  • legal obligations
  • stipulations in laws,
  • imperative data processing to establish, use or protect a right,
  • explicit consent

To provide professional services, to ensure professional services in relation to PwC Turkey’s and its firms’ management for the execution of client contracts.Also, in some cases, we have a legal obligation to provide service in a certain way (e.g., mandatory audit). In order to process special categories of data, there must be relevant laws stipulating to this processing or explicit consent must be provided.

2.  Administration, management and development of businesses and services

PwC Turkey processes personal data to carry out its businesses and professional services and for the following purposes:

  • for planning and executing customer relations management processes, planning and/or tracking customer satisfaction processes, tracking customer demands and/or complaints;
  • to develop businesses and services (define customer needs and improvements to service delivery and have more information about the opportunity of a relationship where a client, PwC Turkey or another PwC Member Firm have interest);
  • when analysing and assessing the strength of interactions between parties (CRM uses an algorithm that helps with this analysis, and ranking is based on interaction regularity, duration, proximity and response time);
  • for planning and executing market research activities for purchasing and marketing and/or promotion of work activities and services;
  • for planning and executing data access authorisations of partners and/or suppliers and managing relationships with partners and/or suppliers;
  • to ensure that data is accurate and up-to-date;
  • to analyse trends, including those related to PwC management, generating criteria concerning services provided, relationship maps, sales intelligence and processes responding to commercial account targets;
  • when using and updating IT systems, managing accounts, updating internal financial reporting and providing IT services (including storing, hosting, maintenance and support activities);
  • when executing processes and operations, finance operations, communications, market research and social responsibility activities and purchasing operations (requests, proposals, evaluations, orders, budgeting, contracts), in order to determine and apply trade and business strategies;
  • to inform authorities as required by legislation;
  • when hosting events;
  • to manage the website, systems and applications;
  • for finance and/or accounting and for tracking legal affairs including lawsuits and enforcement proceedings.

The personal data processed within the each legal grounds stated below:

  • compliance to legal obligations,
  • legitimate interests.

PwC Turkey need to process personal data to for compliance to legal obligations, to manage and develop businesses and services and to protect its legitimate interests on the condition that the basic rights and freedoms of the relevant person are not harmed.

3. Security, quality and risk management activities

PwC Turkey has taken security measures to protect its company information and client information (including personal data). These measures include detecting, investigating and resolving security threats. Personal data might be processed in the course of security monitoring, and automatic scans etc. might be carried out to detect harmful e-mails.

Services provided to customers to improve service quality are monitored in a such a way that personal information in the related client file is also processed. There are policies and procedures in place to manage risks related to client contracts and to monitor service quality.

PwC Turkey processes personal information as part of the client engagement and acceptance procedure. The procedures we execute in the scope of legislation related to the prevention of laundering crime revenue includes carrying out searches using publicly available sources to identify high-risk individuals and companies and to determine whether there is any obstacle related to working with  a certain client (e.g., sanctions, issues related to company leaders such as legal, official or other problems).

The personal data processed within the each legal grounds stated below:

  • legitimate interests,
  • stipulations in relevant laws,
  • compliance to legal obligations.

As long as network and information security is ensured, risks are managed, quality of service is checked and fundamental rights and freedoms of the relevant person are not harmed, when obligatory, PwC Turkey might need to process personal data to protect its legitimate interests, if stipulated in relevant laws or to establish, use or protect a right.

4. Providing information to existing and potential clients about PwC Turkey and its lines of service

Unless the client explicitly states otherwise, PwC Turkey process client contact information it deems is related to it and its services (e.g. sector updates and predictions, other businesses and communications related to events and invitations to events).

PwC Turkey need to process personal data to manage and develop businesses and services and to protect its legitimate interests on the condition that the basic rights and freedoms of the relevant person are not harmed.

5. Complying with legal regulations and regulations of occupational organisations PwC Turkey is a member of

Like every professional service provider, PwC Turkey is subject to administrative and occupational obligations. To ensure compliance of services with said obligations, certain records need to be retained and these records include personal data.

PwC Turkey process personal data to carry out its occupational obligations (e.g. compliance with anti-money laundering regulations)

Data retention

PwC Turkey retain the personal data it processes for the necessary legal period for the purpose for which it was collected.

Unless legal, regulatory and binding terms state otherwise, the retention period for records and other documentary evidence created in the provision of services is 10+1 years. This period is determined in line with the PwC Turkey Policy for Retention and Disposal of Personal Data.

When and how does PwC Turkey share personal data, and where does it process the data?

For further details about the processors (such as IT service providers) used by PwC Turkey and locations of processing please click here. When providing services in line with the contract with the client, we receive support from other entities or organisations should the project necessitate it.

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