Individuals whose personal data PwC Turkey obtains in connection with providing services to the clients

Individuals whose personal data PwC Turkey obtains in connection with providing services to the clients (e.g., client personnel, customers, real persons etc.) 

Collection of personal data

Policy of PwC Turkey is to collect only the personal data necessary for agreed purposes and  ask  clients only to share personal data with PwC Turkey where it is strictly needed for those purposes.

 Where PwC Turkey needs to process personal data to provide its services, PwC Turkey ask our clients to provide the necessary information to the data subjects concerned regarding its use.  Collecting personal data when the Client provides personal data (including the special categories of data) to PwC Turkey about its employees, contractors, clients and other individuals, the Client confirms that it has fulfilled any and all necessary legal requirements, including without limitation notifying the purposes and scope of and obtaining the consents of such employees, contractors, clients or other individuals for the concerned data disclosure to PwC Turkey and the continuing data processing by PwC Turkey.

To manage and maintain PwC Turkey’s relationship with these persons, contact information is collected and used on behalf of clients. For more information about processing such data, see the potential and existing clients and those related to them (CRM) part of this privacy statement.

Considering the variety of services (please refer to this link for information on our services) provided to clients many personal data categories  are processed, including special categories of personal data:

Processing of personal data

PwC Turkey processes personal data for the purposes below:

1. Providing professional services

PwC Turkey provides a wide variety of professional services (please refer to this link for information on our services). To provide services and prepare outputs it is necessary to process personal data. For instance, we examine payroll data as a part of the audit process, and personal data are used to provide global mobility services under people management and organisation consultancy and to carry out tax and payroll services.

Mentioned personal data shall be processed under a below legal reasons:

• carrying out the contract,
• legal obligation,
• stipulation in laws,
• imperative data processing to establish, use or protect a right

The processing of special categories of personal data is based on explicit stipulations in relevant laws or the explicit consent of the relevant person.

2. Administration, management and development of operations and services

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

• planning and executing data access authorisations of partners and/or suppliers, managing relationships with partners and/or suppliers;
• ensuring that data is accurate and up-to-date;
• analysing trends including those related to PwC management, generating criteria concerning services provided, relationship maps, sales intelligence and processes responding to commercial account targets;
• using and updating IT systems (account management, internal financial reporting and provision of IT services, storing, hosting, maintenance, support activities and use of a centrally distributed server system are also included to this scope);
• executing processes and operations, finance operations, communications, market research and social responsibility activities and purchasing operations (requests, proposals, evaluations, orders, budgeting, contracts) that aim to determine and apply trade and business strategies;
• informing authorized people or bodies as required by legislation
• hosting events
• finance and/or accounting and tracking legal matters including lawsuits and enforcement proceedings.

Mentioned personal data shall be processed under a below legal reasons;

• legal obligation,
• legitimate interests

PwC Turkey processes personal data to carry out the obligations laid out by relevant legislation, to manage and develop operations 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 security measures to protect both its own data and its clients’ data (including personal data). These are to identify, investigate and resolve security threats. Personal data can be processed as part of the security monitoring undertaken, automatic scans to detect harmful e-mails, etc. realizable. Services provided to customers for the purpose of improving service quality are monitored, including the processing of personal data kept in the relevant client file. There are policies and procedures implemented to manage risks related to client contracts and to monitor the quality of services.

PwC Turkey processes data as part of customer contracts and admission procedures. As part of the procedures implemented under the legislation on prevention of money laundering, there are procedures (political sanctions, judicial, official or other known issues related to company directors, etc.) that determine individuals and companies in the high-risk group, such as those with a known political influence. ) searches are made using publicly available sources to determine.

Mentioned personal data shall be processed under a below legal reasons;

• stipulations in laws
• legal obligations
• legitimate interest

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. Complying with legal regulations and regulations of occupational organizations PwC Turkey is a member of
Like every professional service provider, PwC Turkey is subject to legal, 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)

Mentioned personal data shall be processed under a below legal reasons:

• stipulations in laws
• legal obligations

For more information about data processors used by PwC Turkey (e.g., IT service providers) and the locations where data processing is carried out, visit to this link.

In line with the contract with the client, we obtain support from other entities or institutions when providing services, if required by the project.

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