Subcontractors and individuals associated with PwC suppliers and subcontractors
Collection of personal data
Personal data related to our suppliers (including subcontractors and persons related to our suppliers and subcontractors) is collected and processed to manage the relationship, contract, to receive services from our suppliers and, where relevant, to provide professional services to the clients. This data usually comprises the information on their business cards, and includes the employee’s name, employer's name, phone number, e-mail address, other business contact information and communications with PwC Turkey.
Processing of personal data
Personal data is used for the purposes below:
1. Receiving services
PwC Turkey processes the personal data of its suppliers and their employees to the extent necessary to receive service. For instance, when a supplier provides PwC Turkey with office management or other services, the personal data related to the persons providing service is processed.
Legal basis: Legitimate interests, execution of the contract
PwC Turkey processes the personal data of its suppliers in the scope of the services it receives in line with its legitimate interests in improving the effectiveness and productivity of the services it provides when this is necessary to establish or carry out contracts and/or as long as the processing does not harm the relevant person’s fundamental rights and freedoms.
2. Providing professional services to clients
When providing services, if PwC Turkey receives services from a supplier it processes the personal data of persons related to the supplier in order to administrate and manage its relationship with the supplier.
Legal basis: Legitimate interests, execution of the contract
PwC Turkey processes personal data related to its suppliers when necessary to establish and carry out contracts with clients, and/or provided it doesn’t harm the fundamental rights and freedoms of the relevant persons, and to serve the legitimate interests of clients receiving professional services as well as to serve its own legitimate interest in improving the effectiveness and productivity of the services it provides.
3. Administration, management and development of businesses and services
PwC Turkey processes personal data to carry out its businesses and for the following purposes:
- provision of independent audit, accounting and consulting in line with the purpose of the services being performed by the relevant business units;
- managing, planning and carrying out relationships with suppliers,
- 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);
- analysing and assessing the strength of interactions with suppliers (CRM uses an algorithm that helps with this analysis, and ranking is based on interaction regularity, duration, proximity and response time);
- planning and executing market research activities for purchasing and marketing and/or promotion of work activities and services;
- 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 (including storing, hosting, maintenance and support activities);
- 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 authorities as required by legislation;
- hosting events;
- to manage the website, systems and applications;
- finance and/or accounting and tracking legal matters including lawsuits and enforcement proceedings.
Legal basis: Execution of the contract, compliance with a legal obligation, legitimate interests
PwC Turkey requires to process personal data to execute a contract signed with suppliers, to carry out obligations laid out by relevant legislation, to manage and develop businesses and services, or to protect its legitimate interest in improving the effectiveness and productiveness of the services it provides as long as the basic rights and freedoms of the related person are not harmed.
4. Security, quality and risk management activities
PwC Turkey has taken security measures to protect its information and supplier information (including personal data). These measures include detecting, investigating and resolving security threats. Personal data shall be processed as a part of security monitoring and automatic scans etc. shall be carried out to detect harmful e-mails.
PwC Turkey has policies and procedures in place to manage risks related to client contracts and to monitor service quality. Personal data is processed as a part of the supplier contract procedures. Activities carried out to monitor service quality includes processing personal data.
Legal basis: Legitimate interests, legal obligation
Processing personal data is necessary to carry out legal obligations arising from relevant legal regulations, to provide network and information security, to manage risks, to monitor service quality and to protect legitimate interests.
5. Providing information about PwC Turkey and the range of services
Unless it states otherwise, PwC Turkey uses supplier contact information to share information it deems to be relevant to it and its services, e.g., sector updates and predictions, businesses and communications related to events and invitations to events.
Legal basis: Legitimate interests, explicit consent
PwC Turkey has a legitimate interest in promoting its business businesses and services, and in this scope needs to process personal data. PwC Turkey honours its legal obligation to obtain explicit consent when necessary.
6. Compliance 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 shall include personal data.
Legal basis: Legal obligations, stipulations in laws and legitimate interests
Personal data needs to be processed as required by relevant regulations and legal obligations, e.g., procedures must be carried out as required by auditor independence rules. When there aren’t any legal obligations, PwC Turkey has a legitimate interest in processing personal data to carry out regulatory or occupational obligations.
For more information about data processors used by PwC Turkey (e.g., IT service providers) and locations where data processing is carried out, please visit to this link.
In line with the contract with the suppliers, support is be obtained from other entities and institutions in the scope of services received.
