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General Privacy Statement

General Privacy Statement

Privacy statement

Last updated 11 June 2020

This website is operated by KPMG Ireland (“KPMG”, “we” or “us”) an Irish partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity.

KPMG is dedicated to protecting the confidentiality and privacy of information entrusted to us and we comply with the Data Protection Acts, 1988-2018, the ePrivacy Regulations 2011 (S.I. 336), and the General Data Protection Regulation (EU) 2016/679 - (“applicable data protection law”).

KPMG is committed to the appropriate protection and use of personal data that has been collected via our website. The term ‘personal data’ means any information concerning or relating to a living person who is either identified or identifiable.  Generally, our intent is to collect only the personal data that is provided voluntarily by online visitors so that we can offer information and/or services to those individuals or offer information about employment opportunities.

Please review this (“Privacy Statement”) to learn more about how we collect, use, share and protect the personal data that we have obtained. This Privacy Statement applies to your use of our websites and more generally to individuals whose personal data we collect and process in the course of our business operations.

1. Collection and use of personal data

  • 1.1 The type of information we collect
  • 1.2 The legal grounds we rely on to use your personal data
  • 1.3 Automatic collection of personal data
    • 1.3.1 IP addresses
    • 1.3.2 Cookies
    • 1.3.3 Analytics
    • 1.3.4 Web beacons
    • 1.3.5 Location-based tools
  • 1.4 Social media widgets and applications
  • 1.5 Children

2. Sharing and transfer of personal data

  • 2.1 Transfer within the network of KPMG firms
  • 2.2 Transfers to third parties
  • 2.3 Transfers outside the EEA

3. Choices

4. Your Rights

  • 4.1 Access
  • 4. 2 Correction
  • 4.3 Erasure
  • 4.4 Object to processing
  • 4.5 Restriction of processing
  • 4.6 Data Portability
  • 4.7 How to Make a Request

5. Data Security and Integrity

6. Links to other sites

7. Provision of professional services

8. Changes to this policy statement

9. Policy questions and enforcement

10. Contacting us

 

1. Collection and use of personal data

1.1 The type of information we collect

We obtain personal data about you should you choose to provide it. For example, you may provide information such as your name, title, work address and email address when registering for services or when contacting our mailboxes. In some cases, you will have previously provided your personal information to KPMG (if, for example, you are a former employee).

If you choose to register or login to a KPMG website using a third party single sign-in service that authenticates your identity and connects your social media login information (e.g., LinkedIn, Google, or Twitter) with KPMG, we will collect any information or content needed for the registration or log-in that you have permitted the social media provider to share with us, such as your name and email address. Other information we collect will depend on the privacy settings you have set with your social media provider, so please review the privacy statement or policy of the applicable service.

By registering and/or submitting personal data to KPMG, we will use this information in the manner outlined in this Privacy Statement. Your personal data is not used for other purposes, unless we obtain your consent or unless such a purpose is permitted by law or professional standards. For example, if you register to a KPMG website and provide information about your preferences, we will use this information to personalize your user experience. Where you register or login using a third-party single user sign-in we may also recognize you as the same user across any different devices you use and personalize your user experience across other KPMG sites you visit. If you send us a resume or curriculum vitae (CV) to apply online for a position with KPMG, we will use the information that you provide to match you with available KPMG job opportunities.

In some cases where you have registered for certain services we will store your email address temporarily until we receive confirmation of the information you provided via an email (i.e. where we send an email to the email address provided as part of your registration to confirm a subscription request).      

1.2 The legal grounds we rely on to use your personal data

KPMG generally collects only the personal data necessary to fulfil your request. Where additional, optional information is sought, you will be notified of this at the point of collection.

Applicable data protection law allows us to process personal data, so long as we have a ground under the law to do so. It also requires us to tell you what those grounds are. As a result, when we process your personal data, we will rely on one of the following processing conditions:

  • Performance of a contract: this is when the processing of your personal data is necessary in order to perform our obligations under a contract;
  • Legal obligation: this is when we are required to process your personal data in order to comply with a legal obligation, such as keeping records for tax purposes or providing information to a public body or law enforcement agency;
  • Legitimate interests: we will process information about you where it is in our legitimate interest in running a lawful business to do so in order to further that business, so long as it doesn’t outweigh your interests; or
  • Your consent: in some cases, we will ask you for specific permission to process some of your personal data, and we will only process your personal data in this way if you agree to us doing so. Where we are processing your personal data on your consent, you may withdraw your consent at any time by contacting KPMG at GDPRqueries@KPMG.ie

Examples of the ‘legitimate interests’ referred to above are:

  • To offer information and/or services to individuals who visit our website or offer information about employment opportunities.
  • To prevent fraud or criminal activity and to safeguard our IT systems.
  • To customize individual’s online experience and improve the performance usability and effectiveness of KPMG’s online presence.
  • To conduct, and to analyse, our marketing activities.
  • To meet our corporate and social responsibility obligations.
  • To exercise our fundamental rights in the EU under Articles 16 and 17 of the Charter of Fundamental Rights, including our freedom to conduct a business and right to property.

In some cases, the personal data that we collect will also include special categories of data, such as diversity related information (including data about racial and ethnic origin, political opinions, religious beliefs and other beliefs of a similar nature, trade union membership and data about sexual life and sexual orientation), or health data and data about alleged or proven criminal offences in each case where permitted by law.    

1.3 Automatic collection of personal data

In some instances, KPMG and its service providers uses cookies, web beacons and other technologies to automatically collect certain types of information when you visit us online, as well as through emails that we may exchange. The collection of this information allows us to customize your online experience, improve the performance, usability and effectiveness of KPMG’s online presence, and to measure the effectiveness of our marketing activities.

1.3.1 IP addresses

An IP address is a number assigned to your computer whenever you access the internet. It allows computers and servers to recognise and communicate with one another. IP addresses from which visitors appear to originate may be recorded for IT security and system diagnostic purposes. This information may also be used in aggregate form to conduct website trend and performance analysis.

1.3.2 Cookies

Cookies may be placed on your computer or internet-enabled device whenever you visit us online. This allows the site to remember your computer or device and serves a number of purposes.

On some of our websites, a notification banner will appear requiring your consent to collect cookies (cookies banner). Below is a summary of the categories of cookies collected on our websites, and how your consent may impact your experience of certain features as you navigate those websites:

  • Strictly necessary cookies: Strictly necessary cookies are essential in order to enable users to move around the website and use its features, such as accessing secure areas of the website. These cookies must be enabled or the site will not function, and cannot be blocked.
  • Performance cookies: Performance cookies are cookies used to gather data to enhance the performance of a website.

You can manage your consent for performance cookies using the cookie banner, or by updating your browser’s settings (often found in your browser’s Tools or Preferences menu) to not accept cookies.

  • Functionality cookies: Functionality cookies are used to remember customer selections that change the way the site behaves or looks. You may opt-out of these cookies, but it will impact your experience on the website, and you may need to repeat certain selections each time you visit.

You can manage your consent for functionality cookies using the cookie banner, or by updating your browser’s settings (often found in your browser’s Tools or Preferences menu) to not accept cookies.

  • Targeting cookies or advertising cookies: Targeting cookies are used to deliver content relevant to your interests They are also used to limit the number of times you see certain marketing materials, as well as help measure the effectiveness of those marketing materials. If you do not provide consent for targeting cookies, your computer or internet-enabled device will not be tracked for marketing-related activities.

You can manage your consent for targeting cookies using the cookie banner, or by updating your browser’s settings (often found in your browser’s Tools or Preferences menu) to not accept cookies.

Although most browsers automatically accept cookies, you can choose whether or not to accept cookies via your browser's settings (often found in your browser's Tools or Preferences menu). If you wish to withdraw your consent to cookies, you may also delete cookies from your device at any time. You may do so by clearing your browser’s cookies, or by updating your preferences in the cookies banner. However, please be aware that if you do not accept cookies, you may not be able to fully experience some of our web sites' features.

Further information about managing cookies can be found in your browser's help file or through sites such as www.allaboutcookies.org.

Below is a list of the types of cookies used on our websites:

Purpose

Description

Type & Expiry

Performance (i.e., User's Browser)

Our web sites are built using common internet platforms. These have built-in cookies which help compatibility issues (e.g., to identify your browser type) and improve performance (e.g., quicker loading of content).

Session, deleted upon closing the browser, or persistent.

Security (e.g. Asp .NET) Cookies

If you register for access to a restricted area, our cookies ensure that your device is logged for the duration of your visit. You will need your username and password to access the restricted areas. 

Session, deleted upon closing the browser, or persistent.

Site Preferences

Our cookies may also remember your site preferences (e.g., language) or seek to enhance your experience (e.g., by personalizing a greeting or content). This will apply to areas where you have registered specifically for access or create an account.

Session, deleted upon closing the browser, or persistent.

Analytical

We use several third-party analytics tools to help us understand how site visitors use our web site. This allows us to improve the quality and content on kpmg.com for our visitors. The aggregated statistical data cover items such as total visits or page views, and referrers to our web sites. For further details on our use of Google Analytics, see below. See below section 1.3.3 Analytics.

Persistent, but will delete automatically after two years if you no longer visit kpmg.com

Social sharing

We use third party social media widgets or buttons to provide you with additional functionality to share content from our web pages to social media websites and email. Use of these widgets or buttons may place a cookie on your device to make their service easier to use, ensure your interaction is displayed webpages (e.g. the social share count cache is updated) and log information about your activities across the Internet and on our web sites. We encourage you to review each provider's privacy information before using any such service. For further details on our use of social media widgets and applications, see below section 1.3.4 Web beacons.

Persistent, but will be deleted automatically after two years if you no longer visit kpmg.com 

Other third-party tools and widgets may be used on our individual web pages to provide additional functionality. Depending on how you set your preferences in your browser and/or the cookie banner, use of these tools or widgets may place a cookie on your device to make their service easier to use, and ensure your interaction is displayed on our webpages properly.

Cookies by themselves do not tell us your email address or otherwise identify you personally. In our analytical reports, we may obtain other identifiers including IP addresses, but this is for the purpose of identifying the number of unique visitors to our web sites and geographic origin of visitor trends, and not to identify individual visitors.

1.3.3 Analytics

KPMG uses Google Analytics. More information about how Google Analytics is used by KPMG can be found here: https://www.google.com/analytics/terms/us.html.

To provide website visitors with more choice on how their data is collected by Google Analytics, Google have developed the Google Analytics Opt-out Browser Add-on. The add-on communicates with the Google Analytics JavaScript (ga.js) to indicate that information about the website visit should not be sent to Google Analytics. The Google Analytics Opt-out Browser Add-on does not prevent information from being sent to the website itself or to other web analytics services.

KPMG also uses Adobe Analytics. Further information on the data gathered is available here: https://docs.adobe.com/content/help/en/analytics/technotes/privacy-overview.html.

1.3.4 Web beacons

A web beacon is a small image file on a web page that can be used to collect certain information from your computer, such as an IP address, the time the content was viewed, a browser type, and the existence of cookies previously set by the same server. KPMG uses web beacons only in accordance with applicable laws.

KPMG or its service providers may use web beacons to track the effectiveness of third-party web sites that provide us with recruiting or marketing services or to gather aggregate visitor statistics and manage cookies.

You have an option to render some web beacons unusable by rejecting their associated cookies. The web beacon may still record an anonymous visit from your IP address, but cookie information will not be recorded.

In some of our newsletters and other communications, we may monitor, from time to time, recipient actions such as email open rates through embedded links within the messages. We collect this information to enhance future user experiences.

1.3.5 Location-based tools

KPMG may collect and use the geographical location of your computer or mobile device. This location data is collected for the purpose of providing you with information regarding services which we believe may be of interest to you based on your geographic location, and to improve our location-based products and services.

1.4 Social media widgets and applications

KPMG websites may include functionality to enable sharing via third party social media applications, such as the Facebook Like button and Twitter widget. These social media applications may collect and use information regarding your use of KPMG web sites (see details on 'Social Sharing' cookies above). Any personal data that you provide via such social media applications may be collected and used by other members of that social media application and such interactions are governed by the privacy policies of the companies that provide the application. We do not have control over, or responsibility for, those companies or their use of your information.

In addition, KPMG web sites may host blogs, forums, crowd-sourcing and other applications or services (collectively "social media features"). The purpose of social media features is to facilitate the sharing of knowledge and content. Any personal data that you provide on any KPMG social media feature may be shared with other users of that social media feature (unless otherwise stated at the point of collection), over whom we may have limited or no control.

1.5 Children

KPMG understands the importance of protecting children's privacy, especially in an online environment. In particular, our sites are not intentionally designed for or directed at children under the age of 16. It is our policy never to knowingly collect or maintain information about anyone under the age of 16, except as part of an engagement to provide professional services.

 

2. Sharing and transfer of personal data

2.1 Transfer within the network of KPMG firms

We share information about you with other member firms of the KPMG network as part of international engagements, and with KPMG International and other member firms where required or necessary to meet our legal and regulatory obligations globally. For example other parts of the KPMG network are also used to provide services to us and you, for example hosting and supporting IT applications, provision of certain forms of insurance for member firms and its clients, performing client conflicts checks and Anti-Money Laundering checks, assisting with client engagement services and otherwise as required in order to continue to run KPMG’s business

2.2 Transfers to third parties

We do not share personal data with third parties, except as necessary for our legitimate regulatory, professional and business needs, to carry out your requests, and/or as required or permitted by law or professional standards. This includes:

  • Our service providers: we transfer your personal data to our third-party service providers, such as our (IT) systems providers, our hosting providers, our payroll providers, consultants (such as legal advisers) and other goods and services providers. KPMG works with such providers so they can process your personal information on our behalf. KPMG will only transfer personal information to them when they meet our strict standards on the processing of data and security. We only share personal information that allows them to provide their services.
  • If we are reorganized or sold to another organization: KPMG will typically also disclose personal information in connection with the sale, assignment, or other transfer of any element of KPMG’s business to which the personal data relates.
  • Courts, tribunals, law enforcement or regulatory bodies: KPMG will disclose personal data in order to respond to requests of courts, tribunals, government or law enforcement agencies or where it is necessary or prudent to comply with applicable laws, court or tribunal orders or rules, or government or professional regulations.
  • Audits: disclosures of personal data will also be needed for data privacy or security audits and/or to investigate or respond to a complaint or security threat.
  • Insurers: our professional rules and our business requirements mean that we carry significant insurance cover in respect of business activities (our ‘insurance programme’). This is required to assist each member firm of the KPMG network in covering the costs associated with claims which may arise in the event that it is alleged that something has gone wrong during the course of providing services to its clients. In order to make the insurance programme work effectively, the insurance programme involves a number of different participants in the insurance market (e.g. brokers, insurers and reinsurers, as well as their professional advisors and other third parties involved should there be a claim). Some of these insurance market participants will require that we disclose personal information about you to them. The information will be used by the insurance market participants in the underwriting and ongoing administration of the insurance programme, where there is a claim that you are relevant to and to allow the insurance market participants to comply with their legal and regulatory obligations. Some of these insurance market participants will handle this information on our behalf (like our service providers described above), but others will want to process information about you independent of us.

KPMG will not transfer the personal data you provide to any third parties for their own direct marketing use.

We may add your personal data to our Contact Relationship Management database (CRM) which we use to develop our relationships with current and prospective contacts. KPMG does not sell your personal data or provide it to third parties for direct marketing use.

2.3 Transfers outside the EEA

KPMG may transfer certain personal data outside of the EEA to companies working with us or on our behalf for the purposes described in this Privacy Statement.

Should this occur your personal data will continue to be protected by means of contracts we have in place with those organizations outside the EEA, containing standard data protection clauses which are in a form approved by the European Commission.

 

3. Choices

In general, you are not required to submit any personal information to KPMG, but we will require you to provide certain personal information in order for you to receive additional information about our services and events. KPMG may also ask for your permission for certain uses of your personal data, which you can agree to or decline those uses. If you opt-in for particular services or communications, such as an e-newsletter, you are able to unsubscribe at any time by following the instructions included in each communication. If you decide to unsubscribe from a service or communication, we will try to remove your information promptly, although we may require additional information before we can process your request.

As described in Section 1.3.2 “Cookies” above, if you wish to prevent cookies from tracking you as you navigate our sites, you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Note, however, that some portions of our sites may not work properly if you elect to refuse cookies.

 

4. Your Rights

If KPMG processes personal information about you, you have the following rights:

4.1 Access

You may request access to your personal data. This is commonly known as a "data subject access request" or “DSAR”. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. If we agree that we are obliged to provide personal information to you, we will provide it to you free of charge. Before providing personal information to you, we may ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information. You can submit a request by clicking here.

4.2 Correction

You may request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

4.3 Erasure

You may request erasure of your personal data. This enables you to request us to delete or remove your personal information from our systems where it is readily identifiable and where you feel there is no legitimate reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).

4.4 Object to Processing

You may object to the processing of your personal data where we are relying on a legitimate interest as proscribed in GDPR (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.

4.5 Restriction of Processing

You may request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.

4.6 Data Portability

You may request the transfer of your personal data to another party.

4.7 How to Make a Request

If you wish to submit a Data Subject Access Request please click here or to exercise any of these rights you can contact our Data Protection Officer directly at GDPRqueries@kpmg.ie. We will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.  In the interests of transparency, please note that communications relating to data requests may be issued through our privacy partners OneTrust.

 

5. Data Security and Integrity

KPMG has reasonable security policies and procedures in place to protect personal data from unauthorized loss, misuse, alteration, or destruction. Despite KPMG's best efforts, however, security cannot be absolutely guaranteed against all threats. To the best of our ability, access to your personal data is limited to those who have a need to know. Those individuals who have access to the data are required to maintain the confidentiality of such information.

We also make reasonable efforts to retain personal data only for so long (i) as the information is necessary to comply with an individual's request, (ii) as necessary to comply with legal, regulatory, internal business or policy requirements, or (iii) until that person asks that the information be deleted. The period for which data is retained will depend on the specific nature and circumstances under which the information was collected.

 

6. Links to other sites

Please be aware that KPMG websites may typically contain links to other sites, including sites maintained by other KPMG member firms that are not governed by this Privacy Statement but by other privacy statements that will often differ somewhat. We encourage users to review the privacy policy of each Web site visited before disclosing any personal data.

By registering on any KPMG web site and then navigating to another KPMG web site while still logged in, you agree to the use of your personal data in accordance with the privacy statement of the KPMG web site you are visiting.   

 

7. Provision of professional services

KPMG will also often receive personal data in the course of providing professional services – ordinarily when we provide services to private individuals, employers, businesses with personal customers, and public sector clients with constituents. Our engagement letter and terms of business govern our relationship with clients, including what we may do with personal data that is provided to us. KPMG provides many different types of services and its role may not always be visible to the individuals who are data subjects.

 

8. Changes to this policy statement

KPMG may modify this Privacy Statement from time to time to reflect our current privacy practices. When we make changes to this statement, we will revise the "updated" date at the top of this page. Any changes to the processing of personal data as described in this Privacy Statement affecting you will be communicated to you through an appropriate channel, depending on how we normally communicate with you.    

 

9. Policy questions and enforcement

KPMG is committed to protecting the online privacy of your personal data. If you have questions or comments about our administration of your personal data, please contact us at GDPRqueries@kpmg.ie. You may also use this address to communicate any concerns you may have regarding compliance with our Privacy Statement.

If you are not satisfied with the response you receive, you may escalate your concern our Data Protection Officer GDPRqueries@kpmg.ie. We will acknowledge your email within 14 days and seek to resolve your concern within one month of receipt. Where the concern is complex or we have a large volume of concerns, we will notify you that the concern will take longer than one month to resolve, and we will seek to resolve your concern within three months of the concern being first raised. We may accept your concern (and in that case implement one of the measures set out in the ‘Your Rights’ section above), or we may reject your concern on legitimate grounds.

In any event, you always have the right to lodge a complaint with the Data Protection Commission by post to Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland or by e-mail at info@dataprotection.ie.

 

10. Contacting us

If you have questions, comments or complaints about our handling or protection of your personal data, please contact our Data Protection Officer at GDPRqueries@kpmg.ie.

If you wish to submit a Data Subject Access Request please click here. In the interests of transparency, please note that communications relating to data requests may be issued through our privacy partners OneTrust.

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