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KPMG LLP (US) - Notice of processing

KPMG LLP (US) - Notice of processing

Last updated November 20, 2020

KPMG LLP (U.S.)1 ("KPMG," “we,” “our,” and “us”) is committed to protecting the privacy of your personal information. Although we do not direct our services to non-U.S. individuals, we may still come into possession of personal information relating to non-U.S. individuals as part of our U.S. service offerings. This Notice of Processing (“Notice”) supplements our Privacy Statement and provides additional information for non-U.S. individuals relating to personal information that has been collected by or provided to us through any of our websites, web-based and mobile applications, meetings and events (in-person and virtual), marketing materials and content and services (collectively, “Activities”). 

Please note that your rights for any particular product or service may be determined by the notice or terms provided with such product or service, and in the event of a conflict between this notice and that notice or terms, the specific notice or terms provided with the product or service shall control.

1. How Do We Collect and Process Personal Information?

Directly – We obtain personal information directly from individuals in a variety of ways, including obtaining personal information from individuals who provide us their business card, complete our online forms, subscribe to our newsletters and register for webinars, attend meetings or events we host, visit our offices or apply for open positions. We may also obtain personal information directly when, for example, we are establishing a business relationship, performing professional services through a contract, or through our hosted software applications.

Indirectly – We obtain personal information indirectly about individuals from a variety of sources, including recruitment services and our clients. We may attach personal information to our customer relationship management records to better understand and serve our business clients, subscribers and individuals, satisfy a legal obligation, or pursue our legitimate interests.

  • Public sources – Personal information may be obtained from public registers (such as Companies House), news articles, sanctions lists and Internet searches.
  • Social and professional networking sites – If you register or login to our websites using social media platforms (e.g., LinkedIn or Twitter) to authenticate your identity and connect your social media login information with us, we will collect information or content needed for the registration or login that you permitted your social media provider to share with us. That information may include your name and email address and depending on your privacy settings, additional details about you, so please review the privacy controls on the applicable service to set how much information you want shared with us.
  • Client services – Our clients may engage us to perform professional services which involves sharing personal information they control as part of that engagement. For example, we will review payroll information as part of an audit and we often need to use personal information to provide global mobility and pension services. Our services may also include processing personal information under our clients’ control on our hosted software applications, which may be governed by different privacy terms and policies.
  • Recruitment services – We may obtain personal information about candidates from employment and recruitment agencies, and other parties including former employers and credit agencies.

2. What Categories of Personal Information Do We Collect?

We may obtain the following categories of personal information about individuals through direct interactions with us, or from information provided through client engagements, from applicants, our suppliers and through other situations including those described in this Notice.

  • Personal information. Here is a list of personal information we commonly collect to conduct our business activities. 
    • Contact details (e.g., name, company name, job title, work and mobile telephone numbers, work and personal email and mailing address).
    • Professional details (e.g., job and career history, educational background and professional memberships, published articles). 
    • Family and beneficiary details for insurance and pension planning services (e.g., names and dates of birth).
    • Financial information (e.g., taxes, payroll, investment interests, pensions, assets, bank details, insolvency records).
  • Sensitive personal information. We typically do not collect sensitive or special categories of personal information about individuals, such as personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometrics information for the purpose of uniquely identifying a natural person, information concerning health or information concerning a natural person's sex life or sexual orientation. When we do need to process sensitive personal information, it is with the consent of the individual unless it is obtained indirectly for certain legitimate purposes. Examples of sensitive personal information we may obtain include:
    • Dietary restrictions or access requirements when registering for in-person events that reveal religious beliefs or physical health.
    • Personal identification documents that may reveal race or ethnic origin, and possibly biometric information of private individuals, beneficial owners of corporate entities, or applicants.
    • Expense receipts submitted for individual tax or accounting advice that reveal affiliations with trade unions or political opinions.
    • Adverse information about potential or existing clients and applicants that may reveal criminal convictions or offences information.
    • Information provided to us by our clients in the course of a professional engagement.
    • Diversity and inclusion information volunteered by participants in certain KPMG professional empowerment programs.
  • Location-based information. We may collect or process geographical locations you enter when seeking an office near you or when you engage in certain Activities, such as the use of certain apps.

3. Why Do We Need Personal Information?

We aspire to be transparent when we collect and use your personal information and tell you why we need it, which typically includes reasons such as the following and others listed in our Privacy Statement:

  • Providing professional advice and delivering reports related to our tax, advisory, audit and assurance, pension plan administration, restructuring, mergers and acquisitions and other professional services. Our services may include reviewing client files for quality assurance purposes, which may involve processing personal information for the relevant client.
  • Promoting and marketing our professional services, products and capabilities to existing and prospective business clients, including the services, products and capabilities of KPMG International, other member firms affiliated with KPMG International or other third parties
  • Sending invitations and providing access to guests attending our events and webinars or our sponsored events.
  • Personalizing online landing pages and communications we think would be of interest based on interactions with us, KPMG International and other member firms affiliated with KPMG International Limited.
  • Administering, maintaining and ensuring the security of our information systems, applications and websites. 
  • Authenticating registered users to certain areas of our sites.
  • Seeking qualified candidates and forwarding candidate career inquiries to our human resources and career teams, which may be governed by different privacy terms and policies.
  • Processing online requests, including responding to communications from individuals or requests for proposals and quotations.
  • Contacting journalists regarding company press releases, invitations to annual press parties, highlighting messages that may be of interest on specific industry topics.
  • Travel arrangement assistance.
  • Helping support clients to run a series of development programs for education and learning purposes to inform leaders in the healthcare, civil service and other industries.
  • Complying with legal and regulatory obligations relating to countering money laundering, terrorist financing, fraud and other forms of financial crime. 

In general, you are not obligated to provide your personal information to us. But in some circumstances not providing your personal information to us may have the consequence that we are unable to provide a service requested by you or your employer, if your information is necessary for the provision of service.

4. What Lawful Grounds Do We Have for Processing Personal Information?

Where required and applicable, we may rely on one or more of the following lawful grounds when we collect and use personal information to operate our business and provide our products and services:

  • Contract – We may process personal information to the extent it is necessary in order to perform our contractual obligations we have with you or for precontractual measures.
  • Consent – We may rely on your freely given consent at the time you provided your personal information to us. 
  • Legitimate interests – We may rely the processing of your personal information on our legitimate interests insofar the processing is necessary for these interests based on our evaluation that the processing is fair, reasonable and balanced. These interests include:
    • Delivering services to our clients – To deliver the professional services our clients have engaged us to provide; and 
    • Direct marketing – To deliver timely market insights and specialty knowledge we believe is welcomed by our business clients, subscribers and individuals who have interacted with us.
  • Legal obligations and public interests – We may process personal information in order to meet regulatory and public interest obligations or mandates. 
  • To protect vital interests – We may process personal information in order to protect the vital interests of individuals.
  • For legal claims – We may process personal information in order to establish, exercise or defend legal claims.
  • For preventative or occupational medicine – subject to local country requirements.
  • For employment, social security and similar purposes – subject to local country requirements.

5. What Privacy Rights Do Non-U.S. Data Subjects Have? 

Certain country laws provide individuals with rights relating to their personal information. Where applicable, those rights may include:

  • Access – You can ask us to verify whether we are processing personal information about you, and if so, to provide more specific information about the personal information concerned.
  • Rectification – You can ask us to correct our records if you believe they contain incorrect or incomplete information about you. 
  • Erasure – You can ask us to erase (delete) your personal information after you withdraw your consent to processing or when we no longer need it for the purpose it was originally collected.
  • Processing Restrictions – You can ask us to temporarily restrict our processing of your personal information if you contest the accuracy of your personal information, prefer to restrict its use rather than having us erase it, or need us to preserve it for you to establish, exercise, or defend a legal claim. A temporary restriction may apply while verifying whether we have overriding legitimate grounds to process it. You can ask us to inform you before we lift that temporary processing restriction.
  • Information Portability – In some circumstances, where you have provided personal information to us, you can ask us to transmit that personal information (in a structured, commonly used, and machine-readable format) directly to another company if this is technically feasible.
  • Right to Object to Direct Marketing – You can object to our use of your personal information for direct marketing purposes, including profiling. We may need to keep some minimal information to comply with your request to cease marketing to you.
  • Right to Withdraw Consent – You can withdraw your consent that you have previously given to one or more specified purposes to process your personal information. This will not affect the lawfulness of any processing carried out before you withdraw your consent. It may mean we are not able to provide certain products or services to you and we will advise you if this is the case.
  • Right to Lodge a Complaint with a Data Protection Authority – If you have any complaints about the processing of personal information you may contact us using the information below or submit a Data Privacy Request. But irrespective of whether you want to contact us, you have the right to lodge a complaint with a data protection authority in your country.

We may need to request specific information from you to help us verify your identity and ensure your right to access the information or to exercise any of your other rights. This helps us to ensure that your personal information is not disclosed to any person who has no right to receive them. No fee is required to make a request unless your request is clearly unfounded or excessive.

Regarding cross-border transfers of personal information you may request from us more information on the safeguards that are put in place, such as a copy of the safeguards. We will make all reasonable and practical efforts to comply with your request as required by applicable law, so long as our doing so would be consistent with KPMG’s contractual requirements, and/or the professional standards applicable to KPMG.

If you have questions or comments about our administration of your personal information or wish to make a Data Privacy Request, please contact us by:

6. How Long Do We Retain Personal Information?

We retain personal information to provide our services, stay in contact with you and to comply with applicable laws, regulations, contractual obligations and our policies and professional obligations. We dispose of personal information in a secure manner when we no longer need it.

7. Do We Change This Notice?

We regularly review this Notice and will post any updates to it on this website, noting the date of last modification at the top of the page.

 

1KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. KPMG International Limited and its related entities do not provide services to clients.