KPMG¹ is dedicated to protecting the confidentiality and privacy of information entrusted to it. As part of this fundamental obligation, KPMG is committed to the appropriate protection and use of personal information (sometimes referred to as “personal data”, "personally identifiable information" or "PII") that has been collected online.

Please review this privacy statement ("Privacy Statement") to learn more about how we collect, use, share and protect the personal information that we have obtained.—   1. Collection and use of personal information

—  1. Collection and use of personal information

—  1.1 What information we collect and why

—  1.2 The legal grounds we have to use your personal information

—  2. Sharing and transfer of Personal Information

—  2.1 Transfers within the network of KPMG firms

—  2.2 Transfers to third parties across borders

—  3. Choices

—  4. Your Rights

—  5. Data security and integrity

—  6. Links to other sites

—  7. Changes to this statement

—  8. Policy questions and enforcement

 

1.Collection and use of personal information

 

1.1What information we collect

We obtain and process personal information about you in a number of ways, including without limitation:

–           Professional Services: Business clients may engage us to perform professional services which involves sharing personal information they control as part of that engagement. We collect and use such personal information only for the purpose of providing professional services, to comply with applicable laws, regulations and professional standards, or for the purpose of obtaining technological, administrative, analytical and clerical services or support.

–      Recruitment Process: We collect personal information about individuals seeking employment or partnership with KPMG for the purpose of evaluating their application, communicating regarding employment opportunities that may be of interest, undertaking recruitment activities such as checking for any existing or potential conflicts of interest or any other restrictions which may restrict an employee’s activities or work engagements within KPMG, and conducting background checks, and if an offer is received from us, criminal history checks;

–      Social and Professional Service Websites: If you 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.

–      Public Sources: Personal information may also be obtained from public registers (such as Registrar of Companies and the Registrar of Titles), news articles, internet searches and other open or public sources.

–      Employee Personal Information: KPMG collects and uses personal information about KPMG personnel in order to manage emoluments, to comply with laws, regulations and professional standards, to provide benefits, to administer performance management tools, to administer, manage, enforce and monitor compliance with KPMG programs, policies and employee relations, and generally to establish, manage employment relationship.

–     Automatic collection of personal information: 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.

 

o   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 will be recorded for IT security and system diagnostic purposes. This information will also typically be used in aggregate form to conduct web site trend and performance analysis.

 

o   Cookies

Cookies will typically 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 web sites, a notification banner will appear requiring your consent to collect cookies. If you do not provide consent, your computer or internet-enabled device will not be tracked for marketing-related activities. A secondary type of cookie referred to as "user-input" cookies may still be required for necessary functionality. Such cookies will not be blocked through the use of this notification banner. Your selection will be saved in a cookie and is valid for a period of 90 days. If you wish to revoke your selection, you may do so by clearing your browser's 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). You may also delete cookies from your device at any time. 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 web sites:

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
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
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
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.	Persistent, but will delete automatically after two years if you no longer visit kpmg.com
Site visitor feedback	We use a third party survey tool to invite a percentage of visitors to provide their feedback. Cookies are used to prevent visitors from being invited multiple times. The first cookie (1) is set if the visitor is not invited to participate in the survey, and is used to ensure visitors are not invited after their first page view. The second cookie (2) is set if the visitor is invited to participate in the survey, and is used to ensure the visitor is not invited again to participate for a period of 90 days.	1 Session Deleted upon closing the browser 2 Persistent Deleted automatically after 90 days or presenting survey invite.
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 on our 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.	Persistent, but will be deleted automatically after two years if you no longer visit kpmg.com

 

Other third party tools and widgets will be used on our individual web pages from time to time to provide additional functionality. Use of these tools or widgets will typically 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 will 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.

 

o   Google Analytics

KPMG uses Google Analytics. More information about how Google Analytics is used by KPMG can be found here: http://www.google.com/analytics/learn/privacy.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.

 

o 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 only uses web beacons in accordance with applicable laws.

KPMG or its service providers will 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 the 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 will monitor recipient actions such as email open rates through embedded links within the messages. We collect this information to gauge user interest and to enhance future user experiences.

 

o Location-based tools

KPMG will 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.

 

o Social media widgets and applications

KPMG web sites will typically include functionality to enable sharing via third party social media applications, such as the Facebook Like button and Twitter widget. These social media applications will collect and use information regarding your use of KPMG web sites (see details on 'Social Sharing' cookies above). Any personal information that you provide via such social media applications will often 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 information that you provide on any KPMG social media feature will typically be shared with other users of that social media feature (unless otherwise stated at the point of collection), over whom we often have limited or no control.

 

o 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 13. It is our policy never to knowingly collect or maintain information about anyone under the age of 13, except as part of an engagement to provide professional services.

When you register or submit personal information to KPMG we will use this information in the manner outlined in this privacy statement. Your personal information is not used for other purposes, unless we obtain your permission, or unless otherwise required or permitted by law or professional standards.

 

1.2     The legal grounds we have to use your personal information

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

The law allows us to process personal information, 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 information, we will rely on one of the following processing conditions:

—  Performance of a contract: this is when the processing of your personal information is necessary in order to perform our obligations under a contract or for the taking of steps with a view to enter into a contract;

—  Legal obligation: this is when we are required to process your personal information 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. These include:

o   To offer information and/or services to individuals who visit our website or offer information about employment opportunities.

o   To prevent fraud or criminal activity and to safeguard our IT systems.

o   To customize individual’s online experience and improve the performance usability and effectiveness of KPMG's online presence.

o   To conduct, and to analyze, our marketing activities.

o   To meet our corporate and social responsibility obligations.

—   Public Task: – this when we process personal information in order to perform a specific task of a public nature exercised in the public interest;

—  Vital Interests: – this is when we process personal information to protect the vital interests of the individual or another natural person; or

Your consent: in some cases, we will ask you for specific permission to process some of your personal information, and we will only process your personal information in this way if you agree to us doing so. You may withdraw your consent at any time by contacting KPMG at kig-fmcaricomprivacy@kpmg.com.

In some cases, the personal data that we collect will involve sensitive personal data. KPMG only collects "sensitive" personal data when the relevant individuals voluntarily provide us with this information and consents to us processing the information. Sensitive personal includes personal information regarding a person's race, ethnicity, political beliefs, trade union membership, religious or similar beliefs, physical or mental health, sexual life or criminal record. Please use your discretion when providing sensitive information to KPMG, and under any circumstances, do not provide sensitive personal to KPMG, unless you thereby consent to KPMG's use of that information for its legitimate business purposes and consent to the transfer and storage of such information to and in KPMG databases. If you have any questions about whether the provision of sensitive personal data to KPMG is, or may be, necessary or appropriate for particular purposes, please contact KPMG at kig-fmcaricomprivacy@kpmg.com.

 

2. Sharing and transfer of personal information

 

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 desirable to meet our legal and regulatory obligations around the world. 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. If we do this your personal information will continue to be protected by means of contracts we have in place with those other member firms.

 

2.2 Transfers to third parties across borders

We do not share personal information with third parties, except as necessary for our legitimate professional and business needs, to carry out your requests, and/or as required or permitted by law or professional standards. For more information on such third parties, please see this link. In addition, KPMG will transfer certain personal information outside of its borders to companies working with us or on our behalf for the purposes described in this Privacy Statement. KPMG will also typically store personal information outside of its borders. We typically send personal information to the following countries. If we do this your personal information will continue to be protected by an adequate level of protection including means of contracts we have in place with those organizations outside of our borders in accordance with the requirements of the law.

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

 

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 will also ask for your permission for certain uses of your personal information, and you can agree to or decline those uses. If you opt-in for particular services or communications, such as an e-newsletter, you will be 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 "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:

—  Access and correction: you have the right to access to that data. This is sometimes called a ‘Subject Access Request’. If we agree that we are obliged to provide personal information to you, we will provide it to you free of charge. If the information we hold about you is incorrect, you are entitled to ask us to correct any inaccuracies in the personal information.

—  Object to processing: you have the right to object to us processing your personal information in certain circumstances.

—  Withdrawal of Consent: you have the right to withdraw your consent that you have previously given to one or more specified purposes to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. However, 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. You may withdraw your consent at anytime by contacting us at: kig-fmcaricomprivacy@kpmg.com

—  Other Rights: in addition, you may have rights to object to us making decisions made about you solely based on automated processing, including profiling, that produced legal effects concerning you or similarly significantly affected you, as well as object to our use of your personal data for direct marketing purposes without your consent.

You can make a request or exercise these rights by contacting KPMG at kig-fmcaricomprivacy@kpmg.com and we will make all reasonable and practical efforts to comply with your request, within 30 days of receipt, so long as it is consistent with applicable law and professional standards. Before responding to your request, we may ask for proof of identity and sufficient information about your interactions with us so that we can locate your personal information as well as to ensure that your personal information is not disclosed to an unathorised third party.

 

5. Data security and integrity

KPMG has reasonable security policies and procedures in place to protect personal information 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 information 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 information 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 web sites will 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 information.

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 information in accordance with the privacy statement of the KPMG web site you are visiting.

 

7. Changes to this statement

KPMG may modify this Privacy Statement from time to time to reflect our current privacy practices and any changes to applicable laws and regulations. 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.

 

8. Policy questions and enforcement

KPMG is committed to protecting the privacy of your personal information. If you have questions or comments about our administration of your personal information, please contact our Privacy Liaison/Data Protection Officer, Keisha Williams, at kig-fmcaricomprivacy@kpmg.com. You may also use this address to communicate any concerns you may have regarding compliance with our Privacy Statement. We will acknowledge your email within 14 days and seek to resolve your concern within 30 days of receipt. 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.

If you are not satisfied with the response you receive, you may escalate your concern to the Global Privacy Officer by sending an email to globalprivacyofficer@kpmg.com. In any event, you always have the right to lodge a complaint with the regulator in charge of protecting personal information.

 

[1] "KPMG," "we," "our," and "us" refers to KPMG in Barbados and the Eastern Caribbean, a partnership registered in Barbados, Antigua and Barbuda, Saint Lucia and St. Vincent and the Grenadines, and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.