We at KPMG Oy Ab and KPMG Baltics OÜ (together “KPMG”), are dedicated to protecting the confidentiality and privacy of information entrusted to us. This Privacy Statement describes what personal data we collect and how we use that data and applies to all of our subsidiaries and affiliates.
This Privacy Statement applies to processing of personal data provided or collected in connection with our business operations, including personal data we may receive in the course of providing professional services. In some cases, we may provide additional Privacy Notices specific to certain products such as technology tools. Those terms are to be read in conjunction with this statement.
Our contact details
KPMG Finland
Address: Töölönlahdenkatu 3, 00100 Helsinki
Telephone: +358 20 760 3000
Email: privacy@kpmg.fi
KPMG Estonia
Address: Ahtri 4, 10151, Tallinn
Telephone: +372 6 26 87 00
Email: dpo@kpmg.ee
Our data processing activities
What personal data do we process and for what purposes?
Personal data related to our professional relationships and potential clients
- We process personal data to maintain our business relationship with our clients throughout this relationship and to provide professional services to them. This includes data processing for purposes such as responding to client requests or queries, seeking feedback, maintaining contact with our clients and keeping them informed of our services, industry developments, and events. We may also use this data to further develop our professional relationships and our service offerings.
- Categories of personal data we process for this purpose include e.g.
- Personal information such as name, position, and name of the employer.
- Contact details such as address, phone number and e-mail address.
- Data related to our professional relationship with clients, such as data concerning the services we have provided to clients or feedback our clients might have provided to us.
- We mainly collect this data directly from our clients and our potential clients. In some cases, we also collect personal data from third parties such as the local Trade Register or other external databases.
- Categories of personal data we process for this purpose include e.g.
Personal data related to our business or client engagements
- When providing our services to clients, we often obtain personal data. The data we process varies depending on the nature of the service we provide. We ask our clients only to share personal data with us when it’s necessary for the provision of our services.
- We provide a variety of services and therefore the nature of the data we collect in the course of providing our services varies. Categories of personal data we process for this purpose might include e.g.
- Personal details such as name, date of birth, nationality and country of residence and other personal details relevant to the particular service.
- Contact details such as address, phone number and email address.
- Employment details such as data on position, role, performance and experience, and other data related to one's employment.
- Financial details such as payroll data, income, benefits, investments and other financial interests, tax status and other details related to one's financial situation.
- Other data necessary for performing our services. Some of our services might involve processing of special category data, such as data related to trade union membership, data related to accessing or financing medical treatment, or tax data indicating an affiliation with a religious community. We only process this data when it’s strictly necessary and related to the service we’re performing.
- The majority of personal data we process for these purposes is supplied by our clients or by third party sources at the request of our clients. In the context of providing professional services to our clients, we may also process personal data of individuals with whom we do not have a direct relationship, such as employees, customers or suppliers of our clients.
- We provide a variety of services and therefore the nature of the data we collect in the course of providing our services varies. Categories of personal data we process for this purpose might include e.g.
Personal data related to the use of our website, newsletters and other communications
- We process personal data to ensure the performance, functionality and security of our website. Please see the section Online Tracking Technologies for further information, including how to disable cookies and otherwise make choices with respect to such data collection.
- We also use third-party marketing automation providers. These industry standard technologies and practices enable us to gather statistics around email opening and clicks to better understand our service offerings meet our stakeholders’ needs.
Personal data we process for operating and managing our business operations
- We process personal data when engaging service providers, other KPMG member firms, contractors or suppliers relating to the operation of our business. This data typically includes personal and contact details as well as data related to our business relationship. In most cases, we receive this data directly from the member firm, contractor or supplier.
- We also process personal data of visitors to our offices and premises. Visitor data is used to control access to our buildings as well as to protect the staff and information in our offices. We may require visitors to sign in at the reception. Some of our offices use CCTV monitoring.
- We process personal data of visitors to our events. We may request voluntary information about dietary requirements in order to cater to your needs when attending our events.
Personal data we process for administrative purposes
- We may also use personal data for administrative purposes such as accounting and tax purposes, as well as to fulfill our statutory duties and meet our other professional requirements.
- This includes processing that is necessary to comply with professional, legal and regulatory obligations that apply to our business, such as auditor independence or anti-money laundering requirements. For example, we process identification and background information as a part of our client acceptance and administration processes, and we request this data directly from our clients or collect the data from sources such as the local Trade Register or other external databases.
- We also process personal data for purposes related to invoicing, billing and financial administration. The data we process for this purpose typically includes contact details and financial information such as payment-related information.
- We may also process personal data to establish, exercise or defend legal rights, or for handling queries by supervisory authorities.
Our legal grounds for processing personal data
When processing personal data, we will rely on one of the following processing conditions:
- Performance of a contract: this is when the processing of personal information is necessary in order to perform our obligations under a contract
- Legal obligation: this is when we are required to process 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 personal information where it is in our legitimate interest in running a lawful business to do so, as long as the processing is compatible with your rights and interests. Our legitimate interests relate to processing personal data e.g
- To offer information and/or services to individuals who visit our website.
- 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 analyze, our marketing activities.
- To meet our corporate and social responsibility obligations.
- To assess any conflict of interest or challenge with regard to independence legislation or other professional standard.
- Consent: in some cases, we will ask the data subjects for a specific permission to process personal information, and we will only process this personal information in this way if they agree to us doing so. A data subject may withdraw their consent at any time by contacting KPMG Finland at privacy@kpmg.fi and KPMG Estonia at dpo@kpmg.ee.
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.
Sharing personal data with third parties
We will not share personal data with a third party outside the KPMG network, except in limited circumstances.
Transfers within the KPMG network
We share personal data 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.
Transfers to third parties
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. This includes:
- Our service providers: in some cases our third party service providers, such as our (IT) systems providers, hosting providers, payroll providers, consultants (such as legal advisers) and other goods and services providers may process personal data on our behalf. KPMG will only transfer personal information to our service providers when they meet our strict privacy and information security standards. We only share personal information that is necessary for them to provide their services.
- If we are reorganized or sold to another organization: in the event of a sale, assignment, or other transfer of any element of KPMG’s business, it may be necessary for us to disclose related personal information.
- Courts, tribunals, law enforcement or regulatory bodies: KPMG will disclose personal information 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 information will also be needed for data protection 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. Some of these insurance market participants (e.g. brokers, insurers and reinsurers, as well as their professional advisors and other third parties involved should there be a claim) will require that we disclose personal data to them. The information will be used by the insurance market participants in the underwriting and ongoing administration of the insurance programme. Some of our insurers process this data on our behalf, but others process personal data independent of us.
Data transfers, storage, and processing globally
KPMG may transfer certain personal information outside of the EEA to outside companies working with us or on our behalf for the purposes described in this Privacy Statement. KPMG may also store personal information outside of the EEA. We routinely send, store or otherwise process your personal information in the following locations:
- where there is a KPMG Member Firm;
- where our Global Data Centers are located;
- where our IT Support Providers are located; and
- where our other service providers are located.
If we do this, any personal information 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 or by another transfer mechanism in compliance with applicable Data Protection Legislation.
Data retention
We retain personal data only for as long as it is necessary for the purpose of processing. The applicable retention period for personal data is defined according to our information management policies and varies depending on the processing activity, taking into account any applicable legal requirements and professional standards that may apply to us or our clients.
We evaluate the applicable retention periods regularly. The data will be either erased or anonymized after the expiration of applicable retention period.
Your choice
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.
For preventing cookies tracking you, see section “Cookies” below.
Your rights
If we process 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. 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. 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 if we are not entitled to use it any more
- Other rights: in addition, you may have rights to have your information deleted if we are keeping it too long, have its processing restricted in certain circumstances and/or to obtain copies of information we hold about you in electronic form.
You can make a request or exercise these rights by contacting KPMG at privacy@kpmg.fi for KPMG Finland and dpo@kpmg.ee for KPMG Estonia and 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.
Finally, you always have the right to lodge a complaint with the regulator in charge of protecting personal information, the national supervisory authority.
Use of online tracking technologies
We use 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 our online presence, and to measure the effectiveness of our marketing activities.
IP addresses: An IP address is a number assigned to your device whenever you access the internet. It allows devices and servers to recognize 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 website trend and performance analysis.
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 serve a number of purposes.
On our websites, we have a notification banner (cookie banner) through which you may provide consent for us to collect cookies. If you wish to revoke your selection, you may do so by updating your preferences by using the "Cookies Settings" button at the bottom of any KPMG website or cookie banner. The purpose, description, type (first/third party cookie) and expiry date of each individual cookie are stated under cookie settings.
Below is a summary of the purposes 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. Therefore, even if you reject all the cookies, we are still allowed to apply the strictly necessary cookies. These are commonly First Party cookies and are stored for a session, a few seconds, or approximately one year.
- 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. These are commonly First Party cookies and are stored for a session or for a few seconds.
- Functional cookies: Functional cookies are used to remember your 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. These are either First Party cookies that are stored for a few seconds or Third Party cookies that are stored for a few seconds or up to one year.
- 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. These are commonly both first and third party cookies and are stored for a session, few seconds or up to one year.
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 websites 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.
Location-based tools
We 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.
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 websites. 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 websites may host social media features such as blogs, forums, crowd-sourcing and other applications or services. 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.
Questions or comments about KPMG’s cookies activities can be addressed to privacy@kpmg.fi for KPMG Finland and dpo@kpmg.ee for KPMG Estonia.
Links to other sites
Please be aware that KPMG websites will typically contain links to other sites, including sites maintained by other KPMG 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 website and then navigating to another KPMG website while still logged in, you agree to the use of your personal information in accordance with the privacy statement of the KPMG website you are visiting.
Data Security
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.
Changes to this 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.
KPMG Oy Ab is a Finnish and KPMG Baltics OÜ is an Estonian limited liability company and a member firm of the KPMG network of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee which provide no client services.