Privacy | KPMG | KE
close
Share with your friends

Privacy

Privacy

Last Updated July 19, 2018

This website is operated by KPMG East Africa (“KPMG”, “we” or “us”), a member firm within the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. KPMG International does not provide client services.

At KPMG East Africa1 we are dedicated to upholding and protecting the confidentiality and privacy of information entrusted to us by, among other things, complying with the EU General Data Protection Regulation (GDPR).

Please read this Privacy Notice to learn about your rights .as a data subject and about how we collect, use, share and protect personal data.

 

 

1. What does the Privacy Notice provide for?

This Privacy Notice provides for your rights as a datasubject and for information on how we collect, use, process, share and protect your personal data.

 

2.  How do we collect personal data?

  • Directly
We obtain personal data directly from individuals who; provide us with their business cards, complete our online forms and surveys, subscribe to our newsletters, attend meetings or events we host, register
for webinars, visit our offices or apply for open roles. 
 
We may also obtain personal data directly when establishing a business relationship, providing professional services through a contract or, through our hosted software applications. 
 
  • Indirectly
 
We obtain personal data indirectly from a variety of sources which we may attach to our customer relationship management records to better understand and serve our business clients, subscribers and individuals, to
satisfy a legal obligation, or to pursue our legitimate interests. 
 
      We indirectly obtain personal data from:
  1. Public sources such as public registers, news articles, sanctions lists, Internet searches and other public domains.
  2. Social and professional networking sites such as LinkedIn, Google, or Twitter. If you register or login to our websites using social media 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.
  3. Business clients - Our business clients may engage us to provide professional services which involve sharing personal data they control as part of that engagement. This may include processing personal data under our clients’ control on our hosted software applications which may be governed by different
    privacy terms and policies.     
  4. Recruitment services. We may obtain personal data about candidates from an employment agency and other parties including former employers and credit reference agencies.

 

3. What categories of personal data do we collect?

We may obtain the following categories of personal data through direct interactions or from information provided to us through client engagements, applications e.g. for employment, third party relationships e.g.
with suppliers and through other situations including those described in this Privacy Notice.

 

Personal data

Below is a list of examples of personal data we commonly collect to conduct our business activities.    

i. Contact details (e.g., name, company name, job title, work and mobile telephone numbers, work and personal email and postal address).                

ii. Professional details (e.g., job and career history, educational background and professional memberships, published articles).                  

iii. Family and beneficiary details for insurance and pension planning services (e.g., names and dates of birth).                

iv. Financial information (e.g., taxes, payroll, investment interests, assets, bank details).                  

v. CCTV footages. CCTV at our sites may collect images of visitors. Our policy is to automatically                overwrite CCTV footage after 45 days.

 

Sensitive personal data

We typically do not collect sensitive or special categories of personal data and when we do need to process sensitive personal data, it is with the consent of the individual unless it is obtained indirectly for legitimate purposes. Examples of sensitive personal data we may obtain include: 

       
I. Dietary restrictions or access requirements when
registering for in-person events that reveal religious beliefs or physical
health.

II. Personal identification documents that may
reveal race or ethnic origin, and possibly biometric data of private
individuals, beneficial owners of corporate entities, or applicants.

III. Expense receipts submitted for individual tax or accounting advice that reveal affiliations with trade unions or political opinions.

IV. Adverse information about potential or existing clients and applicants that may reveal criminal convictions or offences information.

V. Information provided to us by our clients in the course of a professional engagement.

 

Child data

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.

 

Location-based data.

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.

 

4. What lawful reasons do we have for processing personal data?

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.

We rely on the following lawful reasons to collect and use personal data in the course of operating our business and providing our products and services: 

  • Contract.We may process personal data in order to perform our contractual obligations.
  • Consent. We may rely on your freely given consent at the time you provided your personal data to us. 
  • Legitimate interests.We may rely on legitimate interests based on our evaluation that the processing is fair, reasonable and balanced. These include:    
    • Delivering services to our clients – To deliver the professional services our clients have engaged us to provide.      
    • Direct marketing – To deliver timely market insights and speciality 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 data in order to meet legal, regulatory and public interest obligations or mandates. 

 

5.  Why do we need personal data?

We aspire to be transparent when we collect and use personal data and tell you why we need it, which typically includes: 

  • Providing professional advice and delivering reports related to our tax, advisory, audit and assurance, payroll, restructuring, mergers and acquisitions and other professional services. Our services may include reviewing client files for quality assurance purposes, which may involve processing personal data for the relevant client.
  • Promoting our professional services, products and capabilities to existing and prospective business clients.
  • Sending invitations and providing access to guests attending our events and webinars or our sponsored events.
  • Personalising online landing pagesand communications we think would be of interest based on interactionswith us and other KPMG member firms. 
  • 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 People team, 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.
  • Travel arrangement assistance.
  • Helping support clients to run a series of development programs for education and learning purposes to inform leaders in various industries and sectors.
  • Complying with legal and regulatory obligations relating to countering money laundering, terrorist financing, fraud and other forms of financial crime. 

 

 

6.  Do we share personal data with third parties?

We may occasionally share personal data with trusted third parties to help us deliver efficient and quality services. These recipients are contractually bound to safeguard the data we entrust to them. We may engage ith several or all of the following categories of recipients:

  • KPMG member firms, where necessary for administrative purposes and to provide professional services to our clients (e.g., when providing services involving advice from KPMG member firms in different territories).
  • Parties that support us as we provide our services (e.g., providers of telecommunication systems, mailroom support, IT system support, archiving services, document production services and cloud-based software services). 
  • Our professional advisers, including lawyers, auditors and insurers.
  • A potential buyer, transferee, merger partner or seller and their adviser in connection with an actual or potential transfer or merger/acquisition of part or all of our business or assets, or any associated rights or interests. 
  • Payment services providers.
  • Marketing services providers.
  • Law enforcement or other government and regulatory agencies or to other third parties as required by, and in accordance with, applicable law or regulation.
  • Recruitment services providers.

 

7. Do we use cookies?

Our websites may use cookies. Where cookies are used, a statement will be sent to your browser explaining the use of cookies. To learn more, please refer to our cookie policy

 

8. What are your rights as a data subject? 

Below are your data protection rights. 

  • Access. You have a right to access your person data and you can ask us to verify whether we are processing personal data about you, and if so, to provide more specific information.
  • Correction. 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 data 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 data if you contest the accuracy of your personal data, 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.
  • Data portability. In some circumstances, where you have provided personal data to us, you can ask us to transmit that personal data (in a structured, commonly used, and machine-readable format) directly to another company if is technically feasible.
  • Automated Individual Decision-making. You can ask us to review any decisions made about you which we made solely based on automated processing, including profiling, that produced legal effects concerning you or similarly significantly affected you.
  • Right to Object to Direct Marketing including Profiling. You can object to our use of your personal data 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 of processing your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. This may however affect the provision of certain products or services to you and we will advise you if this is the case.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information or to exercise any of your other rights. This helps us to ensure that personal data is not disclosed to a person who has no right to receive it. No fee is required to make a request unless your request is clearly unfounded or excessive Depending on the circumstances, we may be unable to comply with your request based on other lawful grounds.

Should you have a data request, please email through the address privacykenya@kpmg.co.ke. to submit it to us and we shall endeavour to promptly respond. 

 

9. What about personal data security?

We have put appropriate technical and organisational security policies and procedures in place to protect personal data (including sensitive personal data) from loss, misuse, alteration or destruction. We aim to ensure that access to your personal data is limited only to those who need to access it. Those individuals who have access to the data are required to maintain the confidentiality of such information. We may apply eudonymisation, de-identification and anonymisation techniques in efforts to further protect personal data.

If you have access to parts of our websites or use our services, you remain responsible for keeping your user ID and password confidential. Please be aware that the transmission of data via the Internet is not completely secure. Whilst we do our best to try to protect the security of your personal data, we cannot ensure or guarantee the security of your data transmitted to our site; any transmission is at your own risk. 

 

10. How long do we retain personal data?

We retain personal data to provide our services, stay in contact with you and to comply with applicable laws, regulations and professional obligations that we are subject to. Unless a different time frame applies as a result of business need or specific legal, regulatory or contractual requirements, where we retain personal data in accordance with these uses, we retain personal data for ten years. We will dispose of personal data in a secure manner when we no longer need it.

 

11. Do we link to other websites?

Our websites may contain links to other sites, including sites maintained by other KPMG member firms that are not governed by this Privacy Notice. Please review the destination websites’ privacy policies before submitting personal data on those sites. Whilst we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other sites.

 

12.  Who can you contact for privacy questions or concerns?

If you have any question or comment about this Privacy Notice or about how we handle personal data, please contact us through the physical address Privacy Liaison, ABC Towers, P.O Box 40612-00100 Nairobi or on email through the address privacykenya@kpmg.co.ke. We aim to respond within 30 days from the date we receive privacy-related communications.

 

13. Do we change this Privacy Notice?

We regularly review this Privacy Notice and will post any updates to it on this webpage. This Privacy Policy was last updated on Jul 2018.

 

1 KPMG East Africa refers to KPMG East Africa Limited, KPMG Kenya, KPMG Advisory Services Limited, KPMG Rwanda Limited, KPMG Tanzania and KPMG Uganda