Last updated April 2018
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 data (sometimes also referred to as “personal information”).
Generally, our intent is to collect only the personal data that is provided to us so that we can offer information and/or services or offer information about employment opportunities. Please review this privacy statement ("Privacy Statement") to learn more about how we collect, use, share, protect and process the personal data that we have obtained.
- 1. Collection and use of personal information
1.1 What type of data do we collect
1.2 The legal grounds we have to use your personal data
1.3 The purposes for which your personal data will be processed
1.4 Automatic collection of personal information
1.4.1 IP addresses
1.4.2 Web beacons
1.4.3 Location-based tools
1.5 Social media widgets and applications
- 2. Sharing and transfer of personal data
2.1 Transfers to third parties
- 3. Choices
- 4. Your rights
- 5. Data security and integrity
- 6. Links to other sites
- 7. Changes to this statement
- 8. Who is responsible for the processing of your personal data
- 9. Who to contact in case of questions
- 10. Statement questions and enforcement
We obtain personal data about you if you choose to provide it — for example, to contact mailboxes or to register for certain services. In some cases, you may have previously provided your personal data to KPMG (if, for example, you are a former employee). If you choose to register or login to a KPMG web site using a
third party single sign-on 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 may 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, you are giving your explicit consent to us so that KPMG may use this data in accordance with this Privacy Statement. Your personal data is not used for other purposes, unless we obtain your permission, or unless otherwise required or permitted by law or professional standards. For example, if you register to a KPMG web site 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 subscribe to receive direct marketing (i.e. newsletters, insights, events, etc.) we may use your personal data in order to send you such messaging. 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 may store your email address until we receive confirmation within 48 hours of the information you provided (i.e. where we send an email to the email address provided as part of your registration to confirm a subscription request).
KPMG generally collects only the personal data necessary to fulfill your request. Where additional data is sought, you will be notified of this at the point of collection.
The applicable legislation allows us to process personal data, so long as we have a processing 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 legal grounds for processing:
- Performance of a contract: this is when the processing of your personal data is necessary in order to perform our obligations under a contract or the intention to enter into 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 may process data 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: we may occasionally 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. You may withdraw your consent at any time by contacting KPMG at email@example.com.
KPMG only collects special categories of personal data when the relevant individuals voluntarily provide us with this information or where such information is required or permitted to be collected by law or professional standards. Special categories of personal data includes personal data regarding a person's race, ethnicity, political opinions, trade union membership, religious or philosophical beliefs, data concerning health, genetic data, biometric data, sexual life or orientation, or criminal record. Please use your discretion when providing special categories of personal data to KPMG, and under any circumstances, do not provide special categories of personal data to KPMG, unless you thereby explicitly consent to KPMG's use of that information for its legitimate business purposes
We will only process your personal data for specified, explicit and legitimate purposes and we will not process your personal data further in a way that is incompatible with those purposes.
This purpose can be the execution of an engagement, the improvement of your visit on our website or portals, the improvement of our products and services more generally, the offering of services or applications, marketing communications and actions, web personalization, direct marketing, web analytics, etc.
The purpose of each processing of your personal data will be clearly defined in the privacy notice. This privacy notice will be accessible, for example, on a website or portal, on an application, in an electronic newsletter, etc.
An IP address is a number assigned to your computer or internet enabled device whenever you access the internet. It allows computers and servers to recognize 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 web site trend and performance analysis.
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 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 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 may 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.
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.
KPMG web sites 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. 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.
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.
We do not share personal data with unaffiliated 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 would include:
In some instances, KPMG may also share personal Data about you with various outside companies or service providers or vendors working on our behalf.
In addition, KPMG may transfer certain personal data across geographical borders to other KPMG member firms or outside companies working with us or on our behalf. KPMG may also store personal data in a jurisdiction other than where you are based. Transfer of personal data by KPMG takes place in accordance with the applicable Belgian data protection legislation
- KPMG may also disclose personal data to our service providers: KPMG works with reputable partners, service providers or agencies so they can process your personal data on our behalf. KPMG will only transfer personal data to them when they meet our strict standards on the processing of data and security. We only share personal data that allows them to provide their services.
- If we are reorganized or sold to another organization: KPMG may also disclose personal data in connection with the sale, assignment, or other transfer of the business of the site to which the data relates;
- Courts, tribunals, law enforcement or regulatory bodies: KPMG may 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 regulations.
- Audits: disclosures of personal data may also be needed for data privacy or security audits and/or to investigate or respond to a complaint or security threat.
In addition, KPMG may transfer certain personal data 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 data outside of the EEA. If we do this your personal data will continue to be protected by means of contracts we have in place with those organisations outside the EEA, which are in a form approved by the European Commission. By providing personal data online, visitors are consenting to this transfer and/or storage of their personal data across borders.
KPMG will not transfer the personal data you provide to any third parties for their own direct marketing use.
In general, you are not required to submit any personal data to KPMG, but we may require you to provide certain personal data 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, 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.
If you have submitted personal data to KPMG, 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 data to you, we will provide it to you free of charge. Before providing personal data to you, we may ask for proof of identity and sufficient information about your interactions with us that we can locate your personal data. If the information we hold about you is incorrect, you may ask us to correct any inaccuracies in the personal data.
- Object to processing: you have the right to object to us processing your personal data if we are not entitled to use it any more, to have your data deleted if we are keeping it too long or have its processing restricted in
- Right to restriction of processing: you have the right to request a restriction on the processing of your personal data (for example, while the accuracy of your personal data is being checked).
- Right to erasure: you have the right to the erasure of any data concerning you (except in some cases, for example, to prove a transaction or when required by law).
- Right to data portability: under certain conditions, you have the right to receive your personal data, which you have provided to us, in a commonly used, structured machine readable format and to transmit your personal data to any third party of your choice.
You can make a request or exercise these rights by filling out this form 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.
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 personal data are required to maintain the confidentiality of such information.
We also make reasonable efforts to retain personal data only for so long as the data is necessary to comply with an individual's request or with the applicable legislation.
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.
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. We encourage you to periodically review this Privacy Statement to be informed about how KPMG is protecting your data.
If we make any significant changes in the way we treat your personal data we will make this clear via our website.
KPMG is responsible for the processing of your personal data.
KPMG Central Services a Belgian Economic Interest
Luchthaven Brussel Nationaal 1K
We have appointed a data protection officer who will handle your questions or requests relating to this Privacy Statement, any specific privacy notice or your personal data (and its processing).
For any questions or requests or complaints concerning the application of this Privacy Statement or to exercise your rights, as described in this this Privacy Statement, you may contact us at firstname.lastname@example.org.
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 email@example.com.
You may also use this address to communicate any concerns you may have regarding compliance with our Privacy Statement.
In any event, you always have the right to lodge a complaint with the Belgian regulator in charge of protecting personal data, i.e. the Belgian data protection authority.
Data Protection Authority
Drukpersstraat 35, 1000 Brussel
Tel: +32 (0)2 274 48 00
Fax: +32 (0)2 274 48 35
1 "KPMG," "we," "our," and "us" refers to KPMG Central Services ESV/GIE and its members, all Belgian KPMG entities (https://home.kpmg.com/be/en/home/misc/belgian-kpmg-entities.html).