Client Privacy Notice
Effective date: 25 May 2018
PRIVACY NOTICE FOR CLIENT PERSONAL INFORMATION AT BDO UAE
Introduction
Information we collect
▪ Information we collect directly from you
▪ Information we collect from other sources
How we use your personal information and the basis on which we use it
Your rights over your personal information
Information sharing
Information security
Information transfer
Contact us
Changes to privacy notice
Introduction
This Privacy Notice describes how BDO Chartered Accountants & Advisors, UAE (“BDO UAE”) collects and processes personal information about you; how we use and protect this information, and your rights in relation to this information. This privacy notice applies to all personal information we collect about you. Personal information is information, or a combination of pieces of information that could reasonably allow you to be identified.
Throughout this Privacy Notice we use the term “processing” to cover all activities involving your personal information, including collecting, handling, storing, sharing, accessing, using, transferring and disposing of the information.
Information we collect
We may collect your personal information from a variety of sources, including information we collect from you directly (e.g. when you contact us and we provide services to you), and information we collect about you from other sources, including commercially available sources, such as public databases (where permitted by law).
Certain personal information is required as a consequence of any contractual relationship we have with you or your organization, to enable us to carry out our contractual obligations to you or your organization. Failure to provide this information may prevent or delay the fulfilment of these obligations.
Information we collect directly from you
The categories of information that we may collect directly from you include the following:
(a) personal details (e.g. name, age, date of birth, photographs, nationality);(b) contact details (e.g. phone number, email address, postal address or mobile number);
(c) employment details (e.g. job title, employer name, etc.);
(d) KYC Information (e.g. Passport, other KYC documents, Photographs, Curriculum vitae,
etc.);
(e) legal documents (e.g. POA, Will, Confidential contracts, etc.);
(f) Personal financial information (e.g. salary details, investment details, etc.);
(g) any other specific categories of personal data where required.
Information we collect from other sources
The following are examples of the categories of information we may collect from other sources:
(a) personal details (e.g. name, age, date of birth, photographs, nationality);(b) contact details (e.g. phone number, email address, postal address or mobile number);
(c) employment details (e.g. job title, employer name, etc.);
(d) background and referral checks, conflict and independence checks, etc.;
(e) information on criminal convictions, sanctions, any other disciplinary proceedings,
etc.;
(f) other details (e.g. Professional details including memberships, Business activities,
complaints, proceedings and incident details, Professional advice or opinions, Social
media details etc.)
How we use your personal information and the basis on which we use it
We use your personal information to:
- carry out our obligations to you under this contract to provide any services you request from us;
- carry out background checks, conflict and independence checks, prior to accepting you as a client and during the course of the engagement and for continuance of client relationship;
- contact you with questions and other information regarding the services we are providing to you;
- ensure that our records are kept accurate and up to date where you, your employees or contractors work on or visit our facilities;
- ensure we issue accurate invoices for our services;
- send you messages about products and services which we think will be of interest to you;
- comply with legal obligations to which we are subject;
- comply with requests from local and regulatory authorities or proceedings from organisations, local and regulatory authorities, public authorities or institutions.
We must have a legal basis to process your personal information. In most cases the legal basis will be one of the following:
- To fulfil our contractual obligations to you, for example to ensure that invoices are issued correctly and for ensuring you are able to access our premises when required;
- to fulfil our responsibility to adherence with professional standards as applicable to BDO UAE, for example performing Independence and conflict of interest checks, onboarding/engagement acceptance/ client continuance process;
- to comply with our legal obligations to you, for example our obligation to maintain client records, statutory returns, crime prevention, ensure our compliance with anti-money laundering and anti-bribery legislations, Know Your Clients procedures (KYC), health and safety obligations while you are on our premises, or to a third party (e.g. to comply with an order of competent court or tribunal);
- to meet our legitimate interests so that: we are able to provide the services you request; our services function correctly in relation to your business; any complaints or concerns can be promptly relayed to you; we can respond to any questions or concerns you might have; we may carry out research and analysis to ensure products and services we offer are relevant to you, and; our records are kept up to date and accurate; When we process your personal information to meet our legitimate interests we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms. For more information about the balancing test that we carry out to process your personal information to meet our legitimate interests or if you want to object tothese uses of your personal information, please contact us at the details below; and
- send you direct electronic marketing messages to the agreed personnel by post, fax, e-mail, telephone or social media channels, to bring to your attention additional products or services (including those provided by associated BDO entities) which we may consider to be of benefit to you to the extent you have consented to receiving such messages in accordance with applicable law.
Your rights over your personal information
Please let us know if any of the personal information that we hold about you changes so that we can correct and update the information on our systems.
We have taken all reasonable measures to ensure that personal data is processed in accordance with applicable Data Protection Law and any other relevant laws, and to notify you if instruction infringes any law to which we are subject.
You can view, delete, correct or update the personal information you provide to us by contacting the respective engagement manager or dataprivacy@bdo.ae to action the requests.
In certain circumstances you may object to specific processing activities (including where we rely on our legitimate interests as set out above), require us to restrict how we process your personal information and ask us to share your personal information in a usable format with another company. Where you have given your consent to a particular type of processing, you may withdraw that consent at any time.
If you wish to opt-in to receive communications on service offering, events, seminars, newsletters amongst others, you may register with us by visiting our website – www.bdo.ae. However, if you wish to unsubscribe to any of these communications, you may do so by sending an email to marketing@bdo.ae.
You have the right of access under data protection legislation to personal data we hold about you. To exercise any of the above rights, please contact us using the contact details set out below in the notice.
Information sharing
In general, we do not share your personal information with third parties (other than service providers acting on our behalf) unless we have a lawful basis for doing so.
We rely on third-party service providers to perform a variety of services on our behalf, such as website hosting, electronic message delivery, payment processing, data analytics and research, background screening and sanction checks. This may mean that we have to share your personal information with these third parties. When we share your personal information in this way, we put in place appropriate measures to make sure that our service providers keep your personal information secure.
Other situations in which we may disclose your personal information to a third party are:
(a) perform other services we request from service providers;(b) perform other background checks, sanctions screening, conflict and independence
checks, using authorized third-party licenses and tools;
(c) in the course of a sale or an acquisition of a member firm;
(d) where permitted by law, to protect and defend our rights and property; and
(e) when required by law, and/or public authorities.
We may also share aggregated information that cannot identify you for general business analysis, e.g. we may disclose the number of visitors to its websites or services.
Information Security
We have implemented generally accepted standards of technology and operational security to protect personal information from loss, misuse, alteration or destruction. We have taken all reasonable steps to ensure that the personal data is protected against misuse and accidental loss or disclosure, and from unauthorized or unlawful processing, destruction or alteration, and in case of any personal data breach (as defined by applicable Data Protection Law) we will notify you without undue delay upon becoming aware of it. We require all employees and principals to keep personal information confidential and only authorized personnel have access to this information.
We will retain your personal information in accordance with our data retention policy. It is our normal practice to retain documents relating to client engagements as per the retention period prescribed in the local UAE Regulations (which is in between five to ten years depending on the jurisdiction in which the client entity is incorporated or registered) from the end of the relevant Engagement. Where the client is incorporated or registered outside of the UAE, the retention period shall be determined as ten years. Thereafter, unless separate arrangements have been made, we may destroy or erase the documents or papers without reference to you.
We will keep your personal information for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal information for a period of time that enables us to: maintain our business records for analysis and/or audit purposes; comply with record retention requirements under the law; defend or bring any legal claims; and deal with any complaints. We will delete your personal information when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.
Information Transfer
As part of the processing, your personal information may be transferred to, stored, and processed in a country other than the one in which it was provided i.e. your personal data may be transferred to BDO employees including within BDO member firms in other jurisdictions (including relevant KYC information where you have also contacted BDO for provision of other services), use authorized third party licenses or tools or third parties who are bound by appropriate confidentiality and security obligations consistent with the terms of this clause. We shall not sub-contract our processing of personal data without your prior written consent. When we do so, we transfer the information in compliance with applicable data protection laws. When we do so, we transfer the information in compliance with applicable data protection laws. Where the transfer is to a country which provides a lower level of protection we take steps to ensure the security and confidentiality of your personal information in accordance with applicable data protection law, including using the European Commission's approved Standard Contractual Clauses, and for transfers to other BDO Member Firms, we use the BDO Global Privacy Policy, BDO’s Binding Corporate Rules for Controllers and Processors. If you wish to see a copy of the relevant mechanism that we use to transfer your personal information, please contact us using the contact details set out below.
Contact Us
We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If you have questions or concerns regarding the way in which your personal information has been used, please send your queries relating to data privacy to dataprivacy@bdo.ae. We will endeavor to respond to your reasonable enquiries to and also provide you with reasonable assistance to enable you to comply with applicable Data Protection Laws as and when required. For further details on privacy, please visit the privacy page on our website https://www.bdo.ae/en-gb/client-privacy-notice.
Changes to Privacy Notice
You may request a copy of this privacy notice from us using the contact details set out above. We may modify or update this privacy notice from time to time. You will be able to see when we last updated the privacy notice because we will include a revision date. Changes and additions to this privacy notice are effective from the date on which they are posted. Please review this privacy notice from time to time to check whether we have made any changes to the way in which we use your personal information.
Last modified 30 April 2025