MOORE Sweden – Processing of Personal Data

MOORE Sweden and its network firms will process personal data in accordance with applicable law. The personal data that will be processed is obtained from the client, its group companies (where applicable), or other sources, such as the Swedish Tax Agency, the Swedish Companies Registration Office, or publicly available sources, and relates to authorized representatives and other individuals whose personal data is required to manage the client relationship, as well as beneficial owners.

Personal data is processed prior to the acceptance of clients and/or engagements and in connection with the performance of the engagement in order to carry out independence checks, quality controls, conflict of interest checks, measures pursuant to the Swedish Act (2017:630) on measures against money laundering and terrorist financing (“the Anti-Money Laundering Act”), as well as to document measures taken. Such processing is necessary to comply with the legal obligations imposed on MOORE Sweden or an auditor within MOORE Sweden who has undertaken to perform the engagement. 

MOORE Sweden may also process personal data for other risk management purposes (such as insurance matters) and for internal financial reporting. This processing is necessary for MOORE Sweden’s legitimate interest in managing risks and potential claims. The categories of personal data that may be processed for the above purposes include, among others, contact details such as name, address, personal identity number/co-ordination number, telephone number, email address, as well as information regarding departmental affiliation and position. In connection with client registration, MOORE Sweden may also process copies of identity documents for individuals representing the client within the framework of customer due diligence measures required under the Anti-Money Laundering Act. MOORE Sweden may also process personal data such as name, department, position and email address in order to provide information about seminars and other events organized by MOORE Sweden and its firms, as well as to send newsletters and other marketing materials. Processing for these purposes is necessary for MOORE Sweden’s legitimate interest in reaching employees of clients who may be interested in events, marketing and news relevant to their roles. 

Transfers to Third Countries

Personal data may be processed by MOORE Sweden’s network firms and other parties engaged by MOORE Sweden for the purpose of carrying out the measures described above on behalf of MOORE Sweden; such parties may be located both within and outside the EU/EEA. When personal data is transferred for processing to a country outside the EU/EEA that does not ensure an adequate level of protection, MOORE Sweden is responsible for ensuring that appropriate safeguards are in place, for example through standard data protection clauses adopted by the European Commission in accordance with Article 46 of the General Data Protection Regulation, provided that enforceable data subject rights and effective legal remedies are available. 

Recipients of the Information

MOORE Sweden and its network firms are obligated to ensure that information processed in connection with an engagement is not made available to unauthorized parties, which means that personal data will be treated confidentially. 

MOORE Sweden may disclose personal data to network firms or other parties engaged by MOORE Sweden for the purpose of monitoring and maintaining MOORE Sweden’s objectivity and independence, performing quality controls and other risk management measures, and for distributing invitations to events and other marketing materials. MOORE Sweden may also disclose personal data to insurance companies or legal advisors in connection with legal proceedings to the extent required for MOORE Sweden and its network firms to safeguard their legitimate interests, or to other recipients where such disclosure is required by applicable laws and regulations, professional obligations or decisions by authorities.

Security of Personal Data Processing

MOORE Sweden is responsible, in accordance with applicable law, for ensuring that personal data is protected through appropriate technical and organizational security measures, taking into account the nature and sensitivity of the personal data. MOORE Sweden’s systems and organization are structured so that unauthorized persons do not have access to personal data processed in connection with an engagement. 

Retention of Personal Data

Personal data will not be processed for longer than is necessary for the purposes for which it is processed. 

Rights of Data Subjects

In certain cases, data subjects have the right to request information as to whether personal data relating to them is being processed and, if so, to obtain access to such personal data in the form of an extract from the register. Data subjects also generally have the right to have inaccurate personal data corrected. Furthermore, data subjects may have the right to have their personal data erased, to request restriction of processing, or to object to such processing. Data subjects also have the right to lodge a complaint with a supervisory authority regarding the processing. 

With regard to personal data processed in connection with client acceptance and engagements, as well as during the performance of engagements, MOORE Sweden and its network firms are required to retain documentation for at least ten years. This means that it is not permitted to delete personal data included in such documentation before that time, and in some cases it is not permitted to correct the data either. For these reasons, MOORE Sweden is not able, in such cases, to restrict or limit the processing of personal data upon request from a data subject. However, with regard to MOORE Sweden’s processing of personal data for marketing purposes, data subjects have the right to request deletion, correction, restriction and to object to such processing. 

Kontaktperson vid frågor:

Kajsa Larsson

031-722 42 00
 Comment: These are available at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en