This Privacy Statement explains how Santa Fe Associates International L.L.C. processes personal data collected through websites, products, and services (“applications”) and through in-person and digital events, webinars, surveys, marketing activities, and visits to our premises (along with applications, collectively our “offerings”). References to “SFAI Qatar,” “we,” or “our” means Santa Fe Associates International L.L.C. – a QFC registered entity in Qatar. and other entities that belong to the SFAI corporate family and that link to this Privacy Statement.
We may display supplemental privacy notices on occasion, such as when we believe additional transparency would help you make an informed choice about whether to provide personal data. For example, you may see a supplemental privacy notice explaining a particular data collection program, or you may see a supplemental privacy notice when registering for an event.
SFAI Qatar processes personal data for a variety of purposes. We collect this personal data directly from you, for example, if you engage us to prepare your tax return, if you visit SFAI Qatar website, if you submit your contact details to receive marketing communications from us, if you submit event-related data to attend SFAI Qatar events or submit a job application via the SFAI Qatar careers website. Alternatively, we process your personal data in the context of providing professional services to your employer or service provider, for example, conducting an audit of your bank or payroll for the company you work for. Finally, we obtain your personal data via publicly available sources, such as LinkedIn. This privacy notice is intended to cover all the above-mentioned scenarios. Following are the additional sources to collect personal data:
In case you have any inquiries regarding the processing of your personal data or wish to contact the data protection officer of SFAI Qatar, please contact the SFAI Qatar data protection team who will direct your query to the appropriate person or team within the organization.
What data is covered?
In this privacy statement, “personal data” means any information relating to an individual who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data or an online identifier. Personal data also refers to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of an individual.
It also includes special categories of personal data (special category data) from which we can determine or infer an individual’s:
As well as personal data relating to criminal convictions and offenses
Your rights in relation to personal data
You have the following rights in relation to your personal data:
If you have a query or wish to exercise your rights, please speak to the person you usually deal with at SFAI Qatar or contact the SFAI Qatar data protection team.
If you are concerned about an alleged breach of privacy law or any other regulation by SFAI Qatar, you can contact the person you usually deal with at SFAI Qatar, Shoumoukh Tower B, 10th Floor C Ring Road Doha, Qatar.
Purposes for which we process personal data
Visitors to SFAI Qatar website
Personal data that we collect about you when you visit our site falls into several categories.
We collect personal data that you provide voluntarily through our site, for example, when completing online forms to contact us, subscribing to a newsletter, using one of our online benchmark tools, subscribing to receive marketing communications from us, participating in surveys or registering for events that we are organizing. The information we collect about you include the following:
We do not intentionally collect sensitive category data unless you provide us with such data. While there may be free text boxes on the site where you are able to enter any information, we do not intend to process sensitive information. You are not required to provide, and should not disclose, sensitive personal information in the free text boxes. If you choose to provide any sensitive personal information in this manner, you acknowledge you consent to the collection and processing of this sensitive information.
if you register on our site, your personal data will be stored in our CRM system. Data of registrants is deleted after an individual has not actively engaged with SFAI Qatar for 18 months, or sooner if required by law.
If you have opted out of receiving SFAI Qatar publications, your basic contact details will remain on our opt-out list.
Information that we collect automatically
Our site also uses various social media plugins.
Purposes for which we process your personal data as a visitor to our site are:
Legal grounds for processing personal data of visitors of our site are:
When you engage us to provide you with professional services, we collect and use personal data when we have a valid business reason to do so in connection with those services. In the context of providing professional services to clients, SFAI Qatar also processes personal data of individuals who are not directly our clients (for example, employees, customers, or suppliers of our clients)
The majority of the personal data we collect and use to provide our services is supplied voluntarily by (or collected by us from third-party sources at the request of) our clients. Because of this, if you are a client of SFAI Qatar, then it will generally be obvious to you what personal data we collect and use. This information can include:
We use this information:
Given the diversity of the services we provide, we process many categories of personal data. Please see below (non-exhaustive) examples of personal data categories for our four main service lines:
Audit & Assurance
In providing audit and assurance services, SFAI Qatar will process information that contains personal data, such as payroll files, board records and other documents attributable to the audit client’s and any group companies’ activities. Examples of categories of personal data that are processed are:
Examples of personal data categories processed by SFAI Qatar tax client engagement teams are:
Advisory and Human Capital Solution.
In providing advisory and human capital solution services, SFAI processes a wide variety of information, including potentially all types of personal data. The scope depends on the service and the sector in which the SFAI Qatar’s client is active. Examples of personal data categories received or processed by Advisory client engagement teams are:
Individuals whose personal data we obtain in connection with providing services to our clients
As part of the professional services SFAI Qatar provides to clients, SFAI Qatar processes personal data of individuals with whom we do not have a direct (contractual or other) relationship. For example, if we perform a statutory audit, our engagement team will be required to audit our client’s books, which could include payroll data for employees of the client, supplier data, financial administration, data regarding claimants and legal proceedings. To take another example: if we undertake a due diligence review of an acquisition of a target on behalf of a client, SFAI Qatar obtains personal data concerning the target’s employees, management, and customers.
We seek confirmation from our clients that they have the authority to provide personal data to us in connection with the performance of the services and that any personal data they provide to us has been processed in accordance with applicable law.
Given the diversity of services we provide, we process many categories of personal data such as:
Legal grounds for processing personal data of individuals whose personal data we obtain in connection with providing services to our clients are:
Contacts in our customer relationship management (CRM) systems
We process personal data about contacts (former, existing, and potential clients and individuals employed by, or associated with, such clients and other business contacts, such as alumni, consultants, regulators, and journalists) in our CRM systems. These CRM systems support the marketing operations of SFAI Qatar. Contacts in our CRM systems will be sent SFAI Qatar, newsletters, marketing materials, learning opportunities, surveys, and invitations to events.
In our CRM systems, we process the following categories of personal data:
Data of business contacts who have not been actively engaged with SFAI Qatar in the past 18 months will be deleted from our CRM systems. If you have opted out of receiving future SFAI Qatar publications, your basic contact details will remain on our opt-out list.
Legal grounds for processing personal data of business contacts are:
Participants of SFAI Qatar meetings, conferences, events and learning sessions
We process personal data about participants in SFAI meetings, conferences, events and learning sessions (events). We use various applications to manage event registration processes, which applications will contain their own privacy notices explaining why and how personal data is collected and processed by these applications. We encourage participants to refer to the privacy notices available on those applications.
As part of our event management processes, we process the following personal data (but only to the extent required for a specific event):
We do not intentionally collect sensitive category data, unless you provide us with such data
Attendees of SFAI Qatar events hosted at external venues are required to bring a photo ID for identification purposes to safeguard our people, assets and information, and to prevent unauthorized people gaining access to off-site SFAI Qatar events.
SFAI Qatar is allowed to take photographs and make audio or video recordings in public areas of the SFAI Qatar events. We use such media in our marketing materials. Images and voices of attendees will be recorded. Recordings will be edited, copied, exhibited, published, or distributed.
Legal grounds for processing personal data of participants are:
Individuals who visit our social media sites, social media plugins and tools
Social media sites
SFAI Qatar uses various social media platforms, for example, for recruitment or marketing purposes. We use social media to provide you with easy access to relevant information regarding job opportunities at SFAI Qatar and events we organize, and to promote our services and brand.
While SFAI Qatar will be responsible for the content it publishes using social media platforms, SFAI Qatar will not be responsible for managing the social media platforms (such as creating user statistics or placing cookies). When using these social media platforms, you are obliged to adhere to the legal and privacy terms imposed by the social media platform providers. Such providers collect personal data about you, including statistical and analytical data regarding your use of the social media platforms, such as an overview of pages you have accessed, “likes,” recent visits, posts you publish or find interesting. If you require access to such data or want to invoke one of your other rights (such as the right to object to the processing of your data), you should contact the social media platform provider. Some social media providers provide SFAI Qatar with aggregate data relevant for our pages, such as the amount of “likes” triggered by our content or the number of posts, visitors to our sites, photos that are downloaded or links that are clicked.
Social Media Plugins
On our site, we implement so-called social media plugins. When you visit a page that displays one or more of such buttons, your browser will establish a direct connection to the relevant social network server and load the button from there. At the same time, the social media provider will know that the respective page on our site has been visited. We have no influence on the data that the social media providers collect based on the buttons. If you wish to prevent this, please log out of your social media accounts before visiting our website. Social media providers set cookies as well unless you have disabled the acceptance and storage of cookies in your browser settings.
Social media tools
Our site uses the Google Maps map service via an application programming interface (API).
To use Google Maps, it is necessary to save your IP address. This information is generally translated to a Google server in the United States and stored there. We have no influence on this data transfer.
Once LinkedIn members click on SFAI Qatar advertisement, they will see a form that is pre-filled with information from their LinkedIn profile, such as their name, contact information, company name, seniority, job title and location to get connected with SFAI Qatar
Legal grounds for processing personal data of visitors to our social media pages, and the use of social media plugins and tools are:
Individuals who correspond with SFAI Qatar via email
SFAI Qatar uses a variety of tools to maintain the security of our IT infrastructure, including our email facilities. Examples of such tools are:
If you correspond via email with an SFAI Qatar recipient, your emails will be scanned by the tools SFAI Qatar operates to maintain the security of its IT infrastructure, which could result in content being read by authorized SFAI Qatar persons other than the intended recipient.
Legal grounds for processing personal data of individuals who correspond with SFAI Qatar via email:
We collect information from and about candidates in connection with available employment opportunities at SFAI Qatar. The information that we collect, the way it is used, and the timing in which it is gathered varies depending on the country in which you apply. As general matter, the data we collect regarding our job applicants includes resumes or CVs, identification documents, academic records, work history, employment information and references.
We use your personal data to match your skills, experience and education with specific roles offered by SFAI Qatar. This information is passed to the relevant hiring managers and persons involved in the recruitment process to decide whether to invite you for an interview. SFAI Qatar will collect further information if you are invited to the interview (or equivalent) stage and onward. Such information includes interview notes, assessment results, feedback and offer details.
In connection with our recruitment activities including applications and onboarding, we also collect special category data from candidates where we have an employment law obligation to do so. This information is relevant to their future working environment at SFAI Qatar or the future provision of employment benefits, or with the individual’s explicit consent, where collecting such information is permitted by law. For example, where allowed under applicable law, we will collect information about an individual’s disabilities to analyze the diversity of our workforce. Once onboarded, an individual’s provision of information regarding disabilities will also be used to provide a suitable working environment. We will also need to conduct criminal background checks for certain candidates to assess their eligibility to work at SFAI Qatar or for SFAI Qatar clients. In certain countries, we will also ask candidates to provide diversity information about their race and ethnicity, and sexual orientation for diversity monitoring purposes, although the provision of this information will be entirely voluntary. However, where a candidate does not voluntarily provide such information, we could be required by law to make our own assessment of such criteria.
Our recruitment tools and websites contain their own privacy notices explaining why and how personal data is collected and processed by those applications. We encourage individuals using our recruitment tools and websites to refer to the privacy notices available on those tools and websites.
SFAI Qatar collects personal data about candidates (“you”) from the following sources:
Legal grounds for processing personal data of our job applicants are:
SFAI Qatar hopes to maintain a lifelong, mutually beneficial relationship with global SFAI alumni (former member firm partners, employees, and contractors). If we invite you to our alumni community, your name, contact details, role, last SFAI office, rank, service line and country will be used to create a record for you in one of our alumni databases, unless you have indicated that you are not interested in participating in the SFAI Qatar alumni program. You can create a more detailed profile and to decide how much additional information you wish to share with SFAI Qatar and the wider alumni community.
Our alumni databases contain their own privacy notices explaining why and how personal data is collected and processed by those applications. We encourage individuals using our alumni databases to refer to the privacy notices available on those applications.
The legal grounds for processing personal data of our alumni are:
We process personal data about our vendors (including subcontractors, and individuals associated with our vendors and contractors) to manage our relationship and contract, and to receive services from our vendors.
The personal data we process is generally limited to contact information (name, name of employer, phone, email, and other contact details) and financial information (payment-related information).
In addition, we also use data about our vendors to check whether we have a conflict of interest or audit independence restriction to appointing a vendor. Before we take on a new vendor, we also carry out audit independence and other background checks required by law or regulation, for example, adverse media, bribery and corruption, and other financial crime checks.
Legal grounds for processing personal data of our suppliers are:
Visitors to SFAI Qatar office
When you visit an SFAI Qatar office, we process your personal data in order to provide you with certain facilities (such as access to our buildings and conference rooms or Wi-Fi), to control access to our buildings, and to protect our offices, personnel, goods and confidential information (for example, by using CCTV).
The personal data we collect is generally limited to your name, contact information, location, and the time you enter and leave our office.
Visitor records and access badges
We require visitors to our offices to sign in at reception and we keep that record of visitors for a short period of time. Visitors to our offices are provided with a temporary access badge to access our offices. Our visitor records will be used to verify that access badges are returned, to look into a security incident and for emergency purposes (for example, if an office needs to be evacuated).
We monitor and log traffic on our Wi-Fi networks. This allows us to see limited information about a user’s network behavior, but will also include being able to see at least the source and destination addresses the user is connecting from and to.
SFAI Qatar uses CCTV monitoring were permitted by law. CCTV images are securely stored and only accessible on a need-to-know basis (for example, to investigate an incident). We are allowed to disclose CCTV images to law enforcement bodies. We will also share CCTV images with our insurers for purposes of processing an insurance claim because of an incident. CCTV recordings are typically deleted or automatically overwritten after a short period of time unless an issue is identified that requires further investigation.
Legal grounds for processing personal data of visitors to SFAI Qatar offices are:
Transfer of personal data
SFAI Qatar is a member firm of SFAI Global which operate in more than 100 countries across the globe. However, the global SFAI infrastructure is decentralized. In case, an engagement with SFAI Qatar clients span more than one jurisdiction, certain information will need to be accessed by all those within the SFAI organization who are working on the matter. Therefore, your personal data will be transferred to and stored outside the country in which you are located.
We take appropriate security and legal precautions to safeguard the safety and integrity of personal data that is transferred within the SFAI organization.
Your personal data will also be processed by SFAI Qatar support providers that support our internal ancillary processes
We transfer or disclose the personal data we collect to external support providers (and their subsidiaries and affiliates) who are engaged by us to support our internal ancillary processes. For example, we engage support providers to provide (a) general office support including printing, document production and management, archiving, and translation services; (b) accounting, finance, and billing support; (c) conflict checking, risk management and quality reviews.
It is our policy to only use third-party support providers that are bound to maintain appropriate levels of data protection, security, and confidentiality, and that comply with any applicable legal requirements for transferring personal data outside the jurisdiction in which it was originally collected.
SFAI Qatar discloses your personal data:
We would like to draw particular attention to the fact that in certain jurisdictions, SFAI Qatar has a legal obligation to report suspicious transactions and other activity to relevant regulatory authorities under anti-money laundering, terrorist financing, insider dealing or related legislation. SFAI Qatar also reports suspected criminal activity to the police and other law enforcement bodies. We are not always permitted by the law to inform you about this in advance of the disclosure, or at all.
Third-party recipients of personal data include:
SFAI Qatar protects the confidentiality and security of information it obtains during its business. Access to such information is limited, and policies and procedures are in place that are designed to safeguard the information from loss, misuse, and improper disclosure.
Keeping your personal data up to date
We maintain the accuracy and completeness of the personal data we hold. It is important that you inform us of any updates to your contact details or other personal data so that we have the most up-to-date information about you. Please contact the person you usually deal with at SFAI Qatar.
Our policy is to retain personal data only for as long as it is needed for the purposes described in the section “Purposes for which we process personal data.” Note that retention periods vary in different jurisdictions and are set in accordance with local regulatory and professional retention requirements.
In order to meet our professional and legal requirements, to establish, exercise or defend our legal rights, and for archiving and historical purposes we need to retain information for significant periods of time.
Our Site is not intended for use by minors under the age of sixteen (16) years. SFAI Qatar does not knowingly collect, disclose, or sell the personal data of minors under 16 years of age. If you are under 16 years old, please do not provide any personal data even if prompted to do so. If you believe that you have inadvertently provided personal data, please ask your parent(s) or legal guardian(s) to notify us and we will delete your personal data.
Change to this privacy statement
We will occasionally update this privacy notice to reflect changes in our practices and services. When we post changes to this privacy notice, we will revise the “last updated” date at the top of this privacy notice. If we make any material changes in the way we collect, use, and share personal data, we will notify you by prominently posting notice of the changes on the website. We recommend that you check this page from time to time to inform yourself of any changes in this privacy notice.