Data protection policy
We take data protection and confidentiality very seriously and adhere to the provisions of the EU General Data Protection Regulation (EU-GDPR) as well as current national data protection regulations. Please read this data protection information carefully before submitting a report.
Purpose of the Speak Up Portal and legal basis
The Speak Up Portal (BKMS® System) serves the purpose of securely and confidentially receiving, processing and managing reports regarding violations of the compliance rules of TenneT. The processing of personal data in the BKMS® System is based on the legitimate interests of TenneT to detect and prevent misconduct and thus avoid damage to TenneT, its employees and customers. Article 6 (1) (f) EU-GDPR serves as legal basis for this data processing.
Responsible authority
The party responsible for data protection in the Speak Up Portal is
TenneT TSO GmbH
Bernecker Straße 70
95448 Bayreuth
Deutschland
(hereafter also: „TenneT“)
TenneT provides the Speak Up Portal for all its subsidiaries, for instance TenneT GmbH & Co. KG. The Speak Up Portal is operated by a specialised company, EQS Group AG, Bayreuther Str. 35, 10789 Berlin in Germany, on behalf of TenneT.
Personal data and information entered into the Speak Up Portal are stored in a database operated by EQS Group AG in a high-security data centre. Only TenneT has access to the data. EQS Group AG and other third parties do not have access to the data. This is ensured in the certified procedure through extensive technical and organisational measures.
All data are stored encrypted with multiple levels of password protection so that access is restricted to a very small selection of expressly authorised persons at TenneT.
TenneT has appointed data protection officers. Questions on data protection can be sent to datenschutz@tennet.eu.
Type of the collected personal data
Use of the Speak Up Portal takes place on a voluntary basis. If you submit a report via the Speak Up Portal, we collect the following personal data and information:
- your name, if you choose to reveal your identity,
- whether you are employed at TenneT, and
- the names of persons and other personal data of persons that you name in your report.
Confidential handling of reports
Incoming reports are received by a small selection of expressly authorised and specially trained employees of the Compliance & Integrity department of TenneT and are always handled confidentially. The employees of the Compliance & Integrity department of TenneT will evaluate the matter and perform any further investigation required by the specific case.
During the processing of a report or the conduction of a special investigation, it may become necessary to share reports with additional employees of TenneT or employees of other group companies, e.g. if the reports refer to incidents in subsidiaries. The latter may be based in countries outside the European Union or the European Economic Area with different regulations concerning the protection of personal data. We always ensure that the applicable data protection regulations are complied with when sharing reports. All persons who receive access to the data are obligated to maintain confidentiality.
Information of the accused person
As a basic principle we are bound by law to inform the accused persons that we have received a report concerning them, unless this threatens further investigations into the report. In doing so, your identity as reporter is not revealed as far as is legally possible.
Retention period of personal data
Personal data is retained for as long as necessary to clarify the situation and perform an evaluation of the report or a legitimate interest of the TenneT exists or it is required by law. After the report processing is concluded, this data is deleted in accordance with the statutory requirements.
Use of the Speak Up Portal
Communication between your computer and the reporting system takes place over an encrypted connection (SSL). Your IP address will not be stored during your use of the reporting system. In order to maintain the connection between your computer and the BKMS® System, a cookie is stored on your computer that merely contains the session ID (a so-called null cookie). This cookie is only valid until the end of your session and expires when you close your browser.
It is possible to set up a postbox within the Speak Up Portal that is secured with an individually chosen pseudonym / user name and password. This allows you to send reports to the responsible employee at TenneT either by name or in an anonymous, safe way. This system only stores data inside the reporting system, which makes it particularly secure. It is not a form of regular e-mail communication.
Note on sending attachments
When submitting a report or an addition, you can simultaneously send attachments to the responsible employee of TenneT. If you wish to submit an anonymous report, please take note of the following security advice: Files can contain hidden personal data that could compromise your anonymity. Remove this data before sending. If you are unable to remove this data or are unsure how to do so, copy the text of your attachment into your report text or send the printed document anonymously to the address listed in the footer, citing the reference number received at the end of the reporting process.
As a data subject within the meaning of the GDPR, you have the following rights;
- Right of access (article 15) You have the right to request a copy of your personal data or to have access to your personal data.
- Right of rectification (article 16) If it appears that your data is incorrect or incomplete, you can request to change or supplement your data.
- Right to data erasure (right to be forgotten - Article 17) Under certain legal conditions, you have the right to have your data deleted.
- Right to restrict the processing (Article 18) under certain conditions, you have the right to limit the processing of your data.
- Right to data portability (article 20) you have the right to obtain and re-use your personal data for your own purposes for different services.
- Right of objection (Article 21) under certain conditions, you have the right to object against the processing of your personal data.
- Right to appeal to a supervisory authority. (Art. 77 AVG). In the Netherlands this can be done at the Personal Data Authority, Bezuidenhoutseweg 30, 2594 AV DEN HAAG. In Germany you can contact the Bavarian Supervising Authority for Data Protection (BayLDA), Promenade 18, 91522 Ansbach.
- Right to revoke your consent: You can withdraw your consent to the processing of your personal data at any time and request that the processed personal data be deleted. Although you withdraw your consent, the processing of your personal data remains lawful up to the time of withdrawal. Your personal data can only be deleted if there is no other legal basis for the processing of your personal data. If you wish to withdraw your consent, you may submit this request to the Data Protection Officer in The Netherlands or Germany.