Information on data protection
We take data protection and confidentiality very seriously and adhere to the provisions of the European General Data Protection Regulation (GDPR). The valid data protection standards form the basis of our data processing, in particular the Law on Church Data Protection (KDG).
Purpose and legal basis of the whistleblowing system
The whistleblowing system (BKMS® System) serves for securely and confidentially receiving, processing and managing reports concerning the violation of laws and internal policies of Josefs-Gesellschaft gAG and its affiliated companies (hereafter also: “JG Group”). The processing of personal data within the framework of the BKMS® System is based on the legitimate interest of our companies in discovering and preventing abuses and thereby averting harm to the JG Group, its employees, clients, patients and other persons entrusted to its care. The legal foundation for this processing of personal data is Article 6(1)(c), (e), (g) KDG.
Responsible party
The data controller for the whistleblowing system for the purposes of data protection is Josefs-Gesellschaft gAG, Custodisstr. 19-21, 50679 Cologne. The whistleblowing system is operated by a specialised company, EQS Group AG, Bayreuther Str. 35, 10789 Berlin in Germany, on behalf of Josefs-Gesellschaft gAG.
Personal data and information entered into the whistleblowing system are stored in a database at a high security data centre operated by EQS Group AG. Only employees of Josefs-Gesellschaft gAG who are specially obliged to maintain confidentiality have 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 according to a system of permissions so that access is restricted to a very small selection of expressly authorised persons at Josefs-Gesellschaft gAG.
Josefs-Gesellschaft gAG has appointed a data protection officer. Enquiries regarding data protection can be sent to datenschutz@josefs-gesellschaft.de.
Type of collected personal data
Use of the whistleblowing system is voluntary. We collect the following personal data and information when you submit a report using the whistleblowing system:
Your name, provided you choose to disclose your identity, whether you are an employee of Josefs-Gesellschaft gAG or one of its subsidiaries and, if applicable, names of persons or other personal data of persons mentioned in your report.
Confidential handling of reports
Incoming reports are received by a small selection of expressly authorised and specially trained employees of Josefs-Gesellschaft gAG and are always handled confidentially. The employees evaluate the matter and carry out any further investigation that may be required by the specific case.
While processing a report or conducting a special investigation, it may be necessary to share reports with additional employees of the JG Group or employees of other subsidiaries or contract partners, e.g. if the reports refer to incidents in other organisations. We always ensure that the applicable data protection regulations are complied with when sharing reports.
All persons who receive access to the data are obliged to maintain confidentiality.
Information about the accused party
We are legally obliged to inform accused parties of any reports received against them as soon as the disclosure of this information no longer jeopardises the investigation. Your identity as a whistleblower will not be disclosed unless we are legally bound to do so.
Rights of the data subjects
Pursuant to European data protection legislation, you and the persons named in the report have a right of access, rectification, erasure and restriction of processing, and a right to object to the processing of your personal data. If the right to object to the processing of the personal data is exercised, the necessity of the stored data for the examination of a report will be evaluated immediately. Data that are no longer needed will be erased without undue delay. Furthermore, you have a right of appeal to the supervisory authority (www.katholisches-datenschutzzentrum.de).
Retention period for personal data
Personal data are retained for as long as necessary to clarify the situation and perform a final assessment or for as long as a legitimate interest exists on the part of the organisation or retention is required by law. After the report processing is concluded, the data will be erased in accordance with statutory requirements.
Use of the whistleblowing system
Communication between your computer and the whistleblowing system takes place over an encrypted connection (SSL). Your IP address will not be stored during your use of the whistleblowing 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 session cookie). This cookie is only valid until the end of your session and expires when you close your browser.
You can set up a postbox within the whistleblowing system that is secured with an individually-selected pseudonym/ user name and password. This allows you to send reports to the responsible employee at EWDE in a secure manner, either by name or anonymously. This system only stores data inside the whistleblowing system, which makes it particularly secure. It is not a form of regular email communication.
Note on sending attachments
When submitting a report or an addition, you can simultaneously send attachments to the responsible Josefs-Gesellschaft gAG employee. If you wish to submit an anonymous report, please take note of the following security advice: Files may contain hidden personal data that could jeopardise your anonymity. Please remove all such information before sending a file. If you are unable to remove such data or are uncertain about 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.
Date: 1 February 2022