Information on data protection
OHB is committed to protecting the personal rights of anyone whose personal data are processed by OHB. Therefore, we would like to answer a few of the most important questions about the processing of your data in this privacy statement. OHB adheres to the provisions of the EU General Data Protection Regulation (GDPR) as well as the German Federal Data Protection Act and other applicable national data protection regulations. Please read this privacy statement carefully before submitting a report.
Purpose and legal foundation of the whistleblowing system
Our platform We.Create.Integrity. is based on the internet-based whistleblowing system by EQS Group GmbH (BKMS® System). You can find a description of the basic operating principle of BKMS® System here: https://www.eqs.bkms-system.com/de/. We.Create.Integrity. is designed to securely and confidentially receive, process and manage any reports regarding breaches of the OHB Group’s principles of good corporate governance and business conduct. The legal basis for the processing of personal data within the framework of We.Create.Integrity. is the legitimate interest (Article 6(1)(f) GDPR) of our company in discovering and preventing malpractice and thereby preventing harm to OHB, its employees and business partners, provided that the interests of the data subjects do not outweigh this interest.
Responsible parties
The party responsible for data protection in the whistleblowing system is
OHB SE
Manfred-Fuchs-Platz 2-4
28359 Bremen
We.Create.Integrity. is operated by a specialised company, EQS Group GmbH, Bayreuther Str. 35, 10789 Berlin in Germany, on behalf of OHB SE.
Personal data and information entered into the portal We.Create.Integrity. are stored in a database operated by EQS Group GmbH in a high-security data centre. Only authorised persons at the OHB Group can see the data. EQS Group GmbH 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 OHB.
Questions regarding the processing of your personal data or requests for information, rectification or erasure should be directed to our Group data protection officer.
Via email:
datenschutz@ohb.de
Via mail:
OHB SE
Data protection officer
Manfred-Fuchs-Platz 2-4
28359 Bremen
Type of personal data collected
Use of the portal We.Create.Integrity. takes place on a voluntary basis. If you submit a report via the portal We.Create.Integrity., we collect the following personal data and information:
- Your name, if you choose to reveal your identity
- Whether you are employed at a company of the OHB Group
- The names and other personal data of persons whom you list in your report, if applicable.
Confidential handling of reports
Incoming reports are received by a small selection of expressly authorised and specially trained employees of the compliance organisation of OHB and are always handled confidentially. The employees of the OHB compliance organisation evaluate the matter and perform any further investigation 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 OHB, employees of other group companies (e.g. if the reports refer to incidents in subsidiaries) or with law firms or consulting firms. The latter may be based in countries outside the European Union or the European Economic Area with different regulations about the protection of personal data. When sharing reports, we always comply with the applicable data protection regulations.
All persons who receive access to the data are obligated to maintain confidentiality.
Information about the accused
We are legally obligated 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 to access, rectification, erasure, restriction of processing and objection to processing of your personal data. If the right to object to the processing of the personal data is exercised, the need to store the data for examination of a report will be evaluated immediately. Data that are no longer needed will be deleted immediately. You also have the right to lodge a complaint with the supervisory authority.
Retention period of personal data
Personal data are retained for as long as necessary to clarify the situation and perform a final assessment of the report or for as long as a legitimate interest exists on the part of the company or retention is required by law. After the report processing is concluded, the data will be deleted 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 portal We.Create.Integrity. In order to maintain the connection between your computer and the portal We.Create.Integrity., 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.
It is possible to set up an electronic postbox within the portal We.Create.Integrity that is secured with an individually chosen pseudonym/user name and password. This allows you to send reports to the competent person at OHB either by name or in an anonymous, safe way. This system only stores data inside the portal We.Create.Integrity., 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 competent examiner at OHB. 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 message 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.
Version: January 2022