INFORMATION ON DATA PROTECTION
Privacy policy
As a municipal service company, we are obligated to protect your data, and we take this requirement very seriously. The information below details how we process your personal data in connection with the use of the whistleblowing system and also informs you about your rights under applicable data protection law.
Please read this data protection information carefully before submitting a report.
Purpose and legal basis of the whistleblowing system
The whistleblowing system (BKMS® System) serves for securely and confidentially receiving, processing and managing reports concerning violations of applicable legal regulations and against the compliance policies of Holding Graz – Kommunale Dienstleistungen GmbH (Holding Graz). The processing of personal data within the framework of BKMS® System is based on the legitimate interest of Holding Graz and the subsidiaries listed below in uncovering and preventing abuses and thereby averting damage to Holding Graz, the subsidiaries listed below and their employees and customers. The legal basis for this processing of personal data is Article 6(1)(f) GDPR.
Responsible parties
The following parties are responsible for the data processing:
- Holding Graz – Kommunale Dienstleistungen GmbH
Andreas-Hofer-Platz 15
8010 Graz
and
- its subsidiaries
Bestattung Graz GmbH
Grazbachgasse 44-48
8010 Graz
Energie Graz GmbH
Schönaugürtel 65
8010 Graz
Flughafen Graz Betriebs GmbH
8073 Feldkirchen
Freizeit Graz GmbH
Janzgasse 21
8020 Graz
Citycom Telekommunikation GmbH
Gadollaplatz 1
8010 Graz
each as parties with autonomous responsibility.
The whistleblowing system is operated by a specialised company, EQS Group GmbH, Bayreuther Str. 35, 10789 Berlin, Germany, on behalf of Holding Graz.
Personal data and information entered into the whistleblowing system is stored in a database operated by EQS Group GmbH in a high-security data centre. Only the internal auditing department of Holding Graz 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 is 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 in the internal auditing department of Holding Graz.
Holding Graz has appointed a data protection officer. Inquiries concerning data protection in connection with the whistleblowing system used by Holding Graz and the subsidiaries listed above can be sent to:
Holding Graz – Kommunale Dienstleistungen GmbH
Andreas Hofer Platz 15
8010 Graz
datenschutz@holding-graz.at
.
Type of personal data collected
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, if you choose to reveal your identity
- Whether you are employed by Holding Graz or one of the subsidiaries listed above
- 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 internal auditing department of Holding Graz and always handled confidentially. The employees of the internal auditing department of Holding Graz 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 Holding Graz employees or employees of other group companies, e.g. if the reports refer to incidents in subsidiaries. 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 about the accused
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 is no longer needed will be deleted at once. You also have the right to lodge a complaint with the supervisory authority.
Retention period for personal data
Personal data is 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 company or retention is required by statutory provisions. 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 BKMS® System, a cookie is stored on your computer that only contains the session ID (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 a secured postbox within the whistleblowing system with an individually chosen pseudonym/user name and password. This allows you to send reports to the respectively responsible employee of the internal auditing department of Holding Graz either by name or in an anonymous, secure way. 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 internal auditing employee. If you wish to submit an anonymous report, please note 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.
Version: February 2022