Privacy policy
We take data protection and confidentiality very seriously and adhere to the provisions of the EU General Data Protection Regulation (GDPR) as well as current national data protection regulations. Please read this data protection information carefully before submitting a report.
Purpose and legal foundation of the whistleblowing system
The whistleblowing system (BKMS® System) serves for securely and confidentially receiving, processing and managing reports concerning violations of the compliance rules of Silicon Austria Labs GmbH (abbreviated as “SAL”).
The whistleblowing system is operated by a specialised company, EQS Group GmbH, Bayreuther Str. 35, 10789 Berlin, Germany, on behalf of SAL.
Whistleblowers can submit questions and reports within the framework of this system, either anonymously or providing their name and contact details. Personal data and information entered into the whistleblowing system (both the personal data of the whistleblowers and of the persons mentioned in the reports) is stored in a database operated by EQS Group GmbH in a high-security data centre. Only SAL employees 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 SAL.
The processing of personal data within the framework of BKMS® System is based on legal obligations and the legitimate interest of SAL in discovering and preventing abuses and thereby averting damage to SAL, its employees and customers. The legal foundation for this processing of personal data is Article 6(1)(c) and (f) GDPR.
Cookies
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 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 respectively responsible SAL employee either by name or in an anonymous, safe way. This system only stores data inside the whistleblowing system, which makes it particularly secure. It is not a form of regular email communication.
Type of personal data collected
Use of the whistleblowing system takes place on a voluntary basis. If you submit a report via the whistleblowing system, we collect the following personal data and information:
- Your name and contact details, if you choose to reveal your identity,
- whether you are or were employed at SAL
- The names, contact details, correspondence, organisational assignment and other personal data of persons whom you mention in your report, if applicable
If you are authorised by SAL to process received reports, your (user) name, organisational assignment and the work steps set will be processed by SAL.
Confidential handling of reports
Incoming reports are received by a small selection of expressly authorised and specially trained employees of the compliance organisation of SAL and are always handled confidentially. The employees of the SAL compliance organisation evaluate the matter and perform any further investigation required by the specific case.
During the processing of a report or the conducting of a special investigation, it may become necessary to disclose reports to additional SAL employees.
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 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 deleted at once.
If you believe that the processing of your data violates data protection law or that your legal data protection rights or the rights of the data subject have been otherwise violated, please contact the responsible office named in this data protection information. You also have the opportunity to make a complaint with the supervisory authority. In Austria, the Data Protection Authority (https://www.dsb.gv.at/) is responsible as the national supervisory authority.
Retention period of 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 SAL or retention is required by law. After the report processing is concluded, the data will be deleted in accordance with statutory requirements.
Note on sending attachments
When submitting a report or an addition, you can simultaneously send attachments to the responsible SAL 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 this 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.
Responsible parties
The party responsible for data protection in the whistleblowing system is:
Silicon Austria Labs GmbH,
Inffeldgasse 33,
8010 Graz, Austria
SAL has appointed a data protection officer. Enquiries regarding data protection at SAL can be sent to the following address:
Data Protection Office (DPO)
Inffeldgasse 33
8010 Graz
dpo@silicon-austria.com
Version: 17/12/2021