Privacy policy
We take data protection and confidentiality very seriously and guarantee compliance with the applicable data protection provisions of the European General Data Protection Regulation (GDPR) as well as current national data protection regulations (e.g. employee data protection, insurance data confidentiality). Please carefully read the data protection information 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 investigating reports concerning compliance violations. The processing of personal data within the framework of BKMS® System is based on the legitimate interest of our company in discovering and preventing abuses and legal violations in order to prevent harm to DAK-Gesundheit, its employees and customers. The legal basis for the processing of personal data is Article 6(1)(f) of the GDPR (General Data Protection Regulation). The legal basis for the whistleblowing system is the EU directive 2019/1937.
Responsible parties
The party responsible for data protection in the whistleblowing system is DAK-Gesundheit. The whistleblowing system is operated on behalf of DAK-Gesundheit by a specialised company, EQS Group GmbH, Bayreuther Str. 35, 10789 Berlin in Germany.
Personal data and information entered into the whistleblowing system are stored in a database operated by EQS Group GmbH in a high-security data centre. Only the compliance officers of DAK-Gesundheit are able to access or view the data. EQS Group GmbH and other third parties do not have access to the data. This is ensured in an appropriately certified procedure through extensive technical and organisational measures in accordance with Art. 32 GDPR.
All data are stored in an encrypted manner 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 DAK-Gesundheit.
The data protection officer would be happy to answer any questions or receive any information you may have about data protection at DAK-Gesundheit:
Maureen Wobbe
DAK-Gesundheit
Data Protection Officer
Nagelsweg 27 - 31
20097 Hamburg, Germany
Email: datenschutz@dak.de
Information on the submission of non-anonymous reports:
When you submit a non-anonymous report via the whistleblowing system, we collect the personal data that you provide in your report.
Confidential handling of reports
Incoming reports are received by the compliance officers of DAK-Gesundheit and their specially authorised colleagues and handled strictly confidentially. Personally and professionally independent compliance officers evaluate the matter and carry out any investigation required by the specific case.
During the processing of a report, it may become necessary to include employees from other areas of DAK-Gesundheit in the investigation. Compliance with data protection provisions is ensured.
All persons who receive access to the data within the course of the investigation are obligated to maintain confidentiality.
Notification of accused persons
Accused parties must be notified of any reports we have received against them as soon as the disclosure of this information no longer jeopardises the investigation, in particular the ability of public authorities to investigate the case. If you share your identity, this will be handled confidentially – as far as legally possible.
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 as well as 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. If no statutory regulations prevent deletion of the data, data that are no longer needed will be deleted immediately. The data protection officer would be happy to answer any questions or receive any information you may have about data protection at DAK-Gesundheit.
Retention period of 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 company or retention is required by law.
Use of the whistleblowing system
Communication between your device 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 compliance officers 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 unsecured email communication.
Note on sending attachments
When submitting an initial or additional report, you can simultaneously send documents to the compliance officers as attachments. To protect your anonymity, please take note of the following security advice: Files can contain hidden personal data that could indicate your identity and endanger your anonymity. Please remove all such information before sending a file, if possible.
Version: 08/12/2021