Privacy notice
We take data protection and confidentiality seriously and adhere to the provisions of the EU General Data Protection Regulation (EU GDPR) as well as current national data protection regulations. 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 the Deutsche Wohnen Group compliance rules. 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 thereby averting damage for the Deutsche Wohnen Group, its employees, suppliers and lessees. The legal basis for the processing of personal data is Article 6(1)(f) of the GDPR.
Controller
The parties responsible for data protection in the whistleblowing system are: Deutsche Wohnen SE, Mecklenburgische Strasse 57, 14197 Berlin; Vonovia SE, Universitätsstrasse 133, 44803 Bochum; the respective operationally active company; and the respective asset company (hereinafter also: “Deutsche Wohnen”). The whistleblowing system is operated by a specialised company, EQS Group GmbH, Bayreuther Str. 35, 10789 Berlin, Germany, as a contract processor.
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. The controllers 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 the controller’s company/companies. Please note that, for the purposes of investigating the matter, the data entered by you may be shared with third parties such as public authorities, lawyers and service providers insofar as this is permissible by law. Our data protection policy for “Compliance Checks and Measures and Internal Audit” applies in this respect. This can be found at www.deutsche-wohnen.com/datenschutz.
Please direct your questions concerning data protection to our external Data Protection Officer:
Dr Stefan Drewes
c/o Vonovia SE
Universitätsstrasse 133
44803 Bochum, Germany
Email: datenschutz@deuwo.com
Please note that, when using this email address, the content may be viewed by persons other than our data protection officer. If you would like to exchange confidential information, we therefore ask you to initiate contact via this email address without providing any further description of the matter at first. You can also contact the respective responsible company in the Deutsche Wohnen Group by post or by sending an email to datenschutz@deuwo.com.
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 an employee of Deutsche Wohnen SE or a subsidiary and
- 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 in the compliance organisation at Deutsche Wohnen SE and are always handled confidentially. The employees working for the Deutsche Wohnen SE 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 Deutsche Wohnen SE or employees of other group companies, e.g. if the reports refer to incidents in subsidiaries. These subsidiaries may be based in countries outside the European Union or the European Economic Area with different regulations concerning the protection of personal data. 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 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. Data protection law fundamentally requires comprehensive notification of the accused person. An exception to this notification obligation applies if the information must be kept confidential due to overriding interests of third parties. In case of doubt, it is therefore better to submit the report anonymously.
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. You also have the right to lodge a complaint with the supervisory authority.
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 company – such as with regard to criminal prosecution – or retention is required by law. Two months after the report processing is concluded, the data will be erased in accordance with statutory requirements, unless it is still needed in the subsequent processes. In that case, the data are subject to the erasure rules applicable for these processes. If the persons entrusted with processing reports come to the conclusion that the report is unfounded, the report will be erased immediately.
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 merely contains the session ID (a “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 employee responsible at Deutsche Wohnen SE 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 employee at Deutsche Wohnen SE. 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: January 2023