Privacy statement
Dräger is committed to protecting the personal rights of anyone whose personal data are processed by Dräger. Therefore, we would like to answer a few of the most important questions about the processing of your data in this privacy statement. Dräger adheres to the provisions of the EU General Data Protection Regulation (EU-GDPR) as well as to the German Federal Data Protection Act (BDSG) and, apart from this, also considers the current national data protection regulations. Please read this privacy statement carefully before submitting a report.
Purpose and legal basis of the Integrity Channel
Dräger's Integrity Channel is the internet-based whistleblower portal by EQS Group GmbH (BKMS® System). You can find a description of the basic operating principle of the BKMS® System here: https://www.eqs.bkms-system.com/en. Integrity Channel is designed to securely and confidentially receive, process, and manage any reports regarding breaches of Dräger's principles of good corporate governance and business conduct. The legal basis for the processing of personal data within Integrity Channel is the justified interest of our company in discovering and preventing abuses and thereby averting damage to Dräger, its employees and others business partners, unless the interests of the data subject overweigh this interest.
Responsible authority
The party responsible for data protection in the whistleblowing system is
- Drägerwerk AG & Co. KGaA
- Moislinger Allee 53-55
- 23558 Lübeck.
The Integrity Channel is operated on behalf of Drägerwerk AG & Co. KGaA by a specialised company, EQS Group GmbH, Karlstraße 47, 80333 Munich in Germany.
Personal data and information entered into Integrity Channel are stored in a database of a high security data centre operated by EQS Group GmbH. Only Drägerwerk AG & Co. KGaA 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 so that access is restricted to a very small selection of expressly authorised persons at Drägerwerk AG & Co. KGaA.
Questions regarding the processing of your personal data or requests for information, rectification or deletion should be directed to our Group data protection officer.
- Via email:
- dataprivacy@draeger.com
- Via mail:
- Drägerwerk AG &Co. KGaA
- Group data protection officer
- Moislinger Allee 53-55
- 23558 Lübeck, Germany
Type of personal data collected
Use of the Integrity Channel takes place on a voluntary basis. When you submit a report via Integrity Channel, we collect the following personal data and information:
- your name, if you choose to reveal your identity,
- whether you are employed at Dräger, 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 of Drägerwerk AG & Co. KGaA's compliance organisation and always handled confidentially. The employees of Dräger's compliance organisation evaluate the situation and perform 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 Dräger or employees of other group companies (e.g. if the reports refer to incidents in subsidiaries). In some cases, they may also find it necessary to forward information to 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 take into account 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 subject
Pursuant to European data protection legislation, you and the persons named in the report have a right to information, rectification, erasure, restriction of processing and objection to processing of your personal data. If the right of objection to the processing of the personal data is invoked, the necessity of the storage of the data for the examination of a report or for legal reasons will be evaluated immediately. Data that are no longer needed will be deleted at once. You also have the right to appeal with the 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 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 whistleblower portal
Communication between your computer and the whistleblower system takes place over an encrypted connection (SSL). Your IP address will not be stored during your use of the whistleblower portal (Integrity Channel). In order to maintain the connection between your computer and the whistleblower 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 an electronic postbox within the whistleblower portal (Integrity Channel) that is secured with an individually selected pseudonym/user name and password. This allows you to safely send reports to the respectively responsible employee at Dräger, either by name or anonymously, and remain in contact. This system only stores data inside the whistleblowing portal (Integrity Channel), which makes it particularly secure. It is not a form of regular email communication.
Note on sending attachments
When submitting an initial or additional report, you can include attachments for the responsible Dräger 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 put your anonymity at risk. Remove this data before submission. 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 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: February 2020