Notes on data protection
We take data protection and confidentiality very seriously and comply with the provisions of the European 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 the TROX GROUP. 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 TROX GROUP, 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).
Responsible parties
The parties responsible for data protection in the whistleblowing system are
- TROX GmbH, Heinrich-TROX-Platz, 47504 Neukirchen-Vluyn, www.trox.de and
- its subsidiaries
as parties with mutually autonomous responsibility (hereafter also: “TROX”). The whistleblowing system is operated by a specialised company, EQS Group GmbH, Bayreuther Str. 35, 10789 Berlin in Germany, on behalf of TROX GmbH.
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 TROX 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 TROX GmbH.
TROX GmbH has appointed a data protection officer. Inquiries regarding data protection at TROX can be sent to privacy-de@troxgroup.com.
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, if you choose to reveal your identity
- Whether you are an employee of TROX
- 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 compliance organisation of TROX GmbH and are always handled confidentially. The employees of the compliance organisation of TROX GmbH 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 TROX GmbH or employees of other group companies, e.g. if the reports refer to incidents in subsidiaries. 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. We will 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 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. You also have the right to lodge a complaint with the supervisory authority.
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. After the report processing is concluded, the data will be deleted 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 TROX GmbH 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.
Note on sending attachments
When submitting a report or an addition, you can simultaneously send attachments to the responsible TROX GmbH 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.
Version: 9 November 2021
