Notes on data protection
The companies of the Webasto Group, in other words Webasto SE and its affiliated companies / subsidiaries pursuant to §§ 15 ff. Companies Act (AktG) (collectively referred to as “Webasto”) take the topic of data protection and confidentiality very seriously and follow the applicable data protection regulations, especially the EU General Data Protection Regulation (GDPR), the German Data Protection Act (BDSG) and the applicable national data protection regulations. Please carefully read the data protection information below before submitting a report.
Purpose and legal foundation of the whistleblowing system
The whistleblowing system serves the purpose of securely and confidentially receiving, processing and managing reports concerning violations of applicable laws, external regulations and internal policies and rules. The processing of personal data within the framework of the whistleblowing system is based on Webasto’s legitimate interest in discovering and preventing malpractice and abuses and thereby averting damage to Webasto, its employees, customers and business partners. The legal foundation for this processing of personal data is Article 6(1)(f) GDPR.
Responsible parties
The parties responsible for data protection in the whistleblowing system are
- Webasto SE and
- its affiliated companies pursuant to §§ 15 ff. AktG
as parties with mutually autonomous responsibility (Webasto, see above). The whistleblowing system is operated by a specialised company, EQS Group GmbH, Bayreuther Str. 35, 10789 Berlin in Germany, on behalf of Webasto SE.
Personal data
The term personal data refers to information that concerns your person or by which you can be identified. This includes information such as your name, address, postal address, telephone number, IP address, browser type, PC operating system, the website from which you visited us as well as the date, time and web pages you visit.
Processing of personal data by the whistleblowing system
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 a few employees, specially authorised by Webasto, 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 Webasto. Webasto has appointed a group data protection officer.
Inquiries concerning data protection and assertion of your rights can be sent to the Group Data Protection Officer at the following email address: dataprotection@webasto.com
Type of collected personal data
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 Webasto
- 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 legal / compliance organisation of Webasto and are always handled confidentially. The employees of the Webasto legal / 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 Webasto, 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 the provisions of the GDPR, 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 in the future. If the right to object to the processing of personal data is invoked, the necessity of the stored data for the examination of a report will be evaluated immediately. Any processing that has taken place previously remains unaffected by a revocation. You can revoke your consent at any time without stating your reasons by contacting the Group Data Protection Officer of the Webasto Group (dataprotection@webasto.com). Data that are no longer needed will be erased immediately. 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 Webasto or retention is required by law or due to an investigation by public authorities or court proceedings. After the report processing is concluded, the data will be deleted in accordance with local 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 the whistleblowing 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.
It is possible to set up a postbox within the whistleblowing system that is secured with an individually chosen pseudonym/user name and password. This allows you to send reports to the responsible employee of Webasto 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 employee of Webasto. 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: June 2021
