Data protection notice for Denmark
We take data protection and confidentiality very seriously and adhere to the provisions of the EU General Data Protection Regulation (GDPR) as well as current national data protection regulations (including the Danish Data Protection Act 2020). Please read this privacy information carefully before submitting a report.
Responsible party (data controller)
The party responsible for the data processing is:
ALDI Danmark ApS
- CVR-nr.: 89 79 72 17
- Adresse: Herstedøstervej 27-29C, 2620 Albertslund
- Telefon: +45 88 80 35 00
- E-mail: persondata@aldi.dk
Purpose of the whistleblowing system and how it works
The whistleblowing system (BKMS® System) serves for securely and confidentially receiving, processing and managing reports concerning violations of the compliance rules.
The whistleblowing system is operated by a specialised company, EQS Group GmbH, Bayreuther Str. 35, 10789 Berlin in Germany, on behalf of ALDI Denmark.
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 either by name or in an anonymous, safe way. Personal data is exclusively processed within the secure environment of the BKMS® System. It is not a form of regular e-mail communication.
All data are stored encrypted with multiple levels of password protection so that access is restricted to a very small selection of expressly competent and authorised persons at ALDI Denmark, cf. below.
When submitting a report or an addition, you can simultaneously send attachments. If you wish to submit an anonymous report, please take note of the following security advice: files can contain hidden personal data that could endanger your anonymity. Remove this data before sending. 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.
Types of processed personal data
Use of the whistleblowing system takes place on a voluntary basis. When a report is submitted, we collect and process the following personal data and information insofar as it is disclosed by the reporter:
- Name, contact information and place of employment of the reporter (if it is revealed),
- Any personal data contained in the report (including confidential or sensitive personal data or personal data on criminal offences), e.g. information on the relevant alleged misconduct, and
- Names and other personal data of persons who are listed in the report, if applicable.
Legal bases for the processing
Our legal bases for the processing are the following:
- Our legitimate interests in correctly handling and managing our whistleblower system, hereunder establishing, exercising or defending legal claims, cf. Article 6(1)(f) of the GDPR,
- Processing of sensitive personal data is necessary for the establishment, exercise or defence of legal claims, cf. Article 9(2)(f) of the GDPR, and
- Processing of personal data on criminal offences is necessary to safeguard a legitimate interest (cf. above) when the legitimate interest clearly overrides the interests of the data subject, cf. Section 8(3) of the Danish Data Protection Act 2020, or is necessary for the establishment, exercise or defence of legal claims, cf. Section 8(5) of the Danish Data Protection Act 2020.
Sources of personal data
We may collect personal data from the following sources (corresponding to the types of persons who can use the whistlerblower system):
- Employees,
- Members of management,
- Suppliers,
- Business partners, and
- Advisors.
Insofar as the processed personal data is provided by the reporter in connection with making the report, it is voluntary to provide the data. If the data is not provided, we may not be able to process the report.
Categories of recipients
Personal data and information entered into the whistleblowing system are stored in a database of a high security data centre operated by EQS Group GmbH. Only the competent and authorised employees of ALDI Denmark have access to the data. EQS Group GmbH and other third parties do not have access to the data unless such access is given explicitly, cf. below. This is ensured in the certified procedure through extensive technical and organisational measures.
Incoming reports are received by a small selection of expressly competent and authorized specially trained employees of the compliance organisation of ALDI Denmark and are always handled confidentially. The employees of the compliance organisation of ALDI Denmark evaluate the matter and perform any further investigation required by the specific case. All persons who receive access to the data are obligated to maintain confidentiality.
During the processing of a report or the conducting of a special investigation, it may become necessary to forward reports to other parties. We will always ensure that the applicable data protection regulations are complied with when sharing reports.
Depending the circumstances, and taking into consideration relevant legislation on data protection and confidentiality, we may disclose personal data to the following recipients:
- The relevant Aldi subsidiary, if any, which the person making the report or any person mentioned in the report is employed by,
- External counsel, such as lawyers, accountants or other advisors,
- The police or other public authorities, as applicable, and
- The data processor hosting and administering the whistleblower system, hereunder in connection with troubleshooting.
Transfer of personal data to third countries
We do not transfer personal data to third countries (countries outside EU/EEA).
Your rights
Pursuant to European data protection legislation, data subjects have a right of access, rectification, erasure, restriction of processing and to object to the processing of personal data as well as certain other rights. You also have the right to complain to the supervisory authority https://www.datatilsynet.dk/generelt-om-databeskyttelse/klage-til-datatilsynet/.
Retention period of personal data
Personal data is retained for as long as necessary to clarify the situation and perform a final assessment, for as long as a legitimate interest exists on the part of the company or for as long as retention is required by law. After the report processing is concluded, the data will be anonymised and deleted in accordance with statutory requirements. If personal data is disclosed to public authorities, the data will be deleted when the authority has closed the case.
Use of cookies
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 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.
Information on data protection for the website
Please also note the data protection information on our website:
https://www.aldi.dk/services/databeskyttelse.html