Data Protection Information
We take data protection and confidentiality very seriously. We follow the provisions of the EU General Data Protection Regulation (GDPR) and the relevant national data protection regulations. Please read this data protection notice carefully before sending a report.
Purpose of the whistleblowing system and legal basis
The whistleblowing system (BKMS® System) is used to receive, process and administer notices regarding compliance breaches at Hochland Española, S.A. (hereinafter referred to as: “Hochland”) securely and confidentially. The processing of personal data within the framework of the BKMS® System is based on our company’s interest in detecting and preventing irregularities and, therefore, in preventing any harm to Hochland, its employees and its clients. The legal basis for the processing of personal data is Article 6, section 1 of the GDPR.
Data Processing Manager
The person responsible for data processing under the terms of the GDPR in the system is
Hochland Española S.A.
Llobatona, 7
Polígono Industrial del Centro
08840 Viladecans/Barcelona, Spain
Tel. +34 93 637 08 51
www.hochland.es
The data processor has appointed a Data Protection Officer, who can be contacted using the following contact details:
PROFESSIONAL GROUP CONVERSIA SLU
Data Protection Officer
dpo.cliente@conversia.es
902877192
Avinguda Mas Pins 150
17457 Riudellots de la Selva. Girona, Spain
The whistleblowing system is operated by a company that specialises in this field, EQS Group GmbH, Bayreuther Str. 35, 10789 Berlin in Germany, on behalf of and in the name of Hochland SE.
Personal data and information entered in the whistleblowing system are stored in a database operated by EQS Group GmbH in a highly secure data centre. The data can only be seen by Hochland. EQS Group GmbH and other third parties do not have access to the data. This is guaranteed in the certified proceedings by means of comprehensive technical and organisational measures.
All data are encrypted and stored with multi-level password protection and are subject to an authorisation system so that access is limited to a very small group of recipients expressly authorised by Hochland.
Hochland has appointed a Data Protection Officer. Data protection enquiries at Hochland can be sent to this person using the contact details given above.
Type of personal data collected
Use of the notification system is voluntary. If you send a report through the whistleblowing system, we will collect the following personal data and information:
- your name, if you decide to disclose your identity,
- if you are employed at Hochland, and
- the names and other personal data of the people you name in your report.
Confidential report management
The incoming reports are received by a small selection of employees expressly authorised and specially trained by Hochland and are always dealt with confidentially. These Hochland employees will assess the issue and carry out any additional investigations required for the specific case.
While a report is being processed or a special investigation is being carried out, it may be necessary to share reports with other Hochland employees or employees from other companies of the Group, for example, if the reports refer to incidents at other companies of the Group. The latter may be based in countries outside the European Union or the European Economic Area with different regulations concerning the privacy of personal data. When reports are shared, we will always ensure compliance with applicable data privacy regulations.
Everyone who has access to the data is obliged to comply with confidentiality regulations.
If your report requires legal proceedings or if it is required by law, state authorities, including law enforcement agencies, administrative authorities or courts may also be given access to these data.
Informing the defendant
As a general rule, we are obliged by law to inform defendants that we have received a report about them, unless this threatens the continuation of further investigations into the report. In doing so, your identity as a complainant will not be disclosed to the extent that is legally possible.
Rights of the parties concerned
In accordance with European data protection legislation, you and the persons named in the report have the right to consult, rectify, delete or restrict the processing and the right to oppose the processing of personal data that concerns them. If the right to object is exercised, we will immediately examine the extent to which the stored data are still required for the processing of a report. Data that are no longer required will be deleted immediately. In addition, you also have the right to lodge a complaint with a control authority.
Personal data retention period
Personal data will be stored for the amount of time required to understand the situation and make an assessment of the report, if there is a genuine interest on the part of the company or if it is required by law. Once the report has been processed, the data will be deleted in accordance with the legal requirements.
Automated decision-making, including profiling
Your personal data will not be used for automated decision-making, including profiling.
Use of the whistleblowing portal
Communication between the team and the whistleblowing system takes place through an encrypted connection (SSL). Your IP address will not be stored while you are using the whistleblowing system. In order to maintain the connection between your computer and the BKMS® System, a cookie is stored in your computer, which simply contains the session ID (named null cookie). The cookie is only valid until the end of the session and expires when you close your browser.
You are able to set up a postbox within the whistleblowing system, which is protected with an individually chosen pseudonym/user name and password. This allows you to securely send reports to the employee responsible at Hochland, either using your name or anonymously. This system only stores data within the whistleblowing system, which makes it especially secure. It is not a form of regular communication by email.
Notes on sending attachments
When sending a report or an addition, you can simultaneously send attachments to the employee responsible at Hochland. If you wish to send an anonymous report, please note the following security advice: the files may contain hidden personal data that could compromise your anonymity. Please delete these data before sending them. If you cannot delete these data or you are not sure how to do it, copy the text from the attachment into the report text or send the printed document anonymously to the address shown at the bottom of the page, citing the reference number received at the end of the notifying process.
Version: 13/11/2020