Information on data protection
We take data protection and confidentiality very seriously and adhere to the provisions of the EU General Data Protection Regulation (EU-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 the purpose of securely and confidentially receiving, processing and managing reports concerning violations of the law or of dormakaba's internal Rules & Regulations. The processing of personal data within the framework of the BKMS® System is based on the legitimate interest of our company in discovering and preventing wrongdoing and thereby averting damage to dormakaba, its employees and customers. The legal basis for this processing of personal data is Article 6(1)(f) of the EU-GDPR (General Data Protection Regulation).
Responsible body
The responsible bodies for data protection relating to the whistleblowing system are
1) dormakaba International Holding GmbH and
2) its subsidiaries
as bodies with mutually autonomous responsibility (hereafter also: “dormakaba”). The whistleblowing system is operated by a specialised company, EQS Group GmbH, Bayreuther Str. 35, 10789 Berlin in Germany, on behalf of dormakaba.
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. The data can only be accessed by dormakaba. 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 dormakaba Group Compliance.
dormakaba has appointed a data protection officer. Inquiries regarding data protection at dormakaba can be sent to Group Compliance at compliance.global@dormakaba.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 employed at dormakaba, 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 dormakaba Group Compliance and always handled confidentially.
During the processing of a report or the conducting of a special investigation, it may become necessary to forward reports to additional employees of dormakaba or employees of other group companies, such as if the reports refer to activities 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 always ensure compliance with the applicable data protection regulations when sharing reports.
Notification of the persons concerned
We are legally obligated to inform affected 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 obliged to do so.
Rights of the persons concerned
Pursuant to European data protection legislation, you and the persons named in the report have a right of access, rectification, erasure, restriction of processing and objection to processing of your personal data. If the right to object to the processing of the personal data is invoked, 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 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 at least. We reserve the right to carry out stricter deletion routines that exceed the legal requirements, e.g. to meet requirements of any relevant works agreements.
Use of the whistleblowing portal
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 contains only 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 respectively responsible employee at dormakaba either by name or in an anonymous, safe way. This system only stores data inside the whistleblowing system, making it particularly secure. It is not a form of regular e-mail communication.
Note on sending attachments
When submitting a report or an addition, you can simultaneously send attachments to the responsible dormakaba employee. If you want to submit an anonymous report, please take note of the following security advice: files can contain hidden personal data that could put your anonymity at risk. 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.
Version: April 2019
