Information on data privacy
The protection of your data and the confidentiality of your identity are very important to us. Naturally, we process your personal data exclusively in accordance with the EU General Data Protection Regulation (EU-GDPR) and the applicable national data privacy regulations. With the outstanding encryption and permission concept, we additionally guarantee an exceptional level of protection for the data in the whistleblowing system – including your identity. We also offer you the ability to submit your report anonymously. Please read this data privacy 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 legal regulations and internal company rules (code of conduct, company guidelines) by employees of the Otto Krahn Group.
The processing of personal data within the framework of the BKMS® System takes place in accordance with Art. 6(1)(1)(f) EU-GDPR on the basis of our company's legitimate interest in the discovery and prevention of legal violations and malpractices. Such incidents can cause considerable damage to our financial standing and our reputation. Our legitimate interest therefore outweighs the rights of the data subjects to informational self-determination, especially due to the technical and organisational measures we implement to minimise any impairment of said self-determination and to protect confidentiality and data integrity.
Controller
The parties responsible for dataprivacy in the whistleblowing system are
- OTTO KRAHN (GmbH & Co.) KG und
- its subsidiaries according to Attachment 1
as parties with mutually autonomous responsibility (hereafter also: “OTTO KRAHN”). The whistleblowing system is operated by a specialised company, EQS Group GmbH, Bayreuther Str. 35, 10789 Berlin in Germany, on behalf of OTTO KRAHN.
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 decryption and viewing of the data are only possible by OTTO KRAHN. Neither EQS Group GmbH nor other third parties have access to interpretable 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 OTTO KRAHN.
OTTO KRAHN has appointed a data privacy officer. Inquiries regarding data privacy at OTTO KRAHN can be sent to dataprotection@albis.com.
Type of the collected personal data
Use of the whistleblowing system takes place on a voluntary basis. When you submit a report via the whistleblowing system, we initially collect only the personal data that you provide. These data generally consist of:
- your name, if you choose to reveal your identity,
- whether and in which department you are employed at OTTO KRAHN,
- other personal data that are included in your report, and
- the names and other personal data of persons whom you list in your report, if applicable.
In the event that additional personal data are collected within the course of the investigation following from your report, these data may also be processed via the whistleblowing system.
Confidential handling of reports
Incoming reports are received by a small selection of expressly authorised and specially trained employees of the compliance organisation of OTTO KRAHN and always handled confidentially. The employees of the OTTO KRAHN 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 OTTO KRAHN 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 privacy 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. If you did not submit your report anonymously, your identity as a whistleblower will not be disclosed unless this is required by law.
Rights of the data subjects
Pursuant to European data privacy legislation, you and the persons named in the report (the data subjects) 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. In this case, further processing will only take place if we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms. 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 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. Personal data arising within the framework of the investigation will therefore be deleted no later than after two months, unless further storage is required due to continued investigations or preservation of evidence in subsequent court proceedings or longer retention times are required by statutory regulations that take precedence.
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 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.
You can set up a secured postbox within the whistleblowing system with an individually chosen pseudonym/user name and password. This allows you to send additional information to or answer the questions of the employee of OTTO KRAHN responsible for processing your report either using your name or anonymously. All data sent via the postbox are encrypted and stored exclusively in the whistleblowing system, ensuring that the data receive special protection superior to that of typical email communication.
Note on sending attachments
When submitting a report or an addition, you can simultaneously send file attachments to the employee of OTTO KRAHN responsible for the processing of your report. If you wish to remain anonymous, 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: 01 July 2019
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