Data Privacy Notice
We encourage you to read this data privacy information carefully before submitting a report.
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 privacy regulations. This Privacy Policy explains how WS Audiology and its group entities collect, process and retain your personal data when you submit a report via the whistleblowing system and what rights you have as data subject.
Data controller
References in this Privacy Policy to “WS Audiology”, “we”, “us” or “our” mean WS Audiology Group which has entities in several countries with a parent company registered in Denmark. We control the ways your personal data is collected and the purposes for which your personal data is used by WS Audiology. WS Audiology is the “data controller” for the purposes of the applicable European data protection legislation.
Contact us
You can direct any questions or complaints regarding our use of your personal data to the address:
WS Audiology Denmark A/S
Nymøllevej 6
3540 Lynge
Denmark
Reg.no. 15771100
Phone +45 44 35 56 00
You can also directly contact our Data Protection Officer (DPO), who is the responsible person to answer questions about personal data protection. Please use the following email address dpo@wsa.com.
What personal data is collected and processed and sources of data?
Use of the reporting system takes place on a voluntary basis. If you submit a report via the whistleblowing system, we collect the following personal data and information We will collect and process general information about you, such as your name, title, department, country of location, language preferences, whether you are employed at WS Audiology the names of persons and other personal data of persons that you name in your report and any other personal data you may provide us. Apart from that, we will collect information about the incident you report.
All the data we collect, and process will be obtained directly from you when you fill out the BKMS report page or enter reports via other channels like letters or emails.
Why do we need your personal data and legal basis to it?
We use the data you provide us to be able to securely and confidentially receive, process and manage reports regarding violations of the compliance rules of WS Audiology by utilizing the whistleblowing reporting system (BKMS® Incident Reporting). The reporting system is operated by a specialised company, EQS Group AG, Bayreuther Str. 35, 10789 Berlin in Germany, on behalf of WS Audiology.
The processing of personal data in the BKMS® System is based on the legitimate interests of our company to detect and prevent misconduct and thus avoid damage to WS Audiology, its employees, and customers. Article 6 (1) (f) EU-GDPR serves as legal basis for this data processing.
Who will receive/access your personal data?
Personal data and information entered into the reporting system are stored in a database operated by EQS Group AG in a high-security data centre. Only WS Audiology has access to the data. EQS Group AG 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 WS Audiology.
Incoming reports are received by a small selection of expressly authorised and specially trained employees of the Legal and Compliance department of WS Audiology and are always handled confidentially. The employees of the Legal and Compliance department of WS Audiology will evaluate the matter and perform any further investigation required by the specific case.
During the processing of a report or the conduction of a special investigation, it may become necessary to share reports with additional employees of WS Audiology 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 concerning the privacy of personal data. We 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 person
As a basic principle we are bound by law to inform the accused persons that we have received a report concerning them, unless this threatens further investigations into the report. In doing so, your identity as whistle-blower is not revealed as far as is legally possible.
For how long do we keep your personal data?
Personal data is retained for as long as necessary to clarify the situation and perform an evaluation of the report or a legitimate interest of the company exists, or it is required by law. After the report processing is concluded, this data is deleted in accordance with the statutory requirements.
Use of the reporting portal
Communication between your computer and the reporting system takes place over an encrypted connection (SSL). Your IP address will not be stored during your use of the reporting 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 null 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 reporting system that is secured with an individually chosen pseudonym/ username and password. This allows you to send reports to the responsible employee at WS Audiology either by name or in an anonymous, safe way. This system only stores data inside the reporting system, which makes 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 employee of WS Audiology. If you wish to submit an anonymous report, please take note of the following security advice: Files can contain hidden personal data that could compromise your anonymity. Remove this data before sending. If you are unable to remove this data or are unsure 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.
Your rights
According to European data protection law, you and the persons named in the report have certain rights. You can contact us at any time. You can also, at any time, ask for information about our processing of your personal data, receive a copy of the data we keep about you or ask us to send your personal data to somebody else. You can also ask us to rectify wrong or insufficient data about you or request to delete your data. If the right of deletion is claimed, we will immediately examine to what extent the stored data is still necessary for the processing of a report. Data that is no longer required is deleted immediately. In addition, you always have the right to complain about our processing of your personal data to the relevant data protection authority. Contact information of these authorities can be found at: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
This Privacy Policy was last updated May 2021.