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Data protection information for whistleblowers!
The purpose of data processing within the framework of the whistleblower system is to receive and clarify serious cases of suspected violations of regulations, in particular criminal acts in the area of white-collar crime and corruption.
The following data is processed as part of the whistleblower system: Information about the accused person (e.g. surname, first name, title, contact details, position and employment details), information about the (alleged) breaches of conduct and the relevant facts. Since the reporting procedure of the ombudsman’s office stipulates that reports can be made anonymously, no personal data is collected about whistleblowers unless they themselves state otherwise. Otherwise, personal data such as the name of the person making the report, their contact details and, if applicable, the circumstances of their observation may be collected.
The legal basis is the fulfillment of legal obligations pursuant to Art. 6 (1) p. 1 lit. c DS-GVO. In other cases, the processing of personal data in the whistleblower system is based on Art. 6 (1) lit. f to protect the overriding legitimate interest of the mandated company. This legitimate interest lies in preventing and combating corruption as well as in processing serious suspicions about other breaches of the rules and in protecting the mandated company and its employees from possible damage as a result. Since the reporting of violations helps to avoid legal consequences through, for example, criminal prosecution, claims for damages and immense damage to the company’s image, the interests of the data subjects in the exclusion of processing or use that are worthy of protection do not outweigh this.
Personal data will be retained for the period necessary to clarify and conclusively assess the tip. After completion of the investigation, the personal data will be deleted within a reasonable period of time, regularly two months, and in accordance with the legal requirements. In the event that judicial and/or disciplinary proceedings are initiated, they may be retained until the conclusion of the proceedings or until the expiry of appeal periods. Personal data in connection with unfounded reports will be deleted immediately.
If necessary, the data will be passed on to external lawyers, auditors or other professionals who are bound to secrecy under professional law, as well as to the Group companies concerned) and, if necessary, to government agencies (such as the police, public prosecutor’s office or courts). We assure all whistleblowers that their information will be handled confidentially.
As the person concerned, you have the right to information about the personal data stored about you. The identity of the whistleblower is generally excluded from this right to information. If the exercise of this right jeopardizes the clarification of the facts or the securing of necessary evidence, the ombudsman’s office is permitted to fulfill the right at a later point in time. In addition, you have the right to have incorrect data corrected, changed, blocked or deleted if the legal requirements are met. Furthermore, you have the right to lodge a complaint with the competent supervisory authority for data protection at any time. Requests to exercise the data subject rights according to Art. 15-21 DSGVO can be addressed by the data subject to one of the responsible bodies.