Information on data protection
We take data protection and confidentiality very seriously and adhere to the provisions of the EU General Data Protection Regulation (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 Tell Us! serves the purpose of securely and confidentially receiving, processing and managing reports concerning violations of the applicable laws and internal regulations. The processing of personal data within the framework of Tell Us! is based on the justified interest of our company in discovering and preventing abuses and thereby averting damage to STAHLGRUBER GmbH, its affiliated companies, all employees, customers and business partners. The legal basis for this processing of personal data is Article 6(1)(f) of the GDPR.
If you disclose information about your identity, the processing takes place on the basis of your consent in accordance with Article 6(1)(1)(a) GDPR. You have the right to revoke your declared consent, effective in the future, at any time (Article 7(3)(1) GDPR).
Responsible party
The following bear shared responsibility for the processing of your personal data within the framework of Tell Us!:
1) STAHLGRUBER GmbH and
2) its affiliated companies (PV Automotive GmbH, Neimcke GmbH & Co. KG, Optimal AG & Co. KG).
The whistleblowing system is operated by a specialised company, EQS Group AG, Bayreuther Str. 35, 10789 Berlin in Germany, on behalf of STAHLGRUBER GmbH, PV Automotive GmbH, Neimcke GmbH & Co. KG and Optimal AG & Co. KG.
Personal data and information entered into Tell Us! are stored in a database of a high security data centre operated by EQS Group AG. Only the responsible persons can see 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 STAHLGRUBER GmbH, PV Automotive GmbH, Neimcke GmbH & Co. KG and Optimal AG & Co. KG.
The aforementioned responsible parties have appointed a data protection officer. Inquiries concerning data protection can be directed to the data protection officers of the respective organisations, Gruber Straße 65, 85586 Poing, or the email address: datenschutz@stahlgruber.de.
Type of collected personal data
Use of Tell Us! 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 and any other information, insofar as you disclose your identity or these data,
- Whether you are employed at STAHLGRUBER GmbH, PV Automotive GmbH, Neimcke GmbH & Co. KG, Optimal AG & Co. KG or other affiliated companies 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 the Compliance organisation of STAHLGRUBER GmbH and always handled confidentially. They will always evaluate the situation and carry out a further, case-specific investigation, if necessary.
During the processing of a report or the conducting of a special investigation, it may become necessary to forward reports to employees within the affiliated companies. All persons who receive access to the data are obligated to maintain confidentiality. Within the course of the investigation of crimes, personal data may be shared with third parties, such as law enforcement agencies. We will always ensure that the applicable data protection regulations are complied with when sharing reports.
Information about the accused
All data are handled confidentially at all times during the entire processing. However, we are legally obligated to inform persons named in the report that we have received a report mentioning them as soon as the disclosure of this information no longer jeopardises the investigation. If you have decided not to remain anonymous in submitting your report, we are fundamentally also obligated according to Article 14(3)(a) GDPR to inform the accused person, generally within one month of receiving the personal data, of the report and the identity of the source.
Rights of the data subject
Pursuant to European data protection legislation, you and the persons named in the report have a right of access (Article 15 GDPR), rectification (Article 16 GDPR), erasure (Article 17 GDPR), restriction of processing (Article 18 GDPR) and right to object to the processing of your personal data (Article 21 GDPR) if the processing is based on Article 6(1)(1)(f) GDPR. If you object, we will no longer process the personal data concerning you unless we can attest to legitimate reasons for the processing that outweigh your interests, rights or freedoms or the processing serves for the establishment, exercise or defence of legal claims.
You also have the right to appeal with the supervisory authority (Article 77(2)(d) GDPR).
Retention period of personal data
Personal data are retained for as long as necessary to clarify the situation and perform a final assessment or for as long as another legitimate interest exists on the part of the STAHLGRUBER GmbH and its affiliated companies or retention is required by law. In particular, this refers to processing for the establishment, exercise or defence of legal claims. Personal data are deleted when they are no longer needed for the aforementioned purposes and when no further legally binding retention periods apply.
Use of the whistleblower portal Tell Us!
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 Tell Us! 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.
You can set up a postbox within Tell Us! that is secured with an individually-selected pseudonym/user name and password. This allows you to send reports to the competent persons at STAHLGRUBER GmbH or an affiliated company either by name or in an anonymous, safe way. This system only stores data inside Tell Us!, 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 person at STAHLGRUBER GmbH or affiliated companies. If you wish 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 these data before sending. If you are unable to remove these 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-May-2019
