Data protection policy
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 of the whistleblowing system and legal basis
The whistleblowing system (BKMS® System) serves the purpose of securely and confidentially receiving, processing and managing reports regarding violations of the compliance rules of Umdasch Group AG. 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 the Umdasch Group AG and their daughter companies, its employees and customers. Article 6 (1) (f) EU-GDPR serves as legal basis for this data processing.
Responsible authority
The party responsible for data protection in the whistleblowing system is
1) Umdasch Group AG
2) Doka, Umdasch Group Ventures and Umdasch Store Makers
as parties with mutually autonomous responsibility (hereafter also: „UGAG”). The reporting system is operated by a specialised company, EQS Group AG, Bayreuther Str. 35, 10789 Berlin in Germany, on behalf of UGAG.
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 UGAG 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 only selected and authorised persons at UGAG.
Questions on data protection can be sent to dataprotection@doka.com.
Type of the collected personal 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:
- your name, if you choose to reveal your identity,
- whether you are employed at UGAG, and
- the names of persons and other personal data of persons that you name in your report.
Confidential handling of reports
Incoming reports are received by a small selection of expressly authorised and specially trained employees of the Compliance Organisation/- Internal Audit of UGAG and are always handled confidentially. The employees of the Compliance Organisation/- Internal Audit of UGAG 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 UGAG 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 protection of personal data. We always ensure that the applicable data protection regulations are complied with when sharing reports.
All persons who receive access to the data are obligated to maintain confidentiality.
Information of the accused person
At the discretion of the Compliance Organisation/Internal Audit, the accused persons may be informed about a report concerning them, unless this threatens further investigations into the report. In doing so, your identity – if you disclosed it - as whistleblower is not revealed as far as is legally possible.
Rights of the data subjects
As a result of the GDPR, you as data subject have in particular the right:
- to check whether and which personal data we have stored about you (right to information), provided that the provision of this information would not endanger a business or company secret of UGAG or the rights or freedoms of third parties
- request the rectification, integration or deletion of your personal data that is incorrect or is not processed in accordance with the law (right to rectification and deletion)
- require us to restrict the processing of your personal data (right of restriction)
- under certain circumstances to object to the processing of your personal data or to revoke a consent previously granted for the processing (right of objection or revocation of consent)
- to receive the personal data that you have provided to us in a structured, common and machine-readable format and to transfer this data to another responsible person (right to data transferability).
Retention period of 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 / user name and password. This allows you to send reports to the responsible employee at UGAG 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 at UGAG. 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.