Privacy policy
We take data protection and confidentiality seriously and adhere to applicable data protection law. We nonetheless ask you to read this privacy information carefully before submitting a report.
Purpose of the whistleblowing system
The whistleblowing system (BKMS® System) primarily serves the secure and confidential receipt and processing of reports concerning violations of commercial law.
Responsible authority and data security
Data protection responsibility lies with the law office Thiel von Herff | Lawyers, Detmolder Straße 30, 33604 Bielefeld. The whistleblowing system is operated by a specialised company, EQS Group AG, Bayreuther Str. 35, 10789 Berlin in Germany, on behalf of the law office, Thiel von Herff | Lawyers.
Personal data and information entered into the whistleblowing system are stored in a database operated by EQS Group AG in a high-security data centre. Only Thiel von Herff | Lawyers 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 Thiel von Herff | Lawyers.
Type of personal data collected
Use of the whistleblowing 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 WMF, and
- names and other personal data of persons that you name in your report.
Confidential handling of reports
Submitted reports are received by the external confidential lawyer, Dr Thiel von Herff, or another lawyer from the Thiel von Herff | Lawyers office and will be treated with strict confidentiality. The confidential lawyer will investigate the matter.
During the processing of a report or the conducting of a special investigation, it may become necessary to forward reports to members of the WMF Group. These recipients may be based in countries outside the European Union or the European Economic Area with different regulations concerning the protection of personal data. We ensure compliance with the applicable data protection regulations when sharing reports.
All persons who receive access to the data are obligated to maintain confidentiality.
Retention period of personal data
Personal data are retained for as long as necessary to clarify the situation and perform a concluding evaluation. After the report processing is concluded, this data is deleted in accordance with the statutory requirements.
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.
It is possible to set up a postbox within the whistleblowing system that is secured with an individually chosen pseudonym/user name and password. This allows you to send reports to the confidential lawyer either by name or in an anonymous, safe way. This system only stores data inside the whistleblowing 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 confidential lawyer. If you wish to submit an anonymous report, please take note of the following security advice: Files can contain hidden personal data that could endanger your anonymity. 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: April 2016