Data Privacy 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 privacy regulations. Please read this data privacy information carefully before submitting a report.
Purpose of the whistleblowing system and legal basis
The whistleblowing system (BKMS® Incident Reporting) serves the purpose of securely and confidentially receiving, processing and managing reports of alleged misconduct relevant to the Terms of Reference of the ISC as mandated by the International Senate of SOS Children’s Villages (SOS CV). The processing of personal data in the BKMS® Incident Reporting is based on the legitimate interests of the ISC and SOS CV to fulfil the Terms of Reference of the ISC. Article 6 (1) (f) EU-GDPR serves as legal basis for this data processing.
Responsible authority
The ISC is responsible for data privacy in this whistleblowing system. The ISC is mandated by the International Senate of SOS CV as parties with mutually autonomous responsibility. The reporting system is operated by a specialised company, Business Keeper GmbH, Bayreuther Str. 35, 10789 Berlin in Germany, on behalf of the ISC.
Personal data and information entered into the reporting system are stored in a database operated by Business Keeper in a high-security data centre. Only The ISC has access to the data. Business Keeper 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 necessary persons at the ISC.
The ISC has appointed a data protection officer. Questions on data protection and privacy can be sent to contact@independentsc.org.
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, contracted by, or interning/ volunteering at the International Office, General Secretariat, International Office Region, a National Member Association, SOS Children’s Villages, a specific SOS Village, SOS home, or SOS programme, 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 specified members of The ISC and are always handled confidentially. The expressly authorised and specified members of The ISC will evaluate the matter and perform any further investigation required by the specific case.
During the processing of a report or the conduct of an investigation, it may become necessary or legally required, to share reports with entities relevant to the work of The ISC or national authorities that 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 of the individual you are reporting
As a basic principle of due process, we are bound by applicable law to inform the individual you are reporting that we have received a report against them or concerning them, unless doing so poses a threat to any person or threatens further investigations into the report. In doing so, your identity as whistleblower is not revealed as far as is legally possible unless you provide your express and informed consent.
Rights of the data subjects
According to European data protection law, you and the persons named in the report have the right to inquiry, rectification, erasure, restriction of processing and the right to object to processing of personal data concerning them. If the right of objection 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 have the right to lodge a complaint with a supervisory authority.
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 ISC exists, or it is required by applicable 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® Incident Reporting, 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 reporting system that is secured with an individually chosen pseudonym/ user name and password. This allows you to send reports to the responsible expressly authorised and specified member of The ISC 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 expressly authorised and specified member of The ISC. 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.
Version: 01 August 2022