BERTELSMANN takes the topic of data protection and confidentiality very seriously. We 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.
The party responsible for data protection in the whistleblowing system is
Bertelsmann SE & Co. KGaA
33311 Gütersloh, Germany
Telephone: +49 (0) 5241-80-0
Fax: +49 (0) 5241-80-62321
The data protection officer of Bertelsmann SE & Co. KGaA (hereafter: BERTELSMANN) can be reached at the above postal address with the addition "To the Data Protection Officer" or at the email address: firstname.lastname@example.org.
Type of the collected personal data
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 BERTELSMANN and
- the names and other personal data of persons whom you list in your report, if applicable.
Purpose and legal foundation of the data processing
The whistleblowing system (BKMS® System) serves for securely and confidentially receiving, processing and managing reports concerning violations of the compliance rules of BERTELSMANN. The processing of personal data within the framework of the BKMS® System is based on the justified interest of our company in discovering and preventing abuses and thereby averting damage to BERTELSMANN, BERTELSMANN group companies, employees and customers. The legal foundation for this processing of personal data is therefore Article 6 paragraph 1 f) EU-GDPR.
Confidential handling of reports
Incoming reports are received by a small selection of expressly authorized and specially trained employees of the Compliance Organisation of BERTELSMANN and always handled confidentially. The designated employees of the BERTELSMANN Compliance Organisation evaluate the matter and perform any further investigation required by the specific case.
While processing a report or conducting a special investigation, it may be necessary to share reports with additional employees of BERTELSMANN or employees of other BERTELSMANN 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 about the protection of personal data. We always ensure that the applicable data protection regulations are complied with when sharing reports and that the consent of the report submitter is obtained before sharing a report with employees of BERTELSMANN group companies for processing of the issue. All persons who receive access to the data are obligated to maintain confidentiality.
Information about the accused
We are legally obliged to inform accused parties of any reports received against them as soon as the disclosure of this information no longer jeopardises the investigation. Your identity as a whistleblower will not be disclosed unless we are legally bound to do so .
Rights of the data subjects
Pursuant to European data protection legislation, you and the persons named in the report have a right of access, rectification, erasure, restriction of processing and right to object to the processing of your personal data. If the right to object to the processing of the personal data is invoked, the necessity of the stored data for the examination of a report will be evaluated immediately. Data that are no longer required will be deleted at once. If you would like to make use of your right to object, please contact the address listed under item 1.
You also have the option of contacting a data protection authority and submitting a complaint there. The competent authority for our company is the
State Representative for Data Protection and Freedom of Information of North Rhine-Westphalia
Phone: +49 (0) 211/38424-0
Fax: +49 (0) 211/38424-10
However, you can also contact the data protection authority responsible for your place of residence.
No automated decision-making takes place with regard to the processing of your personal data described here.
No profiling takes place.
Retention period of personal data
Personal data are retained for as long as necessary to clarify the situation and issue a final assessment of the report or until existing contractual and/or legal obligations are met, unless overriding statutory retention periods prevent erasure of the data. The same applies if you have revoked your consent.
If this privacy statement is modified, notice of this change will be published on the website and in other suitable locations.
Date of privacy statement: June 2018