The Vienna Airport Group takes data protection very seriously. Flughafen Wien AG (hereinafter referred to as "FWAG") as the parent company of the Vienna Airport Group has created a Whistleblower Hotline which enables reporting of alleged violations of internal regulations by employees of the Vienna Airport Group (together with FWAG referred to as "we" or "our"), such as, e.g., the Code of Conduct of the Vienna Airport Group or violations of statutory provisions, such as e.g., the Austrian Criminal Code [Strafgesetzbuch/StGB]. A report may be made by the whistleblower anonymously or they may state their identity.
The controller as defined in the General Data Protection Regulation (GDPR), other national data protection laws of the Member States or other data protection provisions is the relevant entity of the Vienna Airport Group whose employees are affected by the report (you can find the name and address of the controller in Annex 1).
For what purpose do we process personal data?
The data processed in connection with a report submitted is processed for the purpose of
- investigating the alleged illegal conduct of the employee of the Vienna Airport Group and/or the alleged violation of internal regulations;
- avoiding, preventing and pursuing of criminal sanctions and legal claims/ rights due to damage and/or other financial losses which may be caused by employees of the Vienna Airport Group;
- protecting the financial interests, reputation, assets and rights of the Vienna Airport Group as well as for preventing allegations against employees of the Vienna Airport Group.
Depending on the details and contents of the report, the following personal data may be processed when a report is submitted:
- if stated: name, description of the place of employment and location, contact details such as email address and telephone number;
- case-based data, such as, e.g., third-party involvement or damage caused;
- ll other information which is provided by the whistleblower about the accused person or about himself/ herself in the course of the report.
What is the legal basis for processing personal data?
Data is processed by the controller in accordance with Section 6 (1) (f) GDPR ("legitimate interest"). Compliance with statutory and internal regulations is of utmost importance to the Vienna Airport Group. For that reason FWAG has implemented the Whistleblower Hotline for anonymous reporting and uncovering of shortcomings and/or misconduct of employees of the Vienna Airport Group. Only four employees of FWAG have access to reports submitted to the Whistleblower Hotline. These employees have been specially trained in processing cases and handling the whistleblower system. In addition, they have been put under an obligation to maintain secrecy and confidentiality.
The relevant responsible entity of the Vienna Airport Group and FWAG have a legitimate interest which justifies data processing in connection with the Whistleblower Hotline. The rights of the data subject are adequately protected by numerous measures (e.g. by carrying out a data protection impact assessment or exclusive processing by selected employees) and do not prevail over the interests to data processing of the relevant responsible entity of the Vienna Airport Group and/or FWAG.
How long will your data be stored?
Data will be stored for as long as we process the case. Once the investigations have been concluded by the selected employees the data will be deleted within two months of the change to the processing status. Should the accusations be confirmed, the data will be stored for pursuing legal claims and for carrying out administrative or legal proceedings until they have been concluded.
Who will your data be forwarded to?
Reports will be exclusively processed by specially trained employees of FWAG who have been put under an obligation to maintain secrecy and confidentiality. Thus, the reported data may be transmitted within the Vienna Airport Group. Should the accusations made in the report be confirmed, the data will, if necessary, be forwarded to lawyers, law enforcement and prosecution authorities and/or to other responsible authorities as well as to criminal and/or civil courts.
EQS Group AG, whose registered office is in Berlin (Germany), processes the data as the processor as defined in Section 28 GDPR on the basis of a data processing agreement.
What rights do you have in connection with the processing of your data?
The General Data Protection Regulation (EU Regulation No. 2016/679) grants you certain rights as a data subject, which we would like to make you aware of in the following. Please note that they complement each other so that you may only either request the rectification of your data and/or have it completed or request its erasure.
Right to information: You may request information on the origin, categories, period of storage, recipients and purpose of the data regarding your person processed by FWAG or the relevant responsible entity of the Vienna Airport Group and on the way in which it is processed.
Right to rectification and erasure: In the case that FWAG or the relevant responsible entity of the Vienna Airport Group processes data regarding your person which is incorrect or incomplete you may request that the data be rectified or completed. In addition you may request the erasure of unlawfully processed data.
Right to restriction of processing: If it is unclear whether the data regarding your person that is being processed is incorrect or incomplete or if the data is being processed unlawfully, you may request restriction of processing of your data until the issue is finally resolved.
Right to object: Even if data regarding your person is correct and complete and processed lawfully by FWAG, you may object to processing of this data. However, this is only possible in specific circumstances which you must justify.
Withdrawal of consent: If FWAG or the relevant responsible entity of the Vienna Airport Group stores and processes your personal data based on your consent, you may withdraw your consent at any time. This shall, however, not affect the lawfulness of the processing up to the time of withdrawal.
Right to data portability: You may receive the data regarding your person which FWAG or the relevant responsible entity of the Vienna Airport Group has processed and which we have received from you yourself in a machine-readable format specified by us or instruct us to forward that data directly to a third party chosen by you, provided that that recipient enables us to do so from a technical point of view, and provided no unreasonable expenses or statutory or other obligations to maintain secrecy or considerations regarding confidentiality on the part of FWAG or the relevant responsible entity of the Vienna Airport Group or third parties prohibit the transmission of such data.
Right to lodge a complaint: Finally you are entitled to lodge a complaint with the Data Protection Authority if you are of the opinion that the processing of your personal data violates the General Data Protection Regulation (EU Regulation 2016/679).
Who can you contact to assert your rights as a data subject?
To assert the abovementioned rights please contact the FWAG Data Protection Officer in writing (by letter or email) (please see the contact details below). If you believe that processing of the personal data concerning you violates the GDPR, please do not hesitate to inform us of your concerns in writing to
- Flughafen Wien Aktiengesellschaft [FWAG]
- Attn: Data Protection Officer
- P.O. Box 1
- 1300 Vienna-Airport
- datenschutz@viennaairport.com
and state the relevant entity of the Vienna Airport Group. In such cases you also have a right to lodge a complaint [Beschwerde] with a supervisory authority. For more detailed information on your rights please see www.viennaairport.com/datenschutz.
Annex I: Liste der Verantwortlichen (Name und Sitz)
Vienna Airport Technik GmbH P.O. Box 1, 1300 Vienna-Airport, Austria | Vienna Passenger Handling Services GmbH P.O. Box 1, 1300 Vienna-Airport, Austria |
Flughafen Wien Immobilienverwertungsges.m.b.H. P.O. Box 1, 1300 Vienna-Airport, Austria | Mazur Parkplatz GmbH Hainburger Bundesstr. 143, 2320 Schwechat, Austria |
Vienna Aircraft Handling Ges.m.b.H. Steinriegelweg, Obj. 140, 1300 Vienna-Airport, Austria | Alpha Liegenschaftsentwicklungs GmbH P.O. Box 1, 1300 Vienna-Airport, Austria |
Vienna Int. Airport Security Services Ges.m.b.H. P.O. Box 177, 1300 Vienna-Airport, Austria | VIE Logistikzentrum West GmbH&CoKG 1300 Vienna-Airport, Austria |
VIE Liegenschaftsbeteiligungsges.m.b.H. P.O. Box 1, 1300 Vienna-Airport, Austria | Vienna Airport Health Center GmbH P.O. Box 1, 1300 Vienna-Airport, Austria |
Flugplatz Vöslau BetriebsGmbH Flugfeldstraße 1, 2540 Bad Vöslau, Austria | Vienna Airport Business Park Immobilienbesitzgesellschaft m.b.H. P.O. Box 1, 1300 Vienna-Airport, Austria |
VIE Airport Baumanagement GmbH P.O. Box 1, 1300 Vienna-Airport, Austria | GetService Dienstleistungsgesellschaft m.b.H. P.O. Box 177, 1300 Vienna-Airport, Austria |
VIE Flugbetrieb Immobilien GmbH P.O. Box 1, 1300 Vienna-Airport, Austria | VIE International Beteiligungsmanagement Gesellschaft m.b.H. P.O. Box 1, 1300 Vienna-Airport, Austria |
VIE Office Park 3 BetriebsgmbH P.O. Box 1, 1300 Vienna-Airport, Austria | „GetService“-Flughafen Sicherheits- und Servicedienst GmbH P.O. Box 177, 1300 Vienna-Airport, Austria |
VIE Office Park Errichtungs- und Betriebsgesellschaft m.b.H. P.O. Box 1, 1300 Vienna-Airport, Austria | Airport Services VIE Immobilien GmbH Zeppelinstrasse 9, 2401 Fischamend, Austria |
City Air Terminal Betriebsgesellschaft m.b.H. P.O. Box 1, 1300 Vienna-Airport, Austria | VIE Immobilien Betriebs GmbH P.O. Box 1, 1300 Vienna-Airport, Austria |
Vienna Int. Airport Beteiligungsholding GmbH P.O. Box 1, 1300 Vienna-Airport, Austria | Office Park 4 Errichtungs- und Betriebs GmbH P.O. Box 1, 1300 Vienna-Airport, Austria |
VIE Shops Entwicklungs- und Betriebsges.m.b.H. P.O. Box 1, 1300 Vienna-Airport, Austria | VIE Finance Holding GmbH Flugplatz 1, 2540 Bad Vöslau, Austria |
Flughafen Wien AG P.O. Box 1, 1300 Vienna-Airport, Austria | Load Control International SK s.r.o Letisko Kosice, Kosice IV 041 75, Slovakia |
Airport Parking Ltd. SkyParks Business Centre Ltd, Malta International Airport, Luqa, LQA4000 Malta | BTS Holding a.s. Sturova 4, 81102 Bratislava, Slovak Republic |
KSC Holding a.s. Sturova 4, 81102 Bratislava, Slovak Republic | Malta Mediterranean Link Consortium Ltd. Palazzo Pietro Stiges, 60 St. Christopher Street Valletta VLT 05, Malta |
Malta International Airport plc. Malta International Airport, Luqa, LQA4000, Malta | MMLC Holdings Malta Limited 2nd Floor Administration Office, Malta International Airport, Luqa, LQA4000 Malta |
Sky Parks Business Center Ltd. SkyParks Business Centre Ltd, Malta International Airport, Luqa, LQA4000 Malta | VIE Malta Finance Limited Room 486, Welcomers´Hall Spaceframe Offices, Malta International Airport, Luqa, LQA4000 Malta |
Sky Parks Development Ltd. SkyParks Business Centre Ltd, Malta International Airport, Luqa, LQA4000 Malta | VIE Operations Limited 2nd Floor Administration Office, Malta International Airport, Luqa, LQA4000 Malta |
VIE Malta Limited 2nd Floor Administration Office, Malta International Airport, Luqa, LQA4000 Malta | VIE Operations Holding Limited 2nd Floor Administration Office, Malta International Airport, Luqa, LQA4000 Malta |