Privacy policy
We take data protection and confidentiality very seriously when using the whistleblower system and comply with the applicable data protection regulations. This directive is based on the General Data Protection Regulation (GDPR) and locally applicable data protection law. Please read this privacy information carefully before submitting a report.
Purpose of the whistleblowing system
The whistleblowing system (BKMS® System) serves for securely and confidentially receiving, processing and managing reports regarding alleged violations of applicable laws or internal rules of the Vaillant Group. The Vaillant Group comprises Vaillant GmbH, Berghauser Strasse 40, 42859 Remscheid, Germany, and its subsidiaries.
Responsible authority and data security
The party responsible for data protection in the whistleblowing system is Vaillant GmbH, Berghauser Straße 40, 42859 Remscheid, Germany as parent company (hereafter also: “Vaillant”). The whistleblowing system is operated by a specialized company, EQS Group GmbH, Karlstraße 47, 80333 Munich in Germany, on behalf of Vaillant. Personal data and information entered into the whistleblowing system are stored in a database operated by EQS Group GmbH in a high-security data center. Only Vaillant has access to the data. Any data is stored in such an encrypted way that neither EQS Group GmbH nor other third parties have access to the data. This is ensured through extensive technical and organizational measures in a procedure certified by a data protection authority. All data is encrypted and stored with multiple levels of password protection so that access is restricted to a very small selection of expressly authorized persons at Vaillant and is only passed on within the framework of the processing of information within the Vaillant Group.
Type of the collected personal data
Use of the whistleblowing system is voluntary. If you submit a report via the whistleblowing system, we collect the following personal data and information:
- Your name, if you reveal your identity
- Whether you are employed at Vaillant
- The names of persons and other personal data of persons that you name in your report.
- Name, title and contact details of the persons processing the data
- Facts reported
- Materials collected in connection with the verification of the reported facts
- Minutes of the verification operations
Replies to your message, if you use the protected postbox
Confidential handling of reports
Incoming reports are received by a small selection of expressly authorized and specially trained employees of the Compliance Organization of Vaillant and are always handled confidentially. The employees of the Compliance Organization of Vaillant evaluate the matter and perform any further investigation required by the specific case.
Within the framework of processing a report or within a special investigation, it may be necessary to share reports with additional employees of Vaillant 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 about the protection of personal data. We always ensure that the applicable data protection regulations are followed when sharing reports.
If you have concerns regarding the protection of personal data, please contact us:
Vaillant GmbH
Attn. of external Data Protection Officer (Confidential)
Berghauser Str. 40
42859 Remscheid/ Germany
or
datenschutz@vaillant-group.com
All persons who receive access to the data are obligated to maintain confidentiality.
Retention period of personal data
Personal data is retained for as long as necessary to clarify the situation and perform an evaluation. After the report processing is concluded, this data is deleted in accordance with the statutory requirements.
Use of the whistleblowing system
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 user name and password. This allows you to send reports to the responsible employee at Vaillant 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 responsible Vaillant employee. 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 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.
Supplementary validity of the general data protection conditions
In addition, our general data protection conditions apply under https://www.vaillant-group.com/en/datenschutzerklaerung-368020.html
Version: May 2022