Data protection information
We – the Eckes-Granini Group, including all affiliated companies in accordance with Section 15 of the Companies Act (AktG) (‘Eckes-Granini’) – take data protection and confidentiality very seriously and adhere to the provisions of the EU General Data Protection Regulation (GDPR) as well as current national data protection regulations. Please read this data protection information carefully before submitting a report.
Purpose and legal foundation of the SpeakUP! whistleblowing system
The SpeakUP! whistleblowing system (BKMS® System) serves for securely and confidentially receiving, processing and managing reports concerning violations of the compliance rules of Eckes-Granini. The processing of personal data within the framework of the SpeakUP! whistleblowing system is based on the legitimate interest of our company in discovering and preventing abuses and thereby averting damage to Eckes-Granini, its employees and customers. The legal foundation for this processing of personal data is Article 6(1)(1)(f) GDPR.
Responsible parties
The parties responsible for data protection in the SpeakUP! whistleblowing system are
- Eckes-Granini Group GmbH and
- its subsidiaries
as the sole responsible parties (hereafter also: ‘responsible party’). The SpeakUP! whistleblowing system is operated by a specialised company, EQS Group GmbH, Karlstraße 47, 80333 Munich, Germany, on behalf of Eckes-Granini.
Personal data and information entered into the SpeakUP! whistleblowing system is stored in a database operated by EQS Group GmbH in a high-security data centre. Only Eckes-Granini employees can see the data. EQS Group GmbH 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 according to a system of permissions so that access is restricted to a very small selection of expressly authorised persons at Eckes-Granini.
Eckes-Granini has appointed a data protection officer. Inquiries about data protection at Eckes-Granini can be sent by post to the postal address of Eckes-Granini to the attention of the ‘Data Protection Officer’ or by email to datenschutz@eckes-granini.de.
Type of personal data collected
Use of the SpeakUP! whistleblowing system takes place on a voluntary basis. If you submit a report via the SpeakUP! whistleblowing system, we collect the following personal data and information:
- Your name, if you choose to reveal your identity
- Whether you are employed at Eckes-Granini
- The names and other personal data of persons you name in your report
Confidential handling of reports
Incoming reports are received by a small selection of expressly authorised and specially trained employees of the compliance organisation of Eckes-Granini and are always handled confidentially. The employees of the Eckes-Granini 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 the respective responsible party or with 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, which may have different regulations about the protection of personal data. We always ensure compliance with the applicable data protection regulations when sharing reports.
All persons who receive access to the data are obligated to maintain confidentiality.
Information about the accused
We are legally obligated 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 exercised, the necessity of the stored data for the examination of a report will be evaluated immediately. Data that is no longer needed will be deleted at once. You also have the right to lodge a complaint with the supervisory authority.
Retention period of personal data
Personal data is retained for as long as necessary to clarify the situation and perform a final assessment or for as long as a legitimate interest exists on the part of the company or retention is required by law. After the report processing is concluded, the data will be deleted in accordance with statutory requirements.
Using the SpeakUP! whistleblowing system
Communication between your computer and the SpeakUP! whistleblowing system takes place over an encrypted connection (SSL). The IP address of the computer will not be stored during the use of the whistleblowing system. In order to maintain the connection between your computer and SpeakUP!, 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 the session and expires when the browser is closed.
You can set up a postbox within the whistleblowing system that is secured with an individually-selected pseudonym/user name and password. This allows you to send reports to the respectively responsible Eckes-Granini employee 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 email communication.
Note on sending attachments
When submitting a report or an addition, you can simultaneously send attachments to the responsible Eckes-Granini employee. If you wish to submit an anonymous report, please take note of the following security advice: Files may contain hidden personal data that could jeopardise your anonymity. Remove such data before sending anything. If you are unable to remove these data or you are uncertain, copy the text of your attachment to your report text or send the printed document anonymously to the address of the report recipient (see footer) with specification of the reference number that you receive at the end of the report process.
Version: August 2021
