Information on data protection
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 protection regulations. Please read this data protection information carefully before submitting a report.
Purpose and legal foundation of the whistleblowing system
The whistleblowing system (BKMS® System) serves for securely and confidentially receiving, processing and managing reports concerning compliance violations in the Veritas Group. The processing of personal data within the framework of the BKMS® System is based on the justified interest of our corporate group in discovering and preventing abuses and thereby averting damage to Veritas Group, its employees and customers. The legal basis for this processing of personal data is Article 6 paragraph 1f of the EU-GDPR (General Data Protection Regulation).
Responsible authority
The party responsible for data protection in the whistleblowing system is Veritas AG, Stettiner Straße 1-9, 63571 Gelnhausen, Germany (hereafter "Veritas AG"). The whistleblowing system is operated by a specialised company, EQS Group GmbH, Karlstraße 47, 80333 Munich in Germany, on behalf of Veritas AG and its affiliated companies.
Personal data and information entered into the whistleblowing system are stored in a database of a high security data centre operated by EQS Group GmbH. Only examiners of Veritas AG can access this 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 so that access is restricted to a very small selection of expressly authorised persons at Veritas AG.
Veritas AG has appointed a data protection officer. Requests concerning data protection can be sent by email to datenschutz.extern@veritas-ag.de.
Type of personal data collected
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 a company of Veritas Group, and
- the names and other personal data of persons whom you list in your report, if applicable.
Confidential handling of reports
Incoming reports are received by a small selection of expressly authorised and specially trained employees in the group departments of Compliance and Internal Audit at Veritas AG and always handled confidentially. The employees of the 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 group companies of Veritas Group, e.g. if the reports refer to incidents in the sister company Poppe GmbH or in the subsidiaries of Veritas AG. Some subsidiaries are based in countries outside the European Union or the European Economic Area with different regulations about the protection of personal data. We will always ensure that the applicable data protection regulations are complied with 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 subject
Pursuant to European data protection legislation, you and the persons named in the report have a right of information, rectification, erasure, restriction of processing and objection to processing of your personal data. If no objection to the processing is made, we process the data for the aforementioned purposes of the whistleblowing system, to exercise and defend legal claims and to ensure the availability, data security and data protection monitoring. If the right of objection 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 needed will be deleted or anonymised at once. You also have the right to appeal 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 Veritas Group or retention is required by law. After the report processing is concluded, the data will be deleted or anonymised in accordance with statutory requirements.
Use of the whistleblower portal
Communication between the computer used by you to access the BKMS® System and the whistleblowing system itself takes place over an encrypted connection (SSL). The IP address of your computer 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 contains only 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.
You can set up a secured postbox within the whistleblowing system that is secured with an individually chosen pseudonym/user name and password. This allows you to send reports to the respectively responsible employee of the group Compliance and Internal Audit departments of Veritas AG either by name or in an anonymous, safe way and receive a reply. 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 employee in the group Compliance and Internal Audit departments of Veritas AG. 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 uncertain about 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: 06-Jun-2018