Information on data protection
We take data protection and confidentiality very seriously and adhere to the current national data protection regulations as well as the EU-GDPR. Please read this data protection information carefully before submitting a report.
Purpose and legal foundation of the whistleblowing system
The whistleblowing system (BKMS® Incident Reporting) serves for securely and confidentially receiving, processing and managing reports concerning violations. The processing of personal data within the framework of the BKMS® Incident Reporting is based on the justified interest of our company in discovering and preventing abuses and thereby averting damage to the AGRANA Group, its employees and customers. The legal foundation for this processing of personal data is Article 6 paragraph 1f EU-GDPR.
About the whistleblowing system
In Germany, the whistleblowing system is operated by Business Keeper AG on behalf of AGRANA Beteiligungs-AG and its subsidiaries.
Personal data and information entered into the whistleblowing system are stored in a database of a high security data centre operated by Business Keeper AG, Bayreuther Straße 35, 10789, Berlin. Business Keeper AG and other third parties do not have access to the data.
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 AGRANA.
Use of the whistleblowing system takes place on a voluntary basis. Please note that we can only receive and examine reports if you confirm that you have read and understood this information about data protection and acknowledged the manner of processing of all personal data entered by you in accordance with the present data protection information.
Responsible parties
The parties responsible for data protection in the whistleblowing system are
- AGRANA Beteiligungs-AG and
- its subsidiaries
as parties with mutually autonomous responsibility (hereafter also: “AGRANA”).
Inquiries regarding data protection at AGRANA can be sent to dataprotection@agrana.com.
Type of 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 AGRANA, 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 authorized and specially trained employees of the Compliance organisation and Internal Audit department of AGRANA and are always handled confidentially. The employees of the Compliance Office and Internal Audit department of AGRANA evaluate the matter and carry out any further investigation that may be 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 AGRANA 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, 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.
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 the processing of your personal data. If the right to object 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. 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 concluding evaluation or for as long as a justified interest exists on the part of the company or retention is required by law. After the report processing is concluded, the personal data are deleted in accordance with statutory requirements.
Use of the whistleblowing portal
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® Incident Reporting, 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.
You can set up a secured postbox within the whistleblowing system that is secured with an individually chosen pseudonym/user name and password. 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 AGRANA 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 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.
Principles of data protection
Restricted use
The AGRANA Group may only use personal data for the purposes for which they were originally collected or for which the person concerned has subsequently given his or her approval. The AGRANA Group must further take measures to ensure that personal data are used exclusively for the specified purpose and are correct, complete and up-to-date.
Information about the accused
Upon request, AGRANA must provide the persons concerned with the possibility to access the personal data that is stored about them. In addition, the persons must be given the opportunity to correct, change or delete data that is incorrect. Your identity, i.e. that of the whistleblower, will not be disclosed. Furthermore, these rights can only be utilised if this does not endanger measures to clarify the situation.
Access, rectification, erasure and blocking
The whistleblower and the persons named in the report have the right to access, rectification, erasure and blocking of personal data and can revoke the storage of their personal data at any time without giving reasons. In this case, 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.
Data storage
AGRANA stores reports for as long as this is necessary to carry out follow-up measures, if a justifiable interest exists or if storage of the data is required by law. Reports are subsequently deleted or anonymised, i.e. any links to your identity as a whistleblower and to persons named in the report will be removed permanently and irreversibly.