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 of the whistleblowing system and legal basis
The whistleblowing system (BKMS® System) serves the purpose of securely and confidentially receiving, processing and managing reports regarding violations of the compliance rules of VHV Group. The processing of personal data in the BKMS® System is based on the legitimate interests of our company to detect and prevent misconduct and thus avoid damage to VHV Group, its employees and customers. Article 6 (1) (f) EU-GDPR serves as legal basis for this data processing. If you provide us with your data on a voluntary basis, the legal base may also be derived from Article 6 para. 1 sentence 1 lit. a) EU-DSGVO.
Responsible authority
The party responsible for data protection in the whistleblowing system is
- VHV Vereinigte Hannoversche Versicherung a.G and
- its subsidiaries
as parties with mutually autonomous responsibility (hereafter also: “VHV Group”). The reporting system is operated by a specialised company, EQS Group AG, Bayreuther Str. 35, 10789 Berlin in Germany, on behalf of VHV Group.
Personal data and information entered into the reporting system are stored in a database operated by EQS Group AG in a high-security data centre. Only VHV Group has access to the data. EQS Group AG 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 VHV Group.
VHV Group has appointed a data protection officer. Questions on data protection can be sent to VHV Group, Datenschutz_Sicherheit@VHV.de.
Type of the collected personal data
Use of the reporting 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 VHV Group, and
- the names of persons and other personal data of persons that 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 department of VHV Group and are always handled confidentially. The employees of the Compliance department of VHV Group will evaluate the matter and perform any further investigation required by the specific case.
During the processing of a report or the conduction of a special investigation, it may become necessary to share reports with additional employees of VHV Group 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 concerning the protection of personal data. We 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.
Rights of the data subjects
According to European data protection law, you and the persons named in the report have the right to inquiry, rectification, erasure, restriction of processing and the right to object to processing of personal data concerning them. If the right of objection is claimed, we will immediately examine to what extent the stored data is still necessary for the processing of a report. Data that is no longer required is deleted immediately. In addition, you have the right to lodge a complaint with a supervisory authority. If you have consented to the processing, you can also revoke this consent at any time with future effect. You also have the right to complain to the State Commissioner for Data Protection of Lower Saxony, Prinzenstraße 5, 30159 Hannover.
Retention period of personal data
Your personal data will be deleted as soon as they are no longer required for the above mentioned purposes. It may happen that personal data is retained for the time during which claims can be made against our company ( legal limitation period of three or up to thirty years). We also store your personal data for as long as we are legally obliged to do so. This regularly results from legal obligations to provide evidence and to retain data, which are regulated in the German Commercial Code, the German Fiscal Code or the Money Laundering Act, among others. The storage periods thereafter are up to ten years.
Use of the reporting portal
Communication between your computer and the reporting system takes place over an encrypted connection (SSL). Your IP address will not be stored during your use of the reporting 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 null 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 reporting system that is secured with an individually chosen pseudonym / user name and password. This allows you to send reports to the responsible employee at VHV Group in a confidential and safe way. This system only stores data inside the reporting 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 of VHV Group. Printed documents can be sent confidentially to the address listed in the footer, quoting the reference number provided at the end of the reporting process.
Version: 20. November 2020