The purpose of this information notice, concerning the aforementioned processing activity, is to provide you with all the information required by the applicable regulations and in particular by the General Data Protection Regulation (the “GDPR”).
Identity and contact details of the controller
Compagnie de Saint-Gobain
Saint-Gobain Tower, 12 place de l'Iris
92400 Courbevoie, France
Contact details of the Data Protection Officer (DPO)
To exercise your rights or if you have any queries about the processing of your data within this system, please send your request to the following address: PrivacyContact.CSG.FR@saint-gobain.com
Purpose of the processing
This processing activity has been set up in order to enable:
- Saint-Gobain Group employees and external and occasional collaborators, to report:
- a crime or misconduct;
- a serious and manifest violation of an international commitment duly ratified or approved by France;
- a serious and manifest violation of a unilateral act of an international organisation undertaken on the basis of a duly ratified international commitment;
- a serious and manifest violation of a law or regulation;
- a serious threat or harm to the public interest of which the issuer of the alert has personal knowledge;
- the collection of alerts from Saint-Gobain Group employees concerning the existence of conducts or situations that are contrary to the Saint-Gobain Group's Code of Conduct and are likely to be indicative of corruption or influence peddling.
- the collection of alerts relating to the existence or realisation of risks of serious violations of human rights and fundamental freedoms, human health and safety and the environment, resulting from the activities of Saint-Gobain Group entities, directly or indirectly, as well as from the activities of subcontractors or suppliers with whom Saint-Gobain has an established business relationship, when these activities are related to this relationship;
- the collection of any alerts regarding any behaviour or situation contravening Saint-Gobain Group's code of conduct.
Legal basis for the processing:
Legal obligation: the processing is necessary to comply with a legal obligation requiring the implementation of a whistleblowing system, in particular those provided for in Article L. 225-102-4 of the French Commercial Code and Articles 17.II.2° and 8.III of the “Sapin 2” law.
Legitimate interest: the processing allows the collection of alerts relating to a voluntary commitment by Saint-Gobain Group entities (internal code of conduct). Alerts are issued voluntarily and at the discretion of staff members or external and occasional employees.
Data and retention periods
- Inadmissible alert: without delay
- Closure for inaccuracy or deficiency: Two months from the closure of all admissibility or verification work
- Closure for misuse of the system or for lack of materiality of the facts: End of disciplinary and/or judicial proceedings
Where appropriate, persons are informed whether the data requested is obligatory or optional and the consequences for them if they fail to provide an answer.
The data collected is intended to be used by the persons specifically responsible for managing alerts within Saint-Gobain Group entities and made available to third parties (lawyers, experts, auditors) for the purposes of their analysis and investigation.
Transfer of data outside the European Union
The data collected may be made accessible outside the European Union, provided that this is strictly necessary for the processing of the alerts received, in particular in the context of the investigation to establish the materiality of the breaches. Prior to any transfer of personal data, the controller shall ensure, in particular by means of the European Commission's Standard Contractual Clauses, that the persons having access to such data guarantee an adequate level of protection.
Rights of individuals
Under certain conditions, the regulations may allow you to exercise the following rights over your personal data:
- Right of access;
- Right of rectification;
- Right of erasure;
- Right to restrict processing;
- Right to object.
You also have the right to decide what happens to your data after you die.
If you believe, after contacting us, that your rights are not being respected or that the data processing described herein does not comply with data protection rules, you have the right to lodge a complaint with your supervisory authority.
Report submission via telephone
Your anonymity will also be protected by the BKMS® Incident Reporting when you submit your report via telephone. Neither Saint-Gobain nor Business Keeper will have access to your telephone number. Your description of the incident will be recorded in the BKMS® Incident Reporting. Afterwards, the encrypted sound file is transcribed by the responsible Saint-Gobain employee. If you have set up a secured postbox at the end of the report submission by telephone, you can receive feedback in the form of a voice recording by the responsible employee of Saint-Gobain, and you can add information to your report, if necessary. Alternatively, you can access your secured postbox via the web application, review feedback, and make additions in written form. To protect the confidentiality of your report or addition, you can neither listen to it on your telephone nor in the web-based secured postbox.
Elements of this detailed information note may be subject to change according to the requirements of applicable local law.
To find out at any time the information relating to the data processing implemented, go to the home page of the Saint-Gobain alert system.
Last update on : 27/06/2022