Privacy notice
We 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 whistleblowing system
The whistleblowing system (BKMS® System) serves the purpose of securely and confidentially receiving, processing and managing reports concerning violations of the compliance rules of K.D. Feddersen Holding GmbH. The processing of personal data within the framework of the BKMS® System is based on the justified interest of our company in discovering and preventing abuses and thereby averting damage to K.D. Feddersen Holding GmbH, its employees and customers. The legal basis for our processing of personal data is Article 6(1)(f) of the GDPR (General Data Protection Regulation).
Responsible party
The party responsible for data protection in the whistleblowing system is
- K.D. Feddersen Holding GmbH and
- its subsidiaries
as parties with mutually autonomous responsibility (hereafter also: “K.D. Feddersen”). The whistleblowing system is run on behalf of K.D. Feddersen by a specialised company, EQS Group AG, Bayreuther Str. 35, 10789 Berlin in Germany.
Personal data and information entered into the whistleblowing system are saved in a database operated by EQS Group AG in a high-security data centre. Only K.D. Feddersen can see the data. EQS Group AG and other third parties do not have access to the data. This is ensured by extensive technical and organisational measures within the certified process.
All data are encrypted and saved with multi-level password protection, so that access is limited to a very small number of explicitly authorised recipients at K.D. Feddersen.
K.D. Feddersen has appointed a data protection officer. Questions about data protection at K.D. Feddersen can be sent to datenschutz@kdfeddersen.com.
Type of collected personal data
Using the whistleblowing system is voluntary. When you wish to submit a report using the whistleblowing system, we collect the following personal data and information:
- Your name, if your choose to reveal your identity
- Whether you work at K.D. Feddersen
- Potentially names of people or other personal data of people mentioned in the report.
Confidential handling of reports
Incoming reports are received and processed in a strictly confidential manner by a small circle of explicitly authorised and specially trained employees of the compliance organisation of K.D. Feddersen. The employees of the compliance organisation of K.D. Feddersen will 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 K.D. Feddersen 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 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.
Data subject rights
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 of objection to processing of your personal data. If the right to object 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 at once. You also have the right to lodge a complaint with the supervisory authority.
Retention period of personal data
Personal data are 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 processing of the report is finished, the data are deleted in accordance with the corresponding statutory requirements.
Use of the whistleblowing system
The communication between your computer and the whistleblowing system takes place through an SSL-encrypted connection. 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® System, a cookie is stored on your computer that contains only the session ID (a so-called session cookie). The cookie is only valid until the end of your session and expires when you close your browser.
You can set up a secured postbox with your pseudonym/user name and password of choice in the whistleblowing system. This allows you to send reports to the respectively responsible K.D. Feddersen 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 e-mail communication.
Note on sending attachments
During the report submission or when submitting additional information, you can send attachments to the responsible employee of K.D. Feddersen. If you wish to submit an anonymous report, please take note of the following security advice: files can contain hidden personal data that could put your anonymity at risk. Remove such data before sending. If you are unable to remove these 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: July 2020
