NOTICE CONCERNING PROCESSING OF PERSONAL DATA - WHISTLEBLOWING SYSTEM
Notes on data privacy
The company Fromageries Henri Hutin (hereinafter referred to as “Henri Hutin”) takes data protection and data privacy very seriously and we adhere to the provisions of the General Data Protection Regulation of the European Union (GDPR) and the current national regulations on data protection. Please read this data privacy information carefully before submitting a report.
Purpose of the whistleblowing system and legal basis
The purpose of the whistleblowing system (BKMS® Incident Reporting) is to receive, process and manage reports concerning breaches of the compliance rules of Henri Hutin in a secure and confidential manner. The processing of personal data in the BKMS® Incident Reporting is based on our company’s legitimate interests in detecting and preventing misconduct which may be detrimental to Henri Hutin, its employees and its customers. Article 6, paragraph 1, point f) of the General Data Protection Regulation serves as a legal basis for this processing.
The data controller responsible for processing the personal data within the framework of the whistleblowing system is:
Fromageries Henri Hutin SARL
99 rue du Rattentout - 55320 Dieue-sur-meuse
Tel: 03 29 83 23 23
The whistleblowing system is managed by a specialist company, Business Keeper GmbH, Bayreuther Str. 35, 10789 Berlin in Germany on behalf of Henri Hutin
All personal data and information entered into the whistleblowing system are stored in a database operated by Business Keeper GmbH, in a high-security data centre. Only Henri Hutin has access to the data. Business Keeper GmbH and other third parties do not have access to the data. This is guaranteed by numerous technical and organisational measures, which are part of the certification procedure.
All data are stored in encrypted form with several layers of password protection. Access is therefore limited to a very small number of expressly authorised persons.
Henri Hutin has appointed a data protection officer. Questions regarding data protection and data privacy can be submitted:
03 29 83 23 00
FROMAGERIE HENRI HUTIN SARL
A l’attention du délégué à la protection des données
99 rue du Rattentout – 55320 Dieue-sur-meuse
Type of personal data collected
Use of the whistleblowing system is voluntary. 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,
- if you are employed at Henri Hutin, and
- the names of persons and other personal data of the persons that you mention in your report.
Confidential handling of reports
The incoming reports are received by a small selection of employees who are expressly authorised and specially trained by the Compliance department of Henri Hutin. The reports are always treated in the utmost confidence. The employees of the Compliance department of Henri Hutin will assess the problem and carry out any further investigation that the specific case requires.
While a report is being processed or a special investigation is being conducted, it may be necessary to share reports with other employees of Henri Hutin or with employees of other Group companies, for example if the reports refer to incidents that have occurred within subsidiaries of the Hochland Group. These subsidiaries may be based in countries outside the European Union or the European Economic Area and may have different regulations regarding the confidentiality of personal data. We always ensure that the applicable data privacy regulations are complied with when we share reports.
All persons who receive access to the data are obliged to respect the confidentiality of such data.
Information about the implicated individual
As a basic principle, we are obliged by law to inform the implicated individual that we have received a report concerning him or her, unless such information is likely to prejudice any future investigations conducted in the context of the report. In doing so, your identity as a whistleblower will not be revealed, without prejudice to any legal provisions requiring such disclosure.
Rights of the data subjects
Under European data protection law, you and the persons named in the report have the right of investigation, rectification, erasure, restriction of processing and the right to object to the processing of your personal data. If the right of objection is asserted, we will immediately examine the extent to which the stored data remains necessary for the processing of a report. Data which are no longer necessary are deleted immediately. Furthermore, you have the right to file a complaint with the CNIL.
Retention period for personal data
Personal data are retained for as long as is necessary to clarify the situation and to make an assessment of the report or for as long as a legitimate interest of the company exists, or for as long as is required by law. Once the processing of the report has been completed, these data are deleted in accordance with the legal requirements.
Use of the whistleblowing system
Communication between your computer and the whistleblowing system is achieved via an encrypted connection (SSL). Your IP address will not be recorded during your use of the whistleblowing system. To maintain the connection between your computer and the BKMS® Incident Reporting, a cookie is stored on your computer which only 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.
You can set up a postbox in the whistleblowing system and choose your own pseudonym/user name and password for security. This allows you to send reports to the compliance officer at Henri Hutin, either by using your own name, or by sending the report anonymously and securely. This system only stores data within the whistleblowing system, which makes it particularly secure. It is not a regular form of email communication.
Note on sending attachments
When you submit a report or an addendum, you can simultaneously send attachments to the compliance officer of Henri Hutin. If you wish to submit an anonymous report, please note the following security advice: The files may contain hidden personal data which can compromise your anonymity. Please delete these data before sending them. If you are unable to delete this information, or you do not know how to delete it, please copy the text of your attachment into your report text or send the printed document anonymously to the address at the bottom of this page, specifying the reference number that you will receive at the end of the reporting procedure.
Version: Date: 16/10/2020