Privacy policy
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 information on data protection law carefully before submitting a report.
Purpose and legal basis of the whistleblowing system
The whistleblowing system (BKMS® System) serves for securely and confidentially receiving, processing and managing reports concerning compliance violations. The processing of personal data within the framework of the BKMS® System is based on the legitimate interest in discovering and preventing abuses and thereby averting damage to VDE, its employees and customers. The legal basis for the processing of personal data is Article 6(1)(f) of the GDPR.
Controller
The controller responsible for data protection in the whistleblowing system is
- VDE Verband der Elektrotechnik Elektronik Informationstechnik e.V. and
- VDE Prüf- und Zertifizierungsinstitut GmbH
as parties with mutually autonomous responsibility (hereafter also respectively: “VDE”). The whistleblowing system is operated by a specialised company, EQS Group AG, Bayreuther Str. 35, 10789 Berlin, Germany, on behalf of VDE.
Personal data and information entered into the whistleblowing system are stored in a database operated by EQS Group AG in a high-security data centre. Only VDE employees can see 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 is stored encrypted with multiple levels of password protection according to a system of permissions so that access is restricted to a very small selection of expressly authorised persons at VDE.
VDE has appointed a data protection officer. Our data protection officers can be reached at:
Data protection officer
VDE Verband der Elektrotechnik Elektronik Informationstechnik e. V.
Merianstrasse 28
63069 Offenbach am Main
Phone +49 69 6308-0
datenschutz@vde.com
Type of personal data collected
Use of the whistleblowing system is voluntary. We collect the following personal data and information when you submit a report using the whistleblowing system:
- Your name, if you choose to reveal your identity
- Your contact details if you provide them
- Whether you are employed at VDE or at a company in the VDE Group
- 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 authorised and specially trained employees of the compliance organisation of VDE and are always handled confidentially. The employees of the VDE compliance organisation evaluate the matter and perform any further investigation required by the specific case.
All persons who receive access to the data are obligated to maintain confidentiality.
Data transmission to third parties
While processing a report or conducting a special investigation, it may be necessary to share reports with additional employees of VDE or employees of other companies in the VDE Group, such as if the reports refer to incidents in subsidiaries.
In addition, your personal data are only forwarded to third parties or public authorities for further investigations in individual cases in which there are specific reasons to suspect unlawful activity if this is required for investigating illegal conduct or for prosecution.
The legal basis for the processing of this data is Article 6(1)(f) GDPR. According to this, the data processing is lawful where the controller has a legitimate interest (in this case, our legitimate interest in combating malpractice, prosecuting crimes and defending, asserting and enforcing claims) insofar as these are not outweighed by your interests and fundamental rights.
The abovementioned recipients may be based in countries outside the European Union or the European Economic Area with different regulations about the protection of personal data. We always ensure that the applicable data protection regulations are complied with when sharing reports.
Information about the accused party
We are legally obliged 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.
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 and restriction of processing and a right to object to the processing of your personal data. If the right to object to the processing of the personal data is exercised, the necessity of the stored data for the examination of a report will be evaluated immediately. Data that are no longer needed will be erased without undue delay. You also have the right to lodge a complaint with the supervisory authority.
Retention period for 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 report processing is concluded, the data will be erased in accordance with statutory requirements.
Use of the whistleblowing system
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 device and the BKMS® System, a cookie is stored on your device that merely contains the session ID (a session 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 secured postbox within the whistleblowing system with an individually chosen pseudonym/ user name and password. This allows you to send reports to the respectively responsible VDE 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 email communication.
Note on sending attachments
When submitting a report or an addition, you can simultaneously send attachments to the responsible VDE employee. If you wish to submit an anonymous report, please take note of the following security advice: Files may contain hidden personal data that could jeopardise your anonymity. Please remove all such information before sending a file. If you are unable to remove such 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: 10 April 2023