Data protection policy
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 sending, receiving, processing and managing reports regarding violations of the compliance rules of CHRIST, VALMANO and BRINCKMANN UND LANGE. The processing of personal data in the BKMS® System is based on the legitimate interests of our CHRIST JUWELIERE UND UHRMACHER SEIT 1863 GMBH to detect and prevent misconduct and thus avoid damage to CHRIST, VALMANO and BRINCKMANN UND LANGE, its employees and customers. Article 6 (1) (f) EU-GDPR serves as legal basis for this data processing.
Responsible authority
The party responsible for data protection in the whistleblowing system is CHRIST JUWELIERE UND UHRMACHER SEIT 1863 GMBH. The reporting system is operated by a specialized service provider, the EQS Group GmbH, Bayreuther Str. 35, 10789 Berlin in Germany, on behalf of the CHRIST JUWELIERE UND UHRMACHER SEIT 1863 GMBH.
Personal data and information entered into the reporting system are stored in a database operated by EQS Group GmbH in a high-security data centre. Only CHRIST JUWELIERE UND UHRMACHER SEIT 1863 GMBH has access to the data. EQS Group GmbH and other third parties do not have access to the data. This is ensured in the certified procedure through extensive technical and organisational measures in compliance with Art. 32 of the EU GDPR.
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 CHRIST JUWELIERE UND UHRMACHER SEIT 1863 GMBH.
The CHRIST-Group has appointed a data protection officer. Questions on data protection can be sent to datenschutzbeauftragter@christ.de. All data are stored encrypted with multiple levels of password protection so that access is restricted to a very small selection of expressly authorized persons at CHRIST-Group.
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 CHRIST, VALMANO or BRINCKMANN UND LANGE, and
- the names of persons and other personal data of persons that you name in your report.
At your request, the anonymity of your personal data will be guaranteed by the CHRIST Group.
Confidential handling of reports
Incoming reports are received by a small selection of expressly authorised and specially trained employees of the Compliance department of CHRIST JUWELIERE UND UHRMACHER SEIT 1863 GMBH and are always handled confidentially. The employees of the Compliance department of CHRIST JUWELIERE UND UHRMACHER SEIT 1863 GMBH will evaluate the matter and perform any further investigation required by the specific case.
During the processing of a report, it may become necessary to share reports with additional employees of CHRIST, VALMANO and BRINCKMANN UND LANGE, 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 authorized access to the data are obligated to maintain confidentiality.
Information of the accused person
As a basic principle we are bound by law to inform the accused persons that we have received a report concerning them, unless this threatens further investigations into the report. In doing so, your identity as whistleblower is not revealed as far as is legally possible.
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.
Retention period of personal data
Personal data is retained for as long as necessary to clarify the situation and perform an evaluation of the report or a legitimate interest of CHRIST, VALMANO or BRINCKMANN UND LANGE exists or it is required by law. After the report processing is concluded, this data is deleted in accordance with the statutory requirements.
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 used until the end of your session and is deleted 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/ username and password. This allows you to send reports to the responsible employee at CHRIST JUWELIERE UND UHRMACHER SEIT 1863 GMBH either by name or in an anonymous, 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 CHRIST JUWELIERE UND UHRMACHER SEIT 1863 GMBH. If you wish to submit an anonymous report, please take note of the following security advice: Files can contain hidden personal data that could compromise your anonymity. Remove this data before sending. If you are unable to remove this data or are unsure 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.