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Whistleblower system

Information obligations pursuant to Art. 13 and 14 of the EU GDPR:

For us, compliance means more than just adhering to rules and laws. Karl Späh GmbH & Co KG stands for trustworthiness, responsible action and values such as honesty, reliability and credibility. These are a matter of course for us and form the basis for the trust that our customers, business partners and employees place in us every day. Taking responsibility also means acting lawfully. The integrity of our business activities is very important to us.

To this end, we offer our customers, business partners and employees the “sycoBASE whistleblower portal” to report possible compliance violations. This portal can be used worldwide and around the clock – securely, confidentially and (if desired) completely anonymously. The “sycoBASE whistleblower portal” must be used responsibly. Only information that the whistleblower is convinced to the best of their knowledge and belief is correct should be passed on. False accusations or misleading information do not belong here.

The “sycoBASE Whistleblower Portal” is a web-based system provided by an external service provider (sycoBASE GmbH) for companies to report compliance violations. The system is used to record, process and document reports. Evidence to support the reports can be uploaded as an attachment.

The overriding principle of the “sycoBASE whistleblower portal” is the protection of the whistleblower. Third parties have no possibility of accessing the report data. There is the possibility of an anonymous dialog thanks to a protected and secure mailbox. The technical confidentiality of the data is guaranteed.

To ensure that the whistleblowing system cannot be traced, you will not find a clickable link to the page here, but only the Internet address. https://wbs.sycobase.app Please do not use a direct link (see below) for an anonymous reporting option!

Please copy this link completely into the address line of your private browser and use one of the following search terms to find our company:
Späh, Karl Späh, Karl Späh GmbH & Co. KG, Karl Späh GmbH

If the anonymous reporting option is not offered:
Click on the following link (https://wbs.sycobase.app/case?refId=XACA4XNZJ7EYKDR47PKPD5YJJE6FWUXJ) will take you directly to our whistleblower portal.

 

On the homepage of the portal you will find information on how to deal with notices.

The controller within the meaning of data protection law is:

Karl Späh GmbH & Co. KG
Industriestrasse 4-12
72516 Scheer
Tel.: 07572 602-458
Email: datenschutz@spaeh.de

Contact details of the data protection officer:
Ulrike.eben@danubis.net

The following data is processed as part of the whistleblower system: Information about the accused person (in particular surname, first name, title, contact details, position and employment details), information about the (alleged) breaches of conduct and the relevant facts. As the reporting procedure stipulates that reports can be made anonymously, no personal data is collected unless the whistleblower states otherwise. Otherwise, personal data such as the name of the reporting person, their contact details and, if applicable, the circumstances of their observation may be considered.

The purpose of data processing as part of the whistleblower system is to receive and investigate serious suspicions of breaches of regulations, in particular criminal acts in the area of white-collar crime and corruption.

As a rule, the whistleblower’s personal data is only processed with their consent (Art. 6 para. 1 lit. a GDPR). In other cases, the processing of personal data in the whistleblower system is carried out on the basis of Art. 6 para. 1 lit. f to safeguard the overriding legitimate interest of the controller. This legitimate interest lies in preventing and combating corruption and in processing serious suspected cases of other breaches of regulations and protecting the controller and its employees from potential damage. Since the reporting of violations helps to avoid legal consequences, e.g. criminal prosecution, claims for damages and immense damage to the company’s image, the legitimate interests of the data subjects in the exclusion of processing or use do not prevail.

Personal data will be retained for the period necessary to clarify and conclusively assess the report. Once the investigation has been completed, the personal data will be deleted in accordance with legal requirements. In the event that judicial and/or disciplinary proceedings are initiated, the data may be stored until the conclusion of the proceedings or until the expiry of the time limits for legal remedies. Personal data in connection with groundless reports will be deleted immediately.

The controller shall ensure that personal data is only accessible to a limited number of authorized persons who need to know this data for the provision of the above-mentioned processing purposes.

If necessary to clarify the matter, personal data may be forwarded to individual, carefully selected persons or to an (also external) ombudsman’s office of the controller or – if they are also affected by the matter in question – to affiliated companies of the controller to the extent necessary. Every person who receives access to the data is obliged to maintain confidentiality.

Your personal data will not be passed on or otherwise transferred to third parties unless this is necessary for the purposes of criminal prosecution. If required by law or orders of state bodies, personal data may be disclosed to them.

Your personal data is processed by us exclusively in data centers in the Federal Republic of Germany.

The controller shall implement technical and organizational measures to protect the personal data to be managed through the use of the whistleblowing system from unauthorized access, disclosure, misuse, manipulation, loss and destruction during its collection, processing and use. The service providers used by the controller are obliged to the same extent.

As a data subject, you have the right to information about the personal data stored about you. The identity of the whistleblower is generally excluded from this right to information. If the exercise of this right jeopardizes the clarification of the facts or the securing of necessary evidence, the controller is permitted to comply with the right at a later date. If the legal requirements are met, you also have the right to have incorrect data corrected, amended, blocked or deleted. You also have the right to lodge a complaint with the competent data protection supervisory authority at any time. The data subject can address inquiries regarding the exercise of data subject rights in accordance with Art. 15-21 GDPR to one of the responsible offices.

Contact person of the person responsible:

datenschutz@spaeh.de

You have the option of lodging a complaint with the data protection officer named above or with a data protection supervisory authority. The data protection supervisory authority responsible for us is

The State Commissioner for Data Protection and Freedom of Information Baden-Württemberg
P.O. Box 10 29 32, 70025 Stuttgart
Lautenschlagerstr. 20, 70173 Stuttgart
Tel.: 0711/61 55 41 – 0 Fax: 0711/61 55 41 – 15
E-mail: poststelle@lfdi.bwl.de
Internet: https://www.baden-wuerttemberg.datenschutz.de

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