What information will be registered?
The system can only be used to report on significant matters such as, e.g., financial crimes, significant work safety violations, significant violations of environmental regulations, and on environmental pollution, physical violence, sexual assaults, etc.
If reports on less significant matters, such as, e.g., dissatisfaction with wages, difficulties with cooperation and violations of smoking and alcohol policies are received, this information will be deleted immediately.
The registration of reports takes place anonymously in the system. The only thing that is registered is the report itself. There is no log made as to the IP address or machine ID of the computer on which the report is made.
Correction of registered information
If you realise that you have provided incomplete or incorrect information, just make a new report in the system in which you refer to the previous report and describe what should be corrected.
If you, in connection with the creation of a report, have decided to create a secure post box, you can make the correction by logging in to the system using your case number and the password you had created.
Transfers of registered information
The information registered in the system is generally not transferred to a third party outside of Puratos. However, in the following circumstances, the information may be transferred onward:
- Transfer to an external attorney or auditor in connection with the case processing of the report.
- If the report results in a lawsuit.
- If the law so requires.
Your personal information (name, e-mail and telephone number)
If you provide your personal information, be aware that Puratos can use your personal information when investigating the case, and also during any subsequent lawsuit.
Puratos guarantees that your personal data protection rights will be respected without limitations and will only be used as described above.
Puratos will not share your personal information with third parties outside of Puratos except for the cases as described above in the section ”Transfer of registered information”.
Deletion of registered data
Registered data may only be retained for as long as there is a need for it.
When there no longer is a need for retaining the registered information, the information is deleted.
The reporting system is hosted by Got Ethics A/S, an independent party guaranteeing the system’s security and anonymity.
Got Ethics A/S has taken the necessary technical and organisational measures to prevent personal data from being accidentally or unlawfully destroyed, lost or damaged and to prevent any unauthorised disclosure or misuse of the personal data. The processing of personal data is subject to strict controls and procedures and is in compliance with good practices in the field.
All data is transmitted and stored encrypted. No unencrypted information is sent over the open Internet.
If a report is made from a computer on Puratos’s network, there is a risk that the visited webpages will be logged in the browser’s history and/or Puratos’s log. This risk can be eliminated by submitting the report from a computer which is not connected to Puratos’s network.
If you upload documents, you should be aware that the documents can contain metadata which can compromise your identity. Therefore, you should ensure that any identifying metadata is removed from a document before it is uploaded.
It is optional to make either an anonymous report or a report containing personal data. Puratos encourages non-anonymous reporting as it facilitates further investigations where appropriate. If a reporter chooses not to remain anonymous, the reporter’s identity will be known to the persons that handle the case. In this case the reporter risks being called as a witness in any lawsuit, and the reporter’s anonymity thus can be lost.
Be aware that if you choose to give further information when submitting the report from which you can directly or indirectly be identified, the organization will also process this information when handling the case. This also apply if you have chosen to remain anonymous.
What is the legal basis for Puratos’s processing of information in the system?
The legal basis for the processing of your information is as follows:
- The processing is necessary for the purpose of pursuing a legitimate interest of handling illegalities and this interest clearly exceeds the interests of the registered person, cf. the European Data Protection Regulation article 6, number 1, letter f.
- The processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity. cf. the European Data Protection Regulation article 9, number 2, letter f.
- The processing is necessary for compliance with a legal obligation to which Puratos is subject. cf. the European Data Protection Regulation article 6, number 1, letter c.
- Any specific legislation on mandatory whistleblower solutions.
According to the European Data Protection Regulation you have a number of rights. If you want to exercise these rights, you must contact Puratos.
The right to see information
You have the right to see what personal data Puratos process about you and a number of other information. However, this right may never violate other persons’ rights or freedom rights.
The right of correction
You have the right to have false personal data about you corrected.
The right of deletion
In special cases you have the right to have information about you deleted before the time of the ordinary general deletion occurs.
The right of restriction
In special cases you have the right to have the processing of your personal data restricted. If you have the right to have the processing restricted, Puratos is only allowed to process the information – except from storage – with your consent or to establish, exercise or defend legal claims or to protect a person or a vital public interest.
The right of objection
In special cases you have the right to object to Puratos’s otherwise legitimate processing.
If you have any questions regarding personal data protection, you may contact Jesper Dannemann from Got Ethics A/S by e-mail: firstname.lastname@example.org.
Puratos is data controller for the processing of the personal data that you report and can be contacted through the ordinary communication channels. Likewise, Puratos’s data protection officer can be contacted through the ordinary communication channels (email@example.com) if you have questions about the processing of the information.
If you want to complaint about the processing of your personal data, you are entitled to submit a complaint to the competent supervisory authority.