Purpose of the reporting system and legal basis
The reporting system (BKMS® Incident Reporting) serves the purpose of securely and confidentially receiving, processing and managing reports regarding violations of the compliance rules of Ivoclar Group. The processing of personal data in BKMS® Incident Reporting is based on the legitimate interests of our company to detect and prevent misconduct and thus avoid damage to the Ivoclar Group, its employees and customers. Article 6 (1) (f) EU-GDPR serves as the legal basis for this data processing.
The party responsible for data privacy in the reporting system is
- Ivoclar Vivadent AG (Bendererstrasse 2, 9494 Schaan, Liechtenstein, Tel. +423 235 33 60, E-Mail firstname.lastname@example.org) and
- its subsidiaries (contact details at https://www.ivoclar.com/en_li/tools/group-companies)
as parties with mutually autonomous responsibility (hereafter also: „Ivoclar Group“). The reporting system is operated by a specialized company, Business Keeper GmbH, Bayreuther Str. 35, 10789 Berlin, Germany, on behalf of the Ivoclar Group.
Personal data and information entered into the reporting system are stored in a database operated by Business Keeper GmbH in a high-security data centre. Only defined employees of the Ivoclar Group have access to the data. Business Keeper GmbH and other third parties do not have access to the data. This is ensured by extensive technical and organizational measures set out in the certified procedure.
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 the Ivoclar Group.
The Ivoclar Group has appointed a Data Protection Officer. Questions on data protection and privacy regarding the Ivoclar Group can be sent to the internal Data Protection Officer at email@example.com.
Type of personal data collected
Use of the reporting system takes place on a voluntary basis. If you submit a report via the reporting system, we collect the following personal data and information:
- your name, if you choose to reveal your identity,
- whether you are employed at the Ivoclar Group, and
- the names of persons and other personal data of persons that you name in your report.
Confidential handling of reports
Incoming reports are received by a small selection of expressly authorized and specially trained employees from the Integrity & Compliance department of the Ivoclar Group and are always handled confidentially. The employees will evaluate the matter and perform any further investigation required by the specific case.
During the processing of a report or the conduction of a special investigation, it may become necessary to share reports with additional employees of the Ivoclar Group or employees of other group companies, 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 privacy of personal data. We always ensure that the applicable data privacy regulations are complied with when sharing reports.
All persons who obtain access to the data are obligated to maintain confidentiality.
Information relating to 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 data subjects
According to European data protection law, you and the persons named in the report have the right to information, rectification, erasure, restriction of processing and the right to object to processing of personal data concerning you. 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 for as long as a legitimate interest of the company exists, or while it remains required by law. After the report has been fully processed, 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 via 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 BKMS® Incident Reporting, a cookie is stored on your computer that merely contains the session ID (known as a null 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 postbox within the reporting system that is secured with an individually chosen pseudonym/ user name and password. This allows you to send reports to the responsible employee at the Ivoclar Group securely, either by name or on an anonymous basis. 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 the Ivoclar Group. If you wish to submit an anonymous report, please note 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.
Version: March 2022