We, Hammer SportClub 2008 e.V., have implemented an internal whistleblower system to detect and prevent violations of applicable law and company guidelines.
This whistleblower system is available to employees and business partners (customers, suppliers, etc.) at any time.
With this whistleblower system, we give you the opportunity to report any violations anonymously.
If you as a whistleblower deliberately do not wish to remain anonymous, you can voluntarily provide your first and last name as well as your contact details (telephone number, e-mail address, postal address).
When you submit a report, we are required to process your details about the incident and any contact details (telephone number, email address, postal address) for the purpose of investigating breaches of applicable law or company guidelines or preventing such breaches. This data may be passed on confidentially to third parties, such as external auditors, lawyers or authorities, in accordance with the data protection information below.
If you add files as evidence for your report, you have ensured in advance that there is no unwanted meta information or personal data that could jeopardise your anonymity if you submit an anonymous report.
Privacy policy for the whistleblower system
Hammer SportClub 2008 e.V. and smart-link Gesellschaft für EDV-Systemlösungen as the ombudsman (internal reporting centre within the meaning of the German Whistleblower Protection Act) process personal data as joint controllers within the framework of the whistleblower system.
1. name and address of the data controller
The controller within the meaning of the General Data Protection Regulation and other data protection laws applicable in the Member States of the European Union is
Hammer SportClub 2008 e.V.
Am Südbad 9
59069 Hamm
Tel.: (0 23 81) 87 10 107
Fax: (0 23 81) 53 22 7
and
smart-link Gesellschaft für EDV-Systemlösungen mbH
Eschstr. 27
32257 Bünde
("ombudsman's office")
The rights and obligations of the joint controllers are agreed between them in accordance with Art. 26 GDPR. The respective controller is responsible for the duty to provide information. If you have any questions about data protection or the exercise of your rights (see below), you can contact the contact person named below.
2 Categories of personal data
The following data is processed as part of the whistleblower system Details of the accused person (e.g. surname, first name, title, contact details, position and employment details), details of the (alleged) breaches of conduct and the relevant facts. As Hammer SportClub 2008 e.V.'s reporting procedure stipulates that reports can be made anonymously, no personal data will be 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.
3 Purpose of the data processing
The purpose of data processing within the framework of the whistleblower system is to receive and clarify serious suspicions of breaches of the rules at Hammer SPortClub 2008 e.V., in particular criminal offences in the area of white-collar crime and corruption.
4 Legal basis for data processing
Personal data of the whistleblower is generally processed on the basis of Art. 6 para. 1 lit. c GDPR in conjunction with § 12 HinSchG. 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 GDPR to safeguard the overriding legitimate interest of Hammer SportClub 2008 e.V.. This legitimate interest lies in preventing and combating corruption as well as in processing serious suspected cases of other rule violations and protecting Hammer SportClub 2008 e.V. and its employees from possible damage. Since the reporting of violations helps to avoid legal consequences such as criminal prosecution, claims for damages and immense damage to image, the interests of the data subjects worthy of protection in the exclusion of processing or use do not prevail.
5. recipients or categories of recipients of the personal data
The joint controllers shall ensure that your personal data is only accessible to a limited number of authorised and competent 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 at Hammer SportClub 2008 e.V. Each 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.
6 Duration of data storage
Personal data will be stored for the period necessary to clarify and conclusively assess the report. Once the investigation has been completed, the personal data will be deleted within a reasonable period of regularly one month and in accordance with the 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 unfounded reports will be deleted immediately.
7 Data security
The jointly responsible party uses technical and organisational measures to protect the personal data to be managed by using the whistleblowing system from unauthorised access, disclosure, misuse, manipulation, loss and destruction during its collection, processing and use. Service providers used are obliged to the same extent.
8 Automated decision-making
No automated decision-making pursuant to Art. 22 GDPR takes place within the framework of the whistleblower system.
9. rights of data subjects
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 jeopardises the clarification of the facts or the securing of necessary evidence, the joint controllers are permitted to comply with the right only at a later point in time. If the legal requirements are met, you also have the right to have incorrect data corrected, amended, blocked or deleted. Furthermore, you have the right to lodge a complaint with the competent supervisory authority for data protection at any time. Enquiries regarding the exercise of data subject rights in accordance with Art. 15-21 GDPR can be addressed by the data subject to one of the responsible bodies.
The contact person at Hammer SportClub 2008 e.V. is
Mr Christian Pfeiffer (Data Protection Officer Hammer SportClub 2008 e.V.)
smart-link Gesellschaft für EDV-Systemlösungen
Eschstr. 27
32257 Bünde
05223-6874700
Christian.Pfeiffer@smart-link.de
The contact person for the ombudsman's office is
Mrs Helene Fetz (Data Protection Officer smart-link)
smart-link Company for IT system solutions
Eschstr. 27
32257 Bünde
05223-6874700
Helene.Fetz@smart-link.de