Data protection notice
We take data protection and confidentiality very seriously and abide by the data-protection provisions in force. Please read carefully through this data-protection notice before you file a report.
Purpose of the whistleblowing system and legal basis
The whistleblowing system (BKMS® System) is used to accept and process reports about breaches of la Mobilière Group’s internal rules and external requirements in a secure and confidential manner. Personal data is processed via the BKMS® System given the legitimate interest of our business in identifying and preventing shortcomings and thereby averting any prejudice to la Mobilière Group, its employees or customers.
Use of the whistleblowing portal
An encrypted (SSL) connection is used for communications between your device and the whistleblowing system. Your device’s IP address is not stored during use of the whistleblowing portal. To maintain the connection between your device and the BKMS® System, a cookie is stored on your device that merely contains the session ID (known as a "null cookie"). The cookie remains valid only until your session ends and becomes null and void once you close your browser.
You have the option of setting up a protected postbox in the whistleblowing system with a pseudonym/username and password of your own choice. If you do so, you are able to send reports to the relevant Mobilière employee by name or anonymously. With this system, the data is stored exclusively in the whistleblowing system and is protected by special security arrangements. It is not a standard email communication.
Tips on sending attachments
When filing a report or sending additional information you have the option of sending attachments to the relevant la Mobilière employee. If you wish to file a report anonymously, please bear the following security tip in mind: Files may contain hidden personal data that may endanger your desire for anonymity. Please remove this data before sending the files. If you are unable to remove or unsure about removing this data, copy the text of the attachment to your report document or send the printed document anonymously, quoting the reference number that you will be given at the end of the reporting process to the address stated in the footer.
Unit responsible/h2>
The whistleblowing unit with responsibility for data protection is:
- Swiss Mobiliar Holding Ltd and
- its subsidiaries
As mutually autonomous responsible: units (hereinafter referred to as “la Mobilière” or “Mobilière”). The whistleblowing system is run on la Mobilière’s behalf by a specialised operator, namely EQS Group GmbH, which has its head office at Bayreuther Str. 35, 10789 Berlin in Germany.
If you enter personal data and information in the whistleblowing system, it will be stored in one of EQS Group GmbH’s databases at a high-security data centre. The data may be inspected only by la Mobilière. EQS Group GmbH and other third parties have no access to the data. It will be kept safe as part of the certified process through comprehensive technical and organisational measures.
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 within the Mobilière Group.
The Mobilière Group has appointed a data protection officer. Data-protection questions may be sent to datenschutz@mobiliar.ch.
Nature of the personal data collected
Use of the whistleblowing system and, in particular, the entry of personal data is entirely voluntary. If you file a report using the whistleblowing system, we collect the following personal data and information:
- Your name, should you disclose your identity,
- whether or not you are employed by the Mobilière Group, and
- where appropriate, the name of the individuals and other personal data of the individuals you name in your report.
Confidentiality of reports
Inbound reports are received and handled in confidence by a limited circle of expressly authorised and specially trained la Mobilière Group Compliance Office (COG) staff. The COG staff confirm the facts and, where appropriate, conduct an extensive investigation of the case.
During the handling of a report or as part of a special investigation, it may be necessary to pass on reports to additional Mobilière employees or to employees of other Group companies, e.g. if the report concerns processes in subsidiary companies. We always make sure that we abide by the data protection regulations when passing on reports.
Every person given access to the information is bound by a duty of confidentiality.
Notification of the implicated individual
In certain cases, la Mobilière is obliged in accordance with the data-protection regulations to inform the individual implicated of the accusations made against them. This is required under the law when it can be determined objectively that informing the implicated individual cannot have an adverse effect on the investigation. Your identity as the whistleblower – insofar as possible under the law – is not disclosed in the process, and measures are taken to ensure that you cannot be identified as the whistleblower.
Rights of individuals involved
Under the data protection law, you and the person named in the report have the right to disclosure, to make corrections to, to have deleted, to limit data processing and a right to object to the use of your personal data. If you exercise your right to object, we will check without delay whether the stored data is still required for the handling of a report. Data no longer required is deleted without further delay.
Period of retention of personal data
The data is retained for however long it is necessary to resolve and complete the review of the report or the business has a legitimate interest or it is required for the purpose of a law. At the end of the period of retention, the corresponding data is deleted in line with the statutory requirements.
Version dated: 05/08/2019
