How we handle your information
What happens to the information in a report, in plain terms.
The short version
- If you report anonymously, we hold no information that identifies you. We do not record your IP address, name, device or location.
- What you type is stored. If you name yourself in the text, that text is what we hold.
- Only the people authorized to handle reports can read it.
- Records are deleted three years after the case is concluded.
The controller is the RefrigiWear group company that employs you. For anything about how your information is handled, contact whistle@refrigiwear.com.
We process what you choose to put in the report: the category, your description, and optionally a company and a contact detail. A report will often contain information about other people — the person or conduct you are describing. They have data protection rights too, which is one reason access is restricted.
We process it to receive and follow up whistleblowing reports. For the group companies in scope, that is a legal obligation: the German Hinweisgeberschutzgesetz and the Dutch Wet bescherming klokkenluiders both require an internal reporting channel and require us to act on what comes through it. Where no such obligation applies, we process it in our legitimate interest in detecting and stopping serious wrongdoing.
Access is limited to the people formally authorized to handle reports, who must sign in before they can read anything. We may need to involve others to investigate, or pass a report to an authority or the police where the law requires it. We will not reveal your identity to the person a report is about.
Case records are deleted three years after the case is concluded, in line with ยง11(5) of the German Hinweisgeberschutzgesetz. The three years run from the point the case is closed, not from when you sent it. We keep a record longer only where another legal obligation makes that necessary and proportionate.
Reports are stored in Cloudflare's key-value store, used as our processor, and are readable only through the restricted case view described above.
You have rights over personal data we hold about you, including access, correction and erasure. These rights can be limited where exercising them would reveal a reporter's identity or prejudice an investigation — a protection that works in a reporter's favour as often as against. You can also complain to the data protection authority in your country.
If you reported anonymously we cannot identify your record from your identity, only from your reference code. That is the point of the design, and it is also the limit of what we can do for you without the code.