Privacy statement for the whistleblowing channel
13 Dec 2022
Manna & Co Oy
Business: ID 2623464-9
00510 Helsinki, Finland
2. For what purposes are personal data being collected?
Manna & Co has in place an anonymous whistleblowing channel that allows our employees and external stakeholders to report potential cases of misconduct to the company. Such misconduct includes, for example, activity in breach of laws and regulations, criminal activity and breaches against Manna’s Code of Conduct.
We collect and process personal data potentially generated through this channel. For EU member states, the processing of personal data is based on the fulfilment of a legal obligation as referred to in the Directive (EU) 2019/1937. For countries other than the EU member states, the processing of personal data is based on our legitimate interest to provide our stakeholders with an anonymous channel for reporting their observations and raising their concerns.
3. What data are being collected and from what sources?
Reports to the whistleblowing channel can be made anonymously, but personal data may, however, possibly be collected when an employee or an external stakeholder representative submits an informal message to the whistleblowing channel or the case is being investigated by Manna & Co’s employees. Such data can include, for example, the person’s name, address, place of residence, job title, citizenship, phone number, email address, work history, and information on the supervisor and the case. Other data sources are used within the limits permitted by laws.
4. Who has access to personal data?
Access to the personal data coming through the whistleblowing channel is reserved to persons within Manna & Co Group whose job involves investigating cases of misconduct. As a general rule, we do not disclose the register’s data to parties outside the Group. Data can, however, be disclosed in accordance with the law, for example to police officials for crime investigation.
We use an external service provider for the management of the whistleblowing system and for the processing of the reports. In that case, personal data are disclosed to external service providers only to the extent necessary for implementing the whistleblowing channel.
5. Notification on international data transfer
We may be required to disclose your personal data to authorities by virtue of the law or regulations.
Manna and Manna’s suppliers and cooperation partners process your personal data in the EU/EEA. Appropriate safeguards are in place for transferring your personal data outside the EU/EEA. If personal data are processed outside the EU/EEA, there is either a resolution by the EU Commission that the third country in question provides an equal level of protection or appropriate safeguards to ensure that your rights are protected. Examples of appropriate safeguards are codes of conduct approved in the receiving country, standard contractual clauses and the company’s binding internal rules. Personal data are not disclosed outside the EU/EEA without the aforementioned appropriate safeguards without your explicit and informed consent.
6. Personal data protection measures
We ensure that your personal data are processed with appropriate safeguards. We have put in place technical and organizational safeguards to ensure that your personal data are not changed, lost or destroyed, or accessed without authorization.
7. How long will your personal data be retained?
The data coming through the whistleblowing channel will be destroyed or anonymized in cases where the report is not included in the scope covered by the whistleblowing channel or is found completely false. The reports submitted will be destroyed or anonymized when they are no longer needed for investigation or measures. In most cases, they will be destroyed within two months (60 days) from the completion of the investigation, unless there is a justified reason to retain them, such as an ongoing crime investigation.
8. Rights of data subjects
As a data subject, you have the right to influence the processing of your personal data and to receive information about the processing. Below you will find information about your rights as a data subject. If you wish to exercise any of your rights mentioned below, please contact us by email: [email protected]
Right to inspect data
You have the right to obtain confirmation as to whether or not personal data concerning you are being processed, and to inspect the data we have collected on you.
Rectification of incorrect data
You have the right to request that we supplement or rectify incorrect, inaccurate or incomplete personal data concerning you.
In certain cases, you have the right to restrict the processing of your personal data. You can exercise this right, for example, if any of your data are incorrect. In this case, you have the right to demand that processing be restricted temporarily until the accuracy of your data has been assured.
The right to object to the processing of data
In certain cases and for a justified reason, you have the right to object to the processing of your personal data. You have the right to object to the processing of your personal data, for example, when we process your personal data on the basis of our legitimate interests. In this case, we will assess, on a case-by-case basis, whether an important and justified reason for processing the personal data still exists.
Right to lodge a complaint with a supervisory authority
If you feel that we have illegally processed your personal data, you have the right to lodge a complaint concerning the processing of your personal data with the local supervisory authority.
9. Changes to data protection practices
When we publish changes related to this Privacy Notice, we will update the date at the top of this privacy statement.
10. Contact details
If you have any questions concerning the processing of your personal data, please contact:
Manna & Co Oy