WHISTLEBLOWER REPORTING PRIVACY STATEMENT
| What is the purpose of this Privacy Statement | ||
|
This Privacy Statement gives you information about the personal data we collect about you in relation to your whistleblowing report (hereinafter “Report”), and how and for what purposes we process your personal data.
In Huawei Finland we understand and respect the importance of privacy. This Statement describes how Huawei Finland uses and protects your personal data and how we fulfil our obligations under GDPR. It also contains a summary of your rights in relation to your personal data. |
||
| The identity and contact details of the Controllers | ||
| Huawei Technologies Oy (Finland) Co., Ltd (hereinafter as “Huawei Finland”) |
Registered address:
Läkkisepäntie 23, 00620, Helsinki |
Data Protection Officer contact information:
Huawei DPO Office Hansaallee 205, 40549 Düsseldorf Germany or via electronic contact form: https://www.huawei.com/en/personal-data-request |
| How do we use your data | ||
| Personal Data collected and processed | ||
| The source of personal data | The personal data and information that will be collected are directly provided by you. | |
| Will we process special categories of data? | We may process special categories of data containing in your report only if such data are clearly relevant for the processing of the specific report. | |
| Are you obliged to provide the personal data? And what the possible consequences of failure to provide such data. | 1. If the processing is necessary to fulfil legal obligation, it is mandatory to provide the data based on applicable legislation.
2. Providing data is voluntary, but necessary in the case of processing based on a legitimate interest indicated below. |
|
| Below you will find detailed information on what personal data we process, for what purpose and on what legal basis arising from generally applicable data protection regulations. | ||
| For what purpose does Huawei Finland process your personal information? | What categories of personal data do we process for this processing purpose | Legal basis of processing |
| Comply with our legal obligations. |
1. You can choose to remain anonymous when reporting. In this case, we will not process your personal data;
2. If you choose to identify yourself, only the data delivered by you (e.g. name, contact details) will be processed by Huawei Finland for the purpose of case handling. We will contact you through the information delivered by you to: o provide you with a confirmation that the report has been received by us (within 7 days); o provide you with feedback and result in response to your report (within 3 months after confirmation of receipt). |
Article 6(1)(c) GDPR; Legal obligation of Finnish Act (2022:1171) on the protection of persons who report malpractice; |
| Evaluate suspected serious violations of laws or regulations, as well as suspected breach of Huawei Finland’s policies or Code of Conduct. | Data related to a litigation. | Article 6(1)(f) GDPR; Legitimate interest |
|
Please be informed that if the processing for aforementioned purposes involve any special categories of personal data, the processing will be based on Article 9(2)(e)(g) GDPR. Please also be informed if your report contains personal data which are manifestly not relevant for the handling of a specific report, we will delete it without undue delay. |
||
| How long and where do we store your data | ||
|
We retain your personal data for no longer than that is necessary for the purposes defined in this Statement. In particular: |
||
| Comply with our legal obligations related to whistle blowing. | Your personal data may be retained only for a period of time that is necessary to fulfil the purposes for which the personal data was collected and used. We may retain your personal data for no more than 2 years after the investigation is closed. | |
| Evaluate suspected serious violations of laws or regulations, as well as suspected breach of Huawei Finland’s policies or Code of Conduct. | Your personal data may be retained only for a period of time that is necessary to fulfil the purposes for which the personal data was collected and used. We may retain your personal data for no more than 2 years after the investigation is closed. | |
| Unless otherwise stated hereunder, your personal data will be stored in Germany and China. After the retention period expires, we will erase or anonymize your personal data, unless otherwise required by laws and regulations. | ||
| How do we share your data | ||
| (1) Disclosure of your personal data outside of the EU/EEA: | ||
| Name of activities | Reason for Disclosure and details on the data recipients and countries of transfer | Mechanism for cross-border transfer |
| Huawei Finland may transfer the data subject’s Personal Data when necessary for the purposes specified above to its global parent company: Huawei Investment & Holding Co., Ltd., which is located in People’s Republic of China, to its respective subsidiaries and affiliates or to other categories of Recipients indicated above and who may be located to countries outside of the EU/EEA territory. | When the data are transferred to a third country that does not ensure adequate level of protection of personal data, Huawei Finland complies with applicable legal requirements for providing adequate safeguards by incorporating the Standard Contractual Clauses with relevant supplementary measures in such transfer. You can obtain a copy of them here: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_de. | |
| (2) Disclosures related to legal requirements and business transactions | ||
|
Please be informed that for the purpose of processing your report and conducting investigations, the personal data and other information in your report will be accessed by the authorized investigation team at Huawei Finland, law enforcement authorities or, if required by law, by other local authorities.
Please also be informed that Huawei Finland uses suppliers and service providers to ensure carrying out its business and to ensure adequate protection of the Personal Data. The processing of Personal Data in relation to our suppliers is always commissioned by us and the parties will act only on our behalf as data processors or based on another contractual set-up. Such processing is always protected with contractual arrangements to ensure that your Personal Data is processed in accordance with the laws and good data processing practices. Huawei Finland and its suppliers and service providers shall establish technological, physical, administrative and procedural safeguards all in line with the industry accepted standards in order to ensure the confidentiality, integrity and accessibility of the Personal Data processed; prevent the unauthorized use of or unauthorized access to the Personal Data or prevent a Personal Data breach (security incident). |
||
| What are your rights and choices | ||
| You can enter into the Huawei Data Subject Request Portal to exercise your data subject right. | ||
| Right of Access | You have the right to obtain from Huawei Finland confirmation as to whether or not Personal Data concerning you is being processed and, where that is the case, access to a copy of the Personal Data and specific information about how Huawei Finland processes your Personal Data. | |
| Right of Rectification (Correction) | You have the right to obtain from Huawei Finland the correction of inaccurate Personal Data concerning you and also the right to have incomplete Personal Data completed. | |
| Right of Erasure (Deletion) | You have the right to obtain from Huawei Finland the erasure (deletion) of your Personal Data in particular circumstances. | |
| Right of Restriction | You have the right to obtain from Huawei Finland restriction of processing in particular circumstances. | |
| Right of Objection | You have the right to object to the processing of your Personal Data in particular circumstances. | |
| Right of Portability | In certain circumstances, you have the right to receive your Personal Data in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller. Please bear in mind that the right of portability does not apply in the case of processing personal data on legal obligation or legitimate interests’ basis. | |
| Right to Withdraw Consent | Where the legal basis of processing Personal Data is based on consent, you have the right to withdraw your consent at any time by providing a withdrawal notice to Huawei Finland. Please note, however, that the withdrawal of your consent will not affect any use of the Personal Data made before you withdrew your consent. | |
| Right to lodge a Complaint | If you consider your Personal Data is not being processed in compliance with the applicable laws, you have the right to lodge a complaint with any relevant supervisory authority. List of Supervisory Authorities:
http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm |
|
| How do we update this Statement | ||
|
We encourage you to regularly check for the latest version of this Statement as we may change it from time to time. If we make changes to this Statement, we will notify you by an appropriate method.
Latest update: November 2023 Nordic CSPO team |