In accordance with the provisions of Law 2/2023, of 20 February, regulating the protection of persons who report regulatory infringements and the fight against corruption, all companies with more than 50 employees are obliged to have an internal information channel that allows for the reporting of facts that may involve a serious criminal or administrative infringement, or an infringement of EU law.
In addition, the regulations include the obligation to make available to interested parties information on the use of any internal information channel, as well as the essential principles of the procedure.
To ensure compliance with the above, we provide you with the following:
– SII General Policy _
– Manual for the Use of the Internal Information Channel.
BASE INTERNATIONAL SCHOOL, informs:
COMPLAINTS CHANNEL. This complaints channel guarantees compliance with the provisions of the aforementioned regulations in accordance with the provisions of articles 7 and 9 of the same.
ANONYMOUS COMMUNICATIONS AND PERSONAL DATA. Communications may be anonymous, with the identification of the informant not being obligatory, and will be answered through the same channel through which they were received, for which purpose it will be necessary to keep the tracking code that will be assigned in the message of receipt of the complaint.
Anonymity shall be lifted only with the express consent of the reporter or where it constitutes a necessary and proportionate obligation imposed by Union or national law in the context of an investigation carried out by national authorities or in the framework of judicial proceedings, in particular to safeguard the rights of defence of the person concerned.
During the process, compliance with the data protection legislation in force shall therefore be ensured (LOPD and RGPD).
USE OF THE COMPLAINTS CHANNEL. When you are going to file a complaint, you will notice that you will be directed to an on-line tool external to the domain of BASE INTERNATIONAL SCHOOL, the message is transmitted to the tool of an external provider with the aim of guaranteeing total objectivity and transparency in the process of complaint management.
In any case, the external provider will comply with the instructions established by BASE INTERNATIONAL SCHOOL and always in accordance with the current legislation on data protection, ensuring compliance with the obligations under Art. 28 of the RGPD.
Therefore, this tool can be used by any employee of BASE INTERNATIONAL SCHOOL or any other third party who may have knowledge of unethical, fraudulent or unlawful conduct committed within our Organisation.
This whistleblowing channel is not the appropriate channel for issues relating to your terms and conditions of employment or disciplinary matters. In such cases, you should follow your organisation’s established policies.
The data controller is BASE INTERNATIONAL SCHOOL, which will process the information collected through the channel in compliance with a legal obligation under Law 2/2023, of 21 February, regulating the protection of persons who report regulatory infringements and the fight against corruption, will process the information for the purpose of managing the complaints received through the channel, guaranteeing the confidentiality of the whistleblower’s data and keeping them anonymous without communicating them to third parties unless their identification constitutes a necessary and proportionate obligation imposed by EU or national law in the context of an investigation carried out in the context of an investigation carried out by BASE INTERNATIONAL SCHOOL, ensuring the confidentiality of the whistleblower’s data by keeping them anonymous and not disclosing them to third parties unless their identification constitutes a necessary and proportionate obligation imposed by EU or national law in the context of an investigation carried out by national authorities or in the framework of judicial proceedings, in which case it shall be communicated to the authorities competent in the matter.
Your data will be retained for a maximum period of 3 months from the time the data is entered into the channel, but may remain blocked when it is necessary to evidence the functioning of the crime prevention model or may be required by the competent authority for the initiation of the relevant investigation of the facts.
For more information about the processing of your data or how to exercise your rights, please refer to our Privacy Policy.