| Registration of reports | - Registering reports of (suspected) irregularities (integrity violations and abuses) received via the internal or external BNG reporting channels by persons who report a suspicion of an irregularity in the context of their work-related activities.
| - First and last name of the reporter (*)
- Contact details of the reporter (*)
- Description of the alleged integrity violation or wrongdoing
- Name, job title, contact details of persons involved in the report
- Date and signature of the report
- Audio recording of the report
- Written transcript of the conversation in which the report is made
(*) Unless the report was submitted anonymously | Special category or criminal data is not processed intentionally. However, it may occur that a reporter or other individual voluntarily provides information from which special categories of data or criminal data can be inferred (e.g. concerning alleged criminal offences). | For reports of wrongdoing:- Compliance with a legal obligation (Article 6 (1)(c) GDPR and Article 9 (2)(b) GDPR) – Article 2a Dutch Whistleblower Protection Act (Wet bescherming klokkenluiders)
For reports regarding integrity violations:- Legitimate interest (Article 6 (1)(f) GDPR) – investigating conduct that (may) pose a serious threat to the integrity of BNG’s business operations
- For the unintentional processing of special category personal data: Article 9 (2)(e) GDPR (personal data has been manifestly made public by the data subject.
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| Investigation following a report | - Investigating relevant facts and circumstances to assess whether an irregularity has occurred (‘preliminary investigation’).
- Conducting a further, more detailed investigation into the irregularity.
| - Names and contact details of persons and officers involved in the investigation (‘investigators’)
- Interview notes and summaries of conversations
- Research into the use of means of telecommunication (e.g. email, internet, telephony)
- Observations
- Information from publicly available sources
- Investigation results (whether an irregularity has occurred; if so, in what context it took place, who was involved, and in what capacity)
- Depending on the nature of the report, investigation results may contain all kinds of personal data.
| - Investigation results and the investigation report may contain all sorts of special category personal data, depending on the nature of the report.
- Where, during the investigation, there is a suspicion that a criminal offence has been committed, a report may be filed with the police, an investigative authority or the Public Prosecutor’s Office.
- In such cases, the processing of personal data relating to criminal convictions and offences may occur.
| Legitimate interest (Article 6 (1)(f) GDPR) – investigating conduct that (may) pose a serious threat to the integrity of BNG’s business operations. |
| Contact with the reporter and/or the (legal)adviser or confidential adviser assisting the reporter | - Maintaining contact with the reporter and/or the reporter’s (legal) adviser or confidential counsellor supporting the reporter
| - Name and contact details of the reporter and/or the (legal) adviser or confidential adviser supporting the reporter - Acknowledgement of receipt of the report - Interview notes and summaries of discussions held with the reporter, their (legal) adviser and/or confidential counsellor
- Status updates
- Investigation report
| - Investigation results and the investigation report may – depending on the nature of the report – contain various types of special categories of personal data.
- Where, during the investigation, there is a suspicion that a criminal offence has been committed, a report may be filed with the police, an investigative authority or the Public Prosecutor’s Office.
- In such cases, the processing of personal data relating to criminal convictions and offences may occur.
| Legitimate interest (Article 6 (1)(f) GDPR) – investigating conduct that (may) pose a serious threat to the integrity of BNG’s business operations. |
| Contact with the person to whom an irregularity is attributed (subject of the investigation) | - Maintaining contact with the person to whom an irregularity is attributed
| - Name and contact details
- Interview notes and summaries of discussions with the individual concerned
- Investigation report
| - Investigation results and the investigation report may – depending on the nature of the report – contain various types of special categories of personal data.
- Where, during the investigation, there is a suspicion that a criminal offence has been committed, a report may be filed with the police, an investigative authority or the Public Prosecutor’s Office.
- In such cases, the processing of personal data relating to criminal convictions and offences may occur.
| Legitimate interest (Article 6 (1)(f) GDPR) – investigating conduct that (may) pose a serious threat to the integrity of BNG’s business operations. |
| Contact with witnesses and other persons involved in an investigation | - Maintaining contact with witnesses and other persons involved in an investigation
| - Name and contact details
- Interview notes and summaries of discussions with the witness or person concerned
| Not applicable | Legitimate interest (Article 6 (1)(f) GDPR) – investigating conduct that (may) pose a serious threat to the integrity of BNG’s business operations |