Privacy Policy

Introduction

Integrity Matters® Ethicsline® service is provided by Mitrisk Consulting LLP (hereafter referred to by our trade name as “Integrity Matters®" or as “we”, “us” or “our”). ”. Integrity Matters serves as a processor of data on behalf of its clients, who are responsible (as the ‘controller’) for the processing of personal data by means of this service.

This Privacy Statement applies only to the specific webpages of Integrity Matters® Ethicsline® service. Such webpages only are referred to below as “this Website"

By using this Website you are agreeing to the use of your information as described in this Privacy Policy.

Information we collect

Integrity Matters® manages an Ethics Helpline (whistleblower hotline) service on behalf of its clients with whom we hold formal written agreements. The service enables client stakeholders to report any non-compliance, unethical conduct or malpractice and serves as a mechanism for the detection and prevention of such activity (“the Purpose”). As a user of this Website, you are not required to submit any personal information to be able to use this Website or to fulfill the Purpose.

Where you elect to use this Website to provide personal information relating to yourself or to others, Integrity Matters® will process such personal information strictly as it relates to the Purpose in the performance of our obligations to our clients and in accordance with applicable legislation.

The personal information that we may collect or receive, includes, but is not limited to:

  • Name(s)

  • Contact details

  • Location details

  • Gender

  • Employment details

  • Identity

  • Financial details

  • Complaint details

We do not specifically collect sensitive personal information, such as data relating to race or ethnic origin, religious beliefs, political beliefs or trade union association, physical or mental health, or sexual orientation, except where this is provided to us in fulfillment of the Purpose.

Legal Basis of Processing

Processing of (personal) data via the Ethicsline® service is necessary for the performance of contract of Integrity Matters® clients (as data controllers). Integrity Matters® clients do not require consent for its processing activities from you (as being the data subject). This is not a relevant legal ground with respect to employees given the dependency that results from the employer/employee relationship.

Data Retention Policy

We will retain your personal information for as long as is needed to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

We retain your information for as long as you are obtaining Services. We may also retain your personal information for an extended period under applicable statutory laws. Integrity Matters® will retain Client Data in accordance with a Client’s instructions, including any applicable terms in the Engagement Letter and as required by applicable law.

Data Security

We have in place a range of physical, operational and technological security measures to protect the information provided by users via this Website from unauthorized access, disclosure, alteration, or destruction. Integrity Matters’® achievement of the prestigious ISO/IEC 27001 certification points to our commitment to making good on Client promises on data security and privacy.

Use of Information

When using/visiting the Ethicsline® service, data is only used and processed for the purposes for which the Ethicsline® service is intended.

We only process Client Data on behalf of our Clients and in accordance with their instructions provided in the applicable Services agreement with us. We use the data that we have about you to provide our services and provide support to you. In each case, Integrity Matters processes such information only in so far as is necessary or appropriate to fulfil the purpose of the interaction with our services.

  • To send emails and other communications: We may send you service, technical and other administrative emails, messages and other types of communications. We may also contact you to inform you about changes in our Services and our Services offerings. These communications are considered part of the Services and you may not opt out of them.

  • Client Support: If you send us a request (for example via a support email or via one of our feedback mechanisms), we respond to your request or to help with your issues.

  • For any other purpose as provided for in the Services Agreement between us and the Client, or as otherwise authorized by the Client.

  • In accordance with or as may be required by law.

Cookies

A cookie is a small file that is sent along with pages from this website and is stored by your browser on your device hard drive. We only use strictly necessary cookies needed for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information. We also use session- cookies when visitors access the Ethicsline® web service to better secure communication. The information collected is not stored beyond the individual session and would therefore not compromise privacy. This Website does not make use of web beacons (electronic images that allow this Website to count visitors who have accessed a particular page or to access certain cookies).

Your rights

Our Clients as data controllers are responsible for assuring your rights as being a data subject. Please check their Privacy Policy to find more information on how they will process your data. You can instruct them to:

  • The Right to Access: You have the right to access personal data and supplementary information. You can ask us for a copy of your personal information.

  • The Right of Rectification (correction): You can ask us to change, update or fix your data in certain cases, particularly if it is inaccurate

  • The Right to Erasure (‘right to be forgotten’): You can ask us to erase or delete all or some of your personal information (e.g., if it is no longer necessary to provide Services to you) without undue delay.

  • The Right to Restriction of Processing: You can ask us to stop using all or some of your personal information (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if you think your personal information is inaccurate or unlawfully held). Following are the processings you can use this right if:

    1. you contest the accuracy of the personal data being processed,

    2. the processing is unlawful and you oppose the erasure of your personal data and request the restriction of their use instead,

    3. our Client, as the data controller, no longer needs your personal data for the purposes of the processing, but you have required them for the establishment, exercise or defense of legal claims, and

    4. you object to processing pending the verification of whether the legitimate grounds of the data controller (our Client) override yours;

  • The Right to Object: You have the right to object to the processing of personal data when

    1. processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling),

    2. direct marketing (including profiling) and

    3. processing for purposes of scientific/historical research and statistics.

  • The right to lodge a complaint: You have the right to lodge a complaint with the (public) supervisory authority if you are dissatisfied with the way we handle or process your personal data.

These rights can be exercised by contacting us with your specific request using the details set out in the "Contact Information" section below.

Modifications

We may modify or amend this Privacy Policy from time to time at our discretion. We encourage you to periodically review this Privacy Statement to be informed about how we are protecting your information.

General

This Privacy Policy reflects the internal guidelines of Integrity Matters®, and is not a contract. If you have any questions or concerns regarding your privacy while using this Website, please direct them to our Data Protection Office on privacy@integritymatters.in


Or you may send a letter or email to:
Mitrisk Consulting LLP,
Unit 1211, CENTRUM, Plot No C-3,
S.G. Barve Road, Wagle Estate,
Thane West – 400604,
Maharashtra,
India