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07.06.2017

European Privacy Seal for SpeakUp System

People Intouch B.V. is awarded the EuroPriSe seal for the whistleblowing system SpeakUp which allows messengers to communicate grievances via web and via phone.

The SpeakUp® System enables dedicated client company officers to communicate directly – by telephone or the Internet - with messengers (employees and other associates). Messengers may choose to reveal their identity or to remain anonymous or pseudonymous. Customers of People Intouch (PIT) can provide a phone number and/or a hyperlink to the SpeakUp® System on their websites. Messengers may use the system to report grievances (e.g., criminal activities such as fraud or embezzlement). The SpeakUp® System facilitates a dialogue between messengers and company officers (e.g., compliance officers or corruption agents). A dedicated case management module supports the receiving and handling of the messages by client company officers.  

Users of SpeakUp (customers) are controllers in respect of the processing of personal data that results from the use of this IT-based service. They are provided with guidance on how to comply with EU data protection law in a data protection leaflet and can be sure to act in compliance with EU data protection law if they follow this guidance.

SpeakUp® is a free text system which means that it is up to the messengers to decide which (personal) data they submit or record to the system. People Intouch provides customers with a document that is addressed to messengers and informs them about privacy relevant aspects of the SpeakUp® System. In this document, messengers are advised (i.a.) to only submit or record personal data if and when this is necessary for the proper description of the grievance at hand and to dispense with the submission or recording of sensitive personal data.

It is worth noting that People Intouch and the commissioned translation agencies have access to clear text data. However, they cannot access the case management module to be used by client company officers. To protect messengers' anonymity, both voice files as such and meta data (e.g., phone numbers or IP addresses) are never handed over to customers of PIT. This is explicitly stipulated in a clause of the sample contract to be concluded between People Intouch and each customer and is an important exception from PIT's general obligation to act only on instructions from the customer.

The evaluation according to EuroPriSe was conducted by Johan Dahlsjö (legal + technical expert). The result of the evaluation was that the SpeakUp System complies with all applicable EuroPriSe requirements.

More detailed information on the certification of SpeakUp can be found at https://www.european-privacy-seal.eu/eps-en/pit-speakup.

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