Grifols Ethics Line - Privacy Notice

Privacy notice available in other languages.

Grifols is a global healthcare group founded in Barcelona in 1909 committed to improving the health and well-being of people around the world. Its three main business units – Biopharma, Diagnostic and Bio Supplies – develop, produce and market innovative solutions and services in more than 100 countries.

Grifols respects the privacy rights of all data subjects who entrust Grifols with their personal data and is committed to complying with the data protection regulations applicable in each country.

This privacy notice has been prepared in accordance with the European General Data Protection Regulation (the "GDPR") and applicable privacy and data protection laws; see Section 7 for specific provisions. It outlines Grifols' data collection practices and the choices that data subjects have about the way Grifols collects, uses and shares their personal data.

This privacy notice applies to the processing of personal data of the (a) individuals reporting questions, doubts or potential violation of laws, rules and regulations as well as internal policies and procedures, (b) the reported individuals, and (c) any other third persons involved in said report

1. Identification of the data controller(s)/owner(s) of the personal data

The joint data controllers/owners are Grifols, S.A. jointly with the Grifols' group company based in the country from which the report is received or to which it relates.

The identity and contact details of the Grifols' group companies are available here. The Grifols' group company/ies acting as joint controllers will be referred to as "Grifols".

2. Identification of the data protection officer

The data protection officer acts as an interlocutor between Grifols and you in order to ensure Grifols' compliance with the data protection legislation and to guarantee your rights under such legislation. You may contact the data protection officer at dpo@grifols.com, unless the data controllers are Grifols Deutschland GmbH or Haema AG, in which case you may contact the data protection officer of each of these companies at dsb@grifols.com and dsb@haema.de, respectively.

Although the essential aspects of the joint controllership agreement resulting from what is set out in Section 1 are provided in this Privacy Notice, the data subjects may ask, if they wish so, the data protection officer for more information.

3. Purposes, lawful basis for processing, categories and recipients of personal data

Purpose

To manage individuals' reports addressing questions, doubts or potential violation of laws, rules and regulations as well as internal policies and procedures, including the relevant assessment of the facts reported and the adoption of the corresponding disciplinary measures and appropriate legal actions against the offenders.

Categories of personal data and recipients

Categories of personal data:

- Identification data and personal characteristics¹.

- Contact data².

- Professional data³.

- Special categories of personal data⁴.

- Criminal data (potential violations of laws, rules and regulations as well as internal policies and procedures)
Recipients:

Grifols' group companies.
Providers of products and services.
Public organizations.

Lawful basis: Legal obligation

Public interest: when Grifols shares the results of its own investigations with public organizations or other organizations vested with such public authority.

Legitimate interest: when there is no legal obligation to process the data.

¹For example, name, last name and the personal characteristics in the factual description of the issue.

²For example, phone number, e-mail address and location.

³ For example, the condition of employee or not, title/position and place of work.

⁴ For example, health data, sex life and sexual orientation, racial or ethnic origin, political opinions, trade union membership, genetic data, biometric data and religious or philosophical beliefs.

¹For example, name, last name and the personal characteristics in the factual description of the issue.

²For example, phone number, e-mail address and location.

³ For example, the condition of employee or not, title/position and place of work.

⁴ For example, health data, sex life and sexual orientation, racial or ethnic origin, political opinions, trade union membership, genetic data, biometric data and religious or philosophical beliefs.
Purpose	Categories of personal data and recipients	Lawful basis
To manage individuals' reports addressing questions, doubts or potential violation of laws, rules and regulations as well as internal policies and procedures, including the relevant assessment of the facts reported and the adoption of the corresponding disciplinary measures and appropriate legal actions against the offenders.	Categories of personal data: - Identification data and personal characteristics¹. - Contact data². - Professional data³. - Special categories of personal data⁴. - Criminal data (potential violations of laws, rules and regulations as well as internal policies and procedures) Recipients: Grifols' group companies. Providers of products and services. Public organizations.	Legal obligation Public interest: when Grifols shares the results of its own investigations with public organizations or other organizations vested with such public authority. Legitimate interest: when there is no legal obligation to process the data.

3.1. Additional information about the lawful basis to process personal data

The table above shows the applicable lawful basis to process the personal data by purpose. In this section, you can find additional details of the lawfulness of the processing:

Legal obligation (article 6.1(c) of GDPR): Grifols needs to process the requested personal data to comply with legal obligations. Failure to provide the personal data requested could result in the impossibility for Grifols to comply with such legal obligations. Section 7 includes details of the specific regulations applicable to Grifols that requires the processing of personal data.
Public interest (article 6.1(e) of GDPR): Grifols needs to process the personal data for the performance of a task carried out in the public interest or in the exercise of official authority.
Legitimate interest of Grifols and/or third parties (article 6.1(f) of GDPR): Grifols needs to detect, assess and prevent infringements of applicable laws, regulations and internal policies and procedures in accordance with its corporate principles and values. Therefore, Grifols pursues the following legitimate interests which override the fundamental rights and freedoms of the data subjects, given that the processing is within the data subjects' reasonable expectations based on their relationship with Grifols:
- Prevention of fraud, and
- Daily management of a multinational group of companies and internal administration, which means sharing information with the companies of the Grifols group.

In any event, data subjects may request further information on the legitimate interest or exercise their right to object to the processing of their personal data based on legitimate interest by addressing their request to privacy@grifols.com.

The processing of special categories of personal data (e.g. health data, sex life and sexual orientation, racial or ethnic origin, religious or philosophical beliefs) is based on the fulfilment of obligations and the exercise of specific rights in the field of employment and social security and social protection law (article 9.2(b) of the GDPR), the establishment, exercise or defence of legal claims (article 9.2(f) of the GDPR), or reasons of substantial public interest on the basis of the Whistleblowing Directive and its implementing local regulations (article 9.2(g) of the GDPR).

3.2. Recipients of personal data

The table above shows categories of recipients with whom Grifols may share personal data, by purpose. This section includes additional information regarding these recipients when applicable:

Grifols' group companies: The list is available here.
Providers of products and services: for example, IT service providers and lawyers.
Public or private organizations: for example, governmental organizations, police or judicial authorities.

Grifols will endeavour that the personal data is only transferred to countries that offer an adequate level of data protection. If the personal data is processed in countries that do not offer said level of protection, Grifols and/or the providers (as the case may be) will adopt, if necessary, the appropriate safeguards to carry out such international data transfers in accordance with the applicable data protection legislation. Information on the appropriate safeguards for international data transfers can be obtained from Grifols at privacy@grifols.com.

Grifols does not share personal data with any other third party unless it is authorised by the data subject or required by the applicable law.

4. Retention period

Grifols will retain the personal data for the time strictly necessary for the fulfilment of the purposes for which it has been collected or, if applicable, until the end of the statutes of limitation of any liabilities that may arise, and during the term required to comply with any applicable legal obligation.

5. Sources of personal data

If data subjects do not directly provide Grifols with their personal data, Grifols may obtain the personal data from the reporter and third persons involved in the report (e.g. managers/supervisors and witnesses).

If the individual making the report provides personal data of any third parties, Grifols will provide this privacy notice to said third parties. The provision of this privacy notice to these third parties could be delayed if Grifols, after a case-by-case analysis, considers that providing this information at an early stage could affect the investigation.

6. Data protection rights

The following data protection rights are applicable under the GDPR. Grifols undertakes to respect other data protection rights that may be applicable in accordance with the data protection legislation of each country.

Right

Access

Content: You may request confirmation as to whether or not your personal data is being processed and, if so, you can obtain access to your personal data included in Grifols' files.

Rectification

Content: You may request the rectification of your personal data if inaccurate.

Erasure

Content: You may request the erasure of your personal data.

Objection

Content: You may request that your personal data is not processed under specific circumstances.

Portability

Content: You may request receiving, in an electronic file, the personal data that you provided Grifols with, as well as the right to transmit it to other parties.

Restriction of processing

Content

You may request a restriction on how your personal data is processed when:

the accuracy of the personal data is being verified after you have contested its accuracy.
processing of your personal data is unlawful and you object to its erasure.
Grifols does no longer need the personal data for the purposes of processing it, but you need it in order to prepare, exercise or defend a legal claim.
you have objected to the processing of the personal data for the performance of a task carried out in the public interest or necessary for the purposes of a legitimate interest, while verifying if Grifols' legitimate grounds override yours.

Right	Content
Access	You may request confirmation as to whether or not your personal data is being processed and, if so, you can obtain access to your personal data included in Grifols' files.
Rectification	You may request the rectification of your personal data if inaccurate.
Erasure	You may request the erasure of your personal data.
Objection	You may request that your personal data is not processed under specific circumstances.
Portability	You may request receiving, in an electronic file, the personal data that you provided Grifols with, as well as the right to transmit it to other parties.
Restriction of processing	You may request a restriction on how your personal data is processed when: the accuracy of the personal data is being verified after you have contested its accuracy. processing of your personal data is unlawful and you object to its erasure. Grifols does no longer need the personal data for the purposes of processing it, but you need it in order to prepare, exercise or defend a legal claim. you have objected to the processing of the personal data for the performance of a task carried out in the public interest or necessary for the purposes of a legitimate interest, while verifying if Grifols' legitimate grounds override yours.

You may exercise, when appropriate, your data protection rights by, for example, sending a written communication to Grifols at privacy@grifols.com with the subject line "Whistleblowing". To that end, Grifols may request as many information and documents as appropriate to identify you.

For residents in the United States please contact the Privacy Office at US-PrivacyRights@Grifols.com.

In addition, you may lodge a complaint with a data protection authority, including the one at your residence, place of work or place of the alleged infringement.

7. Specific Provisions

Czech Republic
The legal obligation referred to in Section 3 is regulated in the Act No. 130/2022 of 12 May 2022.
European Union
The legal obligation referred to in Section 3 is regulated in the Directive 2019/1937 on the Protection of Whistleblowers and in the transposed EU members' national laws.
France
The legal obligation referred to in Section 3 is regulated in the Law No. 2022-401 of 21 March 2022.
When Grifols France S.A.R.L. is the data controller, the data subjects have the right to provide guidance on the management of their data after their death.
Italy
The legal obligation referred to in Section 3 is regulated in the Whistleblower Protection Law (179/2017).
Ireland
The legal obligation referred to in Section 3 is regulated in the Protected Disclosures (Amendment) Act of 2022.
Portugal
The legal obligation referred to in Section 3 is regulated in the Law No. 93/2021 of 20 December.
When Grifols Portugal – Produtos Farmacêuticos e Hospitalares, Lda. Is the data controller, the data subjects have the right to provide guidance on the management of their data after their death. When guidance on the management of their data has not been provided by the deceased data subjects, the exercise of their data protection rights defined in Section 6 may be carried out by their heirs. The data subjects may also determine the impossibility of exercising these rights after their death.
When there is a legal obligation of secrecy, the rights of the data subjects cannot be exercised.
People's Republic of China
Mainland China: when your personal data is being processed by any Grifols' group company in mainland of the People's Republic of China, the addendum available here applies to you. The addendum is set out in addition to and forms an integral part of this privacy notice.
Sweden
The legal obligation referred to in Section 3 is regulated in the Whistleblowing Act (Swedish Act (2021:890) on special protection against reprisals for workers who report irregularities).
United Kingdom
All references throughout the document to the GDPR also refer to, as applicable, the GDPR as it forms part of the law of England and Wales, Scotland, and Northern Ireland.

Last update: March 2023

Privacy notice available in other languages

ZH SIMPLIFIED MANDARIN – 隐私声明 - 基立福道德热线 ZH TRADITIONAL – 私隱聲明 — GRIFOLS 道德求助專線 CZ – Oznámení O Ochraně Osobních Údajů – Linka Pomoci Společnosti Grifols Pro Oblast Etiky DE – Datenschutzerklärung – Grifols Ethics Line EN – Privacy Notice – Grifols Ethics Line FR – Avis De Confidentialité – Ligne D'assistance Éthique Grifols HI – गोपनीयता नोटिस – Grifols आचार निति हेल्पलाइन HU – Adatvédelmi Nyilatkozat – Grifols Etikai Segélyvonal IT – Informativa Sulla Privacy – Sistema Di Segnalazione Delle Violazioni Del Codice Etico Di Grifols JP – プライバシー通知 – グリフォルス倫理ヘルプライン PL – Zastrzeżenie Poufności – Infolinia Etyczna Firmy Grifols PT BR – Aviso De Privacidade – Linha Direta De Ética Da Grifols ES – Aviso De Privacidad – Grifols Ethics Line SE – Integritetsmeddelnade – Grifols Ethics Line TH – ประกาศความเป็นส่วนตัว – สายด่วนจริยธรรมของ GRIFOLS