Privacy policy complaints channel

PKF ATTEST SERVICIOS PROFESIONALES S.L. places at your disposal the present channel of communication of possible conduct constituting an infraction for the purposes of Law 2/2023, of 20 February, regulating the protection of persons who report regulatory infractions and the fight against corruption. This channel is constituted as a transparent and absolutely confidential means of communication that aims to channel those complaints that may be received by the entities belonging to PKF Attest Group.

You should only provide us with information that is believed to be correct, to the best of your knowledge and belief, and that is relevant to detect a breach of regulatory compliance and/or the Group's Code of Ethics or Code of Conduct. In the event that the communication is manifestly unfounded or there are, in the opinion of PKF ATTEST SERVICIOS PROFESIONALES S.L. rational indications of having obtained the information through the commission of a crime PKF ATTEST SERVICIOS PROFESIONALES S.L. may initiate any disciplinary and/or legal actions it deems appropriate.

In compliance with data protection regulations, the complainant, potential witness and respondent are hereby informed of the processing of personal data:

Information clause for the whistleblower

The Group's Whistleblower Channel allows the submission of anonymous complaints. However, if the informant or complainant wishes to submit the complaint in a nominative way, PKF ATTEST SERVICIOS PROFESIONALES S.L. may collect, within the framework of a communication, the following types of data from the informant and, where appropriate, from the persons involved in the communication:

Identification data
Contact information
Professional Data

Additionally, PKF ATTEST SERVICIOS PROFESIONALES S.L. may process other types of data by virtue of the facts reported and the supporting documentation that may be appropriate to investigate the complaint. If the information received contains personal data included in the special categories of data, it will be immediately deleted, without any registration or processing of the same.

In no case will personal data be collected that are not necessary for the investigation of the corresponding complaint and therefore, in the event that non-relevant data are collected, these data will be deleted from the Complaints Channel without undue delay. Likewise, any personal data that may have been communicated and that refer to conduct not included in the scope of application of the Whistleblower Protection Act shall be deleted.

In any case PKF ATTEST SERVICIOS PROFESIONALES S.L. informs you that it will treat personal data for the following purposes:

Receive and decide on the admissibility of the communication received,
Conduct the appropriate investigations of the facts reported and, if necessary, adopt the corresponding corrective measures.
Keep the complainant or informant informed about the admission or not of the communication, as well as the progress and results of the investigation process.

The legitimate basis for the processing of your personal data is the fulfillment of legal obligations arising from the application of Law 2/2023 of 20 February regulating the protection of persons who report regulatory infringements and the fight against corruption.

You are also informed that the personal data that you may provide when filing the complaint, as well as any other personal information that may be collected in your case, during the investigation process, may be communicated to:

Public agencies or institutions, judges and courts when necessary for the adoption of disciplinary measures, for the processing of legal proceedings, if any, or in those cases in which it is legally required.
To the Public Prosecutor's Office, when the procedure is within its competence.
To the subsidiaries of the PKF Attest Group in case it is necessary for the investigation of the reported facts, for the adoption of corrective or disciplinary measures, or when the report concerns several entities of the group. You can find information on the entities belonging to the Group in the latest version of the transparency report published on our website

The personal data to which PKF ATTEST SERVICIOS PROFESIONALES S.L. may have had access as a result of the communications received through the Complaints Channel, will be processed for the time necessary to decide on the appropriateness of initiating an investigation into the facts reported and for the management of the communication provided that it is admitted for processing.

Specifically, PKF ATTEST SERVICIOS PROFESIONALES S.L. will process the personal data within a maximum period of three months from the receipt of the communication or, if no acknowledgement of receipt was sent to the informant, three months from the expiration of the seven calendar days that PKF ATTEST SERVICIOS PROFESIONALES S.L. has to acknowledge receipt of the communication.

Once the aforementioned period has elapsed without any investigation proceedings having been initiated, the data shall be deleted from the communication system, except for the purpose of maintaining evidence of the operation of the system and in an anonymized form.

In the case of communications that have not been sent, they will be kept in an anonymized form, completely eliminating personal data.

In any case you can exercise, where appropriate, your rights of access, opposition, rectification, deletion, limitation of processing, portability and not to be subject to automated individual decisions by writing to privacidad@pkf-attest.es or by contacting the Data Protection Officer at the email address mentioned above. Likewise, if you consider that your data have been treated inadequately, you will have the right to file a complaint before the Spanish Data Protection Agency (www.aepd.es).

Informative clause for the defendant

We inform you that your data has been provided in your capacity as an investigated/complainant of a complaint sent by the complainant/reportant through the PKF Attest Group's Complaints Channel.

In compliance with the current regulations on Personal Data Protection, we inform you that the personal data provided by the complainant or informant with the complaint, as well as any other personal information that PKF ATTEST SERVICIOS PROFESIONALES S.L. may collect in the investigation process, will be treated with the sole and exclusive purpose of managing the communication received, carry out the investigation of the reported facts and, where appropriate, take corrective measures as appropriate.

The legal basis that legitimizes the processing of data is the fulfillment of legal obligations in accordance with the provisions of Law 2/2023, of 20 February, regulating the protection of persons who report regulatory violations and the fight against corruption.

All information provided will be treated for the period necessary for its investigation in accordance with the provisions of current regulations. Specifically, PKF ATTEST SERVICIOS PROFESIONALES S.L. will process the personal data within a maximum period of three months from the receipt of the communication.

Your personal data will be treated confidentially and will not be communicated to any third party, unless they are essential for the investigation of the reported facts in which case they may be communicated to public bodies or institutions, judges and courts when necessary for the processing of legal proceedings, where appropriate, or in those cases in which it is legally required and to the Public Prosecutor, when the procedure is within its competence; and to the subsidiaries of the PKF Attest Group in case it is necessary for the investigation of the reported facts, for the adoption of corrective or disciplinary measures, or when the report affects several entities of the group. Information on the entities belonging to the Group can be found in the latest version of the transparency report published on our website.

We also inform you that you can exercise your rights of access, rectification, deletion, opposition, limitation of processing and portability by writing to privacidad@pkf-attest.es or by contacting the Data Protection Delegate at the aforementioned email address proving your identity and specifying your request. Likewise, if you consider that your data have been treated inadequately, you will have the right to file a complaint before the Spanish Data Protection Agency (www.aepd.es).

Witness information clause

We inform you that your data have been provided as a witness of a complaint sent by the complainant/reportant through the PKF Attest Group Complaints Channel.

In compliance with current regulations on the Protection of Personal Data, we inform you that the personal data on your person, have been provided with the complaint, as well as any other personal information that PKF ATTEST SERVICIOS PROFESIONALES S.L may collect in the investigation process, will be treated with the sole and exclusive purpose of managing the communication received, conduct the investigation of the facts reported and, where appropriate, take corrective measures that may be appropriate. The legal basis that legitimizes the processing of data is the fulfillment of legal obligations in accordance with the provisions of Law 2/2023, of 20 February, regulating the protection of persons who report regulatory violations and the fight against corruption.

We also inform you that you can exercise, where appropriate, your rights of access, opposition, rectification, deletion, limitation of processing, portability and not to be subject to automated individual decisions by writing to privacidad@pkf-attest.es or by contacting the Data Protection Officer at the aforementioned email address proving your identity and specifying your request. Likewise, if you consider that your data have been treated inadequately, you will have the right to file a complaint before the Spanish Data Protection Agency (www.aepd.es).

Whistleblower Channel Privacy Policy