Danish National Academy of Music's whistleblower programme
On this page you will find the whistleblower programme for the Danish National Academy of Music. You can use the whistleblower programme to report illegal or reprehensible matters concerning the Danish National Academy of Music.
Please read the information below carefully before submitting your report. You can find all relevant links at the bottom of the page.
You can use the whistleblower programme if you are an employee, student or have previously been employed at the Danish National Academy of Music or have been an (un)paid intern, or if you have been considered for a position at the Danish National Academy of Music, to the extent that the report concerns information acquired in connection with the recruitment process or other pre-contractual negotiations.
You can also use the programme if you are a business partner (including self-employed persons and subcontractors) or employed by a business partner with whom the Danish National Academy of Music has or has had a collaboration.
What matters are covered by the whistleblower programme?
The programme covers serious matters about
- Reports of violations of EU law (see delimitation below in the link to the guide for whistleblowers).
- Criminal offenses, e.g. breach of confidentiality, misuse of funds, theft, fraud, embezzlement, fraud, bribery, etc.
- Gross or repeated violations of legislation, e.g. legislation on the use of force, the Danish Public Administration Act, the Danish Data Protection Act, the Danish Freedom of Information Act, etc.
- Serious or repeated violations of administrative law principles, e.g. the principle of investigation, requirements for objectivity, the principle of misuse of power and proportionality, etc.
- Serious or repeated violations of important internal guidelines, e.g. on business trips, gifts and financial reporting, etc.
- serious personal conflicts in the workplace , e.g. serious harassment
- sexual harassment , e.g. any form of unwanted verbal, non-verbal or physical conduct of a sexual nature with the purpose or effect of violating the dignity of a person, in particular by creating an intimidating, hostile, degrading, humiliating or offensive environment
- Deliberately misleading citizens and business partners.
The Whistleblower Unit at the Danish National Academy of Music will make a specific assessment in each individual case of whether such serious matters are involved.
You cannot use this whistleblower scheme to report matters concerning classified information covered by the Ministry of Justice's circular no. 10338 of December 17, 2014 on the security protection of information of common interest to NATO or EU countries, other classified information and information of security protection interest in general (called the "Security Circular").
If you are an employee, you should be aware that you cannot use the system to report on other matters or on less serious matters. This information should generally be handled via e.g. your immediate manager, coordinator/subject group leader or your union representative. Information about other matters can be, for example
- information about violations of less significant internal guidelines on sick leave, smoking, alcohol, dress, use of office supplies, etc. and
- information about minor staff-related conflicts in the workplace.
If your report falls outside the scope of the scheme, it will be treated as an ordinary inquiry at the Danish National Academy of Music.
You should always have concrete knowledge or reasonable suspicion that such serious matters have been committed before using the whistleblower scheme.
About anonymity and confidentiality
The Danish National Academy of Music's whistleblower programme allows you to anonymously submit information about critical matters to a trusted whistleblower unit, which can investigate the matter further.
Through the whistleblower system, you can also have a follow-up dialog with the whistleblower unit. This dialog is also anonymous.
The Danish National Academy of Music's whistleblower unit is anchored in HR, and only case officers from the whistleblower unit can access your report.
If you send information to the whistleblower programme from a computer that is on the Danish National Academy of Music's network or via the link to the digital whistleblower portal on the Danish National Academy of Music's website, this may be registered as part of the general logging of user activities on the Danish National Academy of Music's network. This can be avoided by typing the web address: https://sdmk.sit-wb.dk/ directly into a browser on a private or public computer that is not connected to the Danish National Academy of Music's network.
If you do not wish to report directly to the Danish National Academy of Music, or if you are in doubt as to whether your report will be treated objectively by our whistleblower unit, you can alternatively make your report to the Danish Data Protection Agency, which operates an external and independent whistleblower scheme.
Case processing and communication
Your inquiry will be treated confidentially and answered as soon as possible by our whistleblowing unit.
Once you have submitted your report, you will receive a receipt that your report has been received. The receipt will contain a 16-digit key code. You can use the code to access the whistleblower portal, where you can, for example, add additional information to your report, communicate with the Danish National Academy of Music's whistleblower unit and receive information about the processing of your report.
The whistleblower unit can also contact you via the whistleblower portal if, for example, it has follow-up questions for the processing of the report. The whistleblower unit will only communicate with you via the digital whistleblower portal.
The communication that takes place on the whistleblower portal between the whistleblower unit and you is anonymous unless you provide your identity or contact details.
It is important that you regularly log in with the 16-digit key code and follow the development of the case, including answering any questions from the whistleblower unit on the whistleblower portal, as this may affect the whistleblower unit's ability to process your report. It is also important that you keep the key code safe, as it cannot be recovered for security reasons.
If you lose your code, you will not be able to access the report on the whistleblower portal and the whistleblower unit will not be able to communicate with you.
Legal protection against retaliation
As a whisteblower, you are protected against retaliation through the Whistleblower Protection Act. This means that you will not be retaliated against if you have made a report in good faith.
Protection of your personal data
When we process your data, the General Data Protection Regulation gives you a number of rights. For example, you have the right to request access to the data we process about you. In certain cases, you also have the right to ask for incorrect data to be corrected, the right to ask for data to be deleted and the right to ask the whistleblower unit to restrict the processing of your data.
It is a prerequisite that you disclose and confirm your identity if you want to exercise your rights. Only in these cases can the whistleblower unit locate your data and ensure that the data is sent to the correct recipient.
According to Article 13 of the General Data Protection Regulation, we must provide you with a number of information when we receive personal data about you.
- The Danish National Academy of Music is the data controller - how do you contact us?
- Contact details of the Danish National Academy of Music's Data Protection Officer (DPO)
- The purposes and legal basis for processing your personal data
- Who has access to your data and who do we disclose it to?
- How long will your personal data be stored
- Your rights as a data subject
You can find more information about the above information in the Danish National Academy of Music's privacy policy.
Relevant links:
- The Danish Data Protection Agency's external whistleblower scheme (ENG)
- Act on the protection of whistleblowers (DK)
- Common guidelines for whistleblower schemes in the state sector (DK)
- Ministry of Justice guidelines for whistleblowers (DK)
- Guidelines for the whistleblower scheme at the Danish National Academy of Music (DK)
- Guidelines on public employees' freedom of expression (DK)
- Good behavior in the public sector (DK)
- Danish National Academy of Music's privacy policy for whistleblowers (ENG)
- Danish National Academy of Music's policy on offensive behavior (ENG)
- Danish National Academy of Music's complaints guide
Contact information:
Danish National Academy of Music
Odeons kvarter 1
5000 Odense C
info@sdmk.dk
tel. 63 11 99 00
You can access the Danish National Academy of Music's whistleblower portal at this link:(https://sdmk.sit-wb.dk)