Prime Membership Anonymous Whistleblowing.

Who needs a prime membership - an anonymous Whistle-blowing scheme?
a solution all in one with no extra cost.

Anonymous Whistleblowing
  • Reporting persons working in the private or public sector
  • Persons who have acquired information about infringements in a work-related context.
  • Workers
  • Self-employed persons
  • Shareholders and persons of the administrative, management, or supervisory organ of an undertaking.
  • Non-executive members, volunteers, and trainees (paid and unpaid)
  • Any person working under the supervision and direction of contractors, subcontractors, and suppliers.
  • Persons whose working conditions have ceased or have not yet begun.
  • Others, e.g. intermediaries.

A membership Whistleblowing scheme to your business.

Reporting step by step The reporter shall make an alert.

 
Reporting step by step The reporter shall make an alert.
 
 
  • The alert is screened Within or outside the scope of the scheme Investigation into the whistleblower’s association with the company/ authority.
  • Examination/ processing of the report
  • Further examination of the substance of the alert.
  • Information to the reporter and the reported company/authority possibly postponement.
  • Handling the reported person’s right of access to information about the person concerned.
  • The investigation is closed Notification to police or other authorities
  • Possible employment law sanctioning
  • Any retention of information in the reported personnel file.
  • Deleting data
 
 
 

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Signup - easy compliance today

In our basic solution you recieve:

1. Link for whistlblowing to add to your site.

2. Legal support – screening and walk-through process

3. Procurement support – support to set up evidence plan for analysis and documentation.

4. On-going information and updates.

5. Yearly training of staff and members.

Ongoing updates and needs to comply are all included in your membership.

Internal reporting

Information on infringements may be reported through internal reporting channels and procedures in accordance with Article 7.
 
 
Obligation to establish:
 
Legal entities in the private sector with or more employees and, as a general rule, all public legal authorities shall establish a WB scheme in accordance with Article 8(3) and (9).
 
No formal requirements for the notification. there is freedom of choice between: Written reporting channels: Post, physical complaint boxes or online platform (either intranet or Internet platform) Reporting channels may be operated internally by a person or department designated for that purpose or provided externally by a third party.
 
Joint reporting: Legal entities with 50-249 employees and municipalities can share resources.
 
 

Internal or external model


 
Internal:
 
A director, compliance officer or genral counsel processes employee reviews.
 
The Management Board shall examine notifications of the Director.
 
 
External
 
(lawyer/ legal adviser) deals with reviews on the Board of Directors External:
 
External company administration Requirement for written data processor agreement.
 
For example, external legal adviser processes all notifications. Possible with delegation option for internal dedicated employee.

Internal procedure requirements

Internal procedure requirements
 
 

Confidentiality:

 
Channels for receiving alerts shall be operated in such a way that the confidentiality of the identity of the reported person and any third party mentioned in the alert is protected.
 
 

Confirmation:

A confirmation of receipt of the alert must be sent within seven days.
 
 

Impartial investigator:

 
An impartial person or department competent to follow up the reports shall be appointed. Careful follow-up.
 
 

Anonymity:

 
Careful follow-up with regard to anonymous reports (if provided for in national law) Feedback: A reasonable time limit to provide feedback that does not exceed 3 months from the acknowledgement of receipt.
 
 

Information:

 
Clear and easily accessible information on the procedures for reporting externally to competent national and EU institutions. See Article 9 of the WB Directive.

Processing of personal data.

Processing of personal data.
 
Any processing of personal data under the WB Directive shall be carried out in accordance with Article 17 of the Data Protection Regulation.
 
Information which is manifestly not relevant to the processing of a specific alert shall not be collected and shall be deleted immediately if it has been collected.
 
The company/authority responsible for the WB scheme must comply with the requirement for good data processing practice.

Accountability

Accountability – Undertakings and authorities should have a procedure for observing the obligation to provide information.
 
Obligation to provide information to the reporter: The obligation to provide information laid down in Article 13 of the Data Protection Regulation shall be observed.
 
Obligation to provide information to the reported person: Since information is not collected directly from the data subject, the obligation to provide information referred to in Article 14 shall apply. 3 exceptions: Crucial private/public interests are opposed, including criminal investigations, pursuant to Article 22 of the Data Protection Act Where disclosure of the information is likely to make it impossible or would seriously impede the achievement of the objectives of the processing, cf.
 
GDPR Article 14(5)(b) (e.g. if the reported is investigated for offences) Where personal data are to remain confidential as a result of professional secrecy within the meaning of Article 16 of the WB Directive, see GDPR Article 14(5)(d).
 
Any derogation (postponement) of the obligation to provide information may only be made after a specific assessment.

REQUIREMENTS for IT Security and Compliance

REQUIREMENTS for IT Security and Compliance ISO/IEC 27001 certified by Intertek Group plc. Our solution can anytime be auditet by client according to OSO27001.
 
ISAE 3000 Type 1 Statement of Assurance in relation to gdpr (PWC) will be a type 2 in May 2021 (see Article 17) Compliant with the Web Accessibility Act and the WCAG 2.1 standard.
 
Complies with the requirements of the WB Directive, in particular the obligation to register in accordance with Article 18 audit log and retention of interviews Complies with country-specific legislation