Module Learning Objective

preserve provenance and integrity

1. Regulatory Concept & Core Standards

Today we will learn to preserve provenance and integrity. Throughout the video, consider the difference between knowing a rule and applying it to a decision. We will work through an example, identify a possible failure and develop a response that can be used at work. Investigation assesses specific allegations impartially and with respect for rights. The methods are recommended organisational practice within legal limits. They do not replace courts or authorities or authorise indiscriminate monitoring.

Assessment needs to establish where evidence came from and whether it changed. Access must be lawful and proportionate. Preservation does not justify unlimited copying of personal devices.

Apply the following rule: Section 19(1) requires personal data collected when receiving reports to be deleted within three months after the procedure is completed. If judicial or disciplinary proceedings against the person concerned or the reporting person have begun, keep the data throughout those proceedings, including an appeal or objection, and delete after one year has passed following their completion. This specific rule also applies to national-law reporting through the cross-references in sections 34 and 35. Do not replace it with an unspecified necessary-and-proportionate period.

2. Practical Implementation & Procedure

Record source, date, collector and changes. Protect originals and use appropriate copies. Check authority and purpose before access. Before moving on, turn this procedure into a sequence you could explain to a colleague. Identify the first check, the action that depends on its outcome and the record that allows the decision to be reconstructed. Follow the sequence on screen and identify the point where an error would change the result.

Consider how a colleague taking over tomorrow would understand the decision. Identify the verified information and its source, who is authorised to decide and who checks the result. The record should connect the decision to the material actually used rather than repeat the whole file. State critical gaps and assign a specific action to resolve them. This makes continuity independent of one person’s memory. Apply the proposed organisational steps within legal powers. In the case, distinguish observation, conclusion and hypothesis. An observation describes available evidence, a conclusion explains what can reasonably be inferred and a hypothesis still needs checking. Do not infer motives merely from unusual behaviour. Identify which further information could change the decision and whether it can be obtained lawfully and proportionately. Incomplete knowledge justifies neither certainty of guilt nor indifference to an actual risk.

3. Case Study & Compliance Action

Two invoice versions have different amounts. The team keeps both with provenance records rather than replacing one. Now read the case carefully. Separate established facts from information you would still need to confirm. Do not add motives or events that have not been described. This distinction matters when choosing a response proportionate to the information available.

The exercise is as follows: Why retain the history? Choose an answer and write one sentence explaining it. During the pause, compare your choice with the criteria we have just considered. Also think about the material you would retain to explain the decision later.

It enables assessment of the sequence of changes and avoids reliance on an unverifiable copy.

One mistake to avoid is: altering originals during analysis.

Now apply the national rule to a second decision. The system deletes every case five years after receipt, regardless of country and pending proceedings. Is this suitable?

No. Apply the specific national retention rule and its starting event. Consider pending judicial or disciplinary proceedings where required. Record the decision by category, include copies and designate the person who reviews a suspension of deletion.

National Legal Framework: Law 6(I)/2022 on Whistleblower Protection, transposing Directive (EU) 2019/1937 of the European Parliament and of the Council on the protection of persons who report breaches of Union law.