Internal reporting, external reporting and public disclosure

1. Regulatory Concept & Core Standards

This video's topic is internal reporting, external reporting and public disclosure. By the end, you should be able to identify the legal role of each reporting route. We will connect the information available, the criterion guiding the decision and the action that must be recorded. Follow the case and compare your answer with the proposed response. Protection requires examination of the person, information, scope and reporting route. An internal policy can accept more subjects than the special law covers. Receipt must not be confused with automatic recognition of protection.

An external technology supplier does not turn a company channel into an authority channel. Public disclosure has separate conditions. Cyprus’s interruption of internal handling following external reporting requires separate application.

Apply the following rule: Reports go to the authority competent for the subject. Sections 11 and 35 permit direct external reporting. Where a person reports externally while an internal procedure is pending, the internal procedure is discontinued and the person must inform the internal channel. Where more than one competent authority is contacted simultaneously, the person informs them and the authorities coordinate. Do not teach that internal and external investigations always continue independently in parallel.

2. Practical Implementation & Procedure

Check recipient, powers and legal route. Do not require employer permission for direct external reporting where permitted. Apply the separate legal test to public publication. 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.

In Cyprus, sections 11 and 35 of Law 6(I)/2022 require the internal procedure to be discontinued when the reporting person submits an external report while internal handling is pending. The reporting person informs the internal channel. Record the event and apply the specific provision without destroying necessary evidence or assuming that all lawful corrective powers of other bodies disappear. If multiple competent authorities were contacted simultaneously, apply the required information and coordination rules.

3. Case Study & Compliance Action

One worker fears retaliation and wants to contact the authority. Another wants to publish the entire file online. 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: Do these options have identical conditions? 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.

No. External reporting and public disclosure are different routes requiring separate assessment.

One mistake to avoid is: confusing a software provider with a competent authority.

Now apply the national rule to a second decision. An advice page is shown as the sole recipient for every report. What should be checked?

Check the recipient’s powers and function. Guidance, external receipt, investigation and protection may belong to different bodies. Instructions must lead to the correct procedure without steps that the law does not require.