Module Learning Objective

retain necessary decision grounds without excessive data

1. Regulatory Concept & Core Standards

This video focuses on how to retain necessary decision grounds without excessive data. Follow the sequence of decisions in the example rather than simply memorising a list. Notice who is involved, what information is needed and the expected result. These points help turn the content into a practice that another person can verify. A conflict can exist without actual corruption. Distinguish KVS public-function requirements from private organisational policy. This course accounts for the 19 July 2026 changes to connected persons and restrictions. It assumes no universal statutory euro limit for gifts.

An interest or gift record supports checking when it explains the decision. Registration does not legalise a prohibited benefit. Minimise related persons’ data. Apply KVS exception-notification and retention rules in their exact scope.

Apply the following rule: Section 10(3) prescribes three years and refers to feedback under section 11(4), while final-outcome feedback now appears in section 11(6). Do not conceal the cross-reference issue or automatically replace it with receipt. Document the legally confirmed starting event before automating deletion. Government Regulation 12 of 2 February 2026 covers the report, collected material and media, review of oral-report minutes and destruction under a procedure approved by the organisation’s head.

2. Practical Implementation & Procedure

Record description, decision-maker, grounds and outcome. Restrict access, link any recusal or transfer, and define retention and review of unusual repetitions. 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.

3. Case Study & Compliance Action

A register describes a gift but shows no decision or refusal evidence. The completed entry identifies the reviewer and explains return of the benefit. 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: Does registration mean approval? 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. It may record refusal, return or an unresolved issue. The decision and grounds must be visible separately.

One mistake to avoid is: assuming every registered gift is permitted.

Now apply the national rule to a second decision. The system deletes every case five years after receipt. Is that correct for Estonia?

No. The three-year period in section 10(3) references feedback rather than automatically receipt. The current cross-reference issue needs a documented legal resolution. Apply Regulation 12 and privacy rules to related material and copies. Do not keep everything indefinitely without grounds.

National Legal Framework: Rikkumisest teavitaja kaitse seadus, transposing Directive (EU) 2019/1937 of the European Parliament and of the Council on the protection of persons who report breaches of Union law.