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. Assess the conditions for each route separately.

Apply the following rule: The National Transparency Authority, EAD, manages the external channel under Law 4990/2022. It distinguishes general complaints, its own internal channel and the external whistleblowing channel. Select the route matching the relationship and subject.

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.

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.