Module Learning Objective

obtain sufficient evidence without excessive access to sensitive cases

1. Regulatory Concept & Core Standards

This video focuses on how to obtain sufficient evidence without excessive access to sensitive cases. 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. Audit compares criteria with evidence within a defined scope. This course proposes internal verification, not official certification or a guarantee that no wrongdoing exists. Identity and report information remain protected during audit.

Evidence must be relevant and sufficient for the conclusion. Interviews explain, records demonstrate and a sample covers selected situations; each has limits. Articles 14–16 of the Croatian Act and the GDPR also apply during audit. Metadata, redacted copies and demonstrations can reduce the need for complete case files.

Apply the following rule: Article 18 requires a record of every report and preservation in a durable form under national rules on protection and processing of documentation. It does not establish a universal five-year period or justify indefinite processing of all personal data. Determine applicable documentation and archival duties and GDPR purpose and retention limits. Under Article 15, manifestly irrelevant personal data must not be collected and, if collected accidentally, must be deleted without undue delay.

2. Practical Implementation & Procedure

Define population and sample. Verify receipt, communications and decisions using necessary records. Compare dates and relevant content without indiscriminate attachment copying. Check risk-plan measures and training. Record exceptions and avoid unsupported universal conclusions from small samples. 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

An audit of five cases finds one delay. The report states population, sample, criterion and failure. It does not claim that 20% of all reports were late without a sampling basis supporting that inference. 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: Is a sample percentage automatically the percentage for the whole population? 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. That depends on sample design and representativeness. State observed results and limits. Findings may justify more checks, but not unsupported generalisation.

One mistake to avoid is: collecting complete files for convenience or extrapolating beyond the evidence.

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

No. Identify the local rule, starting event and any limits or extensions. A uniform schedule may delete records too early or retain them too long. Document the decision by category, include copies and define who reviews a suspension of deletion, rather than keeping everything indefinitely.

National Legal Framework: Zakon o zaštiti prijavitelja nepravilnosti, transposing Directive (EU) 2019/1937 of the European Parliament and of the Council on the protection of persons who report breaches of Union law.