Module Learning Objective

document closure while preserving corrective actions and retention duties

1. Regulatory Concept & Core Standards

In this video we will consolidate a skill: document closure while preserving corrective actions and retention duties. Use the case to test what you would do in a similar situation. We will explain the proposed response step by step so that you can understand each choice and recognise when more information would be needed. Handling a report requires continuity: each stage must leave enough information for the next. This course follows the team's work, distinguishing case administration, factual analysis and communications with the reporting person. The examples concern internal channels.

Closure records what was established, what was not and why. Article 22 separately requires written outcome notice without delay and reporting to the Ombudswoman within 30 days of the decision. Article 18 and applicable rules govern records and retention: do not import a universal foreign five-year rule.

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

Prepare findings, justified measures and limitations. Allocate ownership and proof of correction. Send required communications with confidentiality. Identify the retention rule for each record type and review manifestly irrelevant personal data under Article 15. 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

The assessment does not substantiate the alleged payment but reveals that one person approved both changes and payments. The case records the evidential limitation and proposes separation of duties. The control improvement can proceed without declaring an unproven breach established. 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: Can an improvement be adopted when the report has not been substantiated? 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.

Yes, if the assessment identified a real weakness and the measure is justified. Findings on the report and a decision to improve a control are separate matters that must be clearly documented.

One mistake to avoid is: using closure to erase the history or abandon outstanding corrective actions.

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.