Module Learning Objective

create a form that collects useful information without unnecessary identification

1. Regulatory Concept & Core Standards

In this video we will work through a concrete decision: create a form that collects useful information without unnecessary identification. The aim is to explain the criterion used and apply it to a workplace situation. We will start with the concept, move to the procedure and finish with a case to solve. The demonstrations in this course use a generic platform and fictional data. Field names depend on the chosen product. The aim is to understand which settings to look for and how to verify the result, keeping technical administration rights separate from access to case content. The demonstration uses a fictional platform. Seven-day written acknowledgement and the Hungarian investigation limits are separate events.

Section 26 limits personal data to what is indispensable for investigation and remediation. Form fields influence what reaches the handler. Omitting a name does not prevent identification through a small team, time or file metadata. Assess necessity and the combined identifying effect before making fields compulsory.

Apply the following rule: Under section 22(6), investigation of an internal report from an unidentifiable person may be omitted. Section 49 nevertheless protects a lawful reporter who is later identified and faces the specified adverse treatment or section 42 liability situation. These are distinct questions. In the Commissioner’s protected electronic system, the person may request that only the Commissioner and the Office access their identifying data. This does not mean that nobody knows their identity.

2. Practical Implementation & Procedure

Start with a title and a short explanation. Configure essential and optional fields, attachment limits and help messages. Use neutral wording, such as people mentioned instead of guilty parties. Test unidentified submission, the readability of the privacy notice and the follow-up mechanism. Check whether hidden fields or integrations introduce data that users would not expect. 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

In the mock-up, the department field is mandatory and offers only two teams, each with one worker. Even without a name, the answer may reveal identity. The administrator makes the field optional and explains that users should provide only the context needed to assess the facts. 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 a form without a name field, by itself, guarantee that nobody can identify the reporting person? 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. Context, attachments and other fields may enable indirect identification. Configuration should reduce unnecessary information, and handling must protect those elements too, without promising absolute anonymity in every circumstance.

One mistake to avoid is: requiring personal details that are unnecessary to assess the report.

Now apply the national rule to a second decision. The form always requires a name and identity document, but the page advertises anonymity. How should this be corrected?

First apply the national regime and define what the channel actually offers. Where identity is unnecessary, do not require it for technical convenience. Where it is a condition for a particular status, explain that before submission. Correct the fields and public information together while preserving material already received.

National Legal Framework: Panasztörvény (2023. évi XXV. tv.), transposing Directive (EU) 2019/1937 of the European Parliament and of the Council on the protection of persons who report breaches of Union law.