Module Learning Objective

map the data and people involved in a reporting case

1. Regulatory Concept & Core Standards

In this video we will work through a concrete decision: map the data and people involved in a reporting case. 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. A reporting case may contain data about the reporting person, people concerned and third parties. Data protection must accompany the whole lifecycle, from the form to archiving. This course addresses operational decisions. Legal bases and restrictions on rights require assessment of the specific processing. The Hungarian section 26 requirements apply alongside GDPR. The Commissioner’s five-year rule is not a universal internal-channel period.

Personal data include indirect identifiers, roles and events. In addition to an Article 6 GDPR basis, special-category data require an Article 9 condition and criminal-offence data require Article 10 authority and safeguards. Receipt through the channel does not establish unrestricted processing permission.

Apply the following rule: Section 20 accepts unlawful or suspected unlawful acts, omissions and other abuses. Eligibility to report differs from entitlement to every safeguard. Section 45 requires the statutory route, information obtained in a work-related context and reasonable grounds to believe it true when reported. Apart from section 43 assistance, subchapter 8 protection also requires the section 48 EU subject matter, specified EU restrictive-measures infringements added in 2025, or reasonable grounds to believe the matter falls within that scope. Apply the section 48(2) exclusions.

2. Practical Implementation & Procedure

Map data subjects, categories, origin, purposes, recipients and storage locations. Identify who determines purposes and means and the supplier's role. Assess the proper legal basis. Consent is not an automatic solution for a legally required channel. Consent to record a communication serves a specific purpose and does not replace assessment of all processing. 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 procurement report includes messages containing a colleague's sick-leave information. Relevant approval data sit alongside health data that may be unrelated. Mapping separates purposes and identifies information needing stronger protection or deletion because it is irrelevant. 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 removing a name automatically make all remaining data anonymous? 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. Roles, events and combinations of details may enable identification. Pseudonymisation reduces exposure, but data remain personal if additional information can link them to a person.

One mistake to avoid is: using a consent checkbox to justify every type of channel processing indiscriminately.

Now apply the national rule to a second decision. A report is automatically classified as protected because it contains the word corruption. What check is missing?

Read the facts and apply the national scope, context and conditions for protection. A form label helps organise information but does not determine the legal framework. If the case falls outside the regime, identify an appropriate route without unnecessarily disclosing information.

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.