Module Learning Objective

assess the necessity and conditions of sharing case data

1. Regulatory Concept & Core Standards

This video's topic is controlling access and sharing. By the end, you should be able to assess the necessity and conditions of sharing case data. 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. 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.

Access must follow role and need. Membership of human resources, legal or management does not automatically grant access to all data. External consultants, suppliers and authorities require separate justification. Consider security, confidentiality, contractual responsibilities and any transfers to third countries.

Apply the following rule: Article 4 requires consultation of the indicated trade-union representatives or organisations, written and oral reporting, and an autonomous, specifically trained manager. For public entities required to appoint a corruption-prevention and transparency officer, the internal channel is entrusted to that RPCT. A technology supplier does not automatically replace the legally designated function.

2. Practical Implementation & Procedure

Before sharing, record purpose, recipient and strictly necessary data. Choose a secure method and check permissions. Where a supplier acts as processor, check GDPR article 28 requirements. Assess exports and remote support access. Sharing must remain controlled after a document leaves the platform. 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 consultant reviewing a contract clause requests the whole case. The team supplies the contract and a limited summary without the reporting person's identity, which the task does not require. It records delivery and conditions of use. 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: How should the team decide whether to provide a full case or only part of its information? 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.

By demonstrated purpose and need. Provide only what allows the legitimate task to be performed. If further information is necessary, assess justification and safeguards before sharing.

One mistake to avoid is: assuming that a confidentiality obligation removes the need to limit shared data.

Now apply the national rule to a second decision. The team presents every integrity instrument as mandatory in every country. How should the message be revised?

Distinguish what national law actually requires, the conditions for its application to the entity and the proposed good practices. The specific rule just examined must appear in the corresponding procedure. Each duty needs a source; each management choice needs a purpose, an owner and evidence of implementation.

National Legal Framework: D.Lgs. 24/2023 (Decreto Whistleblowing), transposing Directive (EU) 2019/1937 of the European Parliament and of the Council on the protection of persons who report breaches of Union law.