Module Learning Objective

limit unnecessary identity disclosure

1. Regulatory Concept & Core Standards

Today we will learn to limit unnecessary identity disclosure. Throughout the video, consider the difference between knowing a rule and applying it to a decision. We will work through an example, identify a possible failure and develop a response that can be used at work. Protection concerns both data use and real workplace consequences. Anonymity differs from confidentiality and formal status from the start of safeguards. Consider indirect identification, threats and attempted adverse effects.

Article 9 governs recipients and disclosure conditions. Removing a name is insufficient if filenames or context reveal identity.

Apply the following rule: The Prosecutor’s Office must identify the person to grant formal whistleblower status. However, Article 3(6) provides protection, incentive and assistance measures where an initially anonymous reporter is identified and protection from adverse effects is necessary. Confidentiality covers indirect identification too. Article 9 limits disclosure and provides prior-information requirements and exceptions. Anonymity is not an absolute promise that nobody can identify a person.

2. Practical Implementation & Procedure

Check recipients, headings, attachments and exports. Justify disclosure by function and follow statutory notification and exceptions. 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.

At each step, compare the information available with what is still needed for the decision. Arrange continuity when the designated worker is absent. A substitute receives only the information needed for the task, and their actions must remain verifiable.

Mark an unanswered question as a fact to verify. Identify who could confirm it and what access they actually need. A correct exercise choice alone does not show that the reasoning is understood. If the answer depends on an additional fact, state that condition explicitly.

For the workplace task, name the person who can approve the change and the person who will check that it works. Produce a concrete verifiable action, rather than only a promise to follow rules. Check effects on access rights and user information. Record questions that your organisation still needs to resolve.

3. Case Study & Compliance Action

A management summary omits names but includes a unique workplace and exact time. Identification remains easy. 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 anonymisation end with name removal? 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. Assess context and audience, reduce detail to what is needed and test whether the summary identifies anyone.

One mistake to avoid is: treating name removal as complete anonymisation.

Now apply the national rule to a second decision. An initially anonymous reporter is later identified and faces pressure. Is protection impossible?

That conclusion is unjustified. Article 3(6) provides measures after an initially anonymous reporter is identified where protection against adverse effects is necessary. The Prosecutor’s Office decides formal status and needs identity for that purpose. The organisation should restrict recipients and assess pressure rather than reject the case automatically because it was initially anonymous.

National Legal Framework: Pranešėjų apsaugos įstatymas (XIII-804), transposing Directive (EU) 2019/1937 of the European Parliament and of the Council on the protection of persons who report breaches of Union law.