Module Learning Objective

arrange proportionate protective action

1. Regulatory Concept & Core Standards

This video focuses on how to arrange proportionate protective action. Follow the sequence of decisions in the example rather than simply memorising a list. Notice who is involved, what information is needed and the expected result. These points help turn the content into a practice that another person can verify. 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.

Protection must not itself worsen someone’s position. Choose measures by risk, functions and circumstances. Do not automatically relocate only the reporting person.

Apply the following rule: The Prosecutor’s Office of the Republic of Lithuania performs the competent-authority functions. Direct reporting follows Article 4 conditions, such as serious danger, possible management involvement, a non-functioning channel or ineffective action. Article 4(5) applies on learning of possible indications of a criminal offence. Public disclosure follows the separate Article 4(10) conditions. A software provider is not the Prosecutor’s Office.

2. Practical Implementation & Procedure

Assess threats, appoint an independent contact, justify measures, limit disclosure and schedule review. Explain possible recourse to prosecutors. 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 manager proposes reducing the reporter’s tasks and pay for protection. This may itself be an adverse effect. 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 proposed measure be assessed? 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 real consequences, not intention alone. Choose proportionate action that reduces risk without penalising reporting.

One mistake to avoid is: penalising reporters in the name of protection.

Now apply the national rule to a second decision. A worker is told that reporting to the Prosecutor’s Office requires the manager’s permission. Is that correct?

The Act does not impose such general employer permission. Check the direct-reporting ground under Article 4 and the official submission method. Possible management involvement, a non-functioning channel and ineffective action are circumstances requiring individual assessment. The advice line explains the procedure, but seeking advice is not itself submitting a report. Public disclosure has separate conditions.

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.