Module Learning Objective

detect disclosure before launch

1. Regulatory Concept & Core Standards

In this video we will consolidate a skill: detect disclosure before launch. Use the case to test what you would do in a similar situation. We will explain the proposed response step by step so that you can understand each choice and recognise when more information would be needed. A functioning channel combines people, procedure and technology. The exercises examine practical access, impartiality and timely follow-up. Demonstrations use fictional data and do not establish the configuration of a real UNOVOX account.

Confidentiality also concerns surrounding notifications. A name may appear in an email subject or screen notification even when the platform itself restricts access.

Apply the following rule: Internally, acknowledge receipt within 7 days of receipt. Provide feedback within a reasonable period not exceeding 3 months from acknowledgement or, if none is sent, 3 months after expiry of the 7-day period following the report. Externally, acknowledgement is within 7 days unless the reporting person requests otherwise or identity protection would be jeopardised; feedback is within 3 months or 6 months in duly justified cases. Acknowledgement is neither feedback nor final resolution.

2. Practical Implementation & Procedure

Use a fictional report. Test unauthorised access, notifications and deadlines. Correct findings and repeat the test. 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.

Consider how a colleague taking over tomorrow would understand the decision. Identify the verified information and its source, who is authorised to decide and who checks the result. The record should connect the decision to the material actually used rather than repeat the whole file. State critical gaps and assign a specific action to resolve them. This makes continuity independent of one person’s memory. Apply the proposed organisational steps within legal powers. In the case, distinguish observation, conclusion and hypothesis. An observation describes available evidence, a conclusion explains what can reasonably be inferred and a hypothesis still needs checking. Do not infer motives merely from unusual behaviour. Identify which further information could change the decision and whether it can be obtained lawfully and proportionately. Incomplete knowledge justifies neither certainty of guilt nor indifference to an actual risk.

3. Case Study & Compliance Action

A test message displays the reporting person’s name on a reception screen. It is replaced with a neutral notification. 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: Is a promise of a later fix enough? 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.

Launch must rest on verified suitable operation. A campaign date does not remove confidentiality requirements.

One mistake to avoid is: launching with a known identity disclosure.

Now apply the national rule to a second decision. The platform counts ninety days in every country from first opening the message. Is this configuration correct?

Not without checking the national rule. Use the correct starting event and time unit. Distinguish acknowledgement from feedback. Allow only permitted extensions. Test arrival outside working hours, month-end and the handler’s absence. Opening does not automatically change the lawful receipt date.

National Legal Framework: Protection of the Whistleblower Act (Cap. 527), transposing Directive (EU) 2019/1937 of the European Parliament and of the Council on the protection of persons who report breaches of Union law.