Module Learning Objective

decide PPR changes from incidents and implementation tests

1. Regulatory Concept & Core Standards

In this video we will consolidate a skill: decide PPR changes from incidents and implementation tests. 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. After approving the PPR, the entity needs to establish whether measures were applied and achieved their intended effect. This course moves from planning to implementation records, reports and review. Adapt example indicators to the entity.

Review the PPR every three years or when changes in functions or organisational or corporate structure justify review under the law. Monitoring may identify earlier adjustments to risks or measures. Explain what changed and why. Do not turn reports into publicly identifiable annexes.

National rule: The RGPC provides for review of the PPR every three years or when changes in the entity’s responsibilities or organisational or corporate structure justify reviewing the relevant elements. Monitoring results should inform the necessary adjustments.

2. Practical Implementation & Procedure

Gather control failures, activity changes, audits and aggregated incident information. Assess matrix implications and consult departments. Update owners, measures and priorities. Record versions, required approval and dissemination. Preserve history to explain the plan's evolution rather than rewriting past assessments as though unchanged. 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

The entity begins awarding financial support, which was absent from its PPR. New decisions create new risks. The team adds the process, assesses exposure and defines controls instead of waiting three years to include the relevant activity. 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 the three-year review cycle prevent earlier changes when activity changes? 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. The law provides for review when justified by changes, and management must respond to identified needs. The plan must reflect the actual organisation through reasoned, controlled updates.

One mistake to avoid is: keeping an outdated PPR until the scheduled review date.

Which document, responsible person and evidence from your entity demonstrate application of this rule?

Confirm the scope and applicable source. Record the decision, who can approve it and the evidence required. Application in this lesson should support the following objective: decide PPR changes from incidents and implementation tests Distinguish the legal duty from the organisational method chosen by the entity.

National Legal Framework: Lei n.º 93/2021 & RGPC (DL 109-E/2021), transposing Directive (EU) 2019/1937 of the European Parliament and of the Council on the protection of persons who report breaches of Union law.