Module Learning Objective

keep useful interest and gift records without excessive collection

1. Regulatory Concept & Core Standards

This video focuses on how to keep useful interest and gift records without excessive collection. 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. ZIntPK regulates conflicts and gifts for public officials and other specified participants. Public procurement adds requirements. Private organisations must check applicable law and policy; public-sector thresholds do not automatically apply to every employee.

Records support traceability but do not approve prohibited conduct. A late entry must remain visibly late. The public sector has specific gift-record obligations which internal practice cannot remove.

Apply the following rule: Article 7 generally requires register data to be kept for five years after the procedure ends, unless another Act provides otherwise. Personal data and the report’s contents are then destroyed; register metadata and the article 12(5) report may be retained longer under internal rules. This does not permit indefinite retention of the entire case. Clearly unnecessary personal data must not be collected and, if collected accidentally, must be deleted without undue delay.

2. Practical Implementation & Procedure

Define required fields, access and retention. Link decisions to the relevant procedure. Record refusal, return, authorised acceptance or management measures. Verify implementation and patterns of repetition. Maintain appropriate change history. Do not present retrospective records as contemporaneous. 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 gift is recorded late. The employee wants to backdate the entry to its receipt date to make it appear timely. The team preserves both dates and an explanation. 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 backdating acceptable to create apparent timeliness? 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. Keep an accurate record. Address the delay and any impermissibility of the gift separately.

One mistake to avoid is: altering dates or concealing that a record was created late.

Now apply the national rule to a second decision. The system deletes every item two years after receipt. Is this suitable?

No. Two years since the breach ceased concerns protection, not retention. Article 7 generally uses five years after the procedure ends unless another Act provides otherwise. Distinguish destruction of personal data and contents from possible longer retention of permitted metadata and the report.

National Legal Framework: Zakon o zaščiti prijaviteljev (ZZPri), transposing Directive (EU) 2019/1937 of the European Parliament and of the Council on the protection of persons who report breaches of Union law.