Module Learning Objective

apply data minimisation when receiving and handling reports

1. Regulatory Concept & Core Standards

Today we will learn to apply data minimisation when receiving and handling reports. 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. GDPR, ZVOP-2 and ZZPri operate together. Processing needs purpose, legal basis, proportionate scope and security. A platform does not remove organisational responsibility for data, contracts or actual access rights.

ZZPri prohibits collection of clearly unnecessary data and requires deletion without undue delay where collected accidentally. GDPR requires transparency; information and rights are reconciled with lawful limits and confidentiality rather than automatic secrecy for everything.

Apply the following rule: ZZPri provides for handling anonymous reports; acknowledgements and feedback depend on a specified reply route. A subsequently identified anonymous reporting person can receive protection under statutory conditions. Article 6 confidentiality also covers indirect identifiers. Disclosure without explicit consent has narrow statutory exceptions involving the prosecutor or court and protective conditions. Employers must not seek to establish the reporting person’s identity.

2. Practical Implementation & Procedure

Review form fields and the need for attachments. At intake, identify clearly unrelated information, decide what to do and record the decision without reproducing deleted data. Obtain competent assessment if relevance or retention is uncertain. Do not use reporting to create parallel worker information databases without a legitimate purpose. 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

An attachment contains unrelated customer data. The team limits material relevant to the case rather than distributing the entire list to investigators. 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 marking an unrelated attachment confidential 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.

No. Confidentiality does not replace minimisation. Assess deletion or limitation under ZZPri and record the decision.

One mistake to avoid is: confusing case integrity with indiscriminate retention of everything received.

Now apply the national rule to a second decision. A form requires a name and identity document while promising anonymity. What should change?

Align functionality and user information. Do not demand unnecessary identifiers. Check attachments and indirect identification. Explain anonymity versus confidentiality and provide secure follow-up. Do not promise absolute non-identifiability.

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.