Module Learning Objective

define independent and proportionate follow-up for the Horizonte case

1. Regulatory Concept & Core Standards

Today we will learn to define independent and proportionate follow-up for the Horizonte case. 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. The organisation, people and events are entirely fictional. Horizonte Equipamentos employs 120 workers and operates an internal channel. Five episodes follow a procurement report and turn its findings into preventive improvements.

Normal routing sends procurement matters to the director mentioned in this report. Automatic allocation would create a conflict and unnecessary exposure. The company has an independent alternative. A planned system migration next week may also affect version records needed for assessment.

Apply the following rule: The Act accommodates anonymous reports; the section 11 register does not require an anonymous person’s name and residence. Someone later identified may meet protection conditions. Section 10(7) protects the identity of both the reporting person and the person concerned. Written consent and lawful provision for criminal or administrative-offence proceedings have specific conditions. Do not promise absolute unidentifiability.

2. Practical Implementation & Procedure

The team blocks director allocation, appoints an independent handler and records why. It requests authorised preservation of relevant procurement records. It assesses urgency and any external reporting obligations. Initial plans and questions must not ask the reporting person to seek information they cannot lawfully access. 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 independent handler asks when the change appeared. The author saw the second version two days before the decision but does not know who created it. The team records that limit and examines system logs instead of demanding a name. 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: Should the procurement director receive the whole case merely because they normally lead the department? 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 director is mentioned and a conflict must be addressed. Use the defined independent route with appropriate access. Departmental review must not undermine impartiality or unnecessarily expose the reporting person's identity.

One mistake to avoid is: retaining automatic routing when its recipient is a person concerned by the report.

Now apply the national rule to a second decision. The form requires a name and identity document although it promises anonymity. What must change?

Align the functions and user information. Do not require unnecessary identification. Check attachments and indirect identifiers too. Explain anonymity and confidentiality, restrict access, and assess existing data by legal basis and necessity. Do not promise absolute anonymity.

National Legal Framework: Zákon č. 54/2019 Z. z., transposing Directive (EU) 2019/1937 of the European Parliament and of the Council on the protection of persons who report breaches of Union law.