How can we fulfil the information obligation in relation to reports received, for example, by telephone?

ANSWER

If we have a dedicated hotline for whistleblowers, the information obligation can be fulfilled in a manner commonly used by customer service centres, i.e. by uploading an information clause for playback before the call is connected (this may be implemented in a layered manner, in accordance with the Guidelines on transparency under Regulation 2016/679, p. 21).

Please also bear in mind that under Article 18(2) of the Directive: "If the report is made through a recorded telephone line or other recorded voice communication system, private and public-sector legal entities and competent authorities may, with the consent of the person making the report, document the oral report in one of the following ways:

1. by making a recording of the conversation in a durable and searchable form; or
2. by means of a complete and accurate transcript of the conversation prepared by staff members responsible for handling the report."