Whistleblowing can be a valuable tool for businesses, providing an early warning system against corporate malpractice and demonstrating a compliance culture. Hotlines are now established as an important tool in the whistleblowing process. Hotlines typically involve the personal data of both the reporter (e.g. name, location and the fact that he/she made the report) and the “wrongdoer” (e.g. name and allegation). Introducing hotlines therefore requires careful consideration as regulatory compliance steps must be taken prior to implementation to ensure adherence to data protection laws.

Whistleblowing hotlines are often rolled out on a global basis. Whilst EU data protection laws have been harmonised, to some extent, by the EU Data Protection Directive, Member States have interpreted the laws slightly differently and each country’s data protection authority (DPA) takes a different approach to regulation and enforcement. It is therefore important for multinational corporations to understand that a “one size fits all” approach does not work when implementing whistleblowing hotlines in the EU, and they must instead navigate a patchwork of differing legal requirements.