- Only key employees or top management may be reported in the scheme.
- It is objectively justified to … Continue Reading ››
As of 1 November 2010 the Swedish Data Inspection Board (“Board”) has issued a regulation for whistleblowing. The new regulation takes away some of the formalities for companies which are about to launch whistleblowing schemes in Sweden. The Swedish Data Protection Act (“Act”) prohibits other parties than public authorities to process personal data concerning legal offences. Since whistleblowing schemes may involve the processing of such personal data, companies wanting to implement whistleblowing schemes in Sweden have, in the past, been obliged to procure a formal exemption from the Board. With the new regulation this is no longer necessary (as long as the company complies with the regulation). Basically, the regulation codifies the Board’s view as it has been expressed in its past decisions. In essence this means that a whistleblowing scheme may be implemented provided that: