1. Introduction
Following our previous articles published on
July 30 and
September 25, we conclude our brief analysis of the
Whistleblowing Reporting System (hereinafter
"Whistleblowing") focusing our attention on the
prescription under the privacy law linked to the related reporting
system. For a better understanding of this matter, it should be
noted that by Whistleblowing we intend an employee's reporting
of illicit deeds committed inside of the company where they are
employed.
It should be noted that the Italian Data Protection
Authority's most recent six-month inspection plan, published on 12 September
2019, indicates the verifications to be carried out by the Italian
Authority in the same period, specifically citing the processing of
personal data carried out for the management of the reporting of
unlawful conduct (so-called whistleblowing). The following
indications, therefore, may be useful in view of possible
Inspections by the Italian Data Protection