Επεξεργασία δεδομένων στο πλαίσιο μηχανισμού whistleblowing
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Keywords
Whistleblowing ; Νόμος 4990/2022 ; Μάρτυρας δημοσίου συμφέροντος ; Πληροφοριοδότης ; Αναφορά ; Υπεύθυνος Παραλαβής και Παρακολούθησης Αναφορών ; Εθνική Αρχή Διαφάνειας ; Οδηγία 2019/1937Abstract
The present study starts from the assumption that many scandals that have shaken public opinion would have remained in the dark if there were no individuals to disclose information and evidence about these specific violations. However, these individuals, due to their vulnerable position, have always been afraid to speak out, as they risked retaliation.
In this context, the study first attempts to identify the characteristics of these specific individuals, in order to shape the appropriate legal framework for their protection. Subsequently, the study focuses on the inadequate legislative framework that existed at the international and European level until the adoption of Directive 2019/1937, which marked a turning point for the protection of whistleblowers in the European area. After that, the interest shifts to the Greek legal jurisdiction and particularly to the effort of the national legislator to transpose the text of the Directive into national law.
The present study then proceeds to a critical analysis of the new obligations arising from Law 4990/2022 for whistleblowing, due to the relative incorporation of the Directive, in an attempt to highlight the relevant compliance challenges raised for the obligated organizations during its implementation. Among other things, it seeks to analyze the above legislative reforms for whistleblowing in the light of the personal data protection legislation, especially under the provisions of the General Data Protection Regulation (EU) 2016/679.