I den danske whistleblowerlov findes der et krav om, at man dokumenterer, hvordan man har opfyldt reglerne. En del af dokumentationen kan man indarbejde i sin whistleblowerpolitik, men kravet om den juridiske dokumentation går videre end det.
Det er ikke nok at overholde regler - det skal også dokumenteres
Whistleblowerloven er indrettet lidt anderledes end megen anden lovgivning. Hvis man bliver kontrolleret af en myndighed, så skal man kunne fremvise juridisk dokumentation for, hvordan man har opfyldt reglerne. Det betyder, at det ikke er nok at opfylde reglerne, for man skal også kunne redegøre for hvordan. Straffen for at mangle juridisk dokumentation er en bøde.
Hvordan hænger den juridiske dokumentation sammen med whistleblowerpolitikken?
Hverken whistleblowerloven eller whistleblowerdirektivet er ordet ‘whistleblowerpolitik’ nævnt, og det er lidt uklart, hvad det er for en størrelse. Den juridiske dokumentation går imidlertid videre end hvad man typisk ville inkludere i en whistleblowerpolitik. Den har blandt andet til formål at lette en eventuel efterforskning af anmeldelser om manglende overholdelse af pligten til at etablere en intern whistleblowerordning.
En whistleblowerpolitik retter sig ofte mod medarbejderne og forklarer, hvordan man bruger whistleblowerordningen, og hvordan man er beskyttet som medarbejder i henhold til reglerne i whistleblowerloven. Den vil normalt ikke konkret beskrive de sagsbehandlingsprocedurer, som er indført, såsom hvor og hvordan indberetninger registreres, hvor dokumenter gemmes i virksomhedens IT-system, hvordan de krypteres, og hvordan man giver adgang til de medarbejdere, der har brug for at se dem, osv. Disse procedurer skal imidlertid skriftligt dokumenteres og skal indgå i den juridiske dokumentation.
Man kan ikke bruge en standardtekst
Når man er kunde hos Whistle Tools, følger denne dokumentation med. Det er vigtigt at være opmærksom på, at dokumentationen skal beskrive, hvordan man på den enkelte arbejdsplads har opfyldt reglerne. Man kan derfor ikke nøjes med at finde en standardtekst på nettet. Der skal nemlig beskrives en lang række konkrete forhold på den enkelte arbejdsplads.
Man kan måske sammenligne det med, at man heller ikke kan finde en standardtekst til et testamente på nettet og bare bruge den. Grundlæggende set har man i et testamente brug for at beskrive, hvem der skal arve hvad, og det fremgår jo ikke af en standardtekst. Dette kræver typisk en advokat til at hjælpe med. På samme måde bør man også bruge en rådgiver til at udarbejde den juridiske dokumentation i henhold til whistleblowerloven. Kontakt gerne os for at høre nærmere.
Når det nu kan kaldes ‘en fælde’, så er det fordi de færreste arbejdsgivere nok ikke er opmærksomme på denne dokumentationspligt og meget let kan ende i den situation, at selvom man har en whistleblowerpolitik, så er den ikke udarbejdet, så den kan fungere som dokumentation for, hvordan man har opfyldt reglerne.
Den danske whistleblowerlov er på dette punkt gået længere, end hvad der kræves af direktivet. Her findes der ikke nogen bestemmelse, som direkte pålægger, at man skal udarbejde en juridisk dokumentation.
Vi har udarbejdet en juridisk dokumentation for vores ordning
Som en del af abonnementet på vores whistleblowerordning, har vi udarbejdet en lang række af dokumenter, som ligger i vores bibliotek. Her kan du også finde en skabelon til den juridiske dokumentation, som vi har specielt udarbejdet for vores ordning.
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