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20 Apr 2018

NBlog April 20 - whistleblower policy (UPDATED)

For more than two decades now, I have been fascinated by whistleblowers - people who blow the whistle on various forms of impropriety. 

In my experience, they are high-integrity, ethically-motivated and aggrieved individuals willing to take a stand rather than put up with Things That Should Not Be Going On. They are powerful change agents. To my mind, they are brave heroes taking significant risks to their careers, personal lives, liberty and safety (nods hat to Ed Snowden among others).

I've blogged about it several times, most recently at the start of this month when I said:

Organizations clearly need strategies, policies and procedures for receiving and dealing with incident notifications and warnings of all sorts. 
And that set me thinking: do we actually offer anything along those lines - any awareness and training materials supporting such activities?

We don't currently have a whistleblower policy as such in our suite of information security policy templates, although the term is mentioned in a few of them, generally in reference to a "Whistleblowers' Hotline". We envisage a corporate service being run by a trustworthy, competent and independent person or group such as Internal Audit, or a suitable external service provider.

Whistleblowing has certainly come up in the context of oversight, compliance, governance, fraud etc., so we ought to check through the back catalog to see what we have to hand in the way of guidance/awareness content. I'm thinking the incident management procedures might be adapted to suit, but what else is there? I'll be exploring this further, figuring out the common approaches and concerns and perhaps drafting a whistleblower policy.

This is partially relevant to May's materials on GDPR in that compliant organizations are expected to receive and address privacy-related requests and complaints in a professional manner, a process that arguably ought be in effect today but patently (in my unhappy experience with a certain French hotel chain, for example) it ain't necessarily so. The controversial right to be forgotten, for instance, requires organizations to expunge personal information on request from a data subject, a situation that strongly suggests a serious breakdown of trust between the parties, perhaps as a result of an undisclosed incident. There may be no formal obligation for individuals to explain why they want their personal information erased, but asking the question at least would seem like a sensible thing for the organization to do. It might suggest the need for further investigation, even if the person's reasons are withheld or obscure. 

Obvious when you think about it. I wonder how many are?

Update (June 1st) - a whistleblowing policy template is included in this month's 'Incidents and disasters' security awareness module.

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