On 6 July 2023, the French data protection authority (the "CNIL") updated its guidelines on whistleblowing systems again. The last version dated from December 2019. This update is the result of the French transposition of...more
French Decree No. 2022-1284 of October 3, 2022, which implements French Law No. 2022-401 of March 21, 2022, on whistleblower protections (also known as the "Waserman Law"), came into effect on October 4, 2022 (the "New...more
The French Data Protection Authority (CNIL) published new Guidelines (French only) on December 10, 2019 applicable to whistleblowing schemes, following a public consultation process. The Guidelines replace the former Single...more
France's data protection authority, the CNIL – the Commission Nationale de l’Informatique et des Libertés -- recently published a decision (n° 2017-191) setting out new guidelines with respect to whistleblower hotlines. The...more
On December 10th, France’s National Assembly published a new law on transparency and anti-corruption. As a result France is expected to begin instituting newer and stronger protections for whistleblowers under the updated...more
A landmark decision of the European Court of Justice (ECJ) has held that companies may no longer rely on “Safe Harbour” to justify transferring personal data from the European Union to the US, because the US Government has a...more
Earlier this year, the French data protection regulatory authority (“Commission Nationale de L'informatique” or “CNIL”) significantly broadened the scope of the matters it allows whistleblowers to report through a hotline...more
In France, before implementing a whistleblowing process, a company must inform and consult with its employees’ representatives, inform its employees and notify the French Data Protection Agency (CNIL). There are two...more
United States employers operating in France often face a dilemma. While they may be bound by the whistleblowing requirements of the Sarbanes-Oxley Act ("SOX") and its Dodd-Frank amendments,1 they also are bound by the data...more
On February 11, 2014, the French data protection authority (CNIL) published Deliberation #2014-042 and expanded the list of issues that a whistleblowing program may permissibly receive and process under French privacy laws. ...more