Internal whistleblowing system for 50+ employees: what should the technical solution actually do?
A whistleblowing channel is not just a form or shared mailbox. The Hungarian rules create process, confidentiality and data-handling requirements that need proper case management. The technical platform should support those obligations; legal interpretation should still be confirmed with qualified counsel.
1. Turn the legal obligation into process requirements
The Hungarian Act XXV of 2023 generally requires an internal whistleblowing system for employers with at least 50 workers, with some sector-specific obligations applying regardless of headcount.
- 50+ employee threshold as a general rule
- sector-specific exceptions
- shared systems possible for some 50–249 employee employers
- confirm legal scope with counsel
2. Track acknowledgement and investigation deadlines
Written reports require acknowledgement within seven days and investigation is generally expected within thirty days, with limited extension. The system should own the due dates rather than relying on inbox discipline.
- acknowledgement control
- investigation deadline
- extension reason
- SLA escalation
3. Confidentiality must shape the architecture
Reporter and case-subject information must be restricted to those who genuinely need it. Separate intake, investigation workspace and management reporting.
- case-level access
- limited investigator role
- sensitive-field separation
- auditable access
4. External and anonymous reporting may need a different front end
Power Apps can work well for internal identified users, while Power Pages, a custom portal or a specialist platform may be better for external or anonymous reporting.
- internal Power Apps
- external portal
- anonymous communication design
- choose technology after the threat model
5. Treat investigations as case management
Each case should have a status, investigator, due dates, evidence, actions and closure record. Notifications should not become the database.
- case ID
- investigation log
- evidence
- closure history