The French data protection watchdog has issued guidelines designed to help companies comply with the Sarbanes-Oxley Act, with Faegre & Benson assisting with the project.
The Commission Nationale de l’Informatique et des Libertés (CNIL) issued the advice in December 2005 after extensive consultation.
The guidelines formalise French companies’ whistleblowing obligations under data protection law, and also institute a single authorisation procedure for online whistleblowing.
Faegre partner Robert Bond was asked by the CNIL to respond to the draft guidelines and suggest improvements. Hunton & Williams’ Brussels office produced a response for the International Chamber of Commerce.
The finalised guidelines allow companies to set up whistleblowing action plans and have them approved by the CNIL by return of post following a declaration that the plans comply with the guidelines.
Previously, full dossiers had to be submitted for approval, necessitating a lengthy wait.