CNIL Decision on Whistleblower Hotlines

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 new guidelines implement changes in French law brought about by the Law no. 2016-1691 of December 9, 2016 (the so-called Sapin II Law). Sapin II introduced numerous changes in order to bring about more transparency, to fight corruption and generally to modernize the French economy. Until the mandatory introduction of whistleblower hotlines for companies subject to Sapin II, the CNIL had expressed notable resistance toward such hotlines, bowing begrudgingly to the requirements imposed on U.S. based companies by Sarbanes-Oxley. But Sapin II changed that by mandating the implementation of whistleblower hotlines and the adoption of company codes of conduct. …

CNIL