an employee has lost his case code and can no longer log in to his report

Losing your case code does not mean the report is unreachable

If someone no longer has the case code for a report, they cannot log back in themselves to check the status or provide further information — the code is the only key to that specific file, and it is intentionally not recoverable using a name or email address, because doing so would compromise the reporter's anonymity. For an organization using signalo.eu, this does not mean the report itself is lost: the handler still has access to the file in the handling environment and can track progress there, even if the reporter can no longer enter the case code.

The practical difficulty lies mainly with the reporter who has remained anonymous: without the code, there is no way for the handler to establish contact, because no identity or contact details are known. A reporter who has disclosed their identity can usually return through another channel and request new access. This directly touches on the question who may know who made the report, because every solution for a lost case code must be designed in such a way that this protection is not compromised after all. The fact that the statutory deadlines continue to run in the meantime does not change: the organization remains bound by the moments when a reporter must be informed about the assessment, even when the reporter themselves temporarily has no access to the status.

Where this derives from: the internal procedure and protection of the reporter

Article 2 of the Whistleblower Protection Act requires that the internal reporting procedure provides a way for a reporter to follow what happens with their report and to remain reachable to the organization without compromising the confidentiality of their identity. Article 9 of Directive (EU) 2019/1937 builds on this with the requirement that a reporter be appropriately kept informed of progress after the report is received, which implies that an organization must have a workable route in case the usual means of contact — here the case code — is lost. The House for Whistleblowers points out to employers that setting up the procedure is the organization's own responsibility, provided that the statutory safeguards regarding confidentiality and deadlines remain in place.