In Switzerland, unlike in the EU, the use of whistle-blowing hotlines is not specifically regulated by the FADP or the CO. Therefore, there is neither an explicit legal reporting duty for employees nor a special legal protection for whistleblowers.

However, from a FADP and CO perspective, whistle-blowing hotlines may be used if certain minimum requirements are met, such as:

• transparent informing (especially of employees and contractors) about the existence of the whistle-blowing hotline;

• informing of relevant employees, contractors, etc., of allegations about them contained in a specific whistle-blowing report, unless there is an overriding interest not to do so in order to protect the ensuing investigations or the reporting person;

• adequate safeguards to protect the data subjects from false or slanderous accusations; and

• strong state-of-the-art security measures.

This being said, it is important to verify compliance on an individual basis before implementing a whistle-blowing hotline.