Free template · Updated May 2026

Case Handler: Job Description

A complete job description for the person designated under Article 9(1)(c) of EU Directive 2019/1937 to receive and follow up on whistleblower reports. Covers purpose, scope, responsibilities, independence requirements, KPIs, training, recusal, and reporting line.

Role title

Whistleblower Case Handler (Hinweisgeber-Fallbearbeiter / Référent alertes / Responsabile segnalazioni / Responsable del canal / Meldingenbeheerder).

Purpose

To operate [Organisation]'s internal whistleblowing channel and conduct the triage, investigation, and follow-up of reports received through it, in compliance with EU Directive 2019/1937 and the national transposition.

Scope

Responsible for all reports received through [Organisation]'s channel covering [list of in-scope entities and jurisdictions]. Acts as the named point of contact identified on the channel landing page and in the whistleblowing policy.

Key responsibilities

1. Receive reports submitted through the channel; issue 7-day acknowledgement under Article 9(1)(b).
2. Triage reports: classification, severity, conflict-of-interest check.
3. Draft and revise the investigation plan; oversee or conduct the investigation per the Investigation Protocol.
4. Conduct or oversee witness and subject interviews per the Interview Protocol.
5. Maintain the audit log with timely and accurate entries.
6. Provide substantive feedback to the reporter within 3 months per Article 9(1)(f); manage extensions where justified.
7. Draft the case closure memorandum; secure closure-panel approval.
8. Cooperate with the DPO, the General Counsel, and external counsel as required.
9. Provide aggregate reporting to the Audit Committee on a quarterly basis using the Board Quarterly Report template.
10. Maintain channel awareness through periodic communications and training to managers.
11. Track and apply changes in national whistleblower law and DPA guidance.

Independence requirements

The Case Handler is impartial and free from conflicts of interest in the matters they handle, as required by Article 9(1)(c). To support this:

• The Case Handler reports directly to the Head of Compliance (or, where the Head of Compliance is the Case Handler, to the Audit Committee Chair) on whistleblowing matters.
• The Case Handler does not hold a concurrent management or HR role in the line of business they investigate.
• The Case Handler may not be the supervisor or subordinate of any person whose conduct they are investigating; the alternate handler is engaged in those cases.
• Variable compensation, where any, is not tied to the case outcome.
• The Case Handler can engage external advisors (counsel, forensic, technical) without prior approval up to a budget threshold of [€amount] per case.

Recusal and escalation

Where the Case Handler has a conflict of interest with a particular case, they recuse from that case and the named Alternate Handler takes over. The recusal is documented in the audit log. Where the conflict is structural (cases implicating the whole compliance function), escalation is to the Audit Committee Chair.

Qualifications

• A degree in law, business, or a related field; or equivalent professional experience.
• 5+ years of experience in compliance, internal audit, HR investigations, or legal practice.
• Working knowledge of GDPR, EU Directive 2019/1937, and the national whistleblower regime.
• Fluency in [primary working language]; working ability in [other in-scope languages].
• Demonstrated capacity to maintain confidentiality under pressure.

Training and continuing development

• Initial training of 16 hours (see Training Curriculum) before independent case handling.
• Annual refresher of 8 hours.
• Topic-specific training where required: trauma-informed interviewing, AI-feature governance, cross-border privilege, sector-specific risk areas.
• Attendance at one external whistleblower-protection conference per year.

KPIs

Reporting line

Reports administratively to the Head of Compliance. Reports functionally to the Audit Committee Chair on whistleblower-handling matters and on cases implicating senior management or Compliance itself. Has a dotted-line relationship with the DPO on data-protection questions and with the General Counsel on legal-strategy questions.

Confidentiality

Bound by an additional confidentiality undertaking specific to this role, surviving the end of employment. Access to case content limited to cases assigned to the Case Handler.

Adopted by [Organisation], date [yyyy-mm-dd]. Reviewed annually.