Follow-up contact
Follow-up contact describes the communication channel through which the reporting office can put questions to the whistleblower during case handling and obtain further information, without disclosing the whistleblower's identity.
Follow-up contact with the whistleblower is a central element of case handling under the German Whistleblower Protection Act (HinSchG). It refers to the ongoing communication channel through which the person responsible for the reporting office can raise queries with the whistleblower, fill in missing details and clarify the facts of the matter. The legislator explicitly requires reporting offices to maintain contact, because many reports only become verifiable and actionable through targeted follow-up questions. A functioning follow-up channel is therefore a prerequisite for the effective handling of reports, whether through an internal or an external reporting office.
Crucially, follow-up contact must preserve confidentiality and, where applicable, the anonymity of the whistleblower. For anonymous reports, the communication channel must be designed so that a dialogue remains possible without allowing any conclusions to be drawn about the person's identity; in practice this is achieved through secure mailboxes in digital whistleblowing systems with an anonymous reply function. For open reports, follow-up takes place confidentially via the reporting channel chosen by the whistleblower, that is, in writing, orally or during an in-person meeting. The reporting office may use the data collected for follow-up purposes solely for handling the case.
Follow-up contact is closely tied to the statutory deadlines. Receipt of the report must be acknowledged within seven days, and feedback on planned or implemented follow-up measures must be provided no later than three months afterwards. The follow-up conducted during this period serves to assess the substance of the report as part of the plausibility check and, where appropriate, to prepare an internal investigation. Every contact is subject to the documentation obligation: the content and timing of follow-up contact must be recorded in a traceable manner and retained in line with the storage periods, so that the proper conduct of the procedure can be demonstrated.
Legal Basis
Sections 17, 18 HinSchG (handling of reports, contact with the reporting person); Section 13(1) HinSchG; Art. 9, Art. 11 EU Whistleblower Directive (EU) 2019/1937
Practical Example
At the internal reporting office of a mid-sized company, an anonymous report about possible manipulation of expense claims arrives through the digital whistleblowing system. The responsible person acknowledges receipt within seven days and then uses the system's anonymous reply function to ask specifically which department and which accounting period are affected. The whistleblower responds via the same secure mailbox without revealing their identity. On the basis of this follow-up contact, the reporting office can narrow down the facts, launch an internal investigation and provide well-founded feedback on the measures taken within the three-month deadline. All contacts are documented in an audit-proof manner.