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Whistleblowing Portals

FaceUp

EU-Made Report an error

Panel rating · 6 judges · How to read the stars

Category median

Sovereignty: 2 of 4 dimensions proven

0–5 in half steps. 5 means the rubric's top anchor is met on the evidence.

by FaceUp Technology s.r.o. · www.faceup.com

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Read this page as one judge. Each weighs the same scores by what they care about.

The Skeptic

Weighted verdict

Assumes "audit-proof" and "100% anonymous" are marketing until the evidence says otherwise. Hunts certification claims without certificates, anonymity claims next to analytics scripts, per-report pricing traps and legal-update promises with no named lawyer. Exists to keep the rest of the bench honest.

Same scores as the panel view — this lens weights them the way this judge cares.

Scored by The Skeptic

Reporting channels & reporter experience

How this is scored

The intake side: how a reporter actually submits — web form, anonymous dialog, phone/voice, languages, accessibility — and whether anonymity survives first contact.

0 — A web form that is an email in disguise: no anonymous route, no way to reach the reporter afterwards.

3 — An anonymous form exists but the dialogue ends there — no secured mailbox for follow-up questions, few languages, desktop-only.

5 — Anonymous two-way dialog via a protected mailbox, a usable set of languages, mobile-friendly; voice or phone intake missing or an add-on.

8 — Multiple channels (web, voice message or hotline, QR entry points), broad language coverage with translation support, accessibility considered, and the anonymous dialog is first-class rather than bolted on.

10 — Intake engineered around the frightened reporter: every channel anonymous-capable, dozens of languages, WCAG-conscious, no app install or account required, and the vendor documents how the reporter's identity is kept out of the channel itself.

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The Skeptic

Web, mobile and hotline channels with two-way anonymous follow-up and 113 languages is genuinely strong intake, and the vendor does document how identity is kept out of the channel (IP not stored, metadata removed, voice messages anonymized). But not one word on accessibility/WCAG or QR entry points, so I can't go past the 8 anchor — 'no app install required' is also unverified when a mobile app is the marketed channel. 1 2 3 4

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Case management & deadline discipline

How this is scored

The case worker's side: triage, statutory deadlines (7-day acknowledgment, 3-month feedback), role separation, audit-proof documentation.

0 — Reports land in an inbox; deadlines, roles and history live in a spreadsheet next door.

3 — A case list with status fields, but deadlines are manual, permissions are all-or-nothing, and the record of who did what is thin.

5 — Deadline tracking with reminders for the statutory clocks, case notes and attachments, basic role separation between case handlers; reporting on the caseload is limited.

8 — Automated statutory clocks, conflict-of-interest handling (excluding implicated case handlers), complete tamper-evident case history, retention and deletion rules applied per case, and management reporting.

10 — A case system an external investigator can rely on: enforced workflows, full audit trail, legally aware retention/deletion automation, evidence handling, and statistics that survive a regulator's questions.

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The Skeptic

'Case management with audit trail' and 'advanced reporting and analytics' are feature-blob words — the evidence contains nothing on statutory clocks, conflict-of-interest exclusion, or per-case retention, and the only retention rule found is a 30-day delete on hotline recordings. For a whistleblowing product, total silence on the 7-day/3-month deadlines is information, not an oversight. 2 4

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Legal compliance alignment

How this is scored

How specifically the product implements EU Directive 2019/1937 and national transpositions (HinSchG et al.) — not whether the marketing mentions them.

0 — Generic feedback software wearing a whistleblowing label; no reference to the legal obligations it claims to satisfy.

3 — The directive is invoked in marketing but the mapping is vague; deadline rules, documentation duties and retention periods are the customer's problem.

5 — The statutory duties are implemented as product features — acknowledgment and feedback clocks, documentation, deletion after the retention period — for at least one national law, with guidance for the rest.

8 — Multiple national transpositions supported with their differing details, legal templates and process guidance maintained by named counsel or documented review, and updates when the law moves.

10 — The product is a legal instrument: per-country rule sets kept current, documented legal review, guidance for edge cases (group-wide channels, external ombudsman setups), and the vendor shows its homework in public.

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The Skeptic

The only laws FaceUp names in the entire sheet are GDPR, CCPA and CPRA — the privacy policy is visibly written for California, while EU Directive 2019/1937 and any national transposition appear nowhere in the captured facts. No deadline features, no legal templates, no named counsel; this is a compliance-adjacent anonymous form service, not an implementation of the whistleblowing law. 4 2

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Security & anonymity assurance

How this is scored

Whether the confidentiality promise is engineered and evidenced: encryption, metadata handling, penetration tests, certifications.

0 — Security is a paragraph of adjectives; no certificates, no test reports, no statement on metadata.

3 — TLS and encryption at rest asserted, but nothing audited: no ISO 27001 or equivalent, no published pentest, silence on IP and metadata logging.

5 — A current ISO 27001 (or equivalent) certificate for vendor or hosting, end-to-end encryption of report content claimed with some technical detail, an explicit no-IP-logging statement.

8 — Certified ISMS covering the product, regular third-party penetration tests attested, documented end-to-end encryption architecture, metadata minimization explained, security contact and disclosure policy published.

10 — Assurance a hostile auditor accepts: current certificates with visible scope, recurring pentest summaries public, cryptographic architecture documented, anonymity analysed against the operator itself — the vendor can answer "how would you unmask a reporter?" with "we cannot, and here is why".

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The Skeptic

ISO 27001:2022, SOC 2, 'regular penetration testing', E2EE and an explicit no-IP-logging statement are all claimed — that clears the 5 anchor, but 'SOC 2 certified' with no type or report, no certificate scope, no public pentest summaries, and no security contact or disclosure policy keeps it from 8. The 'choice between standard and symmetrical encryption' reads like E2EE is optional, which nobody explains. 3 4

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Group & multi-entity capability

How this is scored

Whether one contract can serve a corporate group: separate channels per legal entity, central oversight, ombudsman access, white-labeling.

0 — One company, one channel; a group buys and administers N separate instances.

3 — Multiple channels under one account, but no separation of case access per entity and no consolidated view.

5 — Per-entity channels with separated case handlers and a group-level overview; branding per entity is basic; external counsel access possible.

8 — Real multi-tenant group structure: per-entity channels, languages and branding, delegated administration, external ombudsman roles, group reporting that respects entity boundaries.

10 — Group compliance as architecture: hundreds of entities manageable centrally, per-country legal rule assignment per entity, white-label reporting pages, and access separation strong enough to satisfy each subsidiary's works council.

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The Skeptic

The entire multi-entity evidence is one Enterprise bullet — 'Support for multi-entity and multi-country setups' — with zero detail on separated case access per entity, group-level oversight, delegated administration or ombudsman roles. A marketing line locked to the top tier is a claim, not architecture. 2

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European sovereignty

How this is scored

Where reports about people actually live and under whose law — entity, hosting, subprocessors, DPA. In this category the data is by definition the most sensitive a company holds.

0 — Non-EU entity, non-EU-default hosting, no public DPA or subprocessor list — for whistleblowing data.

3 — A DPA exists and an EU region is available on request or on top tiers; subprocessor exposure to US CLOUD Act reach is broad or undocumented.

5 — EU hosting is the default, DPA and subprocessor list published; the vendor or a critical subprocessor is still within non-European jurisdictional reach.

8 — EU entity, EU hosting with named data centers, published subprocessor list free of content-touching non-EU processors, DPA and TOMs public.

10 — Jurisdictionally clean end to end: European ownership, EU-only hosting and subprocessors for report content and metadata, on-premises or sovereign-cloud options, and the whole chain documented publicly.

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The Skeptic

3 4

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Pricing transparency not rated — the vendor publishes no price

How this is scored

Whether an obligated company can compute the real invoice — per entity, per employee band, per year — from public pages alone.

0 — No public prices at all; every tier is a sales conversation.

3 — An entry price exists, but the tiers most obligated companies need are unpriced, or the maths is obscured by employee bands, per-report fees or mandatory setup charges.

5 — Most tiers carry real numbers with billing period and VAT treatment stated, but at least one commonly needed capability — extra entities, extra languages, phone intake — hides in an unpriced add-on.

8 — Every tier priced publicly with employee-band boundaries, entity rules and setup fees stated; only genuine corporate-group contracts are custom.

10 — Complete price computability: every tier, band, add-on and renewal rule public, so the invoice for a 60-employee company and a 5-entity group is a two-minute exercise.

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The Skeptic

The pricing page was captured and it yielded tier names and admin counts — not a single currency figure, no employee bands, no billing period, no VAT, plus an unpriced 'additional fee' for non-listed hosting countries and 'Special Pricing for Schools' with no numbers. No public prices at all means every tier is a sales conversation, which is the 0-1 anchor. 2 3

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European sovereignty — proven facts

2 of 4 dimensions proven

Built only from facts shown on the vendor's own pages. A dimension we could not prove is left open, not scored as zero.

Ownership Not determined — uncited Report an error
Data residency EU optional ⚠ unverified 1/3 pts 4 Report an error
Subprocessors Not determined ⚠ unverified — uncited Report an error

Where this could be wrong

What we left out

A claim that does not survive our checks costs us the claim, not the page. This is what was taken off this one.

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Sources (14)

The pages every claim on this page was read from — each one checked, dated, and kept verifiable.

  1. 1 Vendor homepage www.faceup.com Checked 16 Sep 2026 Details →
  2. 2 Pricing page www.faceup.com Checked 16 Sep 2026 Details →
  3. 3 Security page www.faceup.com Checked 16 Sep 2026 Details →
  4. 4 Privacy policy www.faceup.com Checked 16 Sep 2026 Details →
  5. 5 Whistleblowing product page www.faceup.com Checked 16 Sep 2026 Details →
  6. 6 Data processing agreement (dpa) www.faceup.com Checked 30 Sep 2026 Details →
  7. 7 Reporting channels & reporter experience — found from sitemap support.faceup.com Checked 1 Oct 2026 Details →
  8. 8 Reporting channels & reporter experience — found from sitemap support.faceup.com Checked 1 Oct 2026 Details →
  9. 9 Case management & deadline discipline — found from sitemap www.faceup.com Checked 1 Oct 2026 Details →
  10. 10 Case management & deadline discipline — found from sitemap support.faceup.com Checked 1 Oct 2026 Details →
  11. 11 Legal compliance alignment — found from sitemap www.faceup.com Checked 1 Oct 2026 Details →
  12. 12 Legal compliance alignment — found from sitemap support.faceup.com Checked 1 Oct 2026 Details →
  13. 13 Security & anonymity assurance — found from sitemap support.faceup.com Checked 1 Oct 2026 Details →
  14. 14 Security & anonymity assurance — found from sitemap support.faceup.com Checked 1 Oct 2026 Details →