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Whistleblowing Portals

Whistleblower Software by Formalize

EU-Made Report an error

Panel rating · 6 judges · How to read the stars

Category median

Sovereignty: 3 of 4 dimensions proven

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

by Whistleblower Software ApS · whistleblowersoftware.com

Compare with Whistlelink → Report an error on this page Is this your product? →

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

The Group Counsel

Weighted verdict

Rolls one system out to 25 subsidiaries in a dozen countries. Optimizes for per-entity channels with real access separation, per-country legal rule sets, external ombudsman roles and group reporting that respects entity boundaries. Rejects one-channel products multiplied by twenty-five contracts.

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

Scored by The Group Counsel

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 Group Counsel

Anonymous and confidential intake with two-way follow-up plus an 80+ language system and a TÜV-audited WCAG 2.1 AA certificate clear the two-way bar comfortably. But the evidence evidences exactly one web channel — no phone, voice message or QR intake anywhere — and nothing documents how the reporter's identity is kept out of the channel itself. 1 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 Group Counsel

Case-level and category-level access control and the 4-eye principle are genuine separation primitives, better than all-or-nothing. But 'Advanced case management' is a bare bullet, and the evidence is completely silent on statutory clocks, conflict-of-interest exclusion, tamper-evident history and caseload reporting — the deadline discipline I am contractually on the hook for is unevidenced. 1 4 6

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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 Group Counsel

The Directive and several national frameworks are named on a page — EU 2019/1937, Loi Sapin II, a German governance code — plus 'comply with EU whistleblowing laws' marketing, but naming is not implementing: no acknowledgment or feedback clocks, no per-country retention, no HinSchG specifics, no named counsel review anywhere. The legal mapping remains the customer's problem. 3 4

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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 Group Counsel

The certificate stack is genuinely strong — ISO/IEC 27001:2022 by Intertek, annual ISAE 3000 Type 2, Truesec pentests in both 2023 and 2024, ENS High — and the E2EE claim that 'not even employees' can see case data is architectural, not adjectival. Held below 8 because the ISMS scope is not visible, no security disclosure policy or contact is evidenced, and the privacy policy discloses IP retention for up to 14 months where anonymity assurance wants a no-IP-logging statement and metadata minimization. 1 4 5

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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 Group Counsel

'Unlimited cases, users, languages and channels' and individual case-level access plus SAML/SCIM provisioning are raw material for per-entity separation, but nothing ties access to legal entities: no group-level overview, no delegated administration, no external ombudsman role, no per-entity branding. Rolling this to 25 subsidiaries would be 25 unproven assumptions, not one system. 1 4 6

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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 Group Counsel

EU hosting is the default and named — AWS Frankfurt with backups in EU availability zones — under a Danish controller entity with EEA-only intra-group transfers and a Schrems II nod, which beats 'EU on request'. But the subprocessor list is unpublished (request-only) with Google Analytics sitting in the categories, AWS remains a US-parent critical processor, and no DPA or TOMs appear in the evidence — for the most sensitive data a group holds, that chain is not clean enough. 4 5 6

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Pricing transparency

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 Group Counsel

Both tiers carry a full employee-band ladder in real euros with annual billing stated, and 'unlimited languages and channels' suggests no per-language gouging. But the evidence never says whether one subscription covers one entity or a corporate group — the exact question a 25-subsidiary buyer needs answered — VAT treatment is unstated, and 1000+ employees is 'contact sales', so the group invoice is not computable from public pages. 1 6

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European sovereignty — proven facts

3 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 only ⚠ unverified 3/3 pts 4 Report an error
Subprocessors US CLOUD Act reach ⚠ unverified 0/2 pts 4 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 (6)

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

  1. 1 Product homepage whistleblowersoftware.com Checked 15 Sep 2026 Details →
  2. 2 About page whistleblowersoftware.com Checked 15 Sep 2026 Details →
  3. 3 Parent brand Formalize about page formalize.com Checked 15 Sep 2026 Details →
  4. 4 Security page whistleblowersoftware.com Checked 15 Sep 2026 Details →
  5. 5 Privacy policy whistleblowersoftware.com Checked 15 Sep 2026 Details →
  6. 6 Pricing page whistleblowersoftware.com Checked 15 Sep 2026 Details →