GDPR: How to anonymise or pseudonymise whistleblowers allegations


Whistleblowers around the world still fear retaliation, it is not surprisingly, therefore, that most of them decide to stay anonymous. However, is omitting his own name enough? Probably not, at least for reports made via phone calls. Even without disclosing his name, anyone, while talking on the phone, may release a number of details which … Continue reading GDPR: How to anonymise or pseudonymise whistleblowers allegations

GDPR Why your Data Protection Officer should be a Lawyer


The GDPR is almost here, May is not far, therefore, organisations are increasingly worrying about being compliant with the data protection Regulation. One of the main topics is the DPO selection. Should I hire one? What exactly qualifies to be a DPO? Should a DPO be a lawyer? These are just some of the most … Continue reading GDPR Why your Data Protection Officer should be a Lawyer

ISO 37001, perché non se ne ha bisogno


Chiunque abbia letto questo blog lo sa, non ho una grande opinione delle certificazioni, siano esse compliance, anti riciclaggio, privacy o anticorruzione poco importa. (qui un mio articolo in inglese Compliance Certifications, a Good Investment? ) Purtroppo l’industria della certificazione è in pieno fermento; Regolamento in materia di protezione dei dati personali ed ISO 37001 in primis. … Continue reading ISO 37001, perché non se ne ha bisogno

Is Political Will Necessary to Fight Corruption? Yes!


I recently came across this post  where prof. Michael Johnston defined relying on political will ‘magic thinking’ (actually he extended the same reasoning to the civil society). Given my experience in high risk countries, I respectfully disagree with prof. Johnston. Whilst corruption is strictly connected to the human kind (it can happen everywhere and in … Continue reading Is Political Will Necessary to Fight Corruption? Yes!

Christmas time, review your gift policy


It’s that time of the year again; many business meetings, several deals to close before the end of the year, dinners and…season gifts.  What can be assumed to be an innocent gift can, in reality, be a violation of anti-corruption laws, turning a festive moment into a nightmare. Let’s see what we can do to … Continue reading Christmas time, review your gift policy