How do you submit a report?

KTH has established an internal reporting channel as described below. Pursuant to the Whistleblower Act, KTH has also appointed independent and autonomous persons to be competent to receive reports on KTH’s behalf, have contact with reporting persons, follow up what has been reported and provide feedback on the follow-up to reporting persons.

Submitting a report

Please note that anonymous reports do not constitute whistleblowing in the meaning of the Whistleblower Act and, if received, these will therefore be immediately referred to a competent instance elsewhere in the organisation.

Written reports

• Written reports can be emailed to the function’s email address: internkanal@kth.se .

All email to this address is processed separately by appointed competent persons. 

• Written reports sent by post should be addressed to HR Director Annica Fröberg or University Director Kerstin Jacobson, both of whom are designated competent persons. Mark the envelope “Internal reporting channel# as shown below.
  
  Address:
  Annica Fröberg or Kerstin Jacobsson – Internal reporting channel
  KTH Royal Institute of Technology
  100 44 Stockholm

If the envelope is not correctly addressed and marked “Internal reporting channel”, there is a risk that the information in the report will be accessible to staff other than competent persons.

Oral reporting

• Oral reports can be made at a physical meeting or by telephone. To quickly make contact with a competent person, you should preferably send an email message to the function’s email address, internkanal@kth.se , to arrange a date and time for a telephone or physical meeting. You can also telephone a competent person, see telephone extensions below. 

Oral reports will be documented by either taking minutes or recording/transcribing the meeting. Consent to any recording will be documented during the initial contact prior to a meeting. The reporting person will be offered the opportunity to check, correct and approve the minutes or transcript of the meeting.

The content of the report

It is vital that the report includes a detailed factual description of the irregularity and the work-related context in which the irregularity occurred or is likely to occur. We also request that your report contain the following:

• Your name and role at KTH.
• A brief account of how you became aware of the irregularity, how the irregularity relates to KTH’s operations and the operational unit at KTH in which it occurred/is likely to occur.
• In what way disclosing the irregularity is in the public interest.
• Whether you want confirmation that your report has been received.
• Contact details for sending confirmation, feedback on follow-up measures and any supplementary questions.

You may attach your own documentation but avoid attaching any official documents or other documents. Instead, refer to existing KTH documents by their reference number, or other information that is available to KTH.  

How a report is dealt with

Below is a brief description of how a report is dealt with. For a more detailed description, please refer to the governance document Rules of Procedure for Reports of Irregularities Pursuant to the Swedish Act on Protection for Persons Reporting Irregularities (ref. no. V-2022-0445) . Only appointed competent persons are authorised to process personal data concerning the reporting person. The Whistleblower Act contains provisions on what information must be provided to the reporting person in the event that following up a report entails passing the case on within KTH or to another authority.

All reports submitted via the internal reporting channel are registered by the Registry Office and appointed competent persons and an initial assessment is made of whether or not the report is within the scope of the Whistleblower Act. If the report is within the scope of the Whistleblower Act, it is passed on to the investigative function, which consists of competent persons. If not, the report will be passed on to another function within KTH and the reporting person will receive the feedback described below.

Reports within the scope of the Whistleblower Act are followed up by competent persons to assess whether the assertions made in the report are correct and what further action should be taken. After the investigation, the case is passed on internally within KTH or to a competent external authority or organisation for measures. The investigative function may also decide to close the case without further action. One of the competent persons will then provide feedback to the reporting person.

During the follow-up, it may be necessary to ask supplementary questions and request supplementary information. If possible, one of the competent persons will then contact you. 

Confirmation of a submitted report

Within seven days of receipt, one of the authorized persons will provide the reporting person with confirmation that the report has been received, unless the reporting person has declined confirmation, or the autihorized person has reason to assume that a confirmation would reveal the person’s identity.

Feedback

The person reporting an irregularity that falls within the scope of the Whistleblower Act shall, to a reasonable extent, receive feedback on the measures taken to follow up the report and the reasons for these measures. This feedback will be provided to the reporting person by one of the competent persons within three months of the confirmation of receipt (the Act does allow for exceptions to this rule). Where applicable, the reporting person shall be informed that information that might identify them is to be disclosed, unless doing so would obstruct or impede the aim of the follow-up or measures (for example, a police investigation).

Feedback is also provided if the report is deemed to be outside the scope of the Act, including how the reported irregularity will be dealt with instead, or how else it can be reported.

Appointed competent (authorized) persons

Competent persons appointed to the sorting function

Competent persons appointed to the investigative function

Public access to information and secrecy

A report submitted via the internal reporting channel becomes an official document, meaning that members of the public can request access to the report, as well as any documents added to the case during the follow-up. When a request to access an official document is received, a secrecy examination is always conducted pursuant to the Swedish Public Access to Information and Secrecy Act (SFS 2009:400).

Secrecy applies to information that may reveal the identity of the reporting person. Secrecy also applies to information that may reveal the identity of another individual, unless it is obvious that the information can be disclosed without the individual suffering injury or detriment. In principle, all other information supplied in the case is not subject to secrecy, unless the information is in itself so detailed that it may reveal the identity of the reporting person, or if certain information in the case is covered by a separate secrecy provision. The maximum secrecy period is 50 years.

Only appointed competent persons are permitted direct access to the report and any personal data in the case. In addition to competent persons, archivists and IT system staff have access to data in accordance with KTH’s processing procedures.

Processing personal data

Pursuant to the Whistleblower Act, personal data must only be processed if:

• the processing is necessary in a follow-up case;
• for the provision of information that is necessary to enable measures to be taken based on what has emerged in a case;
• the processing is necessary to enable reports to be used as evidence in legal proceedings; or
• the processing takes place in compliance with an act or ordinance.

The legal basis for processing personal data is that processing is necessary for compliance with a legal obligation to which the controller is subject (Article 6.1 c in GDPR). The same legal basis also applies to any personal data concerning convictions in a criminal case and breaches that might occur in the case.

KTH is the controller of processing that takes place during reporting, follow-up och feedback. When an oral report is made, the conversation may be recorded. Consent to any recording will be documented during the initial contact prior to a meeting, and the recording will be saved as an audio file or transcript. The reporting person will be offered the opportunity to check, correct and approve the transcript of the recording.

Only appointed competent persons, archivists and IT system staff have access to personal data.

You have the right to access personal data concerning you that KTH is processing. This right does not apply if a statutory duty of confidentiality or secrecy provision exists. If you believe that we are processing inaccurate personal data concerning you and wish to rectify it, or if you want to restrict our processing of personal data concerning you, please contact KTH’s data protection officer to discuss the possibility. As KTH’s processing of personal data is supported by the Whistleblower Act, you do not have the right to object to processing.

Reports will be stored for as long as necessary, but no longer than two years after the follow-up case is closed. Personal data that are not archived are stored for up to two years after the case is closed. It is not possible to erase inaccurate personal data in archived documents. Personal data that are clearly irrelevant to dealing with the report in question or that have been collected by mistake will be erased at the earliest opportunity.

If you have any questions or complaints about KTH’s processing of personal data, please contact our data protection officer by email at dataskyddsombud@kth .se or by calling the KTH switchboard on +46 (0)8 790 60 00. You also have the right to complain about our processing of personal data to the Swedish Authority for Privacy Protection (IMY) .