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Whistleblowing channel
Spanish Law 2/2023 · EU Directive 2019/1937

The channel that hides nothing from you.

Spanish Law 2/2023 does not ask for a mailbox. It asks for a procedure: acknowledgement of receipt within seven days, a resolution within three months, reinforced confidentiality for the reporting person, a designated System Officer to run it, a traceable record of everything done, and a route out to the competent authority.

Almost the whole market sells the mailbox. Integryty Lab builds the procedure.

Case file Example

Tracking code

7K2M · 4XQP · 9DR3

Anonymous

Acknowledgement · art. 9.2 Sent · day 2 of 7

Resolution · art. 9.2 Day 34 of 90

Identity of the reporting person

Encrypted with a key of its own for this case. Visible only to the assigned investigator.

SHA-256 chain of custody · 14 chained actions

7 days

Acknowledgement, counted for you

It warns before the deadline, not after

3 months

Resolution, with its regulated extension

One only, and with written grounds

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Competent authorities, already in

The national one and the ten regional

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Third parties in the public form

No typefaces, no analytics, no CDN

The procedure

Six stages, from the form to the authority

The whole route of a report, closed end to end. Each stage leaves its chained trace, and none of them depends on somebody remembering to take the next step.

Still not sure whether the law applies to you? We explain it article by article, in Spanish, in our guide on which companies are required to have a whistleblowing channel.

01 · Report

Public form, anonymous or identified. A tracking code is generated that is the only key to the case file, and only the reporting person holds it.

02 · Triage

Whoever runs the channel weighs seriousness, urgency and risk of retaliation under ISO 37002, and assigns an investigator. They see metadata; they do not see identities.

03 · Investigation

The investigator looks into it, puts questions to the reporting person through a secure channel without breaking anonymity, and attaches the evidence as it is gathered.

04 · Resolution

It closes with a conclusion — substantiated, unsubstantiated or referred — an internal reason and a text addressed to the reporting person. The case file is then sealed.

05 · Case report

A PDF with the verifiable chain of custody, built to leave the organisation without taking with it what must not go out.

06 · Referral

Sent on to the AIPI, the national whistleblower protection authority, or to the competent regional one, with the destination recorded and checkable.

Double-blind

There is no ladder here where the boss sees everything.

The reinforced confidentiality the law requires does not hold up on an internal policy: it holds up on a division of access that makes the question impossible. Each role sees exactly what it needs, and nothing else.

Whoever runs the channel

Every case in the organisation

No identity at all, not even in the cases they assign

Whoever investigates

The identity in their own case

And in no other. Every access is logged

Whoever administers the platform

Users and configuration

And sees no cases whatsoever

Asking for an identity through the role system does not return a «no». It returns an error, because it is a question that mechanism cannot answer.

And when there is a legitimate reason to lift the veil, it takes dual control: a second person from the organisation, a single-use approval and three audit events in order.

The guarantees

Anonymity that holds up under technical scrutiny

Promising confidentiality on the front page is not enough. These are the three pieces that hold it up when somebody really looks.

No third parties

The public form works without JavaScript and without a single request to a third party: no typefaces, no analytics, no CDN. Nothing is left behind to correlate who came in to report.

Encrypted case by case

Each case file is encrypted with a key of its own derived inside AWS KMS. No key is stored, and every access to an identity leaves a trace in the AWS log, not only in ours.

Clean metadata

Documents supplied have author, software and coordinates stripped out, and are then checked to confirm they really did come out clean. If a format cannot be cleaned, we say so.

The deadlines run on their own

The system counts the seven days for the acknowledgement and the three months for the resolution, and applies whichever counting rule fits, depending on whether receipt was acknowledged or not.

The extension, by the book

It allows the extension the law permits: one only, and with written grounds. It stays in the case file like any other action.

It warns before, not after

And a case with no investigator assigned yet warns all the same: that is precisely the one that needs it most.

AI, off by default

Unconfigured it analyses nothing, and even configured it only acts in the organisations that switch it on. A client who does not want AI over their whistleblowers' evidence does not have it.

And in Europe

Processing is restricted by code to European destinations, and there is a test that fails if anybody changes that.

And it can be refused

The reporting person is told their documents will be analysed automatically, before they supply them, and they can refuse. If they refuse, the documents are not analysed.

Contradictions are flagged

If two pieces of evidence in the same case file put the same fact on different dates, or give different amounts, the system flags it and says in which documents. Resolving the contradiction is the investigation itself, and that is done by a person who answers for it.

The report leaves the organisation clean

It is produced by whoever investigates, but it is read by an auditor or an authority, and that decides what goes in it: what happened, when, who did it, how it ended and how to check it. Without the identity, and without the retaliation-risk breakdown, which in a small workforce would let you work out who it is.

Fitting into Spain

It knows which authority to refer to, and which one is actually operating.

Several European competitors handle anonymity and encryption well. What none of them handles is the relationship with the Spanish authorities, and that is where a channel stops being a generic tool and starts being of real use.

Integryty Lab ships the full catalogue — the national AIPI, the independent whistleblower protection authority, and the ten regional ones — transcribed from the official source, with the instrument that created each one.

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competent authorities in the system: the national one and the ten regional, each with the instrument that created it.

And it tells you which one is not operating yet

Some regional authorities have been created but do not yet exercise their powers. The system says so before you refer, not after.

The chain of custody, closed with a seal

Every action is chained with SHA-256. On closing, the case file gets a seal that sums up what it held at that moment: if an event later goes missing, is added or is altered, the seal does not add up and the system refuses to issue the report. A sealed document is taken as good by whoever receives it; so if the chain is broken, what does not happen is handing it over.

The limits

Where the machine ends and you begin

These boundaries are documented decisions, not features still to come. They define the product almost as much as everything above, which is why they are here and not in the small print.

Evidence once supplied stays

There is no route to delete it. Evidence quietly withdrawn is exactly what a whistleblowing channel cannot allow.

A person signs the investigation

The system flags which pieces of evidence contradict each other and in which documents. Deciding which one is right is the investigation itself, and there is no field anywhere for the system to do it in.

The tracking code cannot be recovered

Being able to recover it would mean somebody else can obtain it. That is the honest price of anonymity that holds.

A closed case file stays closed

It is not closed twice, and nothing is written into one already resolved: that would rewrite the conclusion and the seal of a case file that has already gone out. And when something fails, the status «could not be verified» reaches whoever reads the result, instead of staying in an internal field.

Pricing

By headcount, with the price in front of you

A whistleblowing channel is a legal obligation, not an impulse purchase: you need to know what it costs before asking for a meeting. Annual fee paid in advance, no setup fee, and the full terms below.

Essential

1 – 49 employees

€290

per year · VAT not included

For entities under the obligation by a route other than headcount: the public sector, municipalities and sector-specific obliged parties.

Starter Most common

50 – 249 employees

€590

per year · VAT not included

The band where the Spanish Law 2/2023 obligation starts by number of employees.

Professional

250 – 999 employees

€1,490

per year · VAT not included

Organisations with several sites and a case volume that means spreading the investigation across more than one person.

Enterprise

1,000 employees or more

Custom

Groups and multi‑entity

It carries no list price on purpose: at this size the configuration of entities and roles is what decides the scope.

If you have fewer than 50 employees, read this before you sign

Below that threshold, the obligation to have a channel does not come from the number of employees. You may be under it by another route — the public sector, a municipality of more than 10,000 inhabitants, a sector-specific obliged party — or not be under it at all. We cannot tell from headcount and we do not guess: we tell you, and you confirm it before signing.

Terms

No setup feeYou pay the fee, and nothing else.
Annual and in advanceThe year is paid on signing and covers the twelve months.
No lock-in — and no refundWe do not oblige you to renew. But if you leave before the year is up, the fee paid is neither pro-rated nor refunded. We say it here, not in the small print.
Band changes at renewalIf your headcount crosses a threshold, the new price applies on renewal, not mid-year.
Every feature in every bandThe band sets the price, not what you can do.

Why we build it this way

Asking for an identity you are not entitled to returns an error, not a «no»

Because it is a question that mechanism cannot answer, and saying so is more honest than refusing the request. The same idea governs the other two products: we build systems that know when they do not know, and say so.

The JRV Lab paradigm →

Getting started

Your trial starts with the whole route

From the report to the referral, with synthetic data, so you see the entire procedure before deciding anything. The deadlines running, the triage, the double-blind access and the closing report — exactly as they would work in your organisation.

Open a trial