24.08.2026
Disclosure of Internal Investigation Reports: Key Considerations Under the FADP
In a recent decision, the Swiss Federal Supreme Court provided important guidance on the disclosure of internal investigation reports under the FADP. The Court confirmed that data subjects are entitled to information concerning their personal data. However, this does not mean that they are entitled to access the investigation report as a whole. In particular, the Court emphasized that the anonymity and confidentiality of third parties may justify restricting disclosure and that redaction may be insufficient where individuals remain identifiable.
In this Insight, we discuss the key findings of the decision and what they mean in practice for companies handling internal investigations.
