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Otherwise, continue reading to discover some of the most common questions asked about operating a confidential hotline.
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You stated that it was important to communicate the existence of the hotline to employees. What are some of the best ways to do that?
Place posters prominently in employee work areas; ensure the Hotline information and number are in the Code of Conduct; ensure compliance training includes explanation on how the Hotline may be used and include the contact number; include information about the Hotline in organization newsletters; post information on Hotline on organization intranet; etc.
How long should hotline reports be saved?
There should be a Records Retention Policy governing the Compliance Office and Hotline Operation that should be followed. Record retention and expunging should never be an ad hoc process. As a general rule, the Hotline log should be part of the permanent records. Individual case files should be retained as long as the information in current or useful but should not be expunged without an affirmative decision by the Compliance Office.
What kind of hotline operation records should be maintained?
First and foremost, there should be a Hotline Call Log that provides a number of key facts, such as date and time of receipt; nature of the call; tracking on who was resolving the issue; the resolution result, etc. All this should be included in your Hotline Management Policies and Procedures.
With so many people moving to have the hotline outsourced, are vendor charging less for the service?
One would think that with many vendors offering hotline services, the competition would reduce costs. Also, with the introduction of new technologies, such as Web-based reporting, it would be reasonable to believe that costs of service would be going down. However, the reality of the matter is that there has been a consolidation of hotline service companies into large national companies, which has had in effect a reduction in the benefits of competition. The result is that prices either remain the same or on the rise. This is a major reason why we have moved back into this arena.
When urgent call information is received, how should we handle it at our end?
It is important that a system be set up so that a responsible party is closely monitoring receipt of reports. When our hotline staff receives urgent information, they will notify the designated client party via phone, as well as email. It is incumbent on the organization to make sure that they designate the responsible party to receive that information, as well as an alternate in case the primary contact is unavailable.
Can my organization have more than one person receiving the hotline reports? If so, who else besides the compliance officer should get the reports?
Yes, of course. This is especially important where there is a corporate structure and many different sites for the organization. As to whom the other parties may be, it is up to the organization to decide. You may have a corporate compliance officer and a facility level compliance officer or liaison; and having both notified simultaneously may be viewed as desirable and an added control to endure information is being acted upon properly. In publicly traded organizations that fall under the requirements of the Sarbanes-Oxley Act, the Audit Committee of the Board may also want to see unfiltered information coming from the Hotline.
If the government or other outside party comes in to evaluate our hotline management, what are they likely to do?
They will likely begin to look for the hotline poster to be in common work areas. They also will likely want to see evidence of employees being informed through the Code of Conduct and compliance policy documents. The best evidence of determining whether the Hotline operation is being handled in an effective manner is to examine the compliance training to see to what degree the Hotline is addressed. They will also look at the call log that should describe how the organization acts upon caller information.
How often can I expect to receive a call if my organization has about 1,000 employees?
Evidence of operating and managing many hundred of hotlines over many years, suggests that the best rule of thumb on call volume would be about one call per month for every thousand employees. Another measure often used is that one may expect between one and two percent of employees calling the hotline annually.
How do I handle investigating a concern if the employee did not provide enough information?
Often callers will provide enough information to excite organization interest but leave out some needed details in order to properly follow-up on the report. If employees identified themselves, all that is needed is to re-contact them and ask additional questions. The real problem is when the employee remains anonymous. In such cases, it is very important that the individual be assigned an identifying number that can be used to re-contact the Hotline. When they do that, the organization can post questions. In this way some two way communication can occur without compromising the employee’s anonymity.
How long does it typically take to investigate and resolve issues?
Of course this varies according to the complexity and seriousness of the information being provided. However, the great majority of matters reported to the Hotline are fairly routine and mundane. In some cases, employees may only be seeking clarification of a policy. In other cases, the individual may only be seeking a means to vent some frustration and does not expect more than the opportunity to have someone listen to their concerns. Other matters do result in cases to be investigated. On balance, the vast majority of issues can be investigated and resolved in one to three days. However, occasionally there may be a case will require many weeks or months to resolve.