Internal information channel

In application of Law 2/2023 of 20 February, regulating the protection of persons who report regulatory infringements and the fight against corruption,  ANECA has set up:

• An internal reporting channel.
• A strategy, which sets out the fundamental principles of the system.
• A procedure for managing the internal information system.
• A person responsible for the internal information system.

What is the internal information channel?

It is the preferred means for persons with an employment or professional relationship to report directly to ANECA's managers about serious or very serious infringements related to its own activity.

This channel allows the submission and subsequent processing of anonymous communications, if the informant so decides. Otherwise, when making the communication, the informant may indicate an address, e-mail or safe place to receive notifications.

The internal information channel guarantees confidentiality and data protection, preventing access by unauthorised personnel. It also provides the guarantees of protection for the informant provided for in Title VII of Law 2/2023 of 20 February, which regulates the protection of persons who report regulatory infringements and the fight against corruption.

What types of information or complaints can be submitted?

The information processed in this channel must be limited to alleged actions which infringe the legal system within the scope of ANECA's competences. 

Complaints relating to the operation of other administrations, although related to the Ministry, such as the universities themselves or other autonomous bodies not covered by its channel, most of which are dependent on the autonomous communities, will not be admitted for processing. On the other hand, these institutions also have their own channel for this purpose.

Likewise, this channel is not suitable for:

• Requests for information or complaints regarding the management of the Ministry's or ANECA's own procedures.
• The submission of complaints, suggestions or claims to them, which have their own space in the agency's electronic headquarters. 
• The presentation of administrative appeals.

How is the internal information channel used?

This system allows communications to be made in writing, by means of a form, or verbally, by means of a voice file, or both.  

At the informant's request, it may also be submitted by means of a face-to-face meeting within a maximum period of seven days. In this case, the informant is advised that the communication will be recorded and his or her data will be processed in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016.

Verbal communications, including those made through a face-to-face meeting, by telephone or by voice messaging system, shall be documented in one of the following ways, subject to the informant's consent: 

(a) by a recording of the conversation in a secure, durable and accessible format; or 
(b) through a complete and accurate transcription of the conversation by the personnel responsible for handling the conversation.

Without prejudice to his rights under data protection regulations, the informant shall be given the opportunity to verify, rectify and accept by signature the transcript of the conversation.

The internal information channel of the National Agency for Quality Assessment and Accreditation (ANECA) is ready to receive and process possible complaints through the following link:

https://denuncias-aneca.xperta.es/denuncias/crear

External reporting channels 

External information channels are available to report the commission of any actions or omissions included in the scope of application of Law 2/2023, to the Independent Authority for the Protection of the Informant, A.A.I., to the corresponding regional authorities or bodies, and, where appropriate, to EU institutions, bodies or agencies:

• Complaints relating to facts that could constitute fraud or irregularity in relation to projects or operations financed in whole or in part with funds from the European Union: 
  • National Anti-Fraud Coordination Service (S.N.C.A.): https://www.igae.pap.hacienda.gob.es/sitios/igae/es-ES/snca/Paginas/ComunicacionSNCA.aspx
  •  European Anti-Fraud Office (OLAF), information on which can be found at the following link: https://anti-fraud.ec.europa.eu/olaf-and-you/report-fraud_es 
  • European Public Prosecutor's Office, information on which is available at the following link: https://www.eppo.europa.eu/en/reporting-crime-eppo
• Complaints about anti-competitive practices:
  • Competition Directorate of the National Commission of Markets and Competition: https://edi.cnmc.es/buzones-anonimos/sica
• Independent Authority for the Protection of Whistleblowers, provided for in the Law: pending entry into force.