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Article · 16 July 2026 · 6 min read

Internal investigations: the first steps

A framework for setting scope, document preservation and the interview plan when a report comes in.

The first steps after a report determine the credibility of the investigation. Defining the scope in writing, securing the independence of whoever leads it and preserving evidence come first.

Document hold notice

The hold notice to relevant employees and IT should also cover deletion and automatic archiving settings. Information obligations regarding personal data processing should be assessed separately.

Interviews

The order of interviews should be decided after document review. Who keeps the interview notes and in what format should be agreed at the outset.

This article is for general information.

This content is for general information and is not a substitute for legal advice.