Risk & Compliance

Inside the Firewall: Building a Defensible Internal Investigations Program

Purpose and principles

Internal investigations protect people, assets, and reputation. Done right, they encourage reporting and deliver outcomes that withstand legal and regulatory review.

Program architecture

  • Clear mandate: What issues qualify (harassment, fraud, data misuse, safety)? What’s out of scope?
  • Intake channels: Anonymous hotline, manager route, security/legal inbox—one case system behind them all.
  • Role clarity: Case owner, investigator, legal counsel, HR partner, communications.
  • Confidentiality by default: Need-to-know access; documented sharing decisions.

Evidence handling (non-negotiables)

  • Preservation first: Issue legal hold; prevent spoliation; snapshot systems as needed.
  • Chain-of-custody: Unique IDs, timestamps, handlers, storage locations.
  • Forensic soundness: Read-only captures, hash values where applicable.
  • Sensitive media: No redistribution; summaries only; consult counsel.

Procedural playbook

  • Triage & scope: Allegation, risk level, immediate protections.
  • Plan: Sources, interviews, timeline, communications guardrails.
  • Execute: Collect, corroborate, document deviations from plan.
  • Conclude: Findings, substantiation level, recommended actions.
  • Close-out: Notify parties, update policies, training, and controls.

30 / 60 / 90-day plan

  • Day 0–30: Draft mandate; choose a case system; define roles and confidentiality rules.
  • Day 31–60: Publish intake options; train investigators; test legal hold and evidence workflows.
  • Day 61–90: Run a mock investigation; add metrics to the board packet.

Metrics

  • Time from report to initial contact; time to close.
  • % of cases with full chain-of-custody and signed findings.
  • Reporter satisfaction (post-case anonymous pulse).

Pitfalls

  • Ambiguous ownership: Cases stall without a named lead.
  • Over-collection: Creating privacy exposure and discovery risk.
  • Silence post-case: No policy fixes, no training updates.

Result

A fair, repeatable process that protects people and holds up under scrutiny.