Civilian Oversight And Whistleblower Protection In The Armed Forces 2019
Transparency International Anti-Corruption Helpdesk AnswerBest practices in civilian oversight andwhistleblower protection in thearmed forcesAuthor: Jessie Bullock, tihelpdesk@transparency.orgReviewer: Matthew Jenkins, Transparency InternationalDate: 06 March 2019Whistleblowing in the armed forces is mostly seen in terms of national securityexemptions to whistleblower protection, on which there is a great deal of literature (seeOECD 2014). However, there are specificities to the security forces that merit greaterattention to ensure that whistleblowers are afforded sufficient opportunities andprotection to report wrongdoing. Effective civilian oversight and whistleblowing channelsin the security services are crucial, not only to identify corruption, abuse and othermalfeasance but to protect legitimate national security interests from being damaged byuncontrolled leaks of sensitive information to outsiders. 2019 Transparency International. All rights reserved.This document should not be considered as representative of the Commission or Transparency International’sofficial position. Neither the European Commission,Transparency International nor any person acting onbehalf of the Commission is responsible for the use which might be made of the following information.This Anti-Corruption Helpdesk is operated by Transparency International and funded by the European Union.
QueryPlease provide an overview of best practices for civilian oversight and controlmechanisms of armed forces. In particular, please consider whistleblower protectionmeasures that apply to members of the armed forces.Contents1. Overview of civilian oversight of armedforces2. Best practices for civilian oversight andwhistleblower protection of armed forces3. Key players working on civilian oversightof armed forces4. ReferencesOverview of civilian oversightof armed forcesCivilian oversight of the armed forces andwhistleblower protection has been a topic ofrenewed global interest within the last decade,sparked by the Manning and Snowden revelationsof US wartime and surveillance practices. The coreissue that sets civilian oversight of the securitysector apart from oversight in other sectors ofgovernment is national security. This hasimplications for when, how and whomwhistleblowers should contact if they suspectwrongdoing.There is a tension between protecting legitimatenational security interests and exposinginformation about government wrongdoing thatmake civilian oversight more complicated in thesecurity sector. The stakes are high for oversightand accountability for all players at this level: onone hand, whistleblowers within the security sectorsubject themselves to a great deal of legal andpersonal risk, while on the other, states argue thatreckless disclosure of classified information couldjeopardise national security.For this reason, there are often legal exceptionsfor matters of national security in the text ofwhistleblower protection laws (OECD 2014). Theprotections afforded to some civil servants are notMain points— There are tensions between protectingnational security and transparency thatmake whistleblowing in the securitysector riskier than in other sectors.— There should be at least one oversightinstitution that is independent of thesecurity sector and the executive that canreceive whistleblower disclosures.— Employees need clear protocols forinternal and external reporting and rulesfor how to report sensitive information.— The disclosures need to be investigated,acted on, and the whistleblowerprotected from employer reprisal.the same as to those in the security sector.Moreover, reporting policies in the securityservices may have a more formalised protocol; insome countries, security personnel must reportinternally first before turning to external oversightbodies to quality for whistleblower protection(DCAF 2012).Countries and international bodies that haveattempted to improve how whistleblower protectionlaws apply to the security sector tend to focus onthe security sector as a whole, of which the armedforces are just one part. A narrow definition of thesecurity sector typically includes “the armed2Transparency International Anti-Corruption HelpdeskCivilian oversight and whistleblower protection in the armed forces
forces, paramilitary forces, gendarmeries,intelligence and security services, and lawenforcement bodies such as border protectionagencies and police forces” (DCAF 2013). This isimportant to keep in mind for institutional design ofoversight mechanisms, as many of theaccountability institutions are tasked withinvestigating or overseeing not only the armedforces but also a range of other law enforcementbodies.This Helpdesk Answer outlines best practices forestablishing civilian oversight that apply tomembers of the armed forces, paying closeattention to the reporting, protection andenforcement mechanisms throughout thewhistleblowing process.International lawThere are few international legal instruments thatprovide broad guidance related to civilian oversightand whistleblower protection in the armed forces.Moreover, there are no legally binding internationaltreaties on this subject. Most of the guidingprinciples proposed by international bodies focuson the oversight of surveillance and data collectionby intelligence institutions within the securitysector. Though non-binding, the United NationsCompilation of Good Practices on IntelligenceAgencies and their Oversight1 (DCAF 2010) wasone of the main documents to makerecommendations on oversight of the intelligencesector and the security sector’s compliance withthe law, effectiveness and efficiency, finances, andadministrative practices (DCAF 2010). The reportidentified 35 best practices for intelligenceoversight, which either fell under the category of: i)legal basis; ii) oversight and accountability; iii)substantive human rights compliance; or iv) issuesrelated to specific functions of intelligenceagencies. These practices that apply to oversight,which are mainly focused on legal and institutionalreform or setting a high international benchmark,are explained in next section.Following the Snowden revelations, the UnitedNations special rapporteur on human rights andcounter-terrorism issued a report encouragingmember countries to adopt independent oversight1bodies to oversee surveillance agencies and toadopt a process to address any violations of onlineprivacy rights (UN 2014). The UN HighCommissioner for Human Rights advocated for aseparate security sector oversight agency or courtthat included “public interest advocacy positions”(UNHCHR 2014). The Centre for DemocraticControl of the Armed Forces created a list ofquestions that governments can review whenevaluating their existing institutions to see if theyconform with the aforementioned principles (CIDS2015).One of the more influential non-bindinginternational legal instruments is the TshwanePrinciples (Global Principles on National Securityand the Right to Information), initiated in 2013 bythe Open Society Justice Initiative (Open SocietyFoundations 2013). These principles were createdby more than 500 civil society experts and havebeen notably influential in European oversight ofthe security sector (PACE 2013). The TshwanePrinciples focus on accountability and oversight ofthe security sector’s access to information, and aresome of the first sets of principles to recommendpolicies for informal oversight of the security sectorby civil society, the media or NGOs. The mostnotable principles advocate for disclosure ofinformation that is of high public interest (Principle10), broad protections for whistleblowers, eventhose that were not employees (Principles 45, 46,47), and that there should be no exemptions forpublic disclosure requirements, even forintelligence agencies (Principle 5).The recommendations from this initiative trickleddown to recommendations made by theParliamentary Assembly of the Council of Europe(PACE) on parliamentary oversight of the securitysector in Europe (PACE 2013). Therecommendations were endorsed by the Council ofEurope and later adopted by the EuropeanParliament (Council of Europe 2015).Domestic lawThere is much more variation in domesticoversight of the security sector because of thesizeable differences in domestic politicalinstitutions. Different models of civilian oversightHereafter: UN Compilation.3Transparency International Anti-Corruption HelpdeskCivilian oversight and whistleblower protection in the armed forces
and whistleblower protection in the armed forcescan be categorised into three primary groups: internal executive or security sectoroversightindependent public sector oversightand civil society oversightCommonly, oversight of the security services isexercised by the executive branch of government,or even by a body within the security service itself.Given that senior positions within a state’s securityapparatus are typically appointed by and take theirorders from the executive, the security servicesare rarely fully independent of the executive.2 Inthis model, channels of domestic oversight caninclude control and reporting mechanisms withinthe armed forces that are separate from anofficer’s direct supervisor, whistleblowing reportingbodies within the security sector, and sometimescommissioners appointed by the executive whoare tasked with reviewing practices within thesecurity sector (Council of Europe 2015).These internal oversight channels are generallypreferred by the security services themselves, asthey retain a high degree of control over theidentification and management of allegedwrongdoing. While the probability of a nationalsecurity secret being revealed is lower than wherewhistleblowers report wrongdoing to outsiders,such as the media, the chance of inaction or evencover-up is likely higher. Additional independentoversight from legislative or judicial bodies canthus provide an opportunity for more robust controlof the security forces.In fact, some countries operate a second oversightmodel, which involves the legislature or, lesscommonly, the judiciary. Legislative oversightbodies may have the mandate to investigatemultiple aspects of the security sector, such ashuman rights practices, surveillance policy, budgetand administration. These organs typically take theform of a parliamentary committee, but in somesettings, the legislature may appoint anindependent commissioner or external review body.2Of course, in parliamentary systems, the executive inpower will be not be entirely independent of the legislature,The ability to investigate the security sector andthe democratic legitimacy of the committeemembers may make investigation or audit resultsmore credible to an external audience. In addition,these channels may afford better protection towhistleblowers themselves by establishingprocedures for reporting wrongdoing outside of thearmed forces.The Council of Europe (2015) states that, whilejudicial oversight is useful as a nominallyindependent check on executive power, it shouldbe considered to complement rather than replacelegislative oversight (Council of Europe 2015).There are a few reasons for this: judicial efficacydepends on the independence of individual judges,the expertise of individual judges, their propensityto be deferent to the executive, fear that judgesmay “rubber stamp” decisions regarding nationalsecurity and because there are few ex-postoversight bodies over judicial decisions due toseparation of powers (UNHCHR 2014; Council ofEurope 2015). Judicial authorisation for warrantsor subpoenas are some of “the best safeguards forhuman rights”, and should be deployed if otherinstitutions fail, but case law is not a replacementfor well-designed policy.Lastly, there are opportunities for civil society tomonitor the security sector and protectwhistleblowers. Non-governmental actors andinvestigative media outlets can play a vital role inmonitoring the operations of a state’s securityorgans and demanding accountability wherewrongdoing is found to have occurred. As shownin both the Manning and Snowden revelations,media outlets may be the first organisations awhistleblower reaches out to. This is especiallylikely to be the case where whistleblowers havelittle confidence that their concerns will beeffectively redressed via internal channels, or fearretribution. In addition to reporting, investigatingand advocacy activities, civil society organisationsmay have the opportunity to sit on governmentappointed independent commissions and assistgovernment bodies in policymaking regardingoversight and whistleblower protection.but the relationship is not a direct reporting one like therelationship between security sector and the executive.4Transparency International Anti-Corruption HelpdeskCivilian oversight and whistleblower protection in the armed forces
Frontier of whistleblower protectionThe frontier of whistleblower protection includesmultiple channels that involve all three domesticgroups: oversight from within the security sector orexecutiveoversight from independent legislativebodiesprinciples for engaging with civil societyinstitutionsUnambiguous legislation is essential to providewhistleblowers with clear guidance on where todisclose reported wrongdoing and to properlyinform them of the protections, risks andenforcement mechanisms available. This includesclear definitions of what does and does notconstitute whistleblowing, what is the mandate anddomain of these institutions, and what individualsshould do and expect if they want to report.Experts highlight the importance of establishingreporting mechanisms and protections outside ofthe specific branch of the armed forces or securityservices to maintain credibility in the independenceof the oversight body and reassure potentialwhistleblowers that they will be protected uponmaking their disclosure. The UN Compilationstates:“It is good practice for this multilevel system ofoversight to include at least one institution thatis fully independent of both the intelligenceservices and the political executive. Thisapproach ensures that there is a separation ofpowers in the oversight of intelligence service;the institutions that commission, undertakeand receive the outputs of intelligenceactivities and not the only institutions thatoversee these activities” (DCAF 2010, 17).There is no one-size-fits-all model for whichoversight institutions work best, since eachgovernment has its own unique institutions andsecurity threats. Thus far, the most commonchannels appear to be legislative oversight bodiesand independent commissions, which are eitherappointed by the legislature, executive orsometimes both. Legislative oversight bodies havebeen said to have “the ultimate ‘democraticlegitimacy’, as elected individuals oversee securityservices” (TI Georgia 2018, p. 27). Their oversightis key because the security sector uses a lot offinancial resources, and the legislature shouldhave the power to make sure spending is efficientand policies are implemented correctly (CIDS2016). Independent commissions or ombudsmenalso seem to be on the rise – 16 of 28 EU memberstates had established this type of oversight bodyby 2017 (TI Georgia 2018).Best practices for civilianoversight and whistleblowerprotection of armed forcesTransparency International advanced theInternational Principles for WhistleblowerLegislation in 2013 (Transparency International2013). Many of the principles that apply towhistleblowing more broadly are relevant anduseful for whistleblowing in the security sector, butcivilian oversight in the security sector entailsheightened risks in terms of the content of thedisclosure and possible state retaliation. The oneprinciple related to security, Principle 19, statesthat “special procedures and safeguards forreporting that take into account the sensitivenature of the subject matter may be adopted inorder to promote successful internal follow-up andresolution, and to prevent unnecessary externalexposure” (Transparency International 2013).The following best practices should be consideredwhen: drafting legislation and adopting policies tostrengthen civilian oversight structures ofthe armed forcesdefining the action of whistleblowing in thesecurity sectormanaging whistleblowing reporting,protection and enforcement structuresCivilian oversight structuresDue to the tension between exposing criticalinformation on national security and uncoveringgovernment wrongdoing, it is important forgovernments to have oversight institutions that areindependent of the security sector and provide5Transparency International Anti-Corruption HelpdeskCivilian oversight and whistleblower protection in the armed forces
reporting procedures. These bodies fall under thesecond model mentioned above as, unlike theexecutive branch, they do not have directsupervisory powers over the armed forces. Theseinstitutions can include the legislature or legislativecommittees, ombuds institutions, national humanrights or transparency commissions, appointedoversight bodies or the judiciary (TI Georgia 2018).Several UN Compilation practices confirm thatthis is consistent with their best practices: theyadvocate for the importance of establishing anoversight body that is independent of the executiveand security sector (Practices 6) which canconduct its own investigations (Practice 7), hasbroad access to information (Practice 25) and canexamine information sent to foreign entities(Practice 35).The need for independent oversight institutionsin the security sector is paramount. In a UScongressional hearing on the status ofwhistleblowing, a special counsel said, “I’d saythat unless you’re in a position to retire or areindependently wealthy, don’t do it. Don’t put yourhead up because it will get blown off” (DCAF2013, p.70). Given that the potential costs forwhistleblowing in the security sector are ofteneven greater than whistleblowing in civilian life,oversight institutions in this sector shouldprioritise being as explicit as possible andcreating many channels for whistleblowers tocome forward.Public sector oversight bodies that areindependent from the security sector and do nothave direct supervisory power over potentialwhistleblowers are well placed to manage thedelicate balance between the need to rectifypotential government wrongdoing and protectwhistleblowers while also protecting corenational security interests.There are a number of reasons that countriesshould take proactive steps to establishindependent bodies with a mandate to overseethe security forces.First, it sends a credible signal to the public andpotential whistleblowers that wrongdoing,corruption or other abuses by security forces istaken seriously and will be investigatedresponsibly. Independent oversight bodies inboth Japan and Latvia, two highly rankedcountries in Transparency International Defenceand Security Programme’s report on the qualityof legislative oversight, made their reports andrecommendations open to the public to showtheir commitment to the recommendations (TIDefence and Security 2013). Japan’sindependent board of audit made the defencespending report publicly available and Latviamade their auditor general’s office report onmilitary funds for training personnel public. Bothparliaments used these reports in formingcommittees and looking at policy changes orpossible improvements to defence spending.Second, external reporting channels are likely toafford potential whistleblowers greaterprotection. A well-designed oversight institutionwill have a clear protocol on how they willprotect the whistleblower and handle theinformation disclosed, as well as investigate thepotential wrongdoing. UN Compilation practicesadvocate for an independent agency forindividuals to bring and resolves disputes, for awell specified protocol for how members of thesecurity sector can report complaints (DCAF2010, practices 9, 10, 18)Third, where governments provide clear,independent and accessible channels to reportsuspected wrongdoing to state institutions, thismay reduce the risk that a conscientiouswhistleblower with nowhere else to turn leakssensitive security information to the press. UNCompilation practice 8 advocates for oversightinstitutions to “take all necessary measures toprotect classified information and personal data during the course of their work” (DCAF 2010,10).Germany’s parliamentary controlpanelThe parliamentary control panel in Germany,established in 2009, is a legislative committee thatoversees all federal security services, whichincludes their finances, policies and internaladministration (EU FRA 2015). It is one of themost comprehensive legislative oversight bodies of6Transparency International Anti-Corruption HelpdeskCivilian oversight and whistleblower protection in the armed forces
Commission, Germany’s intelligence sectoroversight body (EU FRA 2017). The G10 isan independent oversight body appointedby parliament, whose investigative andoversight powers are protected by aconstitutional amendment.the security sector and includes detailedprocedures on oversight, handling whistleblowingdisclosures and investigative protocol. Themandate of this committee is extensive: it is taskedwith reviewing internal reports from security sectoragencies, investigating possible malfeasance andholding hearings.This committee has established a few measuresthat can be viewed as good practices: Access to information: the members on thiscommittee may access electronic or writteninformation from all members of thesecurity services, intelligence agencies orother branches of the federal governmentfor review. If not granted access, they havea mandate to reach out to the judiciary torequest assistance in obtaining information(TI Georgia 2018). Proactive disclosure of changes in thesecurity sector: the Parliamentary Controlof Federal Intelligence Services Law3,which regulates the panel, requiressecurity sector agencies to proactivelyreport the following to the committee (TIGeorgia 2018: 29):a) notable changes to Germany’sforeign and domestic securitysituationb) internal administrativedevelopments with substantialramifications for the pursuit of theservices’ mandatec) singular events that are subject topolitical discussions or publicreporting Investigate complaints: whistleblowerswithin the security sector can disclosecomplaints to this committee, which hasthe mandate and resources to investigatethem. Between 2015 and 2017, thecommittee received 65 complaints aboutthe security sector, 40 of which were aboutsurveillance. The committee forwarded themore serious complaints to the G10Definition of whistleblowingThe ways that policymakers define the action ofwhistleblowing and the type of information itincludes has important consequences forwhistleblowing in the security sector. Even beforearriving at a definition of whistleblowing, however,it is recommended that countries have a cleardefinition of the security sector’s role, legalmandate, powers and competencies undernational law, compliance with the constitution andinternational human rights law, and extent orlimitations of their role in accordance with theconstitution and international human rights law.Practices 1-5 of the UN Compilation advocatesestablishing a legal basis for these (DCAF 2010).The limitations of the security sector’s reach,especially with regard to discrimination, targetingand human rights are further elaborated inpractices 11-17 (DCAF 2010). Having a clear legalprecedent of the role and mandate of securitysector institutions could make it easierdownstream in adjudicating whether or not theseinstitutions are acting within their mandate or not.In drafting domestic policy, experts recommendadopting a broad definition of a whistleblower andthe act of whistleblowing (TransparencyInternational 2013; DCAF 2013). Definitionstypically state that “whistleblowing is the disclosureor reporting of wrongdoing”, where wrongdoingmay range from corruption and violence toenvironmental crime and even actions to cover upother acts of wrongdoing. By extension, awhistleblower is any public or private sectorindividual who is privy to this information anddiscloses it at their own risk, including but notlimited to employees (Transparency International2013).3Full text of the law is found here: 09.html7Transparency International Anti-Corruption HelpdeskCivilian oversight and whistleblower protection in the armed forces
The third component of the definition, and mostsalient with regards to the security sector, is thethreshold of “reasonable belief of wrongdoing”. Inother words, for the whistleblower to be protectedby the oversight institutions in place, thisreasonable belief must be present (TransparencyInternational 2013).There are a few best practices about “reasonablebelief of wrongdoing” that are related to awhistleblower’s motive and evidence (DCAF 2012,DCAF 2013).First, some states have argued that thewhistleblower’s motive matters, and that only if acomplaint is lodged in good faith should thewhistleblower be protected by all resourcesavailable (DCAF 2012).A policy that would ultimately provide moreprotection for whistleblowers, however, wouldclarify that motive is irrelevant if the disclosureindeed shows government wrongdoing, asmandating a good faith motive to each disclosurecan lead to over-litigating (Public Concern at Work2010). In fact, where a whistleblower’s motive isopen to attack by the authorities, this can be usedto divert attention from the nature of the reportedwrongdoing itself. This became apparent duringthe Manning trials, where prosecutors argued thatManning intended to harm the United Statesmilitary and weaken national security (TheGuardian 2013).Second, the level of evidence required to make adisclosure should also be specified by domesticlaw. Most states use the language “honest andreasonable belief” to describe the level of proof orevidence necessary to classify a disclosure aswhistleblowing (DCAF 2013).Drawing from legislation in Australia, South Koreaand the UK, experts argue that “honest andreasonable belief” is the appropriate level ofspecificity for whistleblowing in the security sector,as demanding higher levels of proof mayencourage whistleblowers to commit illicit acts orleak information to outsiders (DCAF 2013). Inaddition, where the burden of proof is high, awhistleblower’s efforts to collect sufficient evidencecould tip off potential wrongdoers and lead them todestroy evidence. When drafting whistleblowingregulations, policymakers should maintain this“reasonable belief” standard of evidence for thesecurity services and armed forces, rather thangrant them exceptions. For example, if anemployee of the security sector suspectsmalfeasance within their agency but is not certain,they should not violate a data collection law tocollect more evidence to make their case stronger.One way to operationalise this could be for thepolicy to explicitly say that the burden of collectingextra proof is on the independent investigativeoversight institution, not on the whistleblower(especially if it would cause them to break the law).Reporting proceduresReporting procedures for whistleblowing shoulddetail the process and recipient of the disclosureso potential whistleblowers know who to turn toand how disclose their information.Reporting lines and protocols will vary according tothe type of oversight. The literature is clear that nosingle reporting channel is better than the other;rather, it emphasises the importance of multipleindependent channels existing in the same countryand the importance of not applying a one-size-fitsall model to all countries.Where the oversight function is exercised by adirect supervisor, or an institution belonging to theexecutive branch, reporting procedures will differfrom systems in which whistleblowers are entitledto make disclosures to a parliamentary committeeor independent ombudsman.Different still is a tiered reporting system, wherewhistleblowers must bring complaints to differentchannels in a specific order (DCAF 2012). Acrossthese different reporting channels, the biggestdifferences will be the person hearing thecomplaint’s relationship to the whistleblower, theinvestigative powers vis-à-vis the agency beingcomplained about, and the possible retributivepowers (DCAF 2012; DCAF 2013).In all cases, however, best practices entail anunambiguous reporting procedure where thecomplaint process and reporting hierarchy isoutlined clearly. This is consistent with practice 19of the UN Compilation (DCAF 2010). The followingexamples are proactive steps that some countries8Transparency International Anti-Corruption HelpdeskCivilian oversight and whistleblower protection in the armed forces
have taken to facilitate whistleblowing in thesecurity sector at multiple levels of government: Visibility of reporting channels.Reporting channels must be made“visible”, both internally within a givenorganisation and externally to relevantexternal and independent oversight bodies.Where a member of the armed forceswishes to blow the whistle, there should beat least one option to disclose malfeasanceoutside of their unit (DCAF 2013).Dissemination efforts are an importantmeans of promoting all available channelsamong members of the security forces.Australia’s security sector issues print andonline information about whistleblowingreporting channels to employees,described more below.Outline expectations for reporting atdifferent channels. In the UK, legislatorshave outlined a “tiered” approach toreporting, whereby different levels ofseverity of alleged wrongdoing correspondto different reporting bodies and differenttiers of protection the whistleblower isafforded (Banisar 2011). This is anotherreason why there should be visibility andvariety in reporting channels, becausedisclosures may range from minormalfeasance to classified information, anda whistleblower should be well informedabout the risk they are exposed
Overview of civilian oversight of armed forces Civilian oversight of the armed forces and whistleblower protection has been a topic of renewed global interest within the last decade, sparked by the Manning and Snowden revelations of US wartime and surveillance practices. The core issue that sets civilian oversight of the security
SARBANES-OXLEY WHISTLEBLOWER LAW: ROBUST PROTECTION FOR CORPORATE WHISTLEBLOWERS 2 This guide is written based on the adage that "knowledge is power." It provides an overview of the key elements of a SOX whistleblower claim and an overview of the procedures governing the adjudication of SOX whistleblower claims.
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