A protected whistleblower under Portugal's Law No. 93/2021 will escalate legal action against Transcom and Roche following months of systematic non-compliance with GDPR and whistleblower protection obligations.
Despite final deadlines expiring on 8 November (Transcom) and total silence from Roche - including from Global Privacy Office representative Viviana Aguirre - since 24 October 2025, both companies continue to withhold the missing August 20 meeting recording, refuse to justify unlawful redactions and omissions, and fail to establish mandatory Article 8 whistleblowing channels or remedy the retaliatory conduct. Non-compliance continues regarding:
-Full personal data required under Article 15 GDPR (including internal emails, support tickets, account metadata and Roche - Transcom correspondence related to the retaliatory account lockout of 20 August 2025)
-The mandatory confidential internal reporting channels required by Article 8 of Law No. 93/2021
-The audio recording of the 20 August 2025 meeting involving Transcom managers Philip Christopher Brunner, Raquel Joana Silva Sequeira and Maria Goreti Da Silva Batista Carmona Martins
-Direct contact details of Roche's Chief Group Compliance Officer, in direct violation of Roche's own publicly stated Non-Retaliation Policy
All attempts at amicable resolution have been exhausted. Formal proceedings are now being initiated with:
-Comissao Nacional de Protecao de Dados (CNPD) - repeated and aggravated GDPR violations
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