GREECE Law and Practice Contributed by: Semina Zavitsanou, Yannis Ragos, Maria Siraga and Panagiota Kelali, POTAMITISVEKRIS
3.7 Information There is no mandatory information prescribed by law that must be provided to interviewees at the start and/ or at the end of an interview. At the beginning of the interview, the interviewer usually explains the purpose of the investigation, the role of him/her and how the information will be used. It is also good practice to clarify confidentiality expectations and the process for handling personal data. Interviewees should be informed that they can raise additional points, pro - vide documents or suggest further witnesses. At the end of the interview, the interviewer typically outlines the next steps and how follow-up communication will take place. 3.8 Stopping the Interview If an interviewee wishes to pause or end the meet - ing, the interviewer will generally accommodate the request, particularly if the discussion is sensitive or the individual is distressed. The interview may be rescheduled, or the employer may proceed using the information already gathered. 3.9 Minutes Under Greek labour law, the interviewer is not obliged to take minutes. In practice, however, employers generally take minutes to ensure an accurate record of what was discussed. Summaries are acceptable provided they reflect the substance of the interview without distorting the content. Interviewees are often given an opportunity to review the minutes and pro - pose clarifications. While signatures are not legally required, obtaining confirmation helps avoid disputes later. Minutes are usually kept by HR. 3.10 Recording Recording interviews is generally possible. When recordings are made, the interviewee must provide clear, informed consent, to be recorded at the very beginning of the interview. Employers who record interviews typically prepare a transcript that is shared only with individuals directly involved in the investiga - tion. Auditors should remind participants that record - ing is not permitted unless expressly agreed and, especially in remote interviews, should use platform settings that limit unauthorised recordings.
3.11 Other Fact-Finding Employers may supplement interviews with any other means of proof, including document reviews, possi - bly email checks, or even CCTV footage, provided that these methods comply with privacy principles and have been properly communicated to employ - ees in advance. They may also review access logs, timesheets or any other operational records relevant to the matter. Practices that intrude excessively into per - sonal privacy, such as covert monitoring or accessing private communications, are not permitted. The goal is to gather reliable evidence while respecting pro - portionality and the rights of all individuals involved. 4. Protection of the Parties During an HR Internal Investigation 4.1 Protection of the Reporter Any form of retaliation, meaning punishment of some - one or the taking of adverse employment actions (eg, termination of employment contract, detrimen - tal change in working conditions, disciplinary action) because (s)he raised a concern or complaint about potential harassment, discrimination, violence, or retaliation, or because (s)he participated in an inves - tigation is strictly prohibited. Article 66 of GLC pro - vides that the termination of employment effected as a retaliatory measure against an employee who has filed a complaint concerning incidents of violence or harassment is null and void. However, that prohibition is not intended to protect persons who intentionally make false reports. In the case of employees who, knowingly, make a false complaint, disciplinary penal - ties may be imposed, including the termination of the employment agreement. Furthermore, according to Article 65 GLC, any person who is subjected to an incident of violence or harass - ment shall have the right to leave the workplace for a reasonable period of time, without loss of pay or any other adverse consequence, provided that, in their reasonable belief, there exists an imminent and seri - ous risk to his/her life, health, or safety. This applies in particular where the employer is the perpetrator of such conduct, or where the employer fails to take the necessary, appropriate measures to restore workplace peace, or where such measures are insufficient to stop
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