From the Activity Report 2012/2013, p. 65:
Requirements for a whistleblowing systemIn Switzerland, there are no specific legal requirements for the operation of a whistleblowing system in private companies. During our telephone consultation, we answered several inquiries on this topic. Often, the question was also whether there is an obligation to register for the data collection of the whistleblowing system. Several times, companies or their legal representatives contacted us by telephone to find out whether there is a specific legal basis in Switzerland for setting up and operating a whistleblowing system. Within the federal administration, Article 22a of the Federal Personnel Act has applied since January 2011. There are no specific regulations for the private sector, but the provisions of the Data Protection Act in particular must be observed.
Virtually every inquiry also asked whether a Obligation to register the associated data collection exists. Private individuals must register data collections with us if particularly sensitive personal data or personality profiles are regularly processed or personal data is disclosed to third parties. When operating a whistleblowing system, it cannot be ruled out or is even highly probable that personal data requiring special protection is regularly processed on the basis of the reports received. This may not be the operator’s intention, but he cannot really control it either.. Due to this circumstance, we have regularly recommended the calling persons to register the data collection.
Source: FDPIC – Requirements for a whistleblowing system