Impaired information flows

“You have to be adaptable and open to adjustments”, said Simonetta Sommaruga, President of the Swiss Confederation, on August 12, 2020 at the press conference held by the Federal Council [1]. This not only applies to combating the COVID-19 pandemic, but also to combating money laundering. We’ve identified a few issues with the false report about an alleged coronavirus death [2] which are also relevant for compliance.

Frequent causes of impaired information flows:

No effective monitoring mechanisms
Organizational boundaries hinder information flows
Responsibilities are unclear
An incomplete view of the situation; no-one has an end-to-end view of the entire process
Forms that can be filled out incorrectly and lead to incorrect data.

[1] https://youtu.be/xeVhJDxWL7w (03:33)

[2] Chronik eines vermeintlichen Todesfalls.
Tages-Anzeiger, 17.08.2020.

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Data Protection Act

The Swiss Data Protection Act underwent a complete revision in 2020, and its new version took effect on September 1, 2023, along with the new Data Protection Ordinance (DPO). The revision itself is complete, but its practical application continues to evolve. The topic of AI is particularly relevant: On May 8, 2025, the FDPIC confirmed that the DPA is technology-neutral and applies directly to all AI applications. In practice, this means, among other things, that users must know whether they are interacting with AI (transparency requirement, Art. 19), and that a data protection impact assessment is mandatory in cases of high risk—such as profiling or facial recognition (Art. 22). The Federal Office of Justice (FOJ) is drafting a consultation document on AI regulation to be completed by the end of 2026. With this, Switzerland will implement the Council of Europe's AI Convention.

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Impaired information flows

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