Arguments can be made against both (c) and (d).
I don't think (d) will apply to most disclosures. If I report my line manager for procurement fraud no professional secrecy is involved.
Perhaps another approach is to say that the requirement in Art14(2) is limited to information necessary to ensure fair and transparent processing - and identifying the specific whistle- blower does not come within that. Otherwise why is there a separate 14(1) and 14(2) ? It would be very odd if Art 14 required the disclosure of something which could be protected under a SAR by applying
Of course at some stage disclosure may be necessary if action is to be taken - natural justice and all that - but that is another matter.
The more you look at it the drafting of 14(5)(b) is rather odd. If we accept the German position you could have a situation where you have to tell someone the source of some data you have, but not who you are, what information you have, or why you have it! Perhaps therein is the solution to the conundrum? If you don't have to provide para (1) information because doing so "is likely to render impossible or seriously impair the achievement of the objectives of that processing" then the para (2) obligation does not arise at all as that is only "additional" information and you cannot have additional information if the primary obligation has been eliminated.
The same issue arises under Art 15 as the saving in Art 15(4) does not apply to Art 15(1)(g)
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