Can a third party (lawyer, secretary of the Board of Directors of a company...) communicate the appointment of the person responsible for the Internal Information System on behalf of the obliged entity?

Yes. A third party can make the communication of the person in charge of the IIS on behalf of the obliged subject. It will be necessary to accredit it in accordance with the provisions of art. 5.4 of Law 39/2015, of October 1, of the common administrative procedure by any means valid in law that leaves reliable evidence.

In this sense, it is important to clarify that the Anti-Fraud Office of Catalonia is an entity attached to the Parliament of Catalonia that is not a public administration, and therefore does not currently have the possibility of "apud acta" power of attorney through electronic appearance or access to the electronic registers of powers of attorney that allow checking the accreditations of representation and powers of attorney granted before the various public administrations.

In the case of legal entities, it will be necessary to provide documentation that proves that the natural person presenting the communication can act in the name and representation of the legal entity in accordance with the rules or statutes applied.