Whistleblowing is where an individual raises concerns with an organisation or regulatory body of suspected wrongdoing at work. Officially this is called ‘making a disclosure in the public interest’.
Individuals who make such a disclosure are protected by law, under the Public Interest Disclosure Act 1998, from detrimental treatment or victimisation if, in the public interest, they blow the whistle on wrongdoing.
This policy sets out the procedure by which any concerns about possible wrongdoing within St Andrew & St George can be raised to the PCC and how such concerns will be dealt with.
Whistleblowing may apply to situations of unacceptable practice, performance or behaviour.
This policy specifically includes concerns about safeguarding and promoting the welfare of children and vulnerable adults. However if a child or vulnerable adult may be at risk of harm the Parish Safeguarding Officer the Rector or the Diocesan Safeguarding Adviser should be contacted at Diocesan Office, 41 Holywell Hill, St Albans AL1 1HE. Tel: 01727 818107 Email: firstname.lastname@example.org. In an emergency, if a child or vulnerable adult is considered to be at risk of immediate harm the police should be called on 999.
Who is protected?
All members of St Andrew & St George are protected.
Scope of protection
The Public Interest Disclosure Act 1998 provides protection for individuals who raise legitimate concerns about specified matters, called “qualifying disclosures”. A qualifying disclosure is one made in good faith by an individual who has a reasonable belief that:
• a criminal offence;
• a miscarriage of justice;
• an act creating risk to health and safety;
• an act causing damage to the environment;
• a breach of any other legal obligation; or concealment of any of the above; is being, has been, or is likely to be, committed.
It is not necessary for the individual to have proof that such an act is being, has been, or is likely to be, committed – a reasonable belief is sufficient. The individual has no responsibility for investigating the matter ‐ it is the PCC’s responsibility to ensure that an investigation takes place.
Nature of Protection
An individual who makes such a protected disclosure has the right not to be victimised, because he/she has made a disclosure.
The PCC encourages members of St Andrew & St George to raise their concerns under this procedure in the first instance. If an individual is not sure whether or not to raise a concern, he/she should discuss the issue with members of the PCC or the Diocesan Secretary, The Diocesan Office, Holywell Lodge, 41 Holywell Hill, St Albans, Herts. AL1 1HE, Tel: 01727 818131.
(1) In the case of Safeguarding issues, any concerns should be raised with the Parish Safeguarding Officer the Rector or with Mr Jeremy Hirst, Diocesan Safeguarding Adviser, Holywell Lodge, 41,Holywell Hill, St Albans AL1 1HE. Tel: 01727 818107 Email: email@example.com. If you for any reason do not wish to approach any members of the PCC, then you should inform the Diocesan Secretary, who will arrange for another officer to make any necessary enquiries and make his/her own report to the Diocese. Any approach to the Diocesan Secretary will be treated with the strictest confidence. Your identity will be kept confidential as far as possible although if there is a criminal investigation you may be needed as a witness.
(2) The investigation may involve you and other individuals involved giving a written statement. Your statement will be taken into account and you will be asked to comment on any additional evidence obtained. The person who carried out the investigation will then report to the Diocesan Secretary who will take any necessary action, including reporting the matter to any appropriate government department or regulatory agency.
On conclusion of any investigation, you will be told the outcome of the investigation and what the PCC has done, or proposes to do, about it. If no action is to be taken, the reason for this will be explained.
If on conclusion of stages 1 & 2 you reasonably believe that the appropriate action has not been taken, you should report the matter to the proper authority. The legislation sets out a number of bodies to which qualifying disclosures made be made.
• HM Revenue and Customs
• the Financial Conduct Authority;
• the Office of Fair Trading;
• the Health and Safety Executive; and
• the Environment Agency.
Disclosures relating to charities can be made to the Charity Commission and a qualified disclosure to the Commission will be a ‘protected’ disclosure provided the individual makes the disclosure in good faith and has a reasonable belief that:
• The relevant failure relates to the proper administration of charities and funds given or held for charitable purposes; and
• Reasonably believes that the information disclosed and any allegation contained in it are substantially true.
Victimisation of a member of St Andrew & St George for raising a qualified disclosure will be a prosecutable offence.
Approved by the PCC 17th July 2023