Whistleblowing Policy

1. Why this policy exists

The people we support cannot always speak for themselves. Staff are often the only people who can see unsafe practice, and the first to spot that something is wrong. This policy exists so that raising a concern is straightforward, safe and effective, and so that nobody is punished for doing the right thing.

It applies to all staff, bank and agency workers, volunteers, students and contractors.

2. What can be raised

• abuse, neglect or poor practice towards a person we support
• unsafe medicines practice, missed visits or falsified records
• staff working outside their competence or without necessary training
• inadequate staffing that puts people at risk
• bullying, harassment or discrimination
• unsafe equipment, premises or lone working arrangements
• a manager or colleague concealing a mistake
• a breach of data protection, or of this policy set
• any concern that the service is breaking the law or a regulatory requirement

3. Protection for the person raising a concern

A protected disclosure under the Public Interest Disclosure Act 1998 gives legal protection where a worker reasonably believes there is wrongdoing and raises it through an appropriate route. Under this policy, any concern raised in good faith — even if it turns out to be mistaken — will not result in dismissal, disciplinary action, loss of shifts, demotion, harassment or any other detriment.

Concerns may be raised anonymously. Anonymous concerns are investigated, although the investigation may be more limited.

4. How to raise a concern

You can raise a concern in whichever way you feel able:

1. Your line manager or senior carer — for most day-to-day concerns.
2. The Registered Manager — where the concern involves your manager, or is serious.
3. A director of the company — where the concern involves the Registered Manager or a director.
4. The Freedom to Speak Up Guardian — an independent person nominated by the Board who is not part of the management line. Contact details are displayed in the office and in the staff handbook.
5. CQC, the local authority safeguarding team, the Health and Safety Executive, the police or the Information Commissioner — at any time, where you believe the concern has not been addressed, or where it is so serious that external reporting is appropriate. Whistleblowing to a prescribed person in these circumstances is protected by law, and you do not have to tell us first.
6. Protect — the independent whistleblowing charity, offers free confidential advice on 020 3117 2520.

5. What happens next

1. The person receiving the concern records it in writing within 24 hours, with dates, times, people involved and any evidence.
2. Acknowledged to the person raising it within two working days, with the name of whoever is handling it.
3. An investigation is carried out proportionate to the seriousness, by someone not implicated in the concern, with a written record.
4. The person raising the concern is updated on the outcome and the action taken, subject to confidentiality and, where relevant, a police investigation.
5. Where the concern involves the safety of a person we support, our Adult Safeguarding Policy applies immediately and CQC is notified under Regulation 18 where required.

6. Serious incidents

Where a concern suggests a person has suffered serious harm, the Duty of Candour applies: we will be open with the person and their family, apologise, explain what happened and say what we are doing about it.

7. Records and confidentiality

Concerns are logged on a confidential register held by the Freedom to Speak Up Guardian, with only aggregated themes shared with the Board. Identity is disclosed only where necessary for the investigation or required by law.

8. Culture and learning

The Board reviews all concerns quarterly. We monitor whether staff feel confident to speak up through the annual staff survey, and we report numbers, themes and outcomes. A decline in concerns being raised is treated as a possible sign of a closed culture, not as an improvement.

Managers are trained to respond to a concern with thanks, not defensiveness, and this expectation is part of every manager's appraisal.

9. Review

This policy is reviewed annually and after any serious incident, and staff are briefed on it at induction and every two years.