Watney College is committed to maintaining the highest standards of integrity, academic probity, financial transparency and regulatory compliance. This policy establishes safe, independent mechanisms for raising concerns in the public interest.
The College recognises that effective governance requires safe and independent mechanisms for raising concerns. The College will not tolerate retaliation against any person who raises a concern in good faith.
Public Interest Disclosure Act 1998 · Employment Rights Act 1996 · Data Protection Act 2018
A disclosure the individual reasonably believes is in the public interest and tends to show: criminal offence · financial malpractice · regulatory breach · academic standards compromise · health and safety risk · data protection breach · abuse of authority · concealment of wrongdoing. Proof is not required — reasonable belief is sufficient.
Where the allegation concerns senior leadership or the Board, the Chair may appoint an independent external investigator.
No individual will suffer dismissal, disciplinary action, harassment, disadvantage or loss of opportunity as a result of raising a concern in good faith. Retaliation will be treated as gross misconduct.
Disclosures will be handled confidentially so far as reasonably practicable. All personal data is processed in accordance with the College's Data Protection Policy. Anonymous disclosures may be considered but may limit the College's ability to investigate effectively.
Anonymous disclosures will be accepted.
All disclosures acknowledged promptly. Assessed to determine policy scope, immediate protective action needed, and whether external referral is necessary.
Independent investigating officer appointed. Gathers evidence, conducts interviews, produces written findings. External referral to auditors, regulators or law enforcement where appropriate.
Outcomes may include disciplinary action, regulatory notification, process improvement or no further action. Whistleblower informed of outcome subject to confidentiality constraints.
Nothing in this policy prevents individuals from making a protected disclosure to a prescribed regulator under UK law where appropriate.
Malicious or knowingly false disclosures may result in disciplinary action.
The Audit & Risk Committee receives periodic reports on the number and nature of disclosures, status and outcomes, and emerging risk themes. This policy is reviewed annually and approved by the Board of Directors.
| Concern relates to | Report to |
|---|---|
| General operational concerns | Line manager or Principal |
| Principal or senior leadership | Chair of Audit & Risk Committee |
| Board-level concerns | Chair of the Board of Directors (independent investigator may be appointed) |
| Regulatory breach (external) | Prescribed regulator under UK law |
| Risk and systemic themes | Audit & Risk Committee (periodic reporting) |
Last reviewed: 5 November 2025 · Version: 1.0 · Next review: November 2026
Download the full Whistleblowing (Protected Disclosure) Policy (PDF)