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Whistleblowing (Protected Disclosure) Policy

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.

Commitment, scope and what constitutes whistleblowing

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.

This policy applies to:
  • All employees (all categories)
  • Consultants, contractors and agency staff
  • Governors and Board members
  • Volunteers
  • Students where concerns relate to institutional wrongdoing

Legal framework

Public Interest Disclosure Act 1998 · Employment Rights Act 1996 · Data Protection Act 2018

What counts as whistleblowing

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.

Governance, protection and confidentiality

Governance accountability:
  • Board of Directors — ultimate accountability for effective internal control systems including whistleblowing arrangements
  • Audit & Risk Committee — monitors effectiveness, receives anonymised summary reports, reviews systemic risks, ensures independence of investigations
  • Principal — operational implementation and ensuring disclosures are acknowledged and investigated

Where the allegation concerns senior leadership or the Board, the Chair may appoint an independent external investigator.

Protection from detriment

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.

Confidentiality

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.

Procedure for raising and investigating concerns

Concerns may be raised through:
  • Line management (where appropriate)
  • The Principal
  • The Chair of the Audit & Risk Committee
  • The Chair of the Board of Directors

Anonymous disclosures will be accepted.

1
Initial assessment

All disclosures acknowledged promptly. Assessed to determine policy scope, immediate protective action needed, and whether external referral is necessary.

2
Investigation

Independent investigating officer appointed. Gathers evidence, conducts interviews, produces written findings. External referral to auditors, regulators or law enforcement where appropriate.

3
Outcome

Outcomes may include disciplinary action, regulatory notification, process improvement or no further action. Whistleblower informed of outcome subject to confidentiality constraints.

External disclosure

Nothing in this policy prevents individuals from making a protected disclosure to a prescribed regulator under UK law where appropriate.

Malicious disclosures

Malicious or knowingly false disclosures may result in disciplinary action.

Monitoring

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.

Reporting routes and escalation

Concern relates toReport to
General operational concernsLine manager or Principal
Principal or senior leadershipChair of Audit & Risk Committee
Board-level concernsChair of the Board of Directors (independent investigator may be appointed)
Regulatory breach (external)Prescribed regulator under UK law
Risk and systemic themesAudit & Risk Committee (periodic reporting)

Last reviewed: 5 November 2025  ·  Version: 1.0  ·  Next review: November 2026

Download the full Whistleblowing (Protected Disclosure) Policy (PDF)