top of page
Whistleblowing Policy

Issue Date : Oct 2022

Reviewed By: Full Governing Board

Review Date: Oct 2024


1. Introduction

2. Scope

3. What is whistleblowing?

4. Protections for whistle-blowers

5. Obligations for the whistleblower

6. Confidentiality..

7. The School’s commitment

8. Obligations for the Governing Board

9. Whistleblowing procedure

9.1. Stage 1 – Disclosure

9.2. Stage 2 – Investigation

9.3. Step 3 – Report to Headteacher/Governors

9.4. Step 4 – Escalation

10. Data Protection

11. Contacts

1. Introduction
The aim of this Policy is to encourage employees and others who have serious concerns about any aspect of the
School to voice those concerns and feel secure in doing so.
It is important that any fraud, misconduct or wrongdoing is reported and properly dealt with. The School
encourages all individuals to raise any concerns they may have about the conduct of others or the way in which
the School is run.
The School is committed to the principles of honesty and integrity. A culture of openness and accountability is
critical to ensuring these values are authentically lived by.
This policy applies to all employees of the school, workers, agency staff, contractors, service providers,
volunteers, and governors of the School.
This policy does not form part of any employee’s contract of employment and it may be amended at any time.

2. Scope
If an employee’s concern relates to how they have been treated this should be raised under the grievance or
bullying and harassment policies.
The whistleblowing policy will not replace any existing policies or procedures. If misconduct is discovered as a
result of any investigation under this policy the School’s disciplinary policy will be used.
The School encourages individuals to disclose any concerns they may have regardless of whether they are covered
by this or another policy.

3. What is whistleblowing?
Whistleblowing means the reporting of information which relates to actual or suspected wrongdoing. This is
called a “qualifying disclosure”.
Qualifying disclosures are disclosures of information where the worker reasonably believes (and it is in the
public interest) that one or more of the following matters is either happening, has taken place, or is likely to
happen in the future.
- A criminal offence
- The breach of a legal obligation
- A miscarriage of justice
- A danger to the health and safety of any individual
-Damage to the environment
-Deliberate attempt to conceal any of the above.
If a worker is going to make a disclosure it should be made to the employer first, or if they feel unable to use the
organisations procedure the disclosure should be made to a prescribed person, so that employment rights are
It is not necessary for a whistleblower to have proof of such an act for the protections of this policy to apply.
Potential whistle-blowers are encouraged to seek support from a senior manager or their trade union
representative if they are unsure whether to make a disclosure or to access support in making a disclosure,
regardless of whether it is qualifying or not.

4. Protections for whistle-blowers
This policy has been written to take account of the Part IVA of the Employment Rights Act 1996 which protects
workers making protected disclosures.
A qualifying disclosure made to the worker’s employer is a protected disclosure. A qualifying disclosure made by
a worker under this policy will also be a protected disclosure.
A whistleblower who makes a protected disclosure has the right not to be dismissed (if they are an employee) or
subjected to any other detriment, because they have made a protected disclosure.
Dismissing, or subjecting a whistle-blower to any other detriment for raising a protected disclosure will be a
disciplinary offence.
The School will not determine that anyone should cease to work at the school on the basis that they have made a
qualifying disclosure in accordance with the law and this policy.
Whistle-blowers may seek support and advice from organisations such as the whistle blowing charity Protect
( / 020 3117 2520) or ACAS (

5. Obligations for the whistleblower
An instruction to cover up wrongdoing is in itself a disciplinary offence. A whistleblower who is told not to raise
or pursue any concern, even by a person in authority, should not agree to remain silent.
Whistleblowing to an external agency without first using the procedure below may be considered a breach of the
School’s Code of Conduct.
It is not appropriate to whistle blow to the media except in limited circumstances and where those
circumstances do not apply such whistleblowing may be considered gross misconduct.
Maliciously making a false allegation is a disciplinary offence

6. Confidentiality
The School encourages individuals to voice their concerns openly. If anyone wishes to raise concerns
confidentially, the School will make every effort to keep their identity secret.
The person(s) to whom the disclosure is made will consult with the whistleblower before divulging their identity
to any party, including an investigator.
The School does not encourage anonymous disclosures as this may makes it harder to establish the credibility of
an allegation and may make investigation difficult or impossible. Anonymous concerns will be taken seriously
and investigated as far as is possible under this policy.

7. The School’s commitment
Any matter raised under this policy and procedure will be investigated thoroughly, promptly and confidentially.
Whilst the person carrying out the investigation will aim to keep the whistle-blower informed of the progress of
the investigation and likely timescales, sometimes the requirement for confidentiality will prevent full
information about the investigation and any consequential disciplinary action from being disclosed.

8. Obligations for the Governing Board
An appropriate representative of the School (Headteacher or the governor named in section 11 (the named
Governor) will inform Hertfordshire County Council as the maintaining authority of any qualifying disclosures
at the earliest opportunity.
Concerns regarding financial irregularity will be reported to the Shared Internal Audit Service (SIAS); where
concerns relate to child protection these will be handled in keeping with the relevant policy of the School and
reported to the Local Authority Designated Officer (LADO) where the threshold is met.

9. Whistleblowing procedure
9.1. Stage 1 – Disclosure
The whistleblower should initially raise their concern with their line manager. They may do this orally or in
writing. The line manager should inform the Headteacher of the concern.
If the concern relates to the line manager or any person to whom they report (other than the Headteacher) the
whistleblower should raise the issue with the Headteacher.
If the concern relates to the Headteacher, the whistleblower should raise this with the named governor.
9.2. Stage 2 – Investigation
The Headteacher will arrange an investigation into the concerns raised, unless the concern relates to the
Headteacher, in which case the investigation will be arranged by the named governor. This will take place as
soon as is reasonably practicable.
The investigation may involve the whistleblower and other individuals involved meeting with the investigator
and giving a written statement.
At any investigatory meetings the whistleblower is entitled to be accompanied by a recognised trade union
representative or a work colleague.
9.3. Step 3 – Report to Headteacher/Governors
The investigator will report to the person who arranged the investigation before any further action is taken.
That person will decide on potential outcomes including, but not limited to:
- invoking the School’s disciplinary process, or other relevant policy
- referral to the police, Hertfordshire County Council department, government department or
regulatory agency
- no further action.
On conclusion of any investigation, the whistleblower will, as far as is practicable and where it is reasonable to
do so, be told the outcome of the investigation and what the Headteacher/,named governor has done, or
proposes to do, about it. If no action is to be taken, the reason for this will be explained.
9.4. Step 4 – Escalation.
If, on conclusion of stages 1, 2 and 3 the whistle-blower believes that the appropriate action has not been taken,
they should report the matter to the proper authority. The Public Interest Disclosure (Prescribed Persons) Order
2014 (as amended) sets out a number of bodies prescribed by the Secretary of State to which qualifying
disclosures may be made. In order for the report to one of these bodies to be a protected disclosure, the whistleblower must reasonably believe that the matter falls within the matters covered by that body. The whistleblower
must also reasonably believe that the information disclosed, and any allegations contained in it, are substantially
These bodies include:
- the Financial Conduct Authority (formerly the Financial Services Authority)
- the Health and Safety Executive
- the Environment Agency
-Her Majesty’s Chief Inspector of Education Children’s Services and Skills
- the Secretary of State for Education
- the Office of Qualifications and Examinations Regulation.
A full list can be obtained from the charity, Protect or the BEIS (Department for Business, Energy and Industrial
Strategy) list on the website. The DBEIS list contains a description of the type of matter covered by
each prescribed body. Alternatively, a whistle-blower may contact their professional association or trade union
representative for guidance.

10. Data Protection
When an individual makes a disclosure, the Headteacher/named governor will process any personal data
collected in accordance with the School’s data protection policy. Data collected from the point at which the
individual makes the report is held securely and accessed by, and disclosed to, individuals only for the purposes
of dealing with the disclosure.

11. Contacts
The School’s appointed Governor for this purpose is: Patrick Aikman
The independent whistleblowing charity Protect
Helpline 020 3117 2520

bottom of page