Whistleblowing Policy
- Edward Goredema
- Jun 2
- 6 min read
Updated: Jun 5
Revised February 2025, to be reviewed February 2026
Introduction
This policy sets out the values, principles and procedures underpinning The Warren
Neurodiversity Services’ approach to whistleblowing. The Warren Neurodiversity Service
understands “whistleblowing” to refer to actions taken by an employee or employees to
raise concerns about: - alleged, suspected or observed malpractice - assessed, identified or perceived risks (e.g. to the safety of service users) - unethical conduct or possible illegal acts
Any of the above could harm, or create a risk of harm, to service users, colleagues or the
general public.
The policy is in line with the Care Quality Commission (CQC) recommendations for the
reporting of concerns about service user care and the safeguarding provisions under
Regulation 13 of the Health and Social Care Act 2008 (Regulated Activities) Regulations
2014.
The right to whistleblow is also built into the practice of “Good Governance” as described in
Regulation 17, which requires care providers to be transparent and open and comply with
the Public Disclosure Act 1998 (and as amended under the Enterprise and Regulatory Reform
Act (ERRA) 2013).
The policy should be read and used to complement The Warren Neurodiversity Services’
complaints procedure.
The service recognises that “whistleblowing” is distinct from a complaint in that
“whistleblowers” raise their concerns as employees. Complaints about a service are raised
by service users, others acting on their behalf or members of the public. However, it is
recognised that similar procedures should be followed to respond to complaints and
whistleblowing.
Principles
“Whistleblowing” principles can be summarised as follows: - Healthcare services should be promoting open, transparent cultures, which encourage staff to: - Act on and report any concerns about practices that fall below acceptable standards - Staff members are those most likely to observe and be in a position to report on bad practice - Employees, who raise genuine concerns about harmful practices, which they come across in their work (as described above) must be taken seriously and seen to be acting correctly - They should not be regarded as “troublemakers” to be penalised in some way by their employing organisation - The employing organisation should listen to and thoroughly investigate every concern raised by a staff member as they would if the matter was raised as a complaint by a patient or others acting on their behalf - In line with the Public Interest Disclosure Act 1998, the service must make sure that staff members who raise, in good faith, reasonable concerns about unacceptable practices are
not victimised as a result.
The Warren Neurodiversity Service applies these principles in their approach to
whistleblowing policy and the procedures it expects its staff to follow.
Obligations on staff to report malpractice, unacceptable risks and wrongdoing
The Warren Neurodiversity Service recognises that its staff members have a duty of care,
moral and legal obligations to report all incidents where they consider vulnerable adults or
colleagues to have been harmed or are at serious risk of being injured or harmed in the
course of their work.
The service considers that these obligations to report such incidents, which include
suspected breaches of The Warren Neurodiversity Services’ or other employees’ professional
codes of conduct, override any other considerations such as loyalty to colleagues.
Any member of staff who witnesses or suspects abuse by another member of staff should
report the matter without delay to their supervisor or manager. The manager will accept
responsibility for the actions that follow and will assure the “whistleblower” that they have
acted correctly by reporting the matter, will not be victimised and their confidentiality
assured unless there are overriding, e.g. legal reasons for disclosing their identity.
The service accepts that there may be occasions when the staff member does not feel
confident or able to report in the first instance to the manager. In these circumstances, it is
recognised that the “whistleblower” might need to take their concerns to a more senior
manager or the registered person.
The service also accepts the right and obligation of any staff member, who thinks that their
concerns are not being or might not be properly responded to or addressed, to report their
concerns to an outside authority. This could be the police, the local safeguarding adults
authority or the CQC.
Each of these organisations can be expected to respond in line with their respective
procedures. Again, in line with its Public Disclosure Interest Act responsibilities, The Warren
Neurodiversity Service will not penalise or victimise any staff member who responsibly reports
their concerns in any of these ways.
PIPOT (Person in a Position of Trust)
Where concerns relate to a staff member who is in a position of trust and may pose a risk to
vulnerable adults, the Designated Safeguarding Lead must be informed. The Designated
Safeguarding Adult Manager (DSAM) within the local authority will also be notified, in line
with the local authority’s PIPOT protocol. Concerns relating to staff conduct that may present
a risk must be referred regardless of whether the concern relates to conduct within or outside
the work environment.
Safeguarding Children
The Warren Neurodiversity Service recognises its duty under Section 11 of the Children Act
2004 to ensure that it carries out its functions having regard to the need to safeguard and
promote the welfare of children. Whistleblowing procedures apply equally to concerns
relating to the safety or wellbeing of children.
Where a member of staff suspects abuse or risk to a child, they must report their concern to
the Designated Safeguarding Lead immediately. If the concern relates to the behaviour of a
staff member, it must be reported to the Local Authority Designated Officer (LADO) within
the Surrey Safeguarding Children Partnership.
Contact details for the Surrey LADO:
Phone: 0300 123 1650
Email: lado@surreycc.gov.uk
Commitment to staff
The Warren Neurodiversity Service assures its staff that their concerns about any possible
mistreatment of its service users will be listened to and investigated. The service undertakes its
responsibility to assess and investigate any concerns impartially and objectively, so that it
can be fair to all parties concerned in seeking to clarify the facts before taking further
actions.
The service’s management will keep any staff members affected by an investigation aware
of the actions being taken and the outcomes, considering the need to respect the possible
confidentiality of some of the information relating to other staff members and service users,
which has developed in the process of the investigation. Information will usually be treated with the utmost confidence. This might not be possible in all cases, e.g. if the alleged malpractice requires reporting to the police and/or the local safeguarding authority.
Staff are also made aware that all instances of alleged or actual abuse must be notified to
the local safeguarding authority and to the CQC under its notification of serious incidents
procedures.
Investigating and dealing with allegations
The manager to whom abuse by a staff member is reported will take the necessary steps
under the safeguarding policy. In addition, the manager will if possible protect the source of
the information.
If a manager fails to act promptly, suppresses evidence or is involved in any action to
discourage whistleblowing, they will be liable to disciplinary action.
Where the whistleblower has gone directly to the CQC or local safeguarding authority to
report their concerns, The Warren Neurodiversity Service will always co-operate fully with any
resulting enquiries and investigations, and take all necessary actions from the outcomes.
Dealing with interference with or victimisation of “whistleblowing” staff
Any member of staff who attempts to prevent a staff member from reporting their concerns
to a manager or who bullies, attempts to intimidate or discriminates against a colleague in
these circumstances will be dealt with under disciplinary proceedings.
A whistleblower who feels themselves to be subject to hostile action from colleagues should
inform their manager, who should if necessary take steps to alter the staff member’s duties so
as to protect them from the hostile action.
Training
All new staff receive training in this policy on whistleblowing as part of the induction training.
All staff receive updated training as policies change.
The Warren Neurodiversity Service provides staff with information on how to contact Protect
(formerly Public Concern at Work), an organisation that has been established to protect
whistleblowers from victimisation and bullying.
Unjustified reporting
The Warren Neurodiversity Services’ managers take reports from whistleblowers seriously and
investigate all allegations thoroughly. Any allegations against colleagues, however, which
are found to be unwarranted or malicious, may render the person who made them liable to
disciplinary action.
Information
The Warren Neurodiversity Service provides staff with the following information, which they
may need to help raise a concern in confidence:
Whistleblowing Helpline for NHS and Social staff: Tel. 08000 724 725;
Email: enquiries@wbhelpline.org.uk
How to contact the CQC: Tel. 03000 616161; Email: enquiries@cqc.org.uk
Local Safeguarding Authority (Adults): Surrey
Phone: 03456 009 009
Email: contactcentre.adults@surreycc.gov.uk
Local Authority Designated Officer (Children): Surrey
Phone: 0300 123 1650
Email: lado@surreycc.gov.uk