Model Policy for Schools –
Whistleblowing Procedure

1.  Introduction 

1.1  This Oxfordshire model procedure has been drawn up following consultation 
with all the recognised Trade Unions and Associations: ASCL, ATL, NAHT, 
NASUWT, NUT and Unison. 
1.2  Further advice and support on the application of this procedure is available 
from the Schools’ HR team by telephone: 01865 797588 

2.  Scope 

2.1   This procedure applies to all employees working in schools including agency 
workers, self-employed contractors and volunteers.
2.2  It is recommended that Academies also adopt this model procedure. Where an 
academy adopts this policy the word ‘school’ should be taken to refer to the 

3.  Policy Statement

3.1  The school is committed to the highest possible standards of:
•  Openness and inclusiveness
•  Accountability
•  Integrity in-line with that commitment
3.2  The aims of this procedure are to:
a)  encourage those working in the school to report suspected wrongdoing as 
soon as possible, in the knowledge that their concerns will be taken 
seriously and investigated as appropriate, and that their confidentiality will 
be respected.
b)  provide guidance on how to raise concerns.
c)  reassure those raising concerns that they are able to raise genuine 
concerns “made in the public interest” without fear of reprisals, even if they 
turn out to be mistaken.
3.3  The school’s governing body will provide all reasonable protection for those 
who raise concerns “made in the public interest”.
3.4  The governing body will be responsible for ensuring that appropriate personal 
support is offered both to an employee raising a concern and to any employee 
against whom allegations have been made under this procedure.
3.5  School employees who wish to raise a concern or grievance about their own 
employment, should refer the school’s grievance procedure. 

4.  What is 'Whistleblowing'? 

4.1   'Whistleblowing' is defined as 'raising concerns about misconduct within an 
organisation or within an independent structure associated with it' (Nolan 
Committee on Standards in Public Life). In the legislation it is called a 
protected disclosure. The Public Interest Disclosure Act 1998 (PIDA 1988) 
protects employees from suffering a detriment in their employment or being 
dismissed by their employer if they make disclosures in accordance with the 
4.2   An employee has certain common law confidentiality obligations to  their 
employer. However, in a limited set of circumstances whistleblowing may 
override these obligations if an employee reveals  information about  their
employment or the work of the School.  This guidance sets out the 
circumstances under which these disclosures may lawfully be made
4.3   A concern must relate to something which:
a)  is a breach of the school's policies; or
b)  falls below established standards or practice; or
c)  amounts to improper conduct, including something that may be:
  a breach of the law
  a failure to comply with a legal obligation
  a possible miscarriage of justice
  a Health & Safety risk
  damaging the environment
  misuse of public money
  corruption or unethical conduct
  abuse of pupils, students or other users
  deliberate concealment of any of these matters
  any other substantial and relevant concern
4.4.  These issues could have arisen in the past, be currently happening or likely to 
happen in the future. The law does not protect an employee who would be 
breaking the law in making the disclosure.
4.5   If you have a serious concern it should be reported using the following 

5.    How to Raise a Concern ('Whistleblowing')

5.1  All concerns will be treated sensitively and with due regard to confidentiality 
and where possible every effort will be made to protect your identity if you so 
wish. Nevertheless, this information will need to be passed on to those with a 
legitimate need to have this information and it may be necessary for you to 
provide a written statement or act as a witness in any subsequent disciplinary 
proceedings or enquiry. This will always be discussed with you first.
5.2   Where concerns are expressed anonymously the Headteacher in consultation 
with Chair of Governors will decide how to proceed. An investigation may be 
carried out, depending on the nature of the allegations and the 
evidence/information presented.

6.    Step 1

6.1   If you wish to raise a concern you should normally raise it with your line 
manager. This can be in person or in writing. 
6.2   The school recognises that sometimes it may be inappropriate for you to 
approach your line manager with your concern. In these circumstances, a 
number of alternatives are available depending on the nature of your concern. 
You can contact any of the following:
•  Headteacher
•  Chair of Governors/Academy Trust
•  Schools’ HR Team
•  Oxfordshire County Council, Director of Children, Education and Families 
•  Trade union 
6.3   Although you are not expected to prove beyond doubt the truth of your 
concerns, you will need to demonstrate that you have sufficient evidence or 
other reasonable grounds to raise them.
6.4   You may wish to obtain advice  from  a trade union representative or a 
colleague. You may choose to be represented by a trade union representative 
or colleague at any meetings that are required.

7.    Step 2

7.1   The person with whom you have raised your concern will acknowledge its 
receipt as soon as possible and will write to you within 10 days to let you 
know how your concern will be dealt with. 
7.2  The information you can then expect to receive is:
  an indication of how the concern will be dealt with
  an estimate of how long it will take to provide a final response
  whether any initial enquiries have been made
  whether further investigations will take place, and if not why not
  information about support available for you
7.3   The person with whom you have raised your concern will at the same time 
notify Schools’ HR that a whistleblowing allegation has been made.
7.4   Advice on dealing with concerns is available from the Schools’ HR team, the 
council’s Legal or Financial Services.

8.    Step 3

8.1   Initial enquiries will be made to decide whether an investigation is appropriate. 
Where an investigation is necessary, it may take the form of one or more of 
the following:
  an internal investigation by the Headteacher or a governor, which may, for 
example, take the form of a disciplinary investigation 
  an investigation by the Internal Audit Service
  a referral to the Police
  the setting up of an external independent inquiry

9.    Step 4

9.1   You will be informed of the outcome of any investigation, in writing, and/or of 
any action taken, subject to the constraints of confidentiality and the law.
9.2   If you do not feel your concern has been addressed adequately you may raise 
it with an independent body such as one of the following as appropriate:
  your trade union
  the Citizens Advice Bureau
  a relevant professional body or regulatory organisation
  a relevant voluntary organisation
  the Police
  the Local Government Ombudsman
  Oxfordshire Racial Equality Council
  Equality and Human Rights Commission
(See Annex 2 for further details).
9.3  You must make a disclosure “in the public interest”; and in the circumstances 
it must be reasonable for you to make the disclosure.
9.4   If there is an issue of an exceptionally serious nature which you believe to be 
substantially true, then you may disclose the issue to someone other than 
those listed in paragraph 9.2. In determining whether it is reasonable for you 
to have made a disclosure the identity of the person to whom the disclosure is 
made will be taken into account. Disclosures to anyone outside of the 
recognised bodies specified in 9.2 may not be protected disclosures under the 
9.5   You have a duty to the School not to disclose confidential information. This 
does not prevent you from seeking independent advice at any stage or from 
discussing the issue with the charity Public Concern at Work on 020 7404 
6609 and in accordance with the provisions of the Public 
Interest Disclosure Act 1998.
10.  Review and Reporting of the Procedure
10.1  For maintained and voluntary controlled school’s Oxfordshire County 
Council’s Chief Executive, as Head of the Paid Service, and the County 
Solicitor, as the Council's Monitoring Officer, have overall responsibility for this 
procedure. School Governing Bodies are responsible for the management of 
services and staff within their school. For voluntary aided and foundation 
schools the responsibility will lie with the Governing Body, and for academies 
with the Academy Trust.#

10.1  This procedure has been reviewed with reference to equalities, human rights 
and discrimination legislation. Confidential monitoring of the procedures is 
undertaken in order to gather data to help establish whether the procedure is 
operated in a fair and consistent manner. In undertaking monitoring the 
School will not identify individuals.
10.2  This procedure will be regularly reviewed by the Monitoring Officer to ensure 
that it continues to remain compliant and meets the needs of Schools and 
those working in schools.
Responsible Officer:   Monitoring Officer
Date:        July 2013
Review Date:    July 2015
Contact Details (Oxfordshire County Council) 
Schools’ HR  Tel. No: 01865 797588
Address: Unipart House, Garsington Road, 
Oxford, OX4 2GQ
Assistant Chief Executive/Chief 
Finance Officer 
Tel no: 01865 816399 
Address: County Hall, New Road, Oxford. 
0X1 1TH 
Web site: 
Chief Internal Auditor   Tel no: 01865 323875 
Address: County Hall, New Road, Oxford. 
OX1 1TH 
Web site: 
County Solicitor/Monitoring Officer   Tel no: 01865 323907 
Address: County Hall, New Road, Oxford. 
OX1 1ND 
Web site: 
Head of Human Resources   Tel no. 01865 815191 
Address: County Hall, New Road, Oxford. 
OX1 1ND 
Web site: 
Chief Executive   Tel no: 01865 815330 
Address: County Hall, New Road, Oxford. 
OX1 1ND 
Web site: 
Chief Executive’s Office
Children, Education & Families
Social Services
Public Health
Environment & Economy
01865 323574
01865 810163
01865 815827

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