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Division of General Counsel, Governance and Compliance

Public Interest Disclosure Policy & Raising Concerns

Public Interest Disclosure and Raising Concerns about the University

The University believes that members of the University community should feel empowered to raise genuine concerns about serious wrongdoing without fear of receiving detrimental treatment as a result; the right for staff to do so is also set out in law. If you have a serious concern, please refer to the University's Public Interest Disclosure Policy below; if your concern falls within the scope of the policy, you can use the Raising Concerns process and reporting form linked below to report it. For concerns falling outside the scope of the policy, please refer to 'Reporting Other Concerns' below.

Raising Concerns Process

Scope of the Raising Concerns process

1.1 The Raising Concerns process should be used to report serious concerns raised about specific types of matters known as ‘protected disclosures’ or ‘qualifying disclosures’, namely where an individual reasonably believes that one of the following has occurred or is occurring:

  • the committing of a criminal offence (e.g. fraud);
  • failure to comply with a legal obligation (this may include, for example, obligations relating to freedom of speech and academic freedom, obligations under the Equality Act 2010, or compliance with the University’s Charter and Statutes);
  • a miscarriage of justice;
  • endangering the health or safety of any individual;
  • damage to the environment; or
  • deliberate concealment of information tending to show any matter failing within the above.

1.2 The Raising Concerns process should only be used in relation to the types of matters laid out in 1.1 above. Those wishing to raise concerns that do not fall within the scope of 1.1 should use other relevant University procedure(s) instead, as signposted below and at the end of the Public Interest Disclosure Policy.

1.3 Please note that whilst University students and/or workers of any subsidiaries, majority controlled associated undertakings, and joint ventures of the University can also use this reporting process to report concerns of this nature, the specific protection afforded in law in relation to these particular types of concerns only applies to ‘workers’ or staff of the University. Please refer to the University’s Public Interest Disclosure Policy for further details about this protection and the Public Interest Disclosure Act 1998.

Raising a concern

2.1 All concerns falling within this process should be submitted via the online reporting form or directly by email to the Head of Information Management. 

2.2 Any concern raised will be considered by the Head of Information Management in the first instance to ensure that it is a qualifying disclosure and that it is appropriate to be considered under this process. If this is not the case, the Head of Information Management will contact the reporting individual to confirm.

2.3 Where the concern is a qualifying disclosure, the Head of Information Management will contact the reporting individual to acknowledge its receipt. No further action is required by them unless it is considered necessary as part of the investigation. They may not receive any further information about any investigation or the outcome.

Investigation and outcome

3.1 Where the concern is a qualifying disclosure, and it requires investigation, the Head of Information Management will assess the nature of the concern to determine the appropriate route for escalation.

3.2 Most cases will be referred to the Chief Operating Officer, the Chief Financial Officer or General Counsel for investigation. If the concern relates to potential fraud, the Chief Financial Officer will carry out an investigation according to the Fraud Response Plan. If the concern relates to the individual who would normally investigate such types of cases, it will be referred to another appropriately senior/qualified individual at the University.

3.3 The Chief Operating Officer, Chief Financial Officer, or General Counsel may also appoint another appropriate person to undertake the investigation on her/his behalf, depending on the requirements of the investigation.

3.4 Upon the conclusion of an investigation, the investigator(s) will decide what, if any, further action is required. While the University cannot guarantee the outcome that the reporting individual is seeking, the University will deal with the concern fairly and appropriately. As noted in 3.1 above, the reporting individual may not be informed of the outcome.

Protections

4.1 University workers who raise concerns they reasonably believe to be in the public interest in accordance with Public Interest Disclosure Policy and legislation, will not suffer any detrimental treatment from the University as a result, even if they turn out to be mistaken.

4.2 However, if the University concludes that an individual has made malicious or vexatious allegations, that individual may be subject to the University’s disciplinary processes or other appropriate action.

Records and reporting

5.1 The Head of Information Management will keep a record of all concerns raised under the Public Interest Disclosure Policy and this process, including whether the concern was a qualifying disclosure, and details of any investigation and outcome. Upon the conclusion of an investigation, the investigator will report the outcome to the Head of Information Management.

5.2 Records relating to concerns will be kept in line with the requirements of the University’s Records Management policy.

5.3 The Head of Information Management will provide assurance reporting relating to the Public Interest Disclosure Policy through appropriate governance channels including termly report to the University’s Executive Team as necessary. Such reports will include the nature of any concerns received and the outcome of any investigation.

Contacts and advice

6.1 Any queries about the Raising Concerns process can be directed to the Head of Information Management or to the Public Interest Disclosure Policy point of contact, Karen Blackman Information Manager. 

6.2 Contact details for the individuals mentioned in the procedure, as well as Protect, the Whistleblowing Charity, are as follows:

6.3 Guidance and further information can also be provided by Protect, the Whistleblowing Charity. Their details can be found here:

Reporting other concerns

7.1 Concerns which are not qualifying / protected disclosures and fall outside of this process, can be raised through other appropriate University procedures, as follows:

*This page also includes information about applicant complaints