Whistleblowing and Confidential Disclosure Procedures

These procedures are applicable to all Governors, employees, associates, volunteers, Student Teachers, agency staff and other workers engaged by Cheadle Hulme School. Other individuals working within the School community are also encouraged to raise relevant concerns through these arrangements.

Scope

This document explains how an individual can raise a concern about suspected wrongdoing, malpractice or risk within Cheadle Hulme School and how the School will respond.

The School wants individuals to feel able to speak up where something does not seem right. Concerns raised under this procedure will be taken seriously, considered fairly and handled as sensitively as possible.

No individual should suffer detriment, victimisation or unfair treatment because they have raised a genuine concern which they reasonably believe to be in the public interest.

Legal Framework

This procedure is informed by and operates in line with the Public Interest Disclosure Act 1998 (PIDA).
Under this legislation, individuals are protected from victimisation or dismissal where they raise a qualifying disclosure in the public interest, in good faith, and in accordance with this procedure.

What is Whistleblowing?

Whistleblowing is the disclosure of information where an individual reasonably believes that wrongdoing has occurred, is occurring or is likely to occur and that raising the concern is in the public interest.

Examples include:

• safeguarding failures or risks to children or young people;
• criminal offences or suspected criminal activity;
  fraud, financial mismanagement or corruption;
• failure to comply with a legal, statutory or regulatory obligation;
• health and safety risks;
• misuse of School funds, resources or assets;
• damage to the environment;
• unethical conduct or serious breaches of School policies;
• sexual harassment where the concern constitutes a protected disclosure; or
• deliberate concealment of any of the above.

An individual raising a concern is not expected to prove that wrongdoing has occurred. They should have a reasonable belief that the information they are disclosing tends to show wrongdoing and that raising it is in the public interest.

Safeguarding concerns

The safety and welfare of pupils remains paramount. Where a concern relates to the safeguarding or welfare of a child, it must be reported promptly in accordance with the School's Safeguarding and Child Protection arrangements. Nothing in this procedure should delay an immediate safeguarding referral or action required to protect a child.

A safeguarding concern may also amount to a whistleblowing concern, depending upon the circumstances.

Sexual Harassment and Protected Dislcosures

Concerns relating to sexual harassment may fall within this Whistleblowing Procedure where they indicate wider risk, wrongdoing, or a failure to meet legal or regulatory obligations.

Sexual harassment includes unwanted conduct of a sexual nature which violates an individual’s dignity or creates an intimidating, hostile or offensive environment.

Where concerns suggest a broader issue (for example, repeated behaviour, inaction, or risk to others), they may be raised as a protected disclosure under this procedure.

Concerns may also be addressed through other procedures, including the Grievance Procedure or Safeguarding Procedures, and advice can be sought from HR where needed.

Whistleblowing or a grievance?

Whistleblowing is different from raising a personal grievance.

A concern which relates principally to an individual's own employment circumstances – for example their working arrangements, treatment by a colleague or manager, or an individual employment decision – will normally be considered under the Staff Grievance Procedure.

A concern may, however, affect an individual personally while also raising a wider issue affecting colleagues, pupils, the School or the public interest. In these circumstances, HR can provide guidance about the most appropriate procedure. It may sometimes be appropriate for different aspects of a concern to be considered under different procedures.

Raising a concern

Concerns should normally be raised as soon as reasonably practicable.

Where appropriate, an individual may raise a concern with their Line Manager. They are not, however, required to do so where they do not feel comfortable using this route or believe that their Line Manager may be involved.

A concern may therefore be raised directly with:

• the Head; or
• a member of the Executive Team.

Where the concern relates to, or may involve, a member of the Executive Team, it should be raised with the Head.

Where the concern relates to, or may involve, the Head, it should be raised directly with the Chair of Governors.

Where the concern relates to the Chair of Governors, advice should be sought from the Clerk to the Board of Governors or Head about an appropriate alternative Governor to receive the disclosure.

No individual is expected to raise a concern with someone whom they reasonably believe may be involved in the alleged wrongdoing.

How to raise a concern

Concerns should preferably be raised in writing, although a concern raised verbally will also be considered.

Individuals should provide as much information as reasonably possible, including:

• the nature of the concern;
• the names or roles of people involved, where known;
• relevant dates and locations;
• the reasons for the concern;
• any relevant documents or other evidence;
• whether the concern has previously been raised and, if so, with whom; and
• details of any personal interest they have in the matter.

Individuals should not attempt to investigate the matter themselves or obtain evidence in a way which could place themselves or others at risk.

Confidentiality and Anonymity

The School will treat whistleblowing concerns sensitively and will seek to protect the identity of the person raising the concern so far as reasonably practicable.

Absolute confidentiality cannot be guaranteed. Information may need to be disclosed where this is necessary to investigate the concern, protect a child or another individual, comply with a legal obligation or enable the person who is the subject of an allegation to respond fairly.

Where disclosure of identity may become necessary, this will normally be discussed with the whistleblower beforehand where it is appropriate and lawful to do so.

Anonymous concerns will be considered. However, anonymity may make it more difficult to investigate the matter, obtain further information or provide feedback about the outcome.

Initial Response

The recipient of the concern will normally acknowledge it within seven working days.

An initial assessment will be undertaken to determine:

• whether the concern falls within this procedure;
• whether immediate action is required;
• whether safeguarding, regulatory or criminal issues arise;
• whether another School procedure should apply; and
• whether further investigation is required.

The individual raising the concern may be invited to a meeting to provide further information. They may be accompanied by a trade union or professional association representative or a work colleague.

If the concern is more appropriately dealt with under another procedure, this will be explained to the individual.

Investigation 

Where there is sufficient cause for concern, an appropriate investigation will be commissioned.

The person appointed to investigate will be sufficiently independent of the matters raised and will approach the investigation impartially.

Depending upon the nature of the concern, this may involve:

• reviewing relevant documents, records or correspondence;
• interviewing the whistleblower;
• interviewing individuals who are the subject of the concern;
• speaking with relevant witnesses;
• obtaining specialist advice;
• appointing an independent external investigator; and/or
• referring matters to an appropriate external body, regulator, safeguarding authority or the police.

The whistleblower will be given an indication of how the matter will be considered and, where reasonably possible, the anticipated timescale.

Investigations will be undertaken as promptly as reasonably practicable while ensuring that matters are considered thoroughly and fairly.

Wellbeing and support

Whistleblowing concerns can be difficult for everyone involved.

Throughout the process, the School will consider appropriate wellbeing support for both the individual raising the concern and anyone who is the subject of the concern.

Support may include an identified point of contact, access to the Employee Assistance Programme, appropriate workplace adjustments or signposting to other sources of support.

The School will also consider any reasonable adjustments required to enable an individual to participate fully in the process.

Outcome 

Following an investigation, the investigator will normally prepare a report setting out the evidence considered, findings and any recommendations.

Appropriate action will be determined by the relevant decision-maker. This may include:

• no further action;
• changes to School procedures, systems or working practices;
• training or other organisational action;
• consideration under another School procedure;
• referral to a safeguarding or regulatory body; or
• referral to the police or another external authority.

The individual who raised the concern will be informed of the outcome as far as reasonably practicable.

The School may not be able to provide details relating to another individual's personal information, disciplinary action or other confidential matters.

Where appropriate, the School will also consider whether wider organisational learning or changes to policy, practice, training or culture are required.

If the individual remains concerned

Where an individual believes that their concern has not been considered appropriately, they may raise the matter with another appropriate person identified within this procedure, including the Head or Chair of Governors.

External disclosures

The School encourages individuals to raise concerns internally where it is appropriate to do so. This provides the School with an opportunity to investigate and address concerns promptly.

There may, however, be circumstances in which an individual considers it appropriate to make a disclosure to an external prescribed person or body.

Depending upon the nature of the concern, this could include an appropriate regulator, safeguarding authority, inspectorate, the Charity Commission or the police.

Individuals considering an external disclosure are encouraged to obtain independent advice to understand the protections available to them and the appropriate body to approach.

Independent and confidential whistleblowing advice is available from Protect (formerly Public Concern at Work).

Protection from detriment

The School will not tolerate victimisation, harassment, retaliation or other detrimental treatment of an individual because they have raised a genuine whistleblowing concern.

Any individual who believes they have experienced detrimental treatment because they raised a concern should report this to HR, the Head, a member of the Executive Team or Chair of Governors as appropriate.

Retaliation against a whistleblower may itself be treated as a disciplinary matter.

A confidentiality clause, non-disclosure agreement or provision within a settlement agreement or contract of employment cannot prevent an individual from making a protected disclosure where they are entitled to do so by law.

Concerns which are not substantiated

No action will be taken against an individual simply because a concern they raised is not subsequently substantiated.

Individuals are encouraged to speak up where they reasonably believe wrongdoing may have occurred, even where an investigation ultimately finds that there is no case to answer.

Where there is evidence that an allegation has been deliberately fabricated, made maliciously or knowingly contains false or misleading information, the School may consider the matter under the Staff Investigation, Disciplinary and Appeals Procedure.

SLT member responsible:

Director of Finance

supported by the Human Resources Manager

Governor committee responsible:

HR Steering Group

Date of review:

August 2026

Primary policy:

Safer Recruitment and Human Resources Policy

Other related policies and procedures:

Equality, Diversity and Inclusion Policy

To view previous versions of this document please email enquiries@chschool.co.uk