Whistleblowing & Concerns Policy
EXPRESSING CONCERNS AND ‘WHISTLEBLOWING’: POLICY AND GUIDANCE
‘Whistleblowing’ has been recognised as having an important place in developing a strong safeguarding culture within organisations. At the simplest level, anyone can spot a genuine concern and it is important that everyone who does so feels safe to raise that concern. At a more fundamental level, organisations – including the church – can become hierarchical and opaque, and a strong whistleblowing policy recognises the importance of empowering those who may not hold positions of structural influence within the organisation to feel confident enough to speak out, should they believe poor practice to be present.
No one who raises a concern in good faith will suffer any adverse consequences as a result, regardless of whether the concern was found to be justified or not.
The aim of this policy and associated guidance is to provide a clear and transparent way for anyone involved in the parish of St Johns, Copthorne to raise genuine concerns regarding poor practice. It also aims to ensure that any concerns are dealt with effectively and in a timely fashion. This policy and guidance provide a simple set of steps to deal with concerns, ensuring that people are not penalised for raising genuine concerns, even if those concerns appear to be unfounded. This policy and guidance apply to everyone involved in the parish of St Johns, Copthorne, including all workers who are involved on either a paid or voluntary basis.
Like all parish safeguarding policies, this policy should be easily available for all – for instance at the back of church and on the church website. It should not be necessary for someone who wants to see this policy to ask a leader within the church to provide it.
Procedure in Response to Whistleblowing
- Review who is best placed to investigate the concern to ensure an independent, fair and objective outcome.
- Agree and stick to a timescale for dealing with the concern raised. Ensure the timescale is proportionate to the concern raised.
- Establish the facts, for example obtaining accounts from all involved and examining appropriate records, to ensure a thorough and fair investigation
- Take advice from the diocese as appropriate.
- Report outcome(s)to the PCC and the individual who raised the concern.
- Implement changes if indicated.
If a whistleblower gives us their personal information, we will confirm with them whether they wish for us to treat it openly or confidentially. If they ask for confidentiality, they should be informed clearly that we will not share their information without their consent unless required by law to do so. An example of where we might be required to disclose identifying information would be where there is a safeguarding issue which we must refer to a third party for example Diocesan Safeguarding Team, Social Services and Police or where a criminal act is suspected.
We will explain to the individual that protecting their identity may in some circumstances mean we are unable to resolve a concern without revealing their identity, for example where their personal evidence is essential. In such cases, we will discuss with the individual whether and how the matter can best proceed.
It will be much more difficult for us to look in a concern raised anonymously. For example we will not be able to provide any feedback on the investigation or be sensitive to the whistleblower’s personal position.
When a concern is raised, we will want to understand:
- What the individual has witnessed to indicate there may be wrongdoing or malpractice
- What or who may have been put at risk (for example the welfare of an individual, church finances, health and safety issues)
- Whether their concern has been raised with any individual(s) directly by the whistleblower in the past.
The length of time it will take to be able to reach the stage when the whistleblower can be notified outlining what has happened in response to the concern, will depend upon the nature of the concern and the type of action, if any, taken. For reasons of confidentiality it may only be possible to offer limited information.
However it should be possible to indicate whether:
- An investigation has taken place and whether the concern raised was found to be justified or not.
- It has been necessary to refer the matter on further within the Diocese.
- Changes have been made and what they are.
IF THE CONCERN IS IN RELATION TO SAFEGUARDING FOR ADULTS OR CHILDREN, THE GUIDANCE OUTLINED IN THE SAFEGUARDING POLICY MUST BE FOLLOWED.
In other circumstances (in increasing order):
- Lay Leader in Church (e.g. Children’s Work Leader) or Church Manager
- Incumbent /Churchwardens (Churchwardens in a vacancy)
- Archdeacon Horsham
- Bishop Horsham
Additionally the Rural Dean may be able to offer advice in the earlier stages.
What to do if a concern is expressed to you
- If someone tells you that they have a concern, you should arrange to meet him/ her as soon as possible.
- Approach the situation sensitively, recognising the discomfort that the person may feel. Offer to meet him/her away from the church if they wish and allow them to bring a friend if that would help.
- Do not promise confidentiality: you do not know what they are going to share but if they share an immediate safeguarding concern, you will have no choice other than to break that promise.
- However, be prepared to discuss the possibility of anonymity for the person sharing the concern. People may have reasons to want to stay anonymous, even if they know they have to say something and closing this option off may mean that the concern never gets aired.
- Reassure the person that there will be no negative repercussions for any concern shared in good faith – even if it turns out to be unfounded or mistaken. ‘Concerns’ shared out of malice or divisiveness are a different matter but at this stage, assume the person to be acting in good faith.
- You may wish to suggest sources of support for the person – especially if they are on their own without the support of a friend or family member. Sharing concerns in an institutional context can be very intimidating – even in church – and the concern may have been a source of great anxiety for a long time. The person may be sharing the concern with you because this anxiety has reached the point where they feel compelled to act. In coming to you they are expressing a great measure of faith that they will be well-received and not have their intentions misinterpreted. They may wish to speak to someone outside of the immediate context to receive some pastoral support (for instance from a neighbouring parish)/
- Recognise that not everyone expresses genuine concerns appropriately. Someone can say something in the wrong manner, at the wrong time and with the wrong language – but still be right. Don’t be too quick to dismiss what someone says because of how they say it.
- Make notes of the conversation, ideally at the time or immediately afterwards.
- Follow-up your conversation in writing as soon as you can. “On date X, you expressed your concerns about Y. I replied by saying I would look into what you said and would get back to you by date Z’. This helps provide clarity for all involved.
- Make sure you are clear about what you will do with the concern, by when you will do it, and when you will let the person know. Give the person a clear indication of when they can expect to hear back from you and keep to this promise if you have made no progress – hearing from you with no news is better than not hearing from you.