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DCW29-Whistleblowing (Speaking Up) Policy

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Registration Number: {{org_field_registration_no}}

Whistleblowing (Speaking Up) Policy

1. Purpose

The purpose of this policy is to provide a safe and confidential way for staff to speak up about any wrongdoing, misconduct, or failures in care within {{org_field_name}}. We want all team members to feel confident that they can raise concerns without fear. This policy meets the requirements of Care Inspectorate Wales (CIW) and supports a culture of openness, integrity, and accountability. At {{org_field_name}}, we are committed to encouraging staff to report concerns without retaliation, to investigating all concerns fairly and promptly, and to protecting whistleblowers from victimisation or discrimination. We also ensure we meet our legal and regulatory obligations to report concerns to CIW and other relevant bodies when required.

This policy fulfils the Regulated Services (Service Providers and Responsible Individuals) (Wales) Regulations 2017 duty to maintain effective arrangements for staff to raise concerns (including agency and volunteers), and requires the Responsible Individual to assure the policy is implemented in practice, not just on paper. Where concerns indicate abuse, criminality, or serious misconduct, external notifications (Local Authority safeguarding, CIW, police) are made without delay.

2. Scope

Welsh language and accessible routes. Staff can raise concerns and receive all correspondence, meeting invites and outcomes in their preferred language and format (Active Offer of Welsh; large print; interpreter). We record agreed adjustments in the case file and keep them under review throughout the process.

This policy applies to everyone working with or for {{org_field_name}}. It includes all employees (whether full-time, part-time, or agency staff), as well as volunteers, contractors, and agency workers providing services on our behalf. Former employees who wish to raise concerns after leaving are also covered under this policy. In essence, anyone performing work for {{org_field_name}} can use this whistleblowing procedure.

What types of concerns can be raised? This policy is for reporting any situation where you believe something is wrong or endangering the people in our care or our workplace. Examples include, but are not limited to:

If you have a genuine concern that something isn’t right in any of these areas (or similar issues), this policy provides a way to speak up and have the matter addressed. It is important to note that whistleblowing is about matters of general concern (often in the public interest); personal grievances (for example, personal employment disputes) are usually handled through our Grievance Policy rather than this Whistleblowing Policy. If you are unsure which policy applies, you can ask a manager for guidance without immediately having to disclose details.

3. Roles and Responsibilities

Everyone at {{org_field_name}} has a responsibility to help maintain a culture of openness and safety. This section outlines who is responsible for what in relation to whistleblowing:

Ultimately, every individual in the organization has a part to play in creating an environment where speaking up is encouraged. By fulfilling these responsibilities, we ensure that concerns are identified early and handled properly, protecting our service users and our staff.

Allegations involving leadership. If the concern implicates the line manager, Registered Manager or Responsible Individual, an impartial senior manager (or external investigator) will handle the case and chair any meetings/appeals to preserve independence. The alternative decision-maker will be confirmed in writing.

4. Legal and Regulatory Framework

This policy is designed to meet all relevant laws and regulations in Wales regarding whistleblowing and care standards. The following are key pieces of legislation and guidance that inform our approach:

Summary: This Whistleblowing Policy is grounded in the above laws and guidelines. It is regularly reviewed and updated to remain in compliance with any changes in legislation or regulation. By adhering to this policy, {{org_field_name}} and its staff will meet the legal requirements and embody the ethical standards expected in Welsh social care.

5. How to Raise a Concern

We understand that it can feel difficult to raise a concern, but we want to reassure you that you can and should speak up about anything that worries you. We will take every concern seriously and handle it fairly. Below we outline how you can report a concern, either internally within {{org_field_name}} or to external authorities. You do not need to have proof of wrongdoing – a reasonable belief or suspicion is enough to raise a concern. The sooner you raise it, the better we can address it.

5.1 Internal Reporting Process

Wherever possible, we encourage you to report concerns through our internal channels first. Often, issues can be resolved quickly within the organization. The normal steps to follow are:

  1. Report to Your Line Manager: If you feel comfortable, start by telling your immediate supervisor or line manager about your concern. Explain what you have seen or believe is happening. In many cases, the line manager can investigate or correct the issue promptly at a local level. We train our managers to be receptive and responsive to such reports. There will be no blame for raising something in good faith. For example, if you observed a safety risk or a lapse in care, your manager would want to know so that they can fix it and keep people safe.
  2. Report to the Registered Manager: If the problem involves your line manager (for instance, if you suspect your line manager in the wrongdoing), or if you reported it to them but did not feel it was addressed properly, you should escalate the concern to the Registered Manager of the service. The Registered Manager has a higher level of authority and oversight. You can approach the Registered Manager directly with your concern – either in person, in writing, or by phone. Make it clear that you are raising a whistleblowing concern. The Registered Manager will ensure the matter is looked into thoroughly. They may appoint an impartial investigator or look into it themselves, depending on the nature of the issue. At this stage, the Responsible Individual will likely be informed as well, to ensure senior oversight.
  3. Report to the Responsible Individual: If you have tried the above and still feel that the issue is not resolved or taken seriously, or if you believe the problem is truly widespread or involves senior members of staff such that the normal management cannot address it, you should contact the Responsible Individual of {{org_field_name}}. The Responsible Individual is ultimately accountable for the service. You can reach them by [insert appropriate contact method – e.g., email or phone, if available]. When you raise a concern to the Responsible Individual, they will review the handling of your concern and may initiate a new investigation or take action as needed. Bringing a concern to this level is appropriate when other channels have failed or when you genuinely feel you cannot use them. The Responsible Individual will appreciate that you are bringing an important matter to their attention and will ensure it is not ignored.

Contact channels:

Contact channels:
• Email the Registered Manager: {{org_field_registered_manager_email}}
• Call the office: {{org_field_phone_no}} · Out of hours: {{org_field_out_of_hours}}
• Secure web form: {{org_field_website}} (contact page)
We acknowledge concerns within 48 hours and begin enquiries within 5 working days (sooner for safeguarding or criminal risk). Progress updates are provided without breaching others’ confidentiality.

Throughout this internal process, we manage concerns efficiently and sensitively. Typically, once you report a concern, we will acknowledge it within 48 hours so you know it has been received. We aim to start looking into the matter within 5 working days (often sooner). You will be kept informed about the progress of the investigation in a way that doesn’t breach anyone else’s confidentiality. For example, we might update you that “the issue is being investigated by an external person” or “steps are being taken to address the situation,” without sharing detailed confidential information. If at any point you feel your concern is not being handled properly or you are uncomfortable with the process, remember that you can bypass a level (for example, go directly to the Registered Manager or Responsible Individual) – especially if the concern implicates the person who would normally handle it.

Anonymous options and no-gagging rule. Concerns may be raised anonymously and will be examined as far as the information allows. We do not use non-disclosure agreements or settlement terms to prevent, restrict, or deter protected disclosures or cooperation with regulators. Managers must never discourage speaking up. Breach of these standards is misconduct.

5.2 External Reporting (Reporting to Outside Authorities)

You may raise concerns externally at any time, especially where there is risk of harm, criminality, or you believe internal processes won’t be fair or effective. Protected disclosures to regulators (e.g., CIW, Social Care Wales) and safeguarding referrals are lawful and must not result in detriment. We cooperate fully with any external investigation.

We hope and expect that most concerns can be addressed internally. However, if you do not feel safe or able to raise a concern within {{org_field_name}}, or if you have raised it internally but are not satisfied with the outcome, you have the right to report the issue to appropriate external agencies at any time. You will not face disciplinary action or disadvantage for making a legitimate external disclosure in these circumstances. In fact, the law specifically protects your right to reach out to certain external bodies. Here are the key external channels available:

Safeguarding / CIW contact pack. Staff can use the following live contacts for urgent escalation:
• Local Authority Safeguarding: {{org_field_local_authority_authority_name}} — {{org_field_local_authority_phone_number}} (OOH {{org_field_local_authority_out_of_hours_phone_number}}) · {{org_field_local_authority_authority_email}} · Info: {{org_field_local_authority_information_link}}
• Social Care Wales (fitness to practise): via regulator website
• Police: 999 emergency / 101 non-emergency
Managers ensure posters/signage with these details are visible in staff areas and refreshed as numbers change.

When contacting any external body, you should give as much detail as possible about the concern (what is happening, who is involved, dates, any evidence you have, etc.). You do not need to prove the wrongdoing; you only need to honestly believe that it is happening. It is okay to report externally – you do not need our permission, and you will not be punished for it. We have posters and leaflets in our workplace with up-to-date contact details for CIW, the local safeguarding team, and other relevant bodies (these are posted on the staff notice board and included in the staff handbook). We ensure every staff member knows that they have the right to go outside the organization if necessary.

Note: We do encourage you to try internal routes first in most cases, because often we can resolve things quickly. However, we understand there are situations where you might fear retaliation or believe an internal report would not be effective (for example, if the highest levels of management might be involved in wrongdoing). In such cases, going directly to an outside authority is both acceptable and protected by law. The bottom line is: doing nothing is not an option – if something is wrong, please speak up through one of these channels so that the issue can be addressed.

6. Confidentiality and Protection for Whistleblowers

We know that whistleblowers often worry about what will happen to them if they speak up. {{org_field_name}} is committed to protecting anyone who raises a concern. This section explains how we handle confidentiality and how we safeguard whistleblowers from retaliation or harm.

6.1 Confidentiality

Confidentiality and data protection. We limit disclosure to a strict need-to-know basis and store case files securely in line with DCW34. Where law requires disclosure (e.g., safeguarding enquiries, police), we will explain what information must be shared and why. Case records include the concern, actions, advice received, decisions and outcomes.

All whistleblowing reports will be treated in confidence. This means that when you raise a concern, the details will be shared only with those who need to know in order to investigate or address the problem. We will not reveal your identity as the whistleblower to other staff or external people unless it is absolutely necessary to do so. In some cases, we might need to disclose your identity (for example, if your report leads to a police investigation or if it’s necessary to involve a safeguarding authority that asks for cooperation). However, even in those situations, we will discuss it with you first if possible and do everything we can to protect your position.

You are encouraged (but not required) to give your name when raising a concern, because this allows us to reach out to you for more information and to provide feedback. However, if you prefer to raise a concern anonymously, we will still consider and investigate it to the extent feasible. You can, for instance, send a written note without a name or use another anonymous method. Do keep in mind that anonymous reports can be more challenging to investigate – we can’t ask you for clarification and we can’t easily give you feedback. But they will not be ignored. We would rather have an anonymous report than let a problem continue. If you do choose to remain anonymous, please include as much detail and evidence as possible in your report so that we have something to go on.

During the investigation of a concern, those who are involved in the inquiry (which might include a manager, an HR representative, or an external investigator depending on the case) will be aware of the report. They are all bound to keep details confidential. We expect everyone to respect the sensitivity of whistleblowing allegations. Gossip or breach of confidentiality by any staff involved will be subject to disciplinary action. On the other hand, we might ask you as the whistleblower whether you consent to your identity being disclosed to certain key individuals if that would help resolve the issue (for example, if the allegation is about a specific person, sometimes it’s easier to handle if they know what they are being accused of and by whom). If you do not want your name revealed, we will honor that as far as possible. Even if your name is kept confidential, the matter will still be addressed.

We maintain records of whistleblowing reports in a secure manner. Any written records, emails, or documents related to your concern will be kept securely and only accessed by those responsible for managing the case. We do this not only to protect you, but also to ensure a fair process for anyone who might be implicated by the concern.

It is important to note that in some situations, absolute confidentiality may not be possible – for example, if the law requires disclosure of certain information. But in general, we will discuss with you how to proceed in a way that protects your identity. Our goal is to make you feel safe when speaking up.

6.2 Protection from Retaliation

Retaliation or victimisation against anyone who raises a concern is strictly forbidden at {{org_field_name}}. We want all staff to know that they can report issues without fear of losing their job, being demoted, or being mistreated by colleagues or managers as a result. We have a zero-tolerance approach to any form of punishment or harassment aimed at a whistleblower.

Examples of retaliation that are prohibited include: dismissal, disciplinary action, threats, bullying, unwanted changes to work hours or duties because you raised a concern, or any form of intimidation. If you believe someone is treating you badly or unfairly because you spoke up, you should report this to the Registered Manager or Responsible Individual immediately – that in itself is a serious issue. Any employee, regardless of position, who is found to have victimised or retaliated against a whistleblower will face disciplinary proceedings. Such behavior is considered gross misconduct and could result in dismissal.

We recognize that it requires courage to speak up, and we deeply value that courage. {{org_field_name}} will support you all the way. Your raising a concern will not be reflected negatively in your performance reviews, references, or opportunities for advancement. On the contrary, doing the right thing by reporting issues is part of being a responsible member of our team and will be acknowledged as such.

We have systems in place to monitor the well-being of staff who have reported concerns. For instance, our management (or designated Safeguarding Lead) will periodically check in with you after you’ve raised a concern, to ask if you are experiencing any problems as a result or if you need any support. This is to ensure that no subtle or indirect retaliation (perhaps from peers) is occurring. If you feel pressure or harassment, we want to know so we can intervene. Remember, whistleblower protection is also backed by law – the Public Interest Disclosure Act makes it unlawful for an employer to subject a whistleblower to detriment for speaking up. You have the right, ultimately, to legal recourse if you were treated badly for a protected disclosure, but our aim is to resolve any issues internally and promptly so it never comes to that.

In summary, no one will be allowed to punish you for raising a genuine concern. If any colleague tries to deter you from raising issues or retaliates afterward, that is against our policy and will be dealt with decisively. We want to create an environment where everyone feels safe to voice concerns – that way we can correct problems early and improve our service.

Managers complete check-ins with the whistleblower to monitor for subtle detriment (e.g., rostering changes, isolation). Any detriment triggers corrective action and, where appropriate, disciplinary action against those responsible.

6.3 Support for Whistleblowers

Speaking up about wrongdoing can be stressful. We are committed not just to protecting you from negative consequences, but also to providing you with positive support through the process. If you raise a concern, {{org_field_name}} will provide appropriate support measures:

Our aim is that no one ever regrets voicing a concern. If you experience any difficulties or have any needs during or after the process, please let us know. Supporting our staff is a core part of this policy – we are one team, and whistleblowers are valued team members who help us improve. By looking after each other in this way, we maintain a supportive environment for speaking up.

7. Investigation and Outcome

When a concern is raised under this policy, {{org_field_name}} will investigate it promptly and fairly. The exact process may vary depending on the nature of the concern (for example, a concern about a safety hazard might be handled differently than a complex fraud allegation), but generally we follow these steps to ensure a thorough approach:

7.1 Investigation Process

Initial Assessment: Once a concern is received, the first step is an initial review. The Registered Manager (or another appropriate person designated by management) will quickly assess the information to decide what kind of investigation or action is needed. This might involve determining if the concern is within the scope of this policy or if it should be handled under a different procedure (for instance, a personal grievance). If the concern relates to a potential criminal act or serious regulatory breach, we will also consider if immediate external notification is required at this stage (such as informing police or CIW). The initial assessment will also look at any immediate risks – for example, if the concern indicates someone is in danger, we will act at once to ensure safety while the investigation proceeds.

Timeframes and independence. We aim to start formal enquiries within 5 working days of receipt and conclude straightforward cases within 15 working days (complex cases may take longer; revised timelines will be shared). An investigator independent of the line of command will be appointed; in sensitive cases we may instruct an external investigator. Where safeguarding or criminal thresholds are met, internal steps are sequenced to avoid prejudicing external enquiries.

Appointing an Investigator: For most concerns, we will appoint an investigator who is independent enough to examine the issue impartially. This could be a senior staff member not involved in the matter, or an external investigator for serious or sensitive cases. The investigator will usually develop an investigation plan that may include interviews, reviewing documents/records, and gathering evidence. We aim to start the formal investigation quickly (usually within 5 working days of the concern being raised, as noted earlier). If the concern implicates individuals, those people may be removed from their duties temporarily (e.g., suspension or reassignment) pending the outcome, especially if that’s necessary to prevent further issues or to ensure a fair process.

Investigation and Evidence Gathering: The investigator will conduct a fair and objective inquiry. This typically involves interviewing the whistleblower (if known) to get full details, speaking with any other witnesses or people who might have relevant information, and reviewing any physical or digital evidence (such as care records, emails, financial statements, etc., depending on the allegation). We give the investigator appropriate authority and access to carry out their task. If the concern is about potential abuse or harm to a service user, the investigation might be coordinated with external agencies (like the local authority safeguarding team or police) to avoid interfering with any external investigations. In such cases, our internal process might take guidance from the external investigators on how to proceed. Throughout the investigation, confidentiality is maintained as much as possible.

Report and Conclusion: After gathering facts, the investigator will compile a report of findings. We set a target to conclude investigations in a timely manner – for example, aiming for completion within 15 working days for straightforward cases. (Complex cases may take longer, but you will be informed of any extended timelines.) The report will state whether the concern was substantiated (proven), not substantiated, or unable to be proven either way, and will outline the evidence and reasoning. It will also include recommendations for action. The findings are reviewed by the Registered Manager and/or Responsible Individual, who will then decide on the appropriate next steps. These could range from no action (if the concern was not substantiated and no issues were found) through to significant actions such as disciplinary measures against wrongdoers, changes in procedures, additional training, or referrals to external authorities if that hasn’t happened yet.

Taking Action: If the investigation finds that wrongdoing, misconduct, or a risk is present, {{org_field_name}} will act to correct it. This might mean fixing unsafe practices immediately, updating policies, providing extra training to staff, or in some cases reporting matters to CIW or others if that hasn’t already been done. If disciplinary action is warranted against an employee, we will follow our Disciplinary Policy to ensure fairness, but we will not hesitate to discipline or remove staff who breached our standards or put others at risk. Sometimes concerns lead to improvements rather than discipline – for example, a whistleblower might highlight a lack of proper equipment or training, resulting in management investing in better resources. Whatever the outcome, the goal is to address the root of the concern and prevent any recurrence.

Communication of Outcome: Once the investigation is concluded and actions decided, we will inform the whistleblower (if their identity is known) of the outcome in general terms. We might not be able to share every detail for reasons of confidentiality (for instance, we cannot typically share detailed information from someone else’s HR disciplinary process), but we will tell you what we can. For example, we might say, “Your concern was substantiated and we have taken action to resolve the issue,” or “Our investigation did not find evidence to support the allegations, however we will continue to monitor the situation.” The whistleblower will also be told if any further steps will be taken, and if the case has been referred to an external body. We encourage whistleblowers to come to us with any questions they have about the process or outcome; we will answer what we can. The intent is that you feel heard and know that raising the concern led to a fair review.

We keep a clear timeline and documentation during investigations to ensure accountability. If at any point we realize the investigation will take longer than expected, we will update you with revised timelines. Findings from whistleblowing investigations are also used as a learning tool – if a problem was found, we consider whether changes in policy, procedure, or training are needed organization-wide. In this way, whistleblowing contributes to continuous improvement in our service.

Feedback and organisational learning. We provide outcome feedback to the whistleblower in general terms and log all cases (substantiated or not) in the Whistleblowing Log with themes, actions and learning. Findings inform training, supervision and policy updates, and are available to CIW on request.

7.2 Escalation if the Whistleblower Is Unsatisfied

Our aim is to address concerns to your satisfaction, but if you, as the whistleblower, are not satisfied with how your concern was handled or with the outcome, you do have further options:

We encourage you to let us know if you are unsatisfied, because we truly want to improve and do the right thing. However, we understand trust needs to be earned. The escalation routes above are part of ensuring accountability. {{org_field_name}} views whistleblowing as an opportunity to learn and improve, so if the first attempt didn’t resolve the issue, we are open to trying again or involving those who can help.

Remember, the purpose of whistleblowing is to fix problems and protect people – not to bury issues. So we absolutely respect your right to keep pushing the matter if you believe the problem still exists. We will never take action against someone for raising a concern in good faith, even if it ends up being a repeat or taken to an outside body. Our policy and the law forbid that kind of retaliation. We want you to feel confident that by speaking up, you have done the right thing, and we will do everything we can to honor that by properly following through.

8. Training and Awareness

To ensure that this policy is effective, {{org_field_name}} provides regular training and promotes awareness about whistleblowing among all staff:

Through comprehensive training and consistent messaging, we strive to embed whistleblowing as a normal, welcomed part of our work culture. The result we seek is a workforce that is informed, empowered, and unafraid to raise concerns – which ultimately means a safer and higher-quality service for those in our care.

Annual refreshers and visible signposting. Whistleblowing is covered at induction and refreshed at least annually, including scenario-based practice and managers’ training on impartial handling and notifications. Staff areas display “Speak Up” posters with internal and external contacts; digital copies live on the intranet.

Governance and oversight. {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}} maintains the Whistleblowing Log and completes monthly checks for timeliness and follow-through. The Responsible Individual receives a quarterly thematic analysis (volume, themes, actions, repeat issues) and confirms actions are closed. This analysis feeds quality improvement and is available to CIW.

9. Related Policies

Whistleblowing should not be viewed in isolation, as it connects with many other policies and procedures in our organization. The following policies are related and should be read in conjunction with the Whistleblowing Policy:

All these policies support a culture of transparency and safety. They collectively ensure that concerns — whether raised by staff, service users, or others — are addressed. Staff should familiarize themselves with these documents, as they provide additional guidance on specific types of issues (for example, safeguarding or discrimination) that might also fall under whistleblowing. Consistency across our policies is key: our values of honesty, safety, and respect underpin them all. If you need a copy of any related policy or are unsure which policy to follow for a given concern, you can ask your manager or consult the policy manual/portal.

Interface with other procedures. Where a concern mixes public-interest issues and personal employment issues, we will split and run the correct procedures in parallel (e.g., whistleblowing plus grievance) so public-interest matters are not delayed. Substantiated conduct issues will be managed under DCW31 (disciplinary).

10. Policy Review

This Whistleblowing (Speaking Up) Policy will be reviewed at least annually. The Registered Manager and the Responsible Individual are responsible for ensuring the policy remains up-to-date and effective. A formal review will occur every year, checking that the policy complies with any changes in legislation, regulations, or CIW guidance. We also review it in light of our experiences — for example, if we have had whistleblowing cases, we consider whether the policy and process worked well or if improvements are needed.

Additionally, the policy may be reviewed sooner than the annual date if there are any significant changes: this could be changes in the law (for instance, if Welsh Government updates whistleblowing laws or guidelines), changes in our organizational structure, or lessons learned from a concern that suggest we should adjust our approach. CIW updates or best practice recommendations will also prompt an earlier review if needed.

When a review takes place, {{org_field_name}} will involve input from various sources. Management will consult any new regulatory requirements. We may also gather feedback from staff — for example, asking if the training and awareness efforts are effective, or if the procedure is clear. Any updates to the policy will be communicated to all staff (through training sessions, staff meetings, or direct distribution of the revised document). We want to ensure everyone always has the latest information on how to raise concerns.

All versions of the policy will be dated. The current version will be the one available in our official policy repository and on the staff portal. It is each staff member’s responsibility to make sure they refer to the current policy, but we will strive to make that easy by proactively sharing updates.

By regularly reviewing and updating this policy, {{org_field_name}} demonstrates our ongoing commitment to maintaining the highest standards of openness and safety in our service. We will continue to promote an environment where speaking up is welcomed and valued, and we will adapt our approaches as needed to achieve that goal.

Records and retention. Whistleblowing case files (concern, notes, evidence, decisions, referrals, outcomes and learning) are retained for up to 6 years (or longer where litigation/regulatory purposes require), then securely destroyed. Access is restricted to the RM/RI and designated investigators. Subject access requests are handled under DCW34 with third-party data redacted.

Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
Reviewed on: {{last_update_date}}
Next Review Date: {{next_review_date}}
Copyright © {{current_year}} – {{org_field_name}}. All rights reserved.

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