Whistleblowing Policy

Whistleblowing is the reporting of wrongdoing where the individual reasonably believes that the concern is being raised in the public interest. It typically relates to serious matters which affect others beyond the individual raising the concern, such as staff, students, the public, or the integrity of the School.

The following types of concern typically fall within the scope of this Policy, provided they are raised in the public interest:

• A criminal offence

• A failure to comply with legal or regulatory obligations (including OfS conditions)

• A health and safety risk to staff, students or the public

• Environmental damage

• Financial or academic malpractice

• Safeguarding risks or abuse

• Deliberate concealment of any of the above

Where safeguarding risks are raised, they may also be addressed under the School’s Safeguarding Policy (including Prevent) to ensure a coordinated response.

This Policy focuses on wrongdoing in the public interest. Personal grievances, such as bullying, harassment or contractual disputes, do not fall within the scope of this Policy and should be raised under the appropriate policies outlined below.

Only disclosures that meet the legal definition of whistleblowing — including the requirement that the concern is raised in the public interest — are protected under the Public Interest Disclosure Act 1998 (PIDA).

This protection applies to individuals who meet the definition of ‘worker’ under the Act, including employees, agency workers, contractors providing services personally, and individuals undertaking work-like duties on behalf of the School.

Concerns that do not meet this definition will still be handled appropriately under the School’s relevant policies.

Raising a concern in good faith, even if it turns out to be unfounded, will never result in disciplinary action or recrimination. The School does not tolerate any form of detriment against individuals who raise genuine concerns. However, allegations made knowingly and maliciously, with the intent to cause harm or mislead, may be addressed through appropriate disciplinary procedures.

The School encourages all staff, students, and individuals working with or on behalf of the School who have a genuine concern about wrongdoing to raise it. This includes, but is not limited to:

• All employees (whether permanent, fixed-term or temporary)

• Agency workers, contractors, consultants and volunteers

• Members of School bodies (including governors and committees)

• Suppliers and partners providing services to the School

• Students undertaking official duties in a work-like capacity on behalf of the School, such as student governors, programme representatives, ambassadors, peer mentors or research assistants

Only concerns relating to matters that fall within the scope of whistleblowing — those outlined in this section and raised in the public interest — will be handled under this Policy.

Other types of concerns, such as personal grievances about working conditions, workplace behaviour, bullying, harassment, or interpersonal disputes, do not fall within the scope of whistleblowing. Students wishing to raise concerns unrelated to work-like duties should normally use the School’s Student Complaints and Academic Appeals Policy. Staff wishing to raise personal grievances should normally use the School’s Grievance Policy.

The Whistleblowing Officer will assess all concerns or complaints submitted to them to determine the appropriate procedure. While matters outside the scope of this Policy do not carry legal protections under PIDA, the School is committed to handling all concerns fairly and without recrimination. The spirit and principles of this Policy, particularly those relating to good faith, confidentiality, and protection from victimisation, will be applied across all procedures.

The Board is responsible for appointing and overseeing Independent Governors as 'Whistleblowing Officer' and 'Deputy Whistleblowing Officer' and receiving an annual anonymised report on concerns raised and actions taken.

The Whistleblowing Officer is responsible for:

• Receiving disclosures
• Ensuring confidentiality is maintained
• Overseeing triage
• Appointing impartial Investigating Officers

Investigating Officers are appointed by the Whistleblowing Officer. They may be internal or external as appropriate. They must conduct investigations impartially under agreed terms of reference.

Whistleblowers are expected to:

• Act in good faith
• Provide all available evidence
• Cooperate with investigations, including attending interviews where required

Concerns should be raised promptly with the Whistleblowing Officer:

Email: whistleblowing@lsi.ac.uk

Post: Confidential: Whistleblowing Officer
London School of Innovation
6 Sutton Park Road
Sutton
SM1 2GD

If approaching the Whistleblowing Officer is not possible, concerns may be raised with any other unimplicated Board of Governor member, such as the Deputy Whistleblowing Officer, who must refer it to the Whistleblowing Officer. 

Where internal reporting is inappropriate, or has not resulted in timely or adequate action (e.g. no acknowledgement within five working days), concerns may be escalated to external bodies including but not limited to:

• Office for Students (OfS)
• Protect (formerly Public Concern at Work)
• Health and Safety Executive (HSE)
• Charity Commission
• Police (for criminal matters)

Protect (Independent Whistleblowing Charity):

Website: https://protect-advice.org.uk

Advice Line: 020 3117 2520

The Whistleblowing Officer will acknowledge receipt of the concern within five working days.

An initial triage will be conducted by the Whistleblowing Officer within ten working days to determine the appropriate next steps, including whether an investigation is warranted.

The purpose of triage is to assess whether the concern:

• Falls within the scope of this Policy

• Has been raised in good faith

• Contains sufficient information to make reasonable enquiries

An investigation will normally proceed where the concern, if substantiated, would represent a serious issue such as those outlined in the scope above. The threshold for triggering an investigation is whether the concern merits further examination — proof or evidence is not required at this stage.

The School will endeavour to protect the identity of the whistleblower as far as is reasonably possible, taking into account the need to comply with legal obligations and the requirements of a fair and thorough investigation.

The Whistleblowing Officer may request further information from the whistleblower or hold a meeting to clarify the concern. The whistleblower may be accompanied to any such meeting by a representative or colleague (in the case of staff) or a friend or supporter (in the case of students). This same right applies to any meetings held during the process.

Where an investigation proceeds, written terms of reference will outline:

• The scope and objectives;
• Methodology;
• Timetable; and
• Reporting lines.

The whistleblower will be informed of the process and indicative timescales.

Investigations will be conducted by an appointed Investigating Officer, internal or external as appropriate. Investigations will involve:

• Gathering documentation;
• Interviewing the whistleblower (where willing), relevant witnesses and any implicated individuals.

Confidentiality will be maintained throughout, in line with the policy.

Interim measures may be implemented where necessary to protect individuals or preserve evidence. These may include temporary suspension, duty reallocation or restricted access, pending the outcome of the investigation.

A written report and any recommendations will be submitted by the Investigating Officer to the Whistleblowing Officer at the conclusion of the investigation. The Whistleblowing Officer will determine the outcome of the investigation. The Board of Governors will review the findings from a governance perspective and decide whether any further action is required.

Subject to legal and confidentiality constraints, the whistleblower will be informed of the decision of the Whistleblowing Officer within five working days of the report being submitted to the Board of Governors. Subject to the same constraints, the whistleblower will also be informed of any actions or decisions taken by the Board of Governors from a governance perspective within five working days of those actions or decisions being made.

A closure meeting with the Whistleblowing Officer will be offered to discuss the findings, actions taken, and any further support required.

All records related to whistleblowing concerns will be securely stored for a minimum of seven years, in accordance with data protection requirements and the School’s records management procedures.

A whistleblower may request a review of the outcome where they believe one or more of the following grounds apply:

• The correct procedure was not followed;

• There was bias or a conflict of interest in the handling of the concern;

• New, relevant evidence has become available which was not previously considered.

A review must be requested in writing within ten working days of receiving the outcome and should be sent to the Deputy Whistleblowing Officer, who will be an external governor unconnected to the original concern.

The purpose of a review is to assess whether the process was properly followed and whether any further action is required. It is not a re-investigation of the original allegation unless the review identifies a clear procedural failing or material new evidence which justifies further investigation.

Where the review identifies a procedural failing or new evidence which materially affects the outcome, the matter will either be referred back to the Whistleblowing Officer for further investigation or the review may recommend appropriate remedial action to the Board.

The outcome of the review will be final and will be communicated to the whistleblower within twenty working days of receipt of the request.

No individual will suffer any detriment as a result of raising a concern in good faith under this Policy, whether or not the concern is ultimately upheld. Retaliation against anyone who raises a genuine concern will be treated as a serious disciplinary matter. This includes protection against dismissal, disciplinary action, harassment, exclusion or any other form of disadvantage.

This protection reflects the School’s legal obligations under the Public Interest Disclosure Act 1998 (PIDA), which prohibits any detriment to individuals who make a protected disclosure.

Requests for confidentiality will be respected unless disclosure is legally required. Anonymous disclosures will be considered on their merits. Where sufficient detail is provided, anonymous reports may be investigated; however, anonymity can limit the School’s ability to seek clarification, protect the whistleblower or provide feedback.

The School prohibits the use of non-disclosure agreements to prevent individuals from raising whistleblowing concerns or making disclosures in the public interest.

Support includes access to the occupational health services and independent advice from Protect.

This Policy will be published on the School’s website, intranet, and in the Staff and Student Handbooks. It should be referenced during inductions.

All individuals covered by this Policy must complete annual refresher training on whistleblowing. Completion rates will be monitored for compliance. Additional briefings are provided for managers and governors.

Reasonable adjustments will be made to ensure individuals with disabilities can access the process, including alternative formats and communication support. This reflects the School’s commitment to equality, diversity and inclusion.

The Whistleblowing Officer will submit anonymised reports to the Board at its annual meetings, detailing the number of disclosures, categories, investigation status and emerging trends.

The Whistleblowing Officer will ensure that any governance decisions or actions agreed by the Board are delivered and implemented. The annual anonymised report will summarise outcomes and any improvements implemented as a result.

This Policy will be reviewed at least every three years, or sooner in response to legislative, regulatory or feedback requirements. Its continued fitness for purpose will be confirmed annually by the Board as part of governance reporting.