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Whistleblowing Policy

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WHISTLEBLOWING POLICY

Owner

Heads of School & President

Reviewers

School Senior Leadership Team, President

Approved by President: Yes Date approved

August 2026

Next review due by:

August 2027


Contents

Important Contacts

1. Introduction

Designated Safeguarding Lead

2. Aims

Eva Cliffe +40 728 861 933

3. When to use the policy 4. Reasons for reporting a concern

Safeguarding Lead for Primary

5. Barriers to whistleblowing

Deputy Designated Safeguarding Lead (Primary)

6. Confidentiality and anonymity

Carl Helps +40 730 166 952

7. Reporting concerns procedure 8. Guidance for staff when reporting a concern

Safeguarding Lead for Secondary

9. Process and outcomes

Deputy Designated Safeguarding Lead (Secondary)

10. Further action

Doug Andrew +40 732 015 385

11. Links to other policies Safeguarding Lead for online safety Dan Batson +40 731 877 196 Head of Primary & Safeguarding Officer Natalie Kaye +40 735 302 999 Head of Secondary & Safeguarding Officer Jason Porter +40 728 133 436 School President of Crawford House Foundation Corina Corda +40 21 267 891

1. Introduction This policy provides all members of the British School of Bucharest (BSB) community with a safe and confidential way to raise concerns about suspected wrongdoing, malpractice, or behaviour by a member of staff that compromises the safety and integrity of the school.. BSB promotes a culture of honesty, accountability, and transparency, where staff and stakeholders feel confident to speak up without fear of victimisation or retaliation.

2. Aims The school adheres to the UK whistleblowing policy advice and procedures that enable staff to raise and report concerns. A whistleblowing disclosure occurs when a worker reasonably believes that information indicates that wrongdoing has occurred, is occurring, or is likely to occur, and that reporting it is in the public interest. 2


Disclosures of wrongdoing that count as whistleblowing • a criminal offence – e.g. fraud involving school funds • a breach of a legal obligation – e.g. intentionally breaching data protection requirements • a miscarriage of justice – e.g. a staff member identifies that records were altered to influence a court case • someone’s health and safety is in danger – e.g. allowing unsafe equipment to be used • damage to the environment – e.g. incorrect disposal of hazardous waste • sexual harassment – e.g. a staff member sexually harasses other staff members • the deliberate concealment of information tending to show any of the above. This policy provides additional information to help staff understand the role of whistleblowing in the context of unacceptable conduct and attitudes towards children and young people. Whistleblowing is referred to within the Safeguarding Policy and training on awareness and procedures are given to staff on an annual basis. This policy does not apply to ‘low-level’ concerns — that is, situations where a member of staff has fallen short of the expectations set out in the Staff Code of Ethical Practice but the conduct does not reach the threshold of the categories listed above. For complaints, concerns or allegations made against staff, including ‘low-level’ concerns, see the Safeguarding and Child Protection Policy.

3. When to use the policy This policy may be used by anyone employed by the school, in a paid or voluntary capacity, who suspects that a colleague’s conduct is unethical, illegal, dangerous, or harmful to a child.” Do not use this policy for personal employment grievances. Such matters are addressed under the HR Internal Regulation.

4. Reasons for reporting a concern Staff will naturally be reticent to report a concern about the conduct of a colleague. However, each individual has a responsibility to protect members of the school community from harm. Your action not only protects students but also minimises the risk of suggestion that you have colluded with poor practice of which you were aware. Whistleblowing is appropriate when conduct crosses the ‘harm threshold’ — that is, when wrongdoing, if left unchecked, could escalate and result in serious harm to a staff member or student.

5. Barriers to whistleblowing You may worry that you have insufficient evidence; that you will set in motion an unstoppable chain of events; that there will be adverse repercussions for your career; that you may suffer harassment or victimization; or that your concern might be misplaced. These concerns are entirely understandable, but the whistleblowing procedures address them.

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The Public Interest Disclosure Act 1998 (UK) protects employees from reprisals for public interest whistleblowing. A local solicitor or non-governmental organisation can advise on your legal position in Romania, which may differ to the of UK legislation. A UK-based professional union, or a UK based local authority legal services can provide advice from UK legal perspective.

6. Confidentiality and anonymity All concerns are treated in confidence and, as far as possible, your identity will not be revealed if that is your wish. However, absolute confidentiality cannot be guaranteed if, as a result of an investigation, you are required to provide a witness statement or attend a court hearing. You can, if you prefer, raise your concern anonymously. The school will decide whether the gravity and credibility of the concern warrant investigation where the source, and key evidence, are not readily available. The school will support you and take all reasonable steps to protect you from harassment or retaliation arising from whistleblowing. Allegations that prove to be deliberately fabricated and malicious will be dealt with through staff disciplinary procedures. However, no action will be taken against any member of staff who raises a genuine concern that proves to be unfounded.

7. Reporting concerns procedure It may help to write down what you have observed or heard before making your report. Ask yourself: would you want this conduct to continue unchecked if your own child or a family member were affected?” You may raise your concern verbally or in writing, including via CPOMS Staff Concern, using the reporting lines below. CPOMS alerts the Heads of School automatically, therefore a concern about a Head of School should be reported to the other Head of School and the President of Crawford House Foundation directly, and the DSL if it is a Safeguarding issue.

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Department Primary School Secondary School Facilities Office (OMC) Human Resources Enterprises (Events, Marketing, F&B, Transport, CCAs, Trips) GRIT External Communications (Admissions) Finance President of Crawford House Foundation Advisory Board Member with Safeguarding Oversight Designated Safeguarding Lead

Head of Department (email addresses follow firstname.surname@britishschool.ro) Natalie Kaye: Natalie.kaye@britishschool.ro Tel: +40 735 302 999 Jason Porter: Jason.Porter@britishschool.ro Tel: +40 728 133 436 Simona Sasu Andreia Simeria / Zakaria Khalil Elena Solcan Dana Chirica Alexandru Voinea Andrei Atanasiu Oana Calin Corina Corda: Corina.Corda@britishschool.ro Tel: +40 21 267 89 19 Philip Walters Philip.Walters@britishschool.ro Tel: +40 736 901 771 Eva Cliffe Eva.Cliffe@britishschool.ro Tel: +40 728 861 933

In the case where an allegation is made against the Heads of School, the Heads of School must not be informed of the allegation related to safeguarding and child protection prior to contact with the President of Crawford House Foundation, the Designated Safeguarding Lead and the relevant external agencies. If the concern is about a Head of Department, the matter must be reported directly to the President of Crawford House Foundation and, where there is any safeguarding dimension, to the DSL.

8. Guidance for staff when reporting a concern •

A friend or colleague may accompany you to the meeting if you wish.

• A written report of the concern either in an email, letter or CPOMS Staff Concern must also be made. A colleague may support you in this. • You are entitled to be informed of proposed actions and to have a date for a follow-up meeting confirmed by the Head of Department or President of Crawford House Foundation.. • Timescales will depend on the complexity of the initial inquiry, but the case must not be allowed to stall; you should receive initial feedback within 10 working days. •

The timescale for subsequent feedback should then be agreed.

• Ask for clarification about confidentiality and ensure you have any requests regarding the protection of your identity recorded.

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9. Process and outcomes 1. A Head of Department or the President of Crawford House Foundation will make enquiries to establish the facts of the matter and whether conduct has occurred which falls under the whistleblowing concern categories listed in Section 2 (Aims). 2.

Members of the school community may be asked to provide information or advice.

3.

External advice, for example, from egal or human resources or children’s social care services may be sought.

4.

A written record of the conduct, established facts and the outcome of the inquiry will be kept.

5.

The whistleblower will be kept informed of the progress of the inquiry.

6.

The outcome of the inquiry will be one of the following: • No wrongdoing is established - the case is closed. • The concern has some substance but is assessed as a ‘low-level’ concern (e.g. poor practice or inexperience) low-level concern procedures will be followed as set out in the Safeguarding and Child Protection Policy. • Wrongdoing is established - disciplinary proceedings are initiated. • The concern is more serious - a formal investigation is initiated, which may involve the local authority’s legal team, children’s social care services, or the police.

If, at any stage, there is reason to believe that a child is at risk of significant harm, relevant external agencies must be contacted, and relevant staff members may be suspended in accordance with the staff Internal Regulation.

10. Further action If you feel your concern was not handled properly, you may: • report directly to the President of the Crawford House Foundation, (see Complaints Policy for procedure). • Contact an independent organisation such as: o Protect (UK Whistleblowing Charity) – www.protect-advice.org.uk o COBIS, HMC or AoBSO (for British international schools overseas). Alternatively, you can seek advice from your union (if member) or UK based professional association, a solicitor, the police, and/or children’s social care services. Protect is a UK registered charity that offers free and confidential legal advice on workplace malpractice. Protect The Green House, 244-254 Cambridge Heath Road, London E2 9DA, UK. +44 020 3117 2520. https://protect-advice.org.uk

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11. Record Keeping • All reports and investigation records are logged and stored securely by HR. • Records include the concern, actions taken, and outcome summary. • Records are retained for at least 5 years, in accordance with applicable legal requirements. • Anonymity is preserved in all documentation where possible.

12. Links to other policies This policy links to the following policies and procedures: • Behaviour

• Toileting and Intimate Care

• Staff Code of Ethical Practice

• Safer Recruitment

• Complaint

• First Aid

• Health and Safety

• Curriculum

• Attendance

• PSHE

• Online Safety

• Bereavement

• Acceptable Use

• Anti-Bullying

• Prevent Duty

• Equality and Diversity

• Relationship and Sex Education

• Drugs, Alcohol and Tobacco Policy

• Visitors and Volunteers

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REVISION HISTORY

REVISION

Sharepoint Revision no

Ver. 1

n/a

NOTES

Date Approved

Initial Revision

July 2019

Ver. 2

Update in response to KCSIE 2020 and ‘lessons learnt’ identified in Termly Safeguarding Review meetings 2019-20.

July 2020

Ver. 3

Amendment relating to photo and video parental permission now given via admissions documents.

March 2021

Ver. 4

Update in response to KCSIE Jan 2021, Ofsted (2021) Review of Sexual Abuse in Schools and Colleges and ‘lessons learnt’ identified in Termly Safeguarding Review meetings 2020-21.

August 2021

Ver. 5

Amendments for BSO Compliance

February 2022

Ver. 6

Update in response to KCSIE Sept 2022 and new Deputy DSL

August 2022

Ver. 7

Update in response to KCSIE Sept 2023 and new leadership structure and titles, personnel in Safeguarding Team, filtering and monitoring expectations.

August 2023

Ver. 8

Separation from Safeguarding and Child Protection policy

September 2023

Ver. 9

New DSL information. Removal of content which refers to ‘poor practice’, which would fall under the ‘Low Level Concerns’ procedures, not Whistleblowing, which relates to the concern categories listed in the ‘Aims’ section.

August 2024

Ver. 10

Clarification of reporting lines for non-teaching departments

August 2025

Ver. 11

Amendments to contact details, use of CPOMS staff concerns, update to Whistleblowing examples

August 2026

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