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Protected Disclosure Policy

Introduction

The National Museum of Ireland (“NMI”) is committed to fostering an appropriate environment for addressing concerns relating to potential wrongdoing in the workplace and to providing the necessary support for staff that raise genuine concerns.  The Protected Disclosure Act 2014 as amended by the Protected Disclosure (Amendment) Act 2022 (the “Act”) enables workers to raise a concern and disclose information regarding potential wrongdoing that has come to their attention in the workplace by ensuring that safeguards exist should reprisals be taken against them.  It is important to note that in order to enjoy the protections of the Act, disclosures must be made in accordance with the provisions set out in the Act.  The Act provides for a ‘stepped’ disclosure process in which a number of distinct channels (internal, regulatory and external) are available.
  1. NMI is committed to the highest possible standards of compliance with our legal requirements.
  2. Our whistleblowing policy is intended to encourage and enable workers to raise concerns rather than overlooking them.  Under this policy a worker can make a disclosure without fear of penalisation or threat of less favourable treatment.  Anyone who has made a disclosure and who feels like they are being subjected to adverse treatment should report the matter immediately to management.
  3. The outcome of an assessment by management of the complaint will be subject to review by a person who has not been involved in the initial assessment, investigation or decision.
  4. This policy aims to give effect to the obligations and provisions of the Act and does not replace any legal reporting or disclosure requirements arising under other legislation.  Where statutory reporting requirements or procedures exist, these must be fully complied with.
  5. This policy does not replace the NMI’s Grievance Procedures, in particular where the issue relates to an individual worker’s contract of employment this matter should be referred under the NMI Grievance Procedure.
  6. Workers are entitled to seek the assistance of their union in making disclosures and can be represented by their union at any stage.
  7. This NMI policy has been discussed and agreed with our employees and their unions and has their full support.
  8. This policy does not form part of any employee's contract of employment and the NMI may amend it at any time

Aims & Scope of this policy

This policy aims to:
  1. encourage workers to feel confident about raising concerns about relevant wrongdoings;
  2. provide avenues for workers to make disclosures about relevant wrongdoings and receive feedback on any action taken;
  3. ensure that suppliers and clients are aware of their responsibilities;
  4. reassure workers that they will be protected from reprisals for making a disclosure in accordance with this policy and that their identity will be adequately protected;
  5. this policy is intended to cover all aspects of NMI activities including our operations outside of Ireland.

Personnel responsible for this policy

  1. The Head of Operations of NMI has overall responsibility for this policy. This person shall be referred to as the “Protected Disclosures Manager” throughout this policy and may be the person identified as the “designated person” for the purposes of the Act. The Protected Disclosure Manager may delegate his/her duties as he/she deems appropriate.
  2. The contact details for the Protected Disclosure Manager are:
Aoife Hurley
Head of Operations
Ard-Mhúsaem na hÉireann/National Museum of Ireland
Bearaic Uí Choileáin/Collins Barracks
Sr. na Binne Boirbe/Benburb St
Baile Átha Cliath 7/Dublin 7
teil./tel. [01-6486401]
r.phost/email ahurley@museum.ie]
  1. The Protected Disclosures Manager has day-to-day operational responsibility for this policy, and must ensure that all managers and other workers who may deal with concerns or investigations under this policy receive regular and appropriate training.
  2. All workers are responsible for the success of this policy and should ensure that they use it to disclose any suspected danger or wrongdoing.
  3. If workers are not happy with the way in which concerns has been handled, a disclosing person may contact [the Director of the NMI] who may facilitate an appeal by way of written submissions in advance of making a decision as to the subject matter of the appeal.

Protected Disclosure

  1. This policy deals with disclosures that relate to ‘relevant wrongdoings’ as defined in the legislation and aims to protect workers from penalisation and/or detriment where they make a disclosure of information which he or she reasonably believes demonstrates a relevant wrongdoing and which comes to their attention in a work-related context.
These correspond to ‘Relevant Wrongdoings’ in the Act (section 5 subsections 3(a) to (h)) and in summary these are defined as:
  1. An offence that has been, is being or is likely to occur;
  2. Failing or likely to fail to comply with legal obligations (other than one arising under the worker’s contract of employment);
  3. Miscarriage of justice that has occurred or is likely to occur;
  4. The health and safety of any individual has been or is likely to be endangered;
  5. Damage or likely damage to the environment;
  6. The unauthorised or improper use (or likely use) of public funds or resources;
  7. An act or omission which is oppressive, discriminatory grossly negligent or constitutes gross mismanagement;
  8. A breach of any area of EU law provided for under the Act, available at: https://www.irishstatutebook.ie/eli/2022/act/27/section/4/enacted/en/html#sec4
  9. Information which shows the actual or likely destruction or concealment of information relating to any of the above
  10. The aim of this policy is to prevent harm to others or to the NMI a whole. It does not cover personal complaints or personal grievances. Procedures for dealing with grievance issues are detailed in the NMI Grievance Procedure.
  11. It is irrelevant if the wrongdoing referred to occurred in Ireland or elsewhere.
  12. The policy does not cover a disclosure where the worker knowingly conveys false, misleading, frivolous or vexatious information. If it transpires that a worker makes a disclosure, which they know to be false or do not believe to be true NMI may take disciplinary or other appropriate action. If workers are uncertain whether something is within the scope of this policy they should seek advice from the Protected Disclosures Manager.

Reasonable Belief

A reporting person does not need to be certain about the facts in their disclosure, it is sufficient that in the reasonable belief of the reporting person that the information tends to show one or more relevant wrongdoings and the information came to the attention of the reporting person in connection with their employment. Allegations based on suspicion without a tangible foundation are not reasonable beliefs. No reporting person will be subject to negative consequences relating to a protected disclosure   in circumstances where the reporting person had a reasonable belief that the information disclosed showed, or tended to show, wrongdoing. It is an offence under the Act to make a report containing information which is known by the reporting person to be false.

Who is covered by this policy?

  1. This policy applies to all ‘workers’ i.e. NMI employees at all levels, agency workers, trainees, officers, consultants, casual workers, members of the administrative, management or supervisory body, job applicants, apprentices and interns on paid or unpaid work placements, self-employed persons acting on our behalf, volunteers and in certain circumstances the workers of companies that supply us with goods and services.
  2. This policy applies to current and past employees and to any new employees from the recruitment stage forward.

Representation by a trade union

Workers are entitled to seek advice from their trade union about the operation of the Act and are protected when they do so. Every worker can contact, discuss and be represented by their trade union during any meetings or interviews under this policy.

Channels for making a disclosure

  1. The normal channel through which a report should be made in the first instance is line management. Individuals may raise concerns in writing or verbally/via telephone with their line manager. If an individual feels unable to raise the matter with direct line management then a member of the Senior Management Team may be contacted.
  2. If the worker reasonably believes there are circumstances preventing them from reporting their concerns within the line management structure, or to a member of the Senior Management Team, then the worker can contact the Protected Disclosure Manager.  In doing so, the worker should clearly set out the circumstances which prevent reporting the matter to line management in the first instance.
  3. The Act provides for making a ‘protected disclosure’ in defined circumstances, to a Prescribed Person, the Minister, a legal advisor, or others. If the disclosure is made otherwise than to the NMI or other responsible person, prescribed person, minister or a legal advisor, then the worker must have a reasonable belief that the information is substantially true and that the conditions set out in Section 10(2) (a-c) of the Act have been met.

Raising a concern under the internal disclosure procedure

9.1First Steps

  1. A disclosure about a ‘relevant wrongdoing’ should normally be raised using the internal disclosure procedures however this depends on the seriousness and sensitivity of the issues involved and who is suspected of the wrongdoing.
  2. Disclosures made under the NMI internal procedures may be made verbally or in writing to the reporting persons Line Manager or to Senior Management or if appropriate to the ‘Protected Disclosure Manager’.
  3. Reporting persons can be allowed to disclose verbally in the first instance, to be followed with a written communication if necessary. In the case of verbal disclosures, it is recommended that a written record is kept of the disclosure with due regard to confidentiality obligations.
  4. Reporting persons who wish to make a written disclosure are invited to use the format detailed at 9.2 below and to keep a copy of the disclosure and any information provided. It is not necessary to follow this format.

9.2Format for making an Internal Disclosure

The reporting person should provide the following:
  1. give a description of the ‘relevant wrongdoing’;
  2. provide any information that indicates a relevant wrongdoing so as to assist the investigation of the matters raised in the disclosure;
  3. date the disclosure;
  4. give your preferred contact details;
  5. state that the disclosure is made under the Act and state if you do / do not expect confidentiality.
  6. Although reporting persons are not expected to prove the truth of the facts in the disclosure they must have a ‘reasonable belief’ that there are grounds for their concern when making a disclosure using the internal procedure.

Confidentiality 

  1. All concerns will be treated in confidence, unless the worker clearly states that he/she does not object to having his/her name associated with the disclosure.
  2. Disclosures will be kept secure and in a form that that does not endanger confidentiality of the person making the disclosure.  The focus will at all times be on the information in the disclosure rather than the identity of the worker making the disclosure.
  3. At the appropriate time, however, the identity of the reporting person may need to be revealed if it is necessary for an investigation and in accordance with the principles of natural justice and fair procedures. The reporting person will be informed in advance of any decision to disclose the information which will reveal his/her identity. The decision to disclose the identity of the reporting person will be reviewed by someone who has not been involved in the process to that point.

Can a disclosure be made anonomously?

NMI does not encourage anonymous disclosures and/or reports. The Protected Disclosures Manager may exercise its discretion, not to accept and/or follow-up on an anonymous report, unless it is appropriate to do so in the circumstances. Proper investigation may be more difficult or impossible if the Protected Disclosures Manager cannot obtain information from a worker which is necessary for the purpose of conducting a fair and comprehensive investigation. Workers who wish to disclose their concerns under this policy but who are apprehensive about possible reprisals if their identity is revealed should come forward to the Protected Disclosures Manager and appropriate measures can then be considered to preserve confidentiality if and where possible.

How NMI will respond

  1. The NMI will acknowledge in writing to the reporting person receipt of every report made through the internal channel within seven days of its receipt.
  2. The Protected Disclosures Manager will carry out an initial assessment to determine whether there is evidence that a relevant wrongdoing may have occurred. If it is established that there is no evidence that a relevant wrongdoing may have occurred, the Protected Disclosures Manager may close the investigation. However, if after having carried out an initial assessment, the Protected Disclosures Manager decides that there is evidence that a relevant wrongdoing may have occurred, the scope and terms of reference of any next steps which may include an investigation which the Protected Disclosures Manager might decide to carry out shall be determined as appropriate
  3. During the screening process it may become apparent that the information provided involves a personal employment complaint. If that is the case separate procedures may be adopted to investigate the personal employment complaint. If the disclosure is deemed to solely be a personal employment complaint then the worker is encouraged to utilise other processes that are in place so that the complaint is dealt with in the appropriate manner.
  4. Disclosures may, in light of the seriousness of the allegations be referred immediately to the appropriate authorities. Likewise, if urgent action is required (for example to remove a health and safety hazard) this will be taken before any other investigation is conducted.
  5. In order to protect any individuals accused of a ‘relevant wrongdoing’, initial inquiry will be made to decide whether an informal or formal investigation is appropriate and, if so, what form it should take. In cases where the Protected Disclosures Manager decides to conduct an investigation, he/she may appoint an investigator or team of investigators including workers with relevant experience of investigations or specialist knowledge of the subject matter to report on their investigation. The investigator’s report will be sent to a designated member of senior management who will determine what if any action should be taken by the NMI. Such action could include changes to the way the NMI conducts its operations, disciplinary action (following the application of the disciplinary procedure) or a referral to an appropriate third party as mentioned below.
  6. Where appropriate, the matters raised in the disclosure may:
    1. be investigated by management, by the internal auditor, or be referred to the external auditor;
    2. be referred to An Garda Siochána;
    3. be referred to external enforcement agency or regulator;
    4. form the subject of an independent (third party) inquiry;
    5. be dealt with in accordance with NMI’s Dignity at Work, Grievance and Disciplinary Procedures.
  7. Within seven days of a concern being raised, the Protected Disclosure Manager will write to the worker who made the report (where this is known):
    1. acknowledging that the concern has been received;
    2. indicating in summary form how the organisation proposes to deal with the matter;
    3. giving an estimate of how long it will take to provide the next response; or
    4. providing an approximate date by which the person making the disclosure will receive the final communication;
    5. or setting out why no investigation will take place.
  8. The communication will include information on staff support mechanisms including the right to be represented by the individual’s trade union.
  9. The amount of contact between the Protected Disclosure Manager (or the person working on their behalf) and reporting person during the investigations will depend on the nature of the matters raised, the potential matters involved and the clarity of the information provided in the report.
  10. The Protected Disclosure Manager will ensure that the reporting person is aware that the matter is under active consideration and will provide them with a final statement summarising how the concerns raised in the disclosure were dealt with and what action was taken to rectify the wrong doing.
  11. In circumstances where an investigation does not conclude that any relevant wrongdoing has taken place or where the reporting person making the disclosure is mistaken or unaware of all the facts surrounding the issues raised the Protected Disclosure Manager will in the final statement take the opportunity to explain that the concerns are unfounded.
  12. The Protected Disclosure Manager will maintain a record of all concerns raised and reports received along with notes of the investigation and the outcome, in a secure manner which does not endanger workers’ confidentiality or damage reputations or worker’s employment records in the case of inaccurate disclosures.
  13. The Protected Disclosure Manager will report as necessary to the Board of NMI providing a record of the number and type of disclosures received, the actions taken, any breaches of confidentiality or of penalisation and the actions taken to remedy these and a statement on awareness and training on the policy.
  14. The Protected Disclosures Manager will provide feedback to the reporting person no later than three (3) months (or at intervals of (3) months in complex investigations), after issuing the initial acknowledgement. In circumstances where it is likely that NMI will not be in a position to provide feedback within three (3) months, NMI should notify the reporting person, in writing, as soon as practicable. While NMI will use its best endeavours to comply with these timeframes, if it cannot reasonably do so, it will notify the reporting person of any revision to them.
  15. Workers should treat any information about the investigation as confidential.

Raising a concern externally

  1. The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying any wrongdoing in the workplace. In most cases the reporting person should not find it necessary to alert anyone externally.
  2. The law recognises that in some circumstances it may be appropriate for the reporting person to report your concerns to an external body such as a prescribed person (such as a regulator) or the Protected Disclosures Commissioner (within the Office of the Ombudsman). It will very rarely if ever be appropriate to alert the media and in general the reporting person should only do so as a last resort.  As there are specific provisions applicable to external disclosures, NMI strongly encourages the reporting person to seek advice before reporting a concern externally and the reporting person should contact their line manager or the Protected Disclosure Manager for guidance. 
  3. Whistleblowing concerns usually relate to the conduct of workers, but they may sometimes relate to the actions of a third party, such as a customer, supplier or service provider. In some circumstances the law may protect the reporting person if they raise the matter with the third party directly. However, NMI encourages the reporting person to report such concerns internally first. The reporting person should contact your direct line manager or the Protected Disclosure Manger in this regard. 

Making a disclosure to a prescribed person

  1. The Act provides for external reporting of wrongdoing to appropriate authorities in circumstances where:
    1. the worker reasonably believes that the information disclosed and any allegations contained are substantially true and
    2. A reporting person may make a protected disclosure to a prescribed person if the reporting person reasonably believes that the relevant wrongdoing falls within the description of matters in respect of which the prescribed person is prescribed. However, the Act also provides an additional requirement in this case in that the reporting person must reasonably believe that the information disclosed, and any allegation contained in it, are substantially true.
  2. A list and contact details of the various ‘Prescribed Persons’ is available at: https://www.gov.ie/prescribed-persons
  3. The ‘Prescribed Person’ shall appoint an impartial designated person or persons. This designated person must be responsible for providing information on making an external disclosure, receiving and following up on reports, maintaining communication with the reporting person and where necessary, requesting further information from and providing feedback to the reporting person.
  4. Each prescribed person shall publish on a website detail pertaining to the making of a protected disclosure to the prescribed person.

Format for making a disclosure to a prescribed person

  1. State that you are making the disclosure under Section 7 of the Protected Disclosure (Amendment Act) 2022.
  2. Give a description of the ‘relevant wrongdoing’ and why it falls within the Prescribed Person’s area of responsibility.
  3. Provide any copies of information that any information that indicates a relevant wrongdoing so as to assist the investigation of the matters raised in the disclosure.
  4. Include any information relating to your raising (or not raising) the concern under the internal procedure.
  5. Date the disclosure.
  6. Give your preferred contact details.
  7. Make it clear that you expect confidentiality.
  8. Although workers are not expected to prove the truth of the facts in the disclosure they must have a ‘reasonable belief’ that the information and any allegation are substantially true, this a somewhat higher standard than when making the internal disclosure.

Raising concerns externally to the Minister

  1. The Act provides for external reporting to the Minister for Tourism, Culture, Arts Gaeltacht and Sport.
  2. In order to make a disclosure to a relevant Minister, the worker must reasonably believe that the information disclosed tends to show one or more relevant wrongdoings; and one or more of the following must apply:
    1. The worker has previously made a disclosure of substantially the same information to their employer, other responsible person, prescribed person, or relevant Minister, as the case may be, but no feedback has been provided to the worker in response to the disclosure within the period allowed, or, where feedback has been provided, the reporting person reasonably believes that there has been no follow-up or that there has been inadequate follow-up;
    2. The worker reasonably believes the head of the public body concerned is complicit in the relevant wrongdoing reported;
    3. The worker reasonably believes that the disclosure contains information about a relevant wrongdoing that may constitute an imminent or manifest danger to the public interest, such as where there is an emergency or a risk of irreversible damage.
  3. To ensure that the Minister is aware of the worker’s intention, it is recommended that the worker specify when making a disclosure under this channel that it is a disclosure to the Minister under section 8 of the Act. Disclosures received by Ministers are required to be forwarded by Ministers to the Commissioner.

Raising concerns externally to the protected disclosures commissioner

  1. The Act created the Office of the Protected Disclosures Commissioner.
  2. The Commissioner’s primary duty is to refer any reports received under the Act to the most appropriate prescribed person (or other suitable person, if a prescribed person cannot be identified). Only as a last resort should the Commissioner directly follow-up on a report.
  3. The Commissioner may receive disclosures by means of external reporting channels, which must meet the same criteria as the external reporting channels for prescribed persons. The Commissioner may also receive disclosures which have been transmitted onwards from Government Ministers.
  4. When the Commissioner receives a report, within 14 calendar days (or a longer period as deemed reasonable due to the nature and complexity of the report) the Commissioner must identify the prescribed person which the Commissioner considers appropriate and transmit the report to them.
  5. The Commissioner shall publish on a website detail pertaining to the making of a protected disclosure to the Commissioner.

Workers outside the NMI reporting concerns using the internal procedure

  1. Workers from outside the NMI working for our clients or suppliers who become aware of a relevant wrongdoing as part of their work with or for us may make a report to the ‘Protected Disclosure Manager’ in respect of a relevant wrongdoing.
  2. Workers from outside the enterprise making such disclosures are encouraged to use the same format as our workers and give an indication of whether they are willing to participate in any investigation that may take place in response to the disclosure.

Untrue allegations

  1. If a worker makes a report in accordance with this policy, but the information or allegation is subsequently not confirmed by the investigation, no action will be taken against the person making the disclosure. They will be fully protected from any less favourable treatment, penalisation or victimisation.
  2. The motive of the person making the disclosure is not relevant but if an allegation, known to be false is made maliciously by an NMI employee, then disciplinary action may be taken against that employee. It is an offence under the 2022 Act to make a report containing information which is known by the reporting person to be false. 

Worker who is the subject of a disclosure

  1. A worker who is the subject of a disclosure is entitled to fair treatment. While an investigation is on-going, all reasonable steps will be taken to protect the confidentiality of those who are the subject of allegations in a protected disclosure pending the outcome of the investigation. In some circumstances, where the fact of the investigation is widely known, the conclusion of the investigation may involve a statement of exoneration.

Protection from penalisation 

  1. NMI is committed to good practice and high standards and we want to support and protect workers who make disclosures under this policy. Direct or indirect pressure on workers not to make a disclosure or to make a disclosure contrary to this policy will not be tolerated.
  2. NMI recognises that penalisation can take many forms; it can be direct and indirect and may be perpetrated by fellow workers, management or those who supply us with goods and services and our customers and clients.
  3. Examples of penalisation include any unfair or adverse treatment (whether acts of commission or omission) that result in the employee suffering any unfavourable change in his/her conditions of employment including (but not limited to):
    1. suspension, lay-off or dismissal (including a dismissal within the meaning of the Unfair Dismissals Acts), or the threat of suspension, lay-off or dismissal;
    2. demotion or loss of opportunity for promotion;
    3. transfer of duties, change of location of place of work, reduction in wages or change in working hours;
    4. imposition of any discipline, reprimand or other penalty (including a financial penalty);
    5. unequal treatment under sick leave or disciplinary policies, unfair selection for tasks or attendance at events;
    6. coercion, intimidation, discrimination, disadvantage or unfair treatment,
    7. injury damage or loss;
    8. threats of reprisal;
    9. verbal harassment - jokes, comments, ridicule or songs;
    10. written harassment - including faxes, text messages, emails, comments or postings on social media;
    11. physical harassment - jostling, shoving or any form of assault;
    12. intimidatory harassment - gestures, posturing or threatening poses;
    13. isolation or exclusion from social activities;
    14. bullying.
    15. withholding of training,
    16. a negative performance assessment or employment reference
    17. failure to convert a temporary employment contract into a permanent one, where the employee had a legitimate expectation that he or she would be offered permanent employment;
    18. failure to renew or early termination of a temporary employment contract;
    19. harm, including to the reporting person’s reputation, particularly in social media, or financial loss, including loss of business and loss of income;
    20. blacklisting on the basis of a sector or industry-wide informal or formal agreement, which may entail that the person will not, in the future, find employment in the sector or industry;
    21. early termination or cancellation of a contract for goods or services;
    22. cancellation of a licence or permit; or
    23. psychiatric or medical referrals
  4. NMI will not penalise or threaten to penalise the worker for making a protected disclosure. NMI will not allow any other person to penalise or threaten penalisation (including informal pressure) for having made a disclosure in accordance with this policy.
  5. NMI will take appropriate action to prevent and remedy any penalisation or breach of confidentiality of workers when they:
    1. report a relevant wrongdoing or are suspected of making a report about a relevant wrongdoing,
    2. or provide information or act as a witness as part of an investigation under this policy;
    3. seek redress under the provisions of the Act;
    4. or are otherwise involved in actions under this policy.
  6. These protections extend beyond the workplace, for example to conferences and training that occurs outside the workplace and to work-related social events.
  7. Penalisation or threats of penalisation by members of staff will not be tolerated. Such behaviour may constitute misconduct and may lead to disciplinary action up to and including dismissal.
  8. Penalisation or threats of penalisation of our workers by suppliers, clients and others we do business with will not be tolerated and may lead to termination of contracts or suspension of services, or the exclusion from NMI’s premises or the imposition of other sanctions.

Complaints procedure for a case of penalisation

  1. A complaint of penalisation or for a breach of confidentiality under this policy can be made under NMI’s Grievance Policy.
  2. A copy of the complaint of penalisation should be brought to the attention of the Protected Disclosure Manager.
  3. Employees can make a complaint of Penalisation, under the Act to the Workplace Relations Commission in accordance with Schedule 2 of the Act.

Records

  1. Records of concerns raised, including the outcome, will be maintained by the NMI Directorate for a minimum of five years after the closure of the case.
  2. These records will be maintained in a confidential and secure environment.
  3. A summary report on all protected disclosures will be included in NMI’s Annual Report.

 

Communication, monitoring and review

  1. This policy will be communicated to all workers and members and others we do business with.
  2. This policy will be monitored for its effectiveness and will in any event be referred to joint management/union review every two years.
  3. The policy will be reviewed at minimum intervals of two years or when required by the Board of NMI.
  4. While the NMI cannot always guarantee the outcome workers are seeking, it will try to deal with concerns fairly and in an appropriate way. By using this policy workers can help the NMI to achieve this.

 
Appendix A
Contact and Advice Points
 
Protected Disclosure (Amendment Act) 2022
List of Prescribed Persons https://www.gov.ie/prescribed-persons
Copy of the Code of Practice: Grievance and Disciplinary Procedures
Workplace Relations Service - http://www.workplacerelations.ie/en/
Irish Congress Trade Unions - http://www.ictu.ie/
Transparency International - http://transparency.ie/

 
Appendix B
Guidance for NMI Managers in dealing with disclosures
 
All reported disclosures about perceived wrongdoing in the workplace must be treated seriously.
The manager to whom a concern is disclosed should:
  1. Record the disclosure and the steps taken to deal with it.
  2. Clarify the basis of the concerns raised with the worker.
  3. Establish what evidence is available to support the concern.
  4. Consider any personal interest the worker might have in the issue concerned.
  5. Risk assesses the issue and takes immediate action if the alleged wrongdoing involves a serious loss or danger to others.
  6. Carry out relevant enquiries promptly, sensitively and discretely, taking all reasonable steps to protect the identity of the maker of the disclosure.
  7. If it is necessary to reveal the worker’s identity to undertake an effective enquiry, consult with the worker.
  8. Obtain evidence from any relevant witnesses.
  9. Assess whether the disclosure report is based on a reasonable belief but ungrounded, based on a reasonable belief and grounded or a deliberately false report.
  10. Take appropriate action if the disclosure is grounded.
  11. If the disclosure is deliberately false consider action under the NMI Disciplinary Code.
  12. Provide written feedback to the worker within 20 days, including any proposed action.
  13. Report the outcome and forward all records to the Director, NMI.
 

 
Appendix C
Internal Reporting Process Workflow
 
The following diagram summarises the life cycle of disclosures within NMI from the time the report was made, through the assessment phase to establish whether the report was grounded and the action thereafter.
 
 
 
 
 
 
Report Made

 
 
 
 
 
 
Assessment
 
 
 

 
   
 
Report based on Reasonable Belief but ungrounded
 
 
 
 
 

 
 
Deliberately False Report
 
 
Closed
 
 
 
 
 

 
Concerns addressed under relevant policy
Feedback to reporter and then addressed under disciplinary code
 
Feedback to reporter
 
 
 
 
   

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