freedom to speak up policy · 2019 freedom to speak up policy page 4 of 17 1. staff quick reference...
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2019 Freedom to Speak Up Policy Page 1 of 17
Freedom to Speak Up Policy
(Whistleblowing) APPROVED BY: Ratified by Governing Bodies December 2019 – February 2020 See individual details in the version control table on page 2 EFFECTIVE FROM: December 2019 REVIEW DATE: December 2020 This policy must be read in conjunction with the following:
Being Open and Duty of Candour Policy
Clinical Commissioning Group Constitution
Confidentiality Code of Conduct
Standards of Business Conduct and Hospitality
Conflicts of Interest Policy (including Gifts and Hospitality)
Disciplinary Policy
Dignity at Work (Bullying and Harassment) Policy
Fraud Bribery and Corruption Policy
Incident Reporting Policy and Procedure
Individual Grievance Policy
Serious Incident Assurance Policy
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Version Control
Policy Category: Governance
Relevant to: All Staff (including temporary staff, contractors and seconded staff)
Version History
Version No.
Date Changes Made:
0.1 May 2019 Text of standard integrated policy recommended by review by Sir Robert Francis into whistleblowing in the NHS 2016 adapted by EHS and HR CCG
0.2 May 2019 Reviewed by Governance and Policy Officer to be Sussex-wide for the seven CCGs
0.3 June 2019 Reviewed by managers across the seven CCGs
0.4 October 2019 Updated to include new NHS scheme to offer support to whistleblowers
0.5 October 2019 Reviewed by TIAA Local Counter Fraud Specialist
0.6 November 2019 Review by Governance Manager North
0.7 13/11/2019 19/11/2019 20/11/2019 20/11/2019
Approved by NHS Brighton and Hove CCG and NHS High Weald Lewes Havens Audit Committees Approved by NHS Coastal West Sussex CCG Audit Committee Approved by NHS Crawley CCG and NHS Horsham and Mid Sussex CCG Audit Committees Approved by NHS Eastbourne Hailsham and Seaford CCG and NHS Hastings and Rother CCG Audit Committees
1. 05/02/2020 28/01/2020 30/12/2019 29/01/2020
Ratified by NHS Brighton and Hove CCG and NHS High Weald Lewes Havens CCG Governing Bodies Ratified by NHS Coastal West Sussex CCG Governing Body Ratified by NHS Crawley CCG and NHS Horsham and Mid Sussex CCG Governing Bodies Ratified by NHS Eastbourne Hailsham and Seaford CCG and NHS Hastings and Rother CCG Governing Bodies
1.1. 30/04/2020 Policy updated to include new contact details and
corporate template
2019 Freedom to Speak Up Policy Page 3 of 17
Contents
Version Control .................................................................................................................. 2
1. STAFF QUICK REFERENCE GUIDE. ............................................................................ 4
2. RAISING A CONCERN. .................................................................................................. 6
2.1 Process for Raising a Concern. ........................................................................... 6
2.2 What concerns can be raised? ............................................................................ 7
2.3 Feel Safe to Raise Your Concern. ........................................................................ 8
2.4 Confidentiality. ...................................................................................................... 8
2.5 Who can raise concerns? ..................................................................................... 9
2.6 Who should staff raise concerns with? .............................................................. 9
2.7 Fraud, Bribery and Corruption. ............................................................................ 9
2.8 What will we do? ................................................................................................... 9
2.9 Investigation. ....................................................................................................... 10
2.10 Communication. .................................................................................................. 10
2.11 How will we learn from the concern raised? .................................................... 11
2.12 Governing Body oversight. ................................................................................ 11
3. RESPONSIBILITIES. .................................................................................................... 11
4. CCG CONTACTS AND SUPPORT SERVICES. .......................................................... 12
5. TAKING CONCERNS OUTSIDE THE CCG. ................................................................ 13
6. REFERENCES. ............................................................................................................. 13
7. EQUALITY. ................................................................................................................... 15
8. MONITORING AND REVIEW. ...................................................................................... 15
Appendix A: Process for Raising a Concern. ............................................................... 16
Appendix B: A Vision for Raising Concerns in the NHS. ............................................. 16
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1. STAFF QUICK REFERENCE GUIDE.
1.1 The Sussex Clinical Commissioning Groups comprise the following three CCGs:
NHS Brighton and Hove CCG
NHS East Sussex CCG
NHS West Sussex CCG
1.2 The three CCGs that make up the Sussex Clinical Commissioning Groups have historically used different whistleblowing policies. Accordingly, this policy has been created in order to ensure a consistent approach, and will be applied uniformly across the CCGs.
1.3 Speaking up about any concern CCG staff have at work is important. In fact, it is vital because it will help the CCG to keep improving services for all patients, and the working environment of staff.
1.4 Staff may feel worried about raising a concern, but shouldn’t be put off. In accordance with the duty of candour, CCG senior managers and the Governing Body are committed to an open and honest culture. The CCG will look into what staff say and staff will have access to any support needed. The CCG’s Being Open and Duty of Candour Policy is available on the staff Intranet.
1.5 Staff raising legitimate concerns are protected by the Public Interest Disclosure Act
1998. This is an Act to protect individuals who make certain disclosures of information in the public interest to allow such individuals to bring action in respect of victimisation, and for connected purposes.
1.6 This “standard integrated policy” is one of a number of recommendations of the
review by Sir Robert Francis into whistleblowing in the NHS, aimed at improving the experience of whistleblowing in the NHS. It is expected that this policy (produced by NHS England and NHS Improvement) will be adopted by all NHS organisations in England as a minimum standard to help normalise the raising of concerns for the benefit of all patients.
1.7 CCG local processes have been integrated into this policy, adhere to the principles
of this policy and provide more detail about how the CCG will look into a concern.
1.8 Following successful pilots, the NHS will soon offer practical support to any doctor, nurse, or other worker across the country who needs additional support to build their career after raising concerns at work, as part of the NHS Long Term Plan to improve care and treatment. improvement.nhs.uk/resources/whistleblowers-support-scheme/
1.9 The scheme will offer :
Career coaching
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Shadowing opportunities
Work experience
CV writing advice
Interview skills practice
Resilience training
to former or current members of staff who have blown the whistle on poor practice.
1.10 Any person who victimises someone who has raised genuine concerns under this policy will be subject to disciplinary action.
1.11 However, abuse of the process through the raising of unfounded, malicious allegations will also be regarded as a disciplinary matter. The CCG’s Disciplinary Policy is available on the staff Intranet.
1.12 There are several sources of advice and information available to staff who are unsure whether, or how, to raise a concern. See also Sections 4 and 5 of this policy. For full staff contact details, see the staff Intranet.
National Freedom to Speak Up Guardian for the NHS
Henrietta Hughes 0300 067 9000 [email protected]
CCGs’ Freedom to Speak Up Guardians
Brighton and Hove – Jane Chandler
West Sussex - Alison Lewis-Smith
East Sussex - Denise Matthams
Director with responsibility for whistleblowing
Executive Director of Corporate Governance – Terry Willows
Lay members with responsibility for oversight of the whistleblowing process
Brighton and Hove - Andrew Taylor
East Sussex - Carol Pearson
West Sussex - Jeni Graham
Company Secretaries Brighton and Hove / East Sussex - Nicola Bottomley
West Sussex - Mel Brown
CCGs’ Caldicott Guardian for safeguarding patient information
Brighton and Hove / East Sussex / West Sussex - Allison Cannon – Chief Nursing Officer
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2. RAISING A CONCERN. 2.1 Process for Raising a Concern.
Are you able to speak to your line manager?
No Yes
Raise your concern with:
the director with responsibility for whistleblowing
one of the lay members with responsibility for whistleblowing
Issue
resolved
Issue not resolved
Not sure what to do?
Refer to Freedom to Speak up
(Whistleblowing) Policy on staff
Intranet
Raise your concern with your local:
Freedom to Speak Up Guardian
Company Secretary
Issue investigated, appropriate action
taken and feedback given.
All above steps taken, however, issue not resolved or so serious that you
cannot discuss with any of the above
Issue not resolved
Consider raising once again with your local
Freedom to Speak Up Guardian
Company Secretary
Or raise your concern nationally
Raise your concern externally to a prescribed person or regulatory body or other external body as defined in the Public Interest Disclosure Act
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2.2 What concerns can be raised?
A concern can be raised about any risk, malpractice, fraud or wrongdoing in the CCG or that is harming the service(s) the CCG commissions. Examples of this include:
Unsafe patient care
Unsafe working conditions
Inadequate induction or training for staff
Lack of, or poor, response to a reported patient safety incident
Suspicions of fraud, bribery or corruption (which staff can also report directly to the counter-fraud team)
A bullying culture - across a team or organisation rather than individual instances of bullying. For individual instances of bullying, the CCG’s Dignity at Work (Bullying and Harassment) Policy is available on the staff Intranet. For further examples, please see the Health Education England video at hee.nhs.uk/our-work/raising-responding-concerns
2.2.1 Remember that all professionals working in the healthcare system may have a professional duty to report a concern. If in doubt, please raise it.
2.2.2 Don’t wait for proof. The CCG would like the matter raised while it is still a concern.
It doesn’t matter if it turns out to be a mistake as long as it was a genuine concern. 2.2.3 This policy is not for staff with concerns about employment issues that affect only
them. That type of concern is better suited to the CCG’s Individual Grievance Policy, available on the staff Intranet.
2.2.4 If the issue raised is a safeguarding issue then it is not dealt with under this policy. The separate policy on Managing Allegations against staff who work with children or adults should be used. This is available on the staff Intranet and deals with how allegations or concerns about abuse against employees are managed within the CCG. This includes allegations made against staff in their personal lives.
2.2.5 Compliance with the Managing Allegations policy and procedures will help to ensure that allegations against staff who work with adults or children are dealt with quickly, consistently and with a thorough and fair process.
2.2.6 If the issue raised is by a member of staff in a provider organisation rather than the CCG, then they should be referred back to their own internal whistleblowing procedures and also made aware of the possibility of raising their concern nationally.
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2.2.7 A whistleblowing concern is about a risk, malpractice or wrongdoing that affects others. It could be something which adversely affects patients, the public, other staff or the CCG itself.
2.2.8 A grievance on the other hand is a personal complaint against an individual’s own
employment situation: for example, a staff member may feel aggrieved if they think a management decision has affected them unfairly or that they are not being treated properly.
2.2.9 Whistleblowing is where an individual raises information as a witness whereas a
grievance is where the individual is a complainant and not covered under this policy.
2.3 Feel Safe to Raise Your Concern.
Any concerns must be raised at the earliest opportunity.
2.3.1 If a member of staff raises a genuine concern under this policy, there is no risk of them losing their job or suffering any form of reprisal as a result. Staff raising legitimate concerns are protected by the Public Interest Disclosure Act 1998. The CCG will not tolerate the harassment or victimisation of anyone raising a concern. Nor will the CCG tolerate any attempt to bully staff into not raising a concern. Any such behaviour is a breach of CCG values as an organisation and, if upheld following investigation, could result in disciplinary action.
2.3.2 Provided staff act honestly, it does not matter if they are mistaken or if there is an
innocent explanation for their concerns.
2.3.3 Any person who victimises someone who has raised genuine concerns under this policy will be subject to disciplinary action.
2.3.4 However, abuse of the process through the raising of unfounded malicious allegations will also be regarded as a disciplinary matter.
2.4 Confidentiality.
The CCG hopes that staff will feel comfortable raising concerns openly, but also appreciates that they may want to raise it confidentially. This means that while staff are willing for their identity to be known to the person they reported their concern to, they do not want anyone else to know their identity. Therefore, the CCG will keep identity confidential, if that is what is wanted, unless required to disclose it by law (for example, by the police).
2.4.1 Staff can choose to raise their concern anonymously, without giving anyone their
name, but this may make it more difficult for the CCG to investigate thoroughly and give feedback on the outcome.
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2.5 Who can raise concerns? Anyone who works (or has worked) for the CCG, including temporary staff, contractors and seconded staff can raise concerns. This includes agency workers, temporary workers, students, volunteers and members of the Governing Bodies.
2.6 Who should staff raise concerns with?
In many circumstances the easiest way to get a concern resolved will be to raise it formally or informally with your Line Manager. See Appendix A for the difference between raising a concern formally and informally and more details on the process of a concern.
2.6.1 Where staff do not think it is appropriate to do this, they can use any of the options
set out below. Full staff contact details are available on the Intranet.
2.6.2 If raising it with your Line Manager does not resolve matters, or a member of staff does not feel able to raise it with them, they can contact one of the following people:
The Freedom to Speak Up Guardian. This is an important role identified in the Freedom to Speak Up review to act as an independent and impartial source of advice to staff at any stage of raising a concern, with access to anyone in the organisation, including the Chief Executive Officer, or if necessary, outside the organisation
The Company Secretary.
2.6.3 If staff still remain concerned after this, they can contact:
The director with responsibility for whistleblowing
One of the lay members with responsibility for whistleblowing.
2.6.4 All these people have been trained in receiving concerns and will give information about where staff can go for more support.
2.6.5 Staff can also raise concerns using the Whistleblowing section in the staff online web-portal for Conflicts of Interest at: https://SussexCCGs.mydeclarations.co.uk Staff may choose to raise a concern anonymously if they wish.
2.6.6 If, for any reason, staff do not feel comfortable raising their concerns internally,
they can raise concerns with external bodies, see Section 5 below.
2.7 Fraud, Bribery and Corruption. If you are concerned about Fraud, Bribery or Corruption you can raise this with the CCG’s Counter Fraud Team or with the NHS Counter Fraud Authority.
2.8 What will we do?
The CCG is committed to the principles of the Freedom to Speak Up Review and its vision for raising concerns, and will respond in line with them. See Appendix B
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for the vision for raising concerns in the NHS.
2.8.1 The CCG is committed to listening to staff, learning lessons and improving patient care. On receipt, the concern will be recorded and the member of staff will receive an acknowledgement within two working days. The central record will record the date the concern was received, whether confidentiality was requested, a summary of the concerns and dates when updates or feedback were given.
2.9 Investigation.
Where staff have been unable to resolve the matter quickly (usually within a few days) with their Line Manager, the CCG will carry out a proportionate investigation – using someone suitably independent (usually from a different part of the organisation) and properly trained – and will reach a conclusion within a reasonable timescale (of which staff will be notified).
2.9.1 Wherever possible, the CCG will carry out a single investigation. For example,
where a concern is raised about a patient safety incident, a single investigation will usually be undertaken that looks at the concern and the wider circumstances of the incident. If the concern suggests a Serious Incident has occurred, an investigation will be carried out in accordance with the Incident Reporting Policy, available on the staff Intranet.
2.9.2 The CCG has a separate Serious Incident Assurance Policy which focuses on the management of SIs within commissioned providers. It is available on the staff Intranet.
2.9.3 The Whistleblowing investigation will be objective and evidence-based, and will produce a report that focuses on identifying and rectifying any issues, and learning lessons to prevent problems recurring.
2.9.4 The CCG may decide that the concern would be better looked at under another process; for example, bullying and harassment. If so, this will be discussed with the member of staff.
2.9.5 Any employment issues that affect only the member of staff who raised the concern and not others identified during the investigation will be considered separately under the CCG’s Individual Grievance Policy.
2.10 Communication.
The CCG will treat staff with respect at all times and will thank them for raising their concern. The concern will be discussed with the member of staff to ensure the CCG understands exactly what they are worried about. The member of staff will be told how long the investigation is expected to take and be kept up to date with its progress. Wherever possible, the full investigation report will be shared with the member of staff while respecting the confidentiality of others.
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2.11 How will we learn from the concern raised? The focus of the investigation will be on improving the service the CCG provides. Where it identifies improvements that can be made, they will be tracked to ensure necessary changes are made, and are working effectively. Lessons will be shared with teams across the organisation, or more widely, as appropriate.
2.12 Governing Body oversight.
The Governing Bodies will be given high level information about all concerns raised by staff through this policy and what is being done to address any problems. Similar high level information will be included in the annual report. The Governing Bodies support staff raising concerns and want them to feel free to speak up.
3. RESPONSIBILITIES.
3.1 The Chief Executive Officer will regularly review the themes of concerns that have been formally recorded by the Freedom to Speak Up Guardian to ensure local procedures are effective, and to identify areas for improvement.
3.2 The Governing Bodies will consider annually (and by exception when necessary)
a report covering the concerns raised under this policy and the action and learning from these concerns.
3.3 The Executive Management Team is responsible for ensuring this policy is
properly applied and adhered to across the CCGs. Safe and learning cultures are most successful in organisations where responsibility and accountability for local policy and procedures for raising concerns is in the remit of EMT.
3.4 The Local Management Teams ensure that this policy is applied in practice across their own local area.
3.5 Lay members are responsible for seeking assurance that concerns raised are
managed in line with this policy and procedure and that the CCG operates in a culture of openness and learning.
3.6 Director with responsibility for raising concerns. The Executive Director of
Corporate Governance has particular responsibility for reviewing concerns raised across the CCG and ensuring that learning is implemented from these. They are also a point of contact for staff who maybe struggling to resolve concerns within the CCG or may feel unable to raise them with their line manager or senior managers. This director should ensure that the policy and procedure is followed where staff approach them directly.
3.7 The Freedom to Speak Up Guardians are responsible for helping to nurture a
culture of openness, by acting as an independent and impartial source of advice to
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staff at any stage of raising a concern, with access to anyone in the organisation, including the Chief Executive Officer, or if necessary, outside the organisation.
3.8 Line Managers are key to developing a culture of safety and learning, in which all
staff feel safe to raise a concern about anything they believe is harming the services we deliver. Line Managers are responsible for managing concerns effectively in line with this policy; they must also ensure that no member of staff suffers detriment because of raising concerns and where this is the case they must ensure appropriated action is taken to address this.
3.9 All staff have a responsibility to read and understand this policy. Staff are
expected to support the CCG values and support the CCG to maintain a culture of openness and safety. Staff should ensure that they raise concerns in the spirit of this policy and that no colleague who chooses to raise a concern is victimised or bullied, as a result of doing so.
3.10 The Corporate Governance Team will record concerns raised on the appropriate database. They will support and advise staff and managers in the application of this policy and procedure and raise awareness of the policy and procedure.
3.11 Human Resources. Any HR policies invoked as part of this process will be supported in the usual way by HR to ensure consistent and equitable application.
3.12 Counter Fraud. Secretary of State Directions issued to all NHS Bodies require the CCG to appoint and nominate a professionally accredited Counter Fraud Specialist (CFS). The CFS is authorised to receive enquiries from staff confidentially and anonymously and can decide whether the matter raised needs to be investigated.
4. CCG CONTACTS AND SUPPORT SERVICES.
4.1 Concerns can be raised with any of the people listed in the table above, by phone or in writing (including email).
4.2 Whichever route is chosen, please be ready to explain fully the information and circumstances that gave rise to the concern.
4.3 Counselling in Confidence. The CCGs offer an Employee Assistance Programme Counselling in Confidence (CiC). CiC is available to both employees and family members. It is an independent, free and confidential advice service available 24/7/365. Call 0800 085 1376 or 020 7938 0963. Email [email protected] Skype using Confidential Care Adviceline. Website www.well-online.co.uk
4.4 Occupational Health
Employees may also self-refer to the Occupational Health Service.
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5. TAKING CONCERNS OUTSIDE THE CCG.
5.1 There may be occasions when staff, having reported serious concerns, will feel that these have not adequately been dealt with by the CCG and that they have no alternative but to take them further. There may also be occasions when concerns are about actions of the Governing Body or CCG Chair and staff will feel unable to raise them within the CCG.
5.2 Employees have an implied duty of confidentiality and loyalty to their employer. Making allegations to a third party can breach this duty. Staff are therefore advised to consult representatives from their professional association or trade union before taking the matter further. Other organisations that can provide support include:
5.3 ‘Speak Up’ helpline speakup.direct/ This is a free, independent and confidential helpline for people working in NHS and Social Care organisations in England, operated by Social Enterprise Direct Limited on behalf of the Department of Health and Social Care. You can contact them on 08000 724 725 or by completing their contact form.
5.4 Protect www.pcaw.org.uk This is a national charity which aims to protect society by encouraging speaking up in the workplace. It provides legally privileged advice to individuals, supports organisations with their speaking up arrangements and monitors legislative impact and campaigns for change. You can contact them by calling 020 3117 2520 or by emailing [email protected].
5.5 The Department for Business, Energy and Industrial Strategy has produced a useful list of prescribed bodies that can provide support. This document includes information about the matters you can report to each prescribed person. Please ensure that you have selected the correct person or body for your issue.
5.6 The National Guardian's Office provides advice on the Freedom to Speak Up Guardian role and supports the Freedom to Speak Up Guardian network. Please note: the National Guardian’s Office cannot provide legal advice and support.
6. REFERENCES.
Care Quality Commission. www.cqc.org.uk/ Freedom to Speak Up Review. freedomtospeakup.org.uk/
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General Medical Council. www.gmc-uk.org/
www.gmc-uk.org/DC5900_Whistleblowing_guidance.pdf_57107304.pdf Government list of “prescribed persons” under the Public Interest Disclosure Act 1998.
www.gov.uk/government/publications/blowing-the-whistle-list-of-prescribed-people-and-bodies--2
Health Education England. hee.nhs.uk/ National Speak Up Guardian for the NHS.
www.cqc.org.uk/national-guardians-office/content/national-guardians-office NHS England and NHS Improvement. www.england.nhs.uk/ NHS Counter Fraud Authority - concerns about fraud, bribery or corruption.
cfa.nhs.uk/ NHS England – Whistleblowing information.
www.england.nhs.uk/ourwork/whistleblowing/
www.england.nhs.uk/2019/10/nhs-whistle-blower-support-scheme-to-roll-out-across-the-country/?utm_source=feedburner&utm_medium=email&utm_campaign =Feed%3A+NHSCBoard+%28NHS+England%29
improvement.nhs.uk/resources/whistleblowers-support-scheme/ NHS Long Term Plan. www.longtermplan.nhs.uk/ Nursing and Midwifery Council.
www.nmc.org.uk/
www.nmc.org.uk/concerns-nurses-midwives/ Protect www.pcaw.org.uk This is a national charity which aims to protect society by encouraging speaking up in the workplace. Public Interest Disclosure Act 1998.
www.gov.uk/government/publications/the-public-interest-disclosure-act Speak Up. speakup.direct/about-us/ Speak Up is delivered by Social Enterprise Direct on behalf of the Department of Health. The service is specifically aimed at employees and managers of NHS and Social Care organisations in England and Wales.
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7. EQUALITY.
In applying this policy, the CCG will have due regard for the need to eliminate unlawful discrimination, promote equality of opportunity, and provide for good relations between people of diverse groups, in particular on the grounds of the following characteristics protected by the Equality Act (2010); age, disability, sex, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, and sexual orientation, in addition to offending background, trade union membership, or any other personal characteristic.
8. MONITORING AND REVIEW.
8.1 This policy will be reviewed annually. Where review is necessary due to legislative change, this will happen immediately.
8.2 The implementation of this policy will be audited on an annual basis, or when changes in legislation dictate.
8.3 An Equality and Health Inequality Impact Assessment (EHIA) has been carried out on this policy. As a result, there is no anticipated detrimental impact on any equality group.
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Appendix A: Process for Raising a Concern.
Are you able to speak to your line manager?
No Yes
Raise your concern with:
the director with responsibility for whistleblowing
one of the lay members with responsibility for whistleblowing
Issue
resolved
Issue not resolved
Not sure what to do?
Refer to Freedom to Speak up
(Whistleblowing) Policy on staff
Intranet
Raise your concern with:
your local Freedom to Speak Up Guardian
your local Company Secretary
Issue investigated, appropriate action
taken and feedback given.
All above steps taken, however, issue not resolved or so serious that you
cannot discuss with any of the above
Issue not resolved
Consider raising once again with your local
Freedom to Speak Up Guardian
Company Secretary
Or raise your concern nationally
Raise your concern externally to a prescribed person or regulatory body or other external body as defined in the Public Interest Disclosure Act
2019 Freedom to Speak Up Policy Page 17 of 17
Appendix B: A Vision for Raising Concerns in the NHS.
Source: Sir Robert Francis QC (2015) Freedom to Speak Up: an independent report into creating an open and honest reporting culture in the NHS. webarchive.nationalarchives.gov.uk/20150218150343/https:/freedomtospeakup.org.uk/