freedom to speak up: raising concerns (whistleblowing) policy · freedom to speak up: raising...

of 20 next review: January 2021

Freedom To Speak Up Raising Concerns (Whistleblowing) UHL Policy V6 approved by Policy and Guideline Committee on 17 July 2020 (review date extension)

Trust Ref. A15/2001

Freedom To Speak Up Raising Concerns (Whistleblowing) UHL Policy

Approved By: Policy & Guideline Committee

Date of Original Approval:

(Whistleblowing Policy originally approved on 12.11.01 by the Trust Board)

Trust Reference: A15/2001

Version: 6

Supersedes: Version 5 – August 2017 Whistleblowing in the NHS Policy (The Public Interest Disclosure Act 1998) A15/2001

Trust Lead: Freedom to Speak Up Guardian/ Director of Safety of Risk

Board Director Lead:

Chief Executive

Date of Latest Approval

17 July 2020 – Policy and Guideline Committee (review date extended)

Next Review Date: January 2021



Trust Ref. A15/2001

CONTENTS

Section Page

1. Introduction and overview 3

2. Policy Scope 4

3. Definitions and Abbreviations 4

4. Roles, Who Does What? 4-6

5. Freedom to Speak Up/Raising Concerns, Internal Contacts 6-10

6. External Contacts 10 - 11

7. Support Services for You 11

8. Education and Training 12

9. Process for Monitoring Compliance 12

10. Equality Statement 12

11. Supporting References, Evidence Base and Related Policies 13

12. Process for Version Control, Document Archiving and Review 13

Appendices Page

13. Raising a Concern Flowchart Appendix 1 14

14. Managing a Concern Flowchart Appendix 2 15

15. Director on Call Managing Concern Flowchart Appendix 3 16

16. A Vision of Raising Concerns in the NHS Appendix 4 17

17. Health Education England ‘Junior Doctor Whistleblowing Third Party Rights’ Appendix 5

18- 20



Trust Ref. A15/2001

Review Dates and Details of Changes Made During the Review

June 2017 V5 Policy adapted from National Guidance Freedom to Speak up: raising concerns (whistleblowing) policy for the NHS April 2016/ Renamed following staff survey

August 2017 V5 Policy written as first person. Flow charts added to share simplified approach for staff at UHL to raise concerns around patient safety. Contact details added to policy to create an openness and transparency for staff

KEY WORDS

Whistleblowing, genuine concern, raising a concern, disclosure, openness, Freedom to Speak Up Guardian.

1 INTRODUCTION AND OVERVIEW

1.1.1 This document sets out the University Hospitals of Leicester (UHL) NHS Trust’s Policy and Procedure for Freedom to Speak Up: Raising Concerns (Whistleblowing) Policy.

1.1.2 This policy has been adopted by the Trust to help normalise staff raising concerns for

the benefit of all patients and is based on the National Freedom to Speak Up: Raising Concerns (Whistleblowing) Policy, (NHS England and NHS Improvement April 2016).

1.1.3 The Trust is keen to promote, “speaking up safely” and is committed to the

principles of the Freedom to Speak review and its vision.

1.1.4 The Public Interest Disclosure Act (1998) and Freedom to Speak Up Review (2015) provides strong evidence on why organisations should have whistleblowing policies.

1.1.5 A ‘standard integrated policy’ was one of a number of recommendations by Sir Robert Francis into whistleblowing in the NHS and to foster a climate of openness and dialogue which encourages staff to feel able to raise concerns sensibly and responsibly without fear of victimisation, bullying or harassment.

1.1.6 In accordance with the statutory duty of candour, senior leaders and our Trust Board at The University Hospitals of Leicester NHS Trust are committed to an open and honest culture across the Trust. Therefore speaking up about any concern at work is vital, to ensure services are continually improving.

1.2 Feel safe to raise your concern

1.2.1 If you raise a genuine concern under this policy, you will not be at risk of losing your

job or suffering any form of reprisal as a result.

1.2.2 The Trust aims, via this policy, to enable you to have the confidence to raise any suspected wrong doing at an early stage (either informally or formally) and in the knowledge that your concerns will be taken seriously and investigated as appropriate, and respected.



Trust Ref. A15/2001

1.2.3 The Trust will not tolerate the harassment or victimisation of anyone raising a concern. Nor will we tolerate any attempt to bully you into not raising any such concern. However, it is recognised that an individual may have good reasons to raise a concern in confidence and their identity will not be disclosed without their consent (unless disclosure is required by law).

1.2.4 All staff who raise concerns/speak up (Whistle blowers) must not suffer any

detrimental treatment as a result of raising a genuine concern. Detrimental treatment includes: disciplinary action, dismissal, threats or other unfavourable treatment, connected with raising a concern.

1.2.5 If you believe that you have suffered any such treatment, you should inform the Director of Workforce and Organisational Development immediately. Any such behaviour is a breach of our Trust values as an organisation and, if upheld following investigation, could result in disciplinary action.

1.2.6 Provided you are acting honestly with your concern. It does not matter if you are mistaken or if there is an innocent explanation for your concerns. These concerns may include (but not limited to) the disclosure of information which relates to risk, malpractice or wrongdoing that may harm the service we are delivering.

2 POLICY SCOPE – WHO THE POLICY APPLIES TO AND TO ANY SPECIFIC EXCLUSIONS

2.1 This policy applies to all members of staff, who work, (or have worked) for University Hospitals of Leicester NHS Trust (UHL).

2.2 You should not use this policy to settle a personal grievance or dispute. A grievance

is a personal complaint about your own employment situation: for example, you may feel aggrieved that a management decision has affected you unfairly or that you are not being treated fairly.

2.3 In those cases you should use the ‘Staff Grievance and Disputes Policy and Procedure’ (Trust Ref. A7/2004) or Anti-Bullying and Harassment Policy as appropriate (Trust Ref. B5/2016).

3 DEFINITIONS AND ABBREVIATIONS

3.1 Raising a concern/speaking up - raising a genuine concern relating to suspected wrong-doing or danger affecting any of the Trust’s activities

3.2 Employees - who work, (or have worked) for UHL.

4 ROLES – WHO DOES WHAT

4.1 Executive Lead of policy

4.1.1 The Chief Executive is the lead for this policy.

4.2 Freedom to Speak Up Guardian



Trust Ref. A15/2001

4.2.1 A Freedom to Speak up Guardian has been appointed to develop and promote a ‘Freedom to Speak up’ strategy. The role of the guardian is to act in an independent capacity, to support the Trust to become a more open, transparent place to work and to listen and support all employees to raise concerns.

4.2.2 This role has been identified in the Freedom to Speak Up review (please see Appendix 4) to act as an independent and impartial source of advice to you at any stage of raising a concern. The Freedom to Speak up Guardian has access to anyone in the organisation, or if necessary, outside the organisation.

4.2.3 The Freedom to Speak Up Guardian reports to Director of Safety and Risk and the

Chief Executive.

4.2.4 The Freedom to Speak Up Guardian is not part of the investigation process when you have raised a concern.

4.2.5 The role of the Freedom to Speak Up Guardian when a concern is received is to

acknowledge the concern, thank the staff member / staff group for raising the concern and gather further information (please see Appendix 2 for key questions).

4.2.6. Once the further information has been received, and appropriate consent has been

obtained, and the concern will be escalated to the relevant CMG / Corporate and Directorate Lead/ Human Resources CMG Lead to investigate the concern.

4.2.7 This will include highlighting the benefits for staff, the public, and patients of any

improvements made as a result of you raising a concern.

4.2.8 All concerns will be measured (themes and trends), monitored and published, by the Freedom to Speak up Guardian, to Trust Board on a quarterly basis.

4.2.9 Our Quality Outcome Committee will maintain oversight of Freedom to Speak Up (Whistleblowing) concerns via quarterly reporting from the Freedom to Speak Up Guardian / Director of Safety and Risk.

4.3 Director on Call

4.3.1 The Director on Call will review and acknowledge any staff concerns via the 3636 staff reporting line, and decide how best to address the concern (Appendix 3).

4.4 Director of Safety and Risk/ CMG management Team/Corporate Directors Lead

4.4.1 The role of the Director of Safety and Risk is to offer support and line management to the Freedom to Speak up Guardian, ensure that the Trust listens to and responds to staff concerns, triangulates themes from concerns raised and plays back to the Board staff concerns and related actions.

4.4.2 The CMG Management Team / Corporate Directors are responsible for responding to any concerns escalated to them by the Freedom to Speak Up Guardian, as per Appendix

4.5 Managers (including Clinical Education Supervisors for Junior Doctors)

4.5.1 Managers will ensure that all staff are made aware of this policy as part of their local induction and when any significant changes are made to the policy.



Trust Ref. A15/2001

4.5.2 Managers will welcome, thank and encourage staff to raise any concerns within the remit of this policy, and will ensure these concerns are listened to and acted upon in a supported and safe environment.

4.5.3 Concerns will be escalated to the Freedom to Speak up Guardian (where managers

feel it is appropriate. The manager may deal with the concern under a more appropriate procedure. For example: Staff Grievance and Disputes Policy and Procedure (Trust Ref. A7/2004) or Anti-Bullying and Harassment Policy as appropriate (Trust Ref. B5/2016).

4.5.4 Managers will ensure that staff have the opportunity to engage in reflective practice 1

with their colleagues and teams regarding concerns in their work place. This may include, but is not limited to, 1-1 meetings, appraisals, and Continuing Professional Development.

4.5.5 For Junior Doctors raising concerns, further guidance has been published by Health

Education England (please see Appendix 5).

4.6 Staff/ Employees

4.6.1 All health professionals have a duty to raise a safety concern and report unsafe

practice.

4.6.2 You should be able to raise a concern in a supported and safe environment (refer to section 5 and 6 on how to raise a concern and independent advice).

4.6.3 You may have the opportunity to engage in reflective practice with your manager, colleagues and teams regarding concerns in their work. This may include, but is not limited to, one to one meetings, appraisals and Continuing Professional Development to ensure services are continually improving.

4.7 Generalist Human Resources Staff

Human Resources available to provide advice on the interpretation and application of this policy to all parties throughout the process when raising a concern.

4.8 UHL Staff Side

Staff Side are available to provide advice and support to all employees on the application of this policy and throughout any process resulting from the policy.

5 RAISING CONCERNS

5.1 Confidentiality

5.1.1 The Trust hopes you will feel comfortable raising your concern openly under this policy, and appreciate that you may want to raise your concern confidentially. This means that whilst you are willing for your identity to be known to the person you report your concern to, you do not want anyone else to know your identity.

5.1.2 Therefore, your details will be kept confidential, if that is what you want, unless

required to disclose it by law (for example, by the police).

1 Reflective practice is a method used with the aim of learning and personal development using the Gibbs Reflective Cycle

https://jessewandrews.files.wordpress.com/2015/01/gibbs_reflective_cycle.png



Trust Ref. A15/2001

5.1.3 Consent will be obtained in the first instance on whether your details will be shared.

5.1.4 You can choose to raise your concern anonymously, without giving anyone your

name, but that may make it more difficult for us to investigate thoroughly and give you feedback on the outcome. Anonymous reports will not be ignored; however it may not be possible to follow all parts of this policy when concerns are raised anonymously.

5.1.5 If the situation arises where a concern cannot be resolved without revealing an identity (for instance because evidence is needed in court), this will first be discussed with you, so that you are aware that your identity will be revealed.

5.1.6 The Trust will ensure you are supported and will signposted to supportive services.

(See Section 7, Supportive Services).

5.2 How to raise a concern?

5.2.1 You can raise concerns about risk, malpractice or wrongdoing where you think this is harming, or has potential to harm the people we provide care for, the safety of the service we deliver or the staff, paid and unpaid, who work in the Trust:

Below are just a number of examples but are not exhausted to:- Unsafe patient or client care. Unsafe working conditions. Inadequate induction or training for staff or volunteers. Lack of, or poor, response to a reported safety incident. Suspected fraud, which can also be reported to the Counter-Fraud Team. See

section 5.5.1. A bullying culture (across a team or organisation. Individual instances of bullying

will be processed under the Anti-Bullying and Harassment Policy).

5.3 How to raise a concern internally (for information on external advice see section 6)

5.3.1 The Trust is committed to listening to staff, learning lessons and improving patient

care.

5.4 How to raise a concern?

5.4.1 It is encouraged that you raise your concern, in the first instance, with your line manager / Clinical Education Supervisor for Junior Doctors, or the next in line manager if more appropriate i.e. if the concern involves your immediate line manager, following The Raising Concerns Flowchart (appendix 1).

5.5 Routes to raise concerns

5.5.1 You can also raise your concerns via the following mechanisms if you are unable to speak to your line manager:-

5.5.2 Contact your Matron or Head of Service. CMG Clinical Director, Head of Operations, Head of Nursing, and Head of Midwifery or Corporate Director. Clinical Education Supervisors for Junior Doctor. Deputy Medical Director. Medical Director.



Trust Ref. A15/2001

5.5.3 Staff concerns reporting line (“3636”) to raise any Safety Concern, Internally 3636 externally 0116 258 3636. Staff concerns reporting online form on INsite

5.5.4 Contacting the Freedom to Speak Up Guardian for Trust, on INsite (staff intranet), e-

mail, or directly by telephone 07950 839130.

5.5.5 HR helpline – 0116 258 5614. [email protected]

5.5.6 Contact the Confidential Anti-bullying and Harassment advice line - 0116 258 8096

[email protected]

5.5.7 Junior Doctors can complete Junior doctors Gripe Reporting tool form on INsite

5.5.8 By logging concerns on “Staff Room” via InSite.

5.5.9 You can request a Safety walkabout to the area of work by calling 0116 250 2740. Raise your concerns with senior colleagues during safety walkabout visits.

5.5.10 Book on Director Breakfasts (Breakfast with the Boss) which are advertised on INsite.

5.5.11 Access Staff Side Representatives (local) and Staff Side Offices across sites 0116 258 4080

5.5.11 Contact the Health and Safety Services Team on 0116 258 3386/ 0116 258 3769/ 0116 258 3392/ 0116 2588031

5.5.13 Concerned about Fraud, speak in confidence too: Neil Mohan 01509 604029

[email protected], or Gina Lekh on 01223 552333 [email protected] or Juliette Meek on 01603 883099 [email protected] NHS confidential fraud and corruption reporting line on 0800 0284060 and www.reportnhsfraud.nhs.uk

5.5.14 If you feel unable to raise the matter with any of the above routes. Staff can access any of the following below:

Director of Safety & Risk Telephone: 0116 250 2740 Email: [email protected]

Director of Workforce and Organisational Development Telephone: 0116 258 8903 Email: [email protected]

Medical Director Telephone: 0116 258 3871 Email: [email protected]

Director of Corporate & Legal Affairs Telephone: 0116 258 8615 Email: [email protected]

Chief Nurse

Telephone: 0116 258 5488 Email: [email protected]

mailto:[email protected]





http://insite.xuhl-tr.nhs.uk/homepage/clinical/clinical-education/junior-doctors/doctors-in-training-committee/gripe-reporting-tool

http://staffroom/default.asp

http://insite.xuhl-tr.nhs.uk/index.asp?pgid=51679




http://www.reportnhsfraud.nhs.uk/








Trust Ref. A15/2001

Non-Executive Director Telephone: 0116 258 8615 Email: [email protected]

Chief Executive Telephone 0116 258 8940 Email: [email protected]

Chairman Telephone 0116 258 8615 Email: [email protected]

5.6 Once your concern has been received

5.6.1 Once a concern has been raised, there is a process of escalation and investigation in order to identify possible malpractice or wrongdoing to take the appropriate steps to deal with it.

5.6.2 Your concern will be recorded securely on datix, this data is closed, the staff with

access to this are:- Director of Safety and Risk, Senior Patient Safety Manager, Freedom to Speak up Guardian, Information Patient Safety Information Analyst/ Assistant.

5.6.3 Your concern will be acknowledged within two working days and cascaded to the

relevant manager, CMG Directorate (including Clinical Education Supervisors for Junior Doctors) to investigate.

5.6.3 Human Resources may be contacted to identify if the concern is known to them and to discuss any appropriate actions.

5.6.4 The action plan and feedback will be shared with the Freedom to Speak Up Guardian

throughout the process.

5.7 What will we do when a concern has been raised?

5.7.1 How the concern is investigated may vary, dependent on the nature of the concern

raised, and further information may be requested, (so, for example, where a concern is raised about a patient safety incident, we will usually undertake a single investigation that looks at your concern and the wider circumstances of the incident).1

5.7.2 We may decide that your concern would be better looked at under another process; for example, our process for dealing with bullying and harassment (Anti-

Bullying and Harassment Policy Trust Ref. B5/2016). If so, this will be discussed with you.

5.7.3 The 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. The person investigating the concern raised will provide an estimated time frame; this may vary depending on the nature of the concern.

1 If your concern suggests a Serious Incident has occurred, an investigation will be carried out in accordance with the Serious Incident Framework.




https://improvement.nhs.uk/resources/serious-incident-framework/





Trust Ref. A15/2001

5.7.4 All parties will be offered the support of AMICA, the confidential staff counselling service. Please see section 7 Support Services for you.

5.7.5 In some instances, it may be inappropriate to detail the precise action being taken. For example, where this would infringe a duty of confidence owed to someone else such as any disciplinary action taken as a result.

5.7.6 In addition, other relevant advice and support may be given, for example from Trade

Union or staff organisation representatives. (Please see section 5 and 6).

5.7.7 An external investigator(s) may be appointed where appropriate.

5.8 Independent Internal Advice

5.8.1 If you are unsure whether to use this policy or if you want independent advice at any stage, you may contact:

Jo Dawson Freedom to Speak Up Guardian Human Resources Department via 0116 258 5495 Your appropriate union or professional association via the Staff Side Office 0116

258 5803.

5.9 What If Staff are Dissatisfied with Internal Procedures?

5.9.1 Whilst it may not always be possible to guarantee the response you might wish for, you should be assured that every effort will be made to handle your concern appropriately, fairly, and sensitively. If however, you feel unhappy with the response, you can escalate your concern to the Freedom to Speak Up Guardian.

6 HOW TO RAISE A CONCERN EXTERNALLY

6.1 While it is hoped this policy provides you with the reassurance needed to raise your concern internally, the law recognises that there may be circumstances where matters can be reported to outside bodies, such as regulatory bodies (e.g. General Medical Council), or the police.

6..2 Concerns can also be raised outside the organisation with the following external

bodies:-

6.3 NHS Improvement for concerns about: How NHS trusts and foundation trusts are being run.

Other providers with an NHS provider licence.

NHS procurement, choice and competition.

https://www.gov.uk/government/organisations/monitor/about/complaints-procedure

6.4 The Care Quality Commission (CQC) for quality and safety concerns, 03000 616161 Email: [email protected]

6.5 Health Education England for education and training in the NHS.

https://hee.nhs.uk/about-us/how-we-work

6.6 NHS Counter Fraud Authority (NHSCFA) www.nhsbsa.nhs.uk/about-nhs-protect

https://www.gov.uk/government/organisations/monitor/about/complaints-procedure


http://www.nhsbsa.nhs.uk/about-nhs-protect



Trust Ref. A15/2001

6.7 Prior to contacting the media, seek advice from The Trust Communications Team on 0116 258 8963 and use the mechanisms detailed within this policy.

6.8 Public Concern at Work (or a professional association or union) can provide external

advice and support for staff raising whistle blowing concerns. Public Concern at Work can be contacted on 020 7404 6609 or via the web site: http://www.pcaw.org.uk/.

6.9 The National Whistleblowing helpline 08000 724725 or [email protected].

6.10 The National Guardian for Freedom to Speak Up can independently review how staff have been treated having raised concerns where NHS Trusts and foundation trusts may have failed to follow good practice, working with some bodies listed above to take action where needed. The Trust’s Freedom to Speak up Guardian will assist you on how you can access the National Guardian.

6.2 Making a ‘protected disclosure’

6.2.1 There are very specific criteria that need to be met for an individual to be covered by whistleblowing law when they raise a concern (to be able to claim the protection that accompanies it). There is also a defined list of ‘prescribed persons’3, similar to the list of outside bodies in section 6, who you can make a protected disclosure to.

6.2.2 To help you consider whether you might meet these criteria, please seek

independent advice from the Whistleblowing Helpline for the NHS and Social Care, Public Concern at Work or a legal representative. See section 6.8, 6.9

7 SUPPORT SERVICES FOR YOU

7.1 The Trust recognises the support required for you when raising a concern.

7.2 There are a number of supporting mechanisms in place for staff who raise concerns.

These include:-

AMICA Counselling Service 0116 254 4388 Occupational Health 0116 258 5307 Organisational Development. 0116 2586623 Mentoring. Staff Side Representatives (local) and Staff Side Office 0116 258 4080 Freedom to Speak up Guardian 07950 839130 Chaplaincy Service 0116 258 4243

7.3 You may be given the opportunity to engage in reflective practice1 with your

managers, colleagues and teams regarding concerns in their work. This may include, but is not limited to, one to one meetings, appraisals and Continuing Professional Development.

3 List of Prescribed people bodies www.gov.uk/government/publications/blowing-the-whistle-list-of-prescribed-people-and-bodies-- 2/whistleblowing-list-of-prescribed-people-and-bodies

http://www.pcaw.org.uk/

http://www.pcaw.org.uk/


https://www.gov.uk/government/publications/blowing-the-whistle-list-of-prescribed-people-and-bodies--2/whistleblowing-list-of-prescribed-people-and-bodies

http://www.gov.uk/government/publications/blowing-the-whistle-list-of-prescribed-people-and-bodies--2/whistleblowing-list-of-prescribed-people-and-bodies





Trust Ref. A15/2001

8 EDUCATION AND TRAINING

8.1 There is no specific education or training required to implement this policy.

8.2 Resources available on E-learning for Healthcare Raising and Responding to concerns (http://www.e-lfh.org.uk/programmes/freedom-to-speak-up/additional- resources/)

8.3 This policy will be discussed as part of the corporate induction programme, with dedicated slides and hand-outs to raise awareness of this policy to new staff to the Trust.

9 PROCESS FOR MONITORING COMPLIANCE

Element to

be monitored

Lead Tool Frequency Reporting Arrangements

Key indicators relating to

the number of concerns

raised

Director of Safety and Risk/ Freedom to Speak

Up Guardian

Annual Staff Attitude and

Opinion Survey results

Annually Trust Board

Issues raised

under the policy

Freedom to Speak

up Guardian

3636 staff reporting

line/ CQC/ Bullying and harassment line/ Junior

Doctor Gripe Tool/

Fraud

Quarterly reports to the

Quality Assurance Committee

(subcommitte e of Trust

Board)

Quarterly figures sent

to the National Guardian

Office

EQB ( as part of Quality

schedule – Involving

employees in improving

standards of care)

10 EQUALITY STATEMENT

10.1 The Trust recognises the diversity of the local community it serves. Our aim therefore is to provide a safe environment, free from discrimination and treat all individuals fairly, with dignity and appropriately, according to their needs.

10.2 As part of its development, this policy and its impact on equality have been reviewed and no detriment was identified.

http://www.e-lfh.org.uk/programmes/freedom-to-speak-up/additional-resources/








Trust Ref. A15/2001

11 SUPPORTING REFERENCES, EVIDENCE BASE AND RELATED POLICIES

11.1 This procedure compliments other Trust policies and procedures as listed below. There are no hard and fast rules about which policy or procedure to use in which circumstances.

11.2 The general principles are as follows:

If the issue causing concern relates to a management decision or conditions of service which affect the member of staff personally, or a group of staff, it is probably more appropriate to raise it as a grievance under the Staff Grievance and Disputes Policy and Procedures (Trust Ref. A7/2004).

If the issue relates to bullying, victimisation or harassment of staff then the Anti- Bullying and Harassment Policy and Procedure should be used (Trust Ref. B5/2016).

If the issue relates to an isolated clinical incident, refer to Incident and Accident

Reporting Policy (including the investigation of serious, RIDDOR and security incident (Trust Ref. A10/2002).

National Freedom to Speak Up: Raising Concerns (Whistleblowing) Policy. NHS

England and NHS Improvement April 2016 https://improvement.nhs.uk/uploads/documents/whistleblowing_policy_final.pdf

The Public Interest Disclosure Act (1998) www.legislation.gov.uk/ukpga/1998/23

Freedom to Speak Up Review (2015) http://freedomtospeakup.org.uk/wp- content/uploads/2014/07/F2SU_web.pdf

11.3 In addition to complementing the procedures referred to above, this policy should be read in conjunction with the Trust’s Fraud Policy (Trust Ref. A1/2010). Where the concern raised is believed to fall within the scope, the procedures outlined in the policy will be followed and will take precedence over that which is contained within this document.

12 PROCESS FOR VERSION, DOCUMENT ARCHIVING AND REVIEW

12.1 The updated version of the policy will then be uploaded and available through INsite Documents and the Trust’s externally-accessible Freedom of Information publication scheme. It will be archived through the Trust’s SharePoint system.

12.2 This policy will be reviewed every three years and it is the responsibility of the

Freedom to Speak Up Guardian to commence this process in a timely manner.

http://www.legislation.gov.uk/ukpga/1998/23

http://freedomtospeakup.org.uk/wp-



Trust Ref. A15/2001

Section 13 - Appendix 1



Trust Ref. A15/2001
