Whistleblowing Policy and Procedure
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Signed: March 2026
To be reviewed: March 2028
Introduction
It is BDEF’s aim to:
- To encourage staff and volunteers to feel confident in reporting serious concerns about any aspects of the setting’s work
- To provide ways for staff and volunteers to report concerns
- To ensure that staff and volunteers get a response to their concerns and that they know what to do if they are not satisfied with this
- To reassure staff and volunteers that they will not be penalised for coming forward with their concerns
Definitions
Whistleblowing
Whistle blowing is reporting a serious concern, which someone reasonably believes shows wrongdoing or a cover-up by that organisation.
The concern may relate to something that has happened, is happening or that a person may fear will happen in the future. This may be passed on to a senior member of staff or management for action if they are not complicit but may go directly to an appropriate external organisation.
Serious concerns
A serious concern might be:
- a criminal offence
- abuse or neglect of children or vulnerable adults
- bullying or victimisation of staff, volunteers or adults or children
- financial malpractice
- a health and safety risk
- a failure to deliver appropriate standards of care
There may be other serious concerns, which do not fit into these categories.
How to report a concern
Internal
Any staff member, trustee or volunteer can report a concern.
Concerns can be reported verbally or in writing.
In most circumstances this would be to the Director.
If the concern involves the Director or it is felt they are unlikely to take any action, the member of staff should contact BDEF Trustee’s Board through BDEF’s Co-Chairs ([email protected]).
External
If the concern involves the management of the organisation and there is no one internally to report to safely, then a report should be made to an appropriate external organisation.
Staff who feel unsure about whether or how to raise a concern or want confidential advice can contact the independent charity Protect, Speak up, Stop Harm. Their lawyers can give free confidential advice on how to raise a concern about serious malpractice at work.
Staff can also contact the organisations listed at the end of this document.
What will happen next?
All reported concerns will be investigated.
Verbal concerns will be recorded in writing.
The person to whom the concern has been reported to will assess what action needs to be taken. This could be an internal enquiry or more formal enquiry, for example involving the Police. More senior management will be informed.
In some cases, the concern may be better addressed under another policy or procedure, such as Discipline and Grievance or Health and Safety.
The person reporting the concern will be advised of the outcome as soon as possible, normally within 2 weeks of the date of their disclosure. Where a longer period is needed for investigation, the person will be informed in writing.
Where a person is not satisfied with the outcome, they should put their concerns in writing to the person in charge of the organisation.
If the staff member has needed to report their concerns externally in the first instance, then they should be guided by the external organisation in term of what will happen next.
Confidentiality
Staff are encouraged not to report concerns anonymously as this makes them more difficult to investigate. Any concerns raised will be dealt with confidentially wherever this is possible.
If other organisations need to be involved, it may not be possible to conceal the source of the information.
Safeguards
BDEF CIO will not tolerate any harassment or victimisation and will take appropriate action to protect those who report a concern in good faith.
No action will be taken against anyone who makes an allegation in good faith, reasonably believing it to be true, even if the allegation is not subsequently confirmed by the investigation.
Updates from April 2026
From 6 April 2026 sexual harassment will be added to the list of relevant failures that can form the subject-matter of a “whistleblowing disclosure” i.e. a protected disclosure.
The change means that workers will not need to identify an existing legal obligation, criminal offence or breach of health and safety to make a qualifying disclosure about sexual harassment, provided that they have complied with the other requirements in the legislation, such as holding a reasonable belief that the issue is in the public interest.
Separately, the Employment Rights Act 2025 includes a new measure which will make void any provision in an agreement between an employer and a worker which tries to prevent the worker making an allegation or disclosure about harassment or discrimination. It also includes disclosures about how the employer responds to such an allegation or disclosure.
The Act provides that an “excepted agreement” would be outside the scope of the new provisions. A recently published impact assessment looking at the new provisions now indicates that a confidentiality clause or non-disclosure agreement requested by a worker may be outside the scope of the new provisions.
Versions
There is an Easy Read version of this document in development. When it is finalised and signed off, it will be linked to here.
Review
This statement shall be reviewed every 2 years upon its adoption. An earlier review may take place if:
- We approve a proposal that changes the policy
- There’s a change to the organisation that will change the policy
- There’s a change in the law that affects the policy
Appendix A – Legal framework and contact details
The Public Interest Disclosure Act 1998 protects employees against detrimental treatment or dismissal as a result of any disclosure of normally confidential information in the interests of the public.
Protect, Speak up, Stop harm (formerly PCAW) on 020 3117 2520 for confidential advice relating to serious malpractice at work. Or by webform
Ofsted regulates childcare providers in England in line with the Early Years Foundation Stage (EYFS). Ofsted’s role is to make sure that the childcare provider is following all registration requirements and to take action if necessary
NSPCC Whistleblowing Hotline. Provides free help and advice to people who suspect their organisation might be putting children at risk, even if they're not certain that this is the case.