Policy on Public Interest Disclosure

2. Scope of Policy

2.1 Although the PIDA limits protection to employees, agency workers and self-employed workers, this policy additionally covers members of the Board of Governors, students and providers of services through a profession or business.

2.2 This policy is designed to allow employees and such other persons as are covered by PIDA or the policy (see previous paragraph) to raise concerns or disclose information at a high level, which the discloser believes in good faith to show evidence of serious malpractice. These are referred to as Qualifying Disclosures.

2.3 A number of University policies are already in place to address grievances, complaints, harassment, and discipline. The defining aspect of this policy is that it covers concerns which are in the public interest and which therefore may need to be addressed separately, even if other University policies and procedures are subsequently invoked. The concerns within the workplace which may prompt a Qualifying Disclosure may relate to one or more of the following:

• Financial malpractice, impropriety or fraud
• Failure to comply with a legal obligation or with the Instrument and Articles of Government of the University
• Serious compromising of health and safety or damage to the environment
• Criminal activity
• Academic or professional malpractice
• A serious miscarriage of justice
• Improper conduct or unethical behaviour
• Serious conflicts of interest without disclosure
• Attempts to conceal any of the above

2.4 Examples (not exhaustive) within the University or higher education context could include:

a) financial or non-financial maladministration and malpractice, bribery or fraud e.g. improper record keeping or processing information (contracts, overtime or expenses claims) for personal gain or to assist others in gaining from such acts;

b) misuse of University property or facilities for personal gain or to assist others in gaining from such acts;

c) evidence of academic or professional malpractice e.g. falsifying or misrepresenting academic qualifications;
d) failure of an individual(s) to disclose a serious conflict of interest in order to influence the decision-making processes;
e) action or inaction that could lead to damaging the reputation of the University, (such as a failure to notify management of any health and safety issues which may cause injury to an individual on University premises or any breaches of relevant requirements relating to research which is governed by legislation/statutory requirements). In this latter example, if a disclosure is made in relation to potential research misconduct the University Secretary may determine that it would be more appropriate for the issue to be referred to a designated person under the Policy and Procedures for dealing with Allegations of Research Misconduct. In such circumstances the University Secretary will inform the individual who raised the concern, to whom it has been forwarded, for consideration under this other policy.

2.5 Although individuals are not expected to prove the truth of any allegation, s/he will need to demonstrate that there is a sufficient reason for making initial enquiries.