Whistleblowing Policy - privacy notice

Croydon Council is committed to promoting the highest standards of openness, probity and accountability for all of its employees, contractors and members and takes very seriously any form of malpractice that is identified or discovered.

‘Whistleblowing’ is when someone raises a concern about a possible fraud, crime, danger or other serious risk that could threaten colleagues, members of the public, members of the Council or the Council’s reputation. This means that it is in the public interest that such concerns are disclosed.

What information we hold about you

When you make a disclosure (that is, you share your concerns about possible wrongdoing), you are asked to provide the following information:

  • Name
  • Job Title
  • Contact details
  • Details of the concern you have reported.

You may make a disclosure anonymously but this will make it more difficult for us to investigate thoroughly and give you feedback on the outcome.

Information we hold about other individuals

  • Details of people who have been referred to in a disclosure that may have been made

and/or

  • Details of people who have been investigated following a disclosure under the Whistleblowing Policy.

How is this information will be used

The information will be used by the Council’s Monitoring Officer (who is responsible for the investigations undertaken in accordance with the Whistleblowing Policy) to investigate allegations of wrongdoing in accordance with the Employment Rights Act 1996, as amended by the Public Interest Disclosure Act (PIDA) 1998, and the Council’s powers to undertake investigation in respect of alleged wrongdoing, in relation to the services the Council is responsible for and to protect the ‘public purse’.

Who we share your information with within and outside the Council

Information about the disclosure will be shared with those tasked by the Monitoring Officer to undertake the investigation. Ordinarily, this will not include details of the individual who has made the disclosure, but may include the identities of those against whom an allegation of wrongdoing has been made.

People tasked with investigating the disclosure may include:

  • Legal Services
  • Human Resources
  • Corporate Finance
  • Housing Service Teams
  • Welfare Service Teams
  • Other public authorities
  • Police
  • Her Majesty’s Revenue and Customs.

The information will be shared in respect of the disclosure, and will be shared on a confidential basis by those tasked with investigating the disclosure, both within and where appropriate outside of the Council.

We also have a legal duty to pass information to third-party organisations such as the Police and/or the Department of Work and Pensions and anti-fraud agencies for the purposes of preventing and detecting crime, or for anti-fraud purposes, or for the protection of public funds.

The Monitoring Officer is responsible for the conduct of the investigation and will record what information is shared and the reasons for doing so.

How we keep your information safe and secure

We are committed to ensuring that your information is securely held.

We manage, maintain and protect all information according to legislation, our policies and best practice. All information is stored, processed and communicated in a secure manner. We provide training to staff who handle personal information and how to report and escalate when something goes wrong.

When we no longer need to keep information about you, we will review it and archive it for any relevant legal retention period and ultimately dispose of it in a secure manner, normally after 7 years of an allegation being resolved.

Confidentiality

We hope you will feel comfortable raising your concern openly, but we also appreciate you may want to raise it confidentially. This means that while you are willing for your identity to be known to the Monitoring Officer, you do not want anyone else to know that you have submitted this concern.

We will keep your identity confidential if that is what you want, unless we are required to disclose it by law (for example, if the police require it). This might be, for example, where your information is about a child or vulnerable adult who is at risk, or where there is a possible criminal offence. We will let you know if we have to tell the police or another official body.

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.

Contacting the Monitoring Officer

Please write to:

Monitoring Officer, Bernard Weatherill House, 8 Mint Walk, Croydon, CR0 1EA

Or email MonitoringOfficer@croydon.gov.uk

Requesting access to your personal data

Under the General Data Protection Regulation (GDPR) and the Data Protection Act 2018, you have the right to request access to information that we hold about you. To make a request for your personal information, contact the Council’s Information Management Team at SAR@croydon.gov.uk.

Further information

The GDPR and Data Protection Act 2018 give you a number of rights to control what personal information is used by us and how it is used by us. Information about your individual data rights is listed in the Council’s corporate privacy notice.

For advice about data protection issues, you can contact the Information Commissioner’s Office (ICO).

We reserve the right to amend this privacy notice at any time and will keep it under review.

Last updated: March 2022