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Whistleblowing Policy

1. Purpose

This policy sets out how concerns about wrongdoing, risk, or malpractice can be raised within the clinic. Although the clinic has no employees and is run solely by three partners, this policy ensures a transparent, accountable, and safe environment for the partners, contractors and patients.

Its purpose is to:

  • Encourage partners to raise concerns early
  • Provide clear channels for reporting
  • Protect individuals from unfair treatment when concerns are raised in good faith
  • Ensure that all concerns are taken seriously and investigated appropriately

2. Scope

This policy applies to:

  • The three clinic partners
  • Any contractors, locum clinicians, or external service providers
  • Volunteers or trainees
  • Any individual who works with or on behalf of the clinic

It covers concerns relating to:

  • Patient safety
  • Clinical malpractice or unsafe practice
  • Breaches of professional standards
  • Misuse of clinical data or confidentiality breaches
  • Fraud, financial irregularities, or misrepresentation
  • Breach of regulatory or legal obligations (CQC, GMC/NMC standards, MHRA safety requirements)
  • Improper conduct or unethical behaviour
  • Concealment of any of the above

3. Principles

The clinic is committed to:

  • A culture of openness, honesty, and integrity
  • Zero tolerance for retaliation against whistleblowers
  • Fair and proportionate investigation of all concerns
  • Compliance with professional and legal standards

Whistleblowing concerns should relate to issues in the public interest, not personal grievances.

4. Raising a Concern

A concern may be raised verbally or in writing. Partners and associated personnel should raise issues as soon as possible.

4.1 Internal Reporting Routes

Because the organisation consists only of three partners, concerns should be raised in the following order:

  1. Raise the issue with one of the other partners
  2. If the concern relates to one partner personally, the other two partners should be notified.
  3. If the concern involves all partners or cannot be raised internally, external reporting is available (see Section 6).

Concerns should include:

  • A clear description of the issue
  • Relevant dates, people, or evidence
  • Any immediate risks identified

5. How Concerns Will Be Handled

  1. The partner receiving the concern will acknowledge receipt within 5 working days.
  2. A preliminary assessment will determine whether the concern requires:
    • Immediate action (e.g., patient safety risk)
    • A formal internal investigation
    • External reporting to a regulator
  3. The partners will appoint an appropriate investigator. This may be:
    • One of the partners not involved in the concern
    • An external clinical governance consultant or legal advisor
  4. The investigation process may include interviews, evidence review, and audit of practice or documentation.
  5. The whistleblower will be provided with feedback, subject to confidentiality and legal constraints.

6. External Reporting

If the whistleblower believes the concern cannot be safely or appropriately raised internally, or if internal action is insufficient, concerns may be raised with:

  • GMC, NMC, or HCPC (depending on clinician involved)
  • Healthcare Improvement Scotland
  • Information Commissioner’s Office (ICO) for data breaches
  • MHRA for medication-related safety issues
  • Police for criminal matters
  • Professional indemnity provider or medical defence organisation

Partners should encourage external reporting where required for safety or legal compliance.

7. Protection and Non-Retaliation

No partner, contractor, or whistleblower will face detrimental treatment for raising a genuine concern in good faith, even if the concern is ultimately unfounded.

Detriment includes:

  • Bullying or intimidation
  • Exclusion from clinical or business activity
  • Loss of partnership rights
  • Victimisation or reputational damage

Any form of retaliation will itself be treated as misconduct.

This policy does not protect malicious or knowingly false allegations.

8. Confidentiality

Concerns can be raised confidentially. The identity of the whistleblower will be protected as far as possible. However, in cases where legal or regulatory requirements mandate disclosure, the whistleblower will be informed before any action is taken.

Anonymous concerns will be considered, although they may limit the ability to investigate fully.

9. Record Keeping

All concerns, investigations, and outcomes will be documented and retained securely. Records will include:

  • Date concern was raised
  • Summary of issue
  • Actions taken
  • Outcomes and recommendations

All documentation will comply with GDPR requirements.

10. Learning and Continuous Improvement

Findings from investigations will be used to improve clinic safety and governance. The partners will:

  • Review lessons learned
  • Implement changes to policy or practice
  • Update clinical protocols or training as needed

11. Policy Review

This policy will be reviewed annually, or sooner if:

  • Clinical practice changes
  • Regulatory guidance is updated
  • An incident or investigation identifies the need for revisions