Whistleblowing
DAIS-POL-025
Whistleblowing Policy
Encouraging staff and stakeholders to raise serious concerns in good faith
Data and AI School of London | Account No. 11001657 | Version 1.0 | June 2026
| Policy Owner | Head of Centre (Ali Fraz Khan FHEA) |
| Approved By | Head of Centre |
| Date Effective | 24 June 2026 |
| Review Cycle | Annual |
| Next Review | 24 June 2027 |
| Related Documents | DAIS-POL-003 Complaints Policy, DAIS-POL-010 Malpractice Policy, DAIS-POL-004 Conflicts of Interest Policy |
| Legal Reference | Public Interest Disclosure Act 1998, Employment Rights Act 1996 |
1. Purpose
This policy provides a clear, confidential, and protected route for staff, contractors, learners, and other stakeholders to raise serious concerns about wrongdoing, malpractice, or risk to learners or to the integrity of the centre. The Data and AI School of London (DAIS) is committed to maintaining the highest standards of openness, integrity, and accountability. Where individuals identify activity that they reasonably believe is unlawful, unethical, or contrary to the centre's policies, they should feel able to raise the matter without fear of detriment.
2. Scope
This policy applies to all staff (employed, contracted, and voluntary), learners, parents or guardians where applicable, external IQAs, assessors, and any third parties engaged by DAIS. It complements the Complaints Policy (DAIS-POL-003) and Malpractice Policy (DAIS-POL-010) but is specifically intended for concerns of a more serious nature that go beyond a routine complaint, including matters of public interest.
3. What is Whistleblowing
Whistleblowing, in the context of this policy, refers to the disclosure of information that the individual reasonably believes shows one or more of the following:
• A criminal offence has been committed, is being committed, or is likely to be committed.
• A person has failed, is failing, or is likely to fail to comply with any legal obligation.
• A miscarriage of justice has occurred, is occurring, or is likely to occur.
• The health or safety of any individual has been, is being, or is likely to be endangered.
• The environment has been, is being, or is likely to be damaged.
• Information tending to show any of the above has been, is being, or is likely to be deliberately concealed.
• Serious malpractice, maladministration, or fraud relating to assessment, certification, or NCFE compliance has taken place.
4. Distinction from Complaints
A complaint is typically a personal grievance about how an individual has been treated and is handled under DAIS-POL-003. Whistleblowing concerns are typically about wrongdoing that affects other people, the integrity of the centre, learners as a group, or the public interest. If you are unsure which route applies, raise the matter under this Whistleblowing Policy and the Head of Centre will determine the appropriate handling route.
5. Protection for Whistleblowers
Any individual raising a genuine concern in good faith under this policy is protected from detriment, retaliation, dismissal, or any other adverse treatment as a consequence of making the disclosure. This protection is provided by the Public Interest Disclosure Act 1998 and is reinforced by this policy.
Specifically, DAIS guarantees that:
• The identity of the whistleblower will be kept confidential to the extent compatible with a proper investigation.
• No disciplinary action will be taken against a whistleblower acting in good faith, even if the concern is subsequently found to be unsubstantiated.
• Whistleblowers will not face dismissal, demotion, withdrawal of work, exclusion from opportunities, or any other detriment as a result of raising a concern.
• Any attempt by another individual to deter, intimidate, or victimise a whistleblower will itself be treated as a disciplinary matter.
Anonymous disclosures will be considered but may be harder to investigate. Whistleblowers are encouraged to identify themselves so that the matter can be addressed thoroughly.
6. Bad Faith and Malicious Disclosures
Disclosures made maliciously, knowingly without basis, or for personal gain are not protected under this policy. Where it is established that a disclosure was made in bad faith, the matter may be addressed as a disciplinary issue.
7. How to Raise a Concern
7.1 Internal Routes
Concerns should normally be raised internally in the first instance, as follows:
• First contact: The Head of Centre, Ali Fraz Khan FHEA, by email to [email protected] or by telephone on +44 207 0990 956. Mark the communication "Whistleblowing - Confidential".
• Where the concern relates to the Head of Centre: Concerns may be raised directly with NCFE's Investigations Team or with the appropriate external regulator (see Section 7.2 below).
Concerns should be set out clearly in writing where possible, including the nature of the concern, dates and any individuals involved, the basis for the belief that wrongdoing has occurred, and any supporting evidence available.
7.2 External Routes
Where internal routes are inappropriate (for example, where the concern relates to the Head of Centre, or where an internal investigation has failed to address the matter), concerns may be raised externally with:
• NCFE Investigations Team: [email protected], or by writing to NCFE, Q6, Quorum Business Park, Benton Lane, Newcastle upon Tyne, NE12 8BT.
• Ofqual (the qualifications regulator): [email protected]
• Information Commissioner's Office (for data protection concerns): [email protected]
• Police, where the concern involves criminal activity.
• Protect (the whistleblowing charity): [email protected] - provides free confidential advice.
8. Investigation Process
On receipt of a whistleblowing disclosure, the Head of Centre (or NCFE, where the concern relates to the Head of Centre) will:
• Acknowledge receipt of the concern in writing within 5 working days.
• Carry out an initial assessment to determine the appropriate investigation route.
• Appoint an investigator independent of the matter being raised.
• Conduct an investigation proportionate to the seriousness of the concern, typically within 30 working days.
• Maintain confidentiality throughout the process.
• Provide the whistleblower with feedback on the outcome of the investigation, subject to legal and confidentiality constraints.
• Take appropriate action as a result of the investigation, which may include disciplinary action, reporting to external bodies, changes to policy or practice, or referral to NCFE or other regulators.
9. Confidentiality
All disclosures under this policy will be treated in confidence to the maximum extent possible. Disclosure of the whistleblower's identity will only occur where strictly necessary for the conduct of a proper investigation or where required by law. The whistleblower will be informed in advance if their identity must be disclosed.
10. Record Keeping
A confidential whistleblowing register is maintained by the Head of Centre, recording the date the concern was raised, the nature of the concern, the investigation route, the outcome, and any actions taken. Records are retained securely for a minimum of 6 years in line with the Data Protection Policy (DAIS-POL-006) and are accessible only to the Head of Centre and any external investigator appointed under this policy.
11. Monitoring and Review
This policy is reviewed annually by the Head of Centre, or sooner where legislative changes or operational learning require an update. Patterns or themes arising from whistleblowing disclosures are reviewed at the annual Self-Assessment Review (DAIS-SD-010) and contribute to the Quality Improvement Plan (DAIS-SD-011).
12. Communication
This policy is made available to all staff at induction (DAIS-SD-002), to learners through the Learner Handbook (DAIS-LH-001), and is published in the policy section of the DAIS website and Moodle VLE. All staff are required to confirm they have read and understood this policy as part of their induction.