Whistleblowing and raising a concern policy

Published: 31 May 2024
Freedom of information class: How we take decisions

Registers of Scotland is committed to ensuring high standards of conduct in all that it does, these standards are reinforced by the Civil Service Code.

1. Purpose and scope

1.1 This policy sets out RoS commitment to ensuring high standards of conduct in all that it does, these standards are reinforced by the Civil Service Code.

However, wrongdoing can occur and it is important that employees know what to do if, in the course of their work, they come across something that they think is fundamentally wrong, illegal or endangers others within the department or the public.

The Public Interest Disclosure Act PIDA 1998 was designed to protect employees who make certain disclosures of information in the public interest and to allow those employees who “blow the whistle” on any of the instances of wrongdoing that are set out in the Act, to complain to an employment tribunal if they suffer any form of detriment for doing so. Alongside the Act, employees who are civil servants have the protection set out in the Civil Service Code.

1.2 This policy applies to all employees, contractors and temporary staff of RoS and therefore includes all categories of contingent worker.

2. Guiding principles

2.1 The Policy, Procedures and Frequently Asked Questions will guide employees through the process of raising a concern, which is sometimes referred to as ‘blowing the whistle’.

The following principles underpin the Whistleblowing and Raising a Concern Policy:

  • employees are encouraged to raise any concerns they may have about wrongdoing as soon as they notice it
  • employees raising a concern will be afforded protection as detailed in the procedure
  • all genuine concerns will be handled responsibly, professionally and in a positive manner
  • help and support will be available to employees where concerns are raised under the relevant Whistleblowing and raising a concern procedure.

3. The policy

3.1 Registers of Scotland (RoS) is committed to ensuring high standards of conduct in all that it does, these standards are reinforced by the Civil Service Code.

3.2 Policy Summary

3.2.1 Key areas covered by this policy and its procedures include:

  • what is a relevant concern
  • how to raise such a concern
  • how it will be handled
  • confidentiality and anonymity
  • provision of protection and support to employees.

3.3 Raising a Concern and Support

3.3.1 If an employee experiences something in the workplace which they consider to be in conflict with the Code they should in the first instance raise their concerns with their Line Manager and follow the Whistleblowing Procedure. In certain circumstances it may be appropriate to raise the concern directly with the Nominated Officer. The Nominated Officer at RoS is David Blair and details of how he may be contacted are set out below:

  • Telephone: 0131 378 4950
  • Email: david.blair@ros.gov.uk
  • Post: Registers of Scotland, Meadowbank House, 153 London Road, Edinburgh, EH8 7AU

Contingent Workers such as self-employed, agency workers and contractors should follow a modified procedure.

Such workers should, in the first instance, raise their concern immediately with their employing agency, if applicable and the manager to whom they report at RoS. Both parties should be contacted concurrently.

If this route is not appropriate for whatever reason, the worker should contact the Nominated Officer at RoS.

Contingent Workers are not covered by the same Civil Service Commission protections as Civil Servants.

Employees may also contact the whistleblowing charity Protect. You may view further information on their work and how they can support you at https://protect-advice.org.uk/.

Alternatively, employees may raise a concern with Audit Scotland or the Auditor General for Scotland.

4. Roles and responsibilities

4.1 The Executive Management Team is responsible for the content of this policy, its approval and review.

They are responsible for ensuring its implementation in practice and for monitoring this over time.

They are responsible for ensuring that appropriate procedures, guidelines or standards as are required to support this are maintained and ownership for these assigned appropriately.

5. Approval and review

5.1 This policy will be reviewed and approved annually by the RoS Executive Management Team, unless earlier review is appropriate, and in consultation with the Audit and Risk Committee.

AuthorHead of HR
ReviewedHead of People and Change
Cleared Corporate Director
Approval Executive Management Team Approval date May 2024
Policy version V 3.0
Review responsibility Executive Management Team Review date May 2025
Publication scheme Yes
Email to contactHR@ros.gov.uk