FOI Request - Whistleblowing Policy

Request 101003895194

I am seeking information about your council’s whistleblowing policy eligibility and any updates following the Supreme Court judgment in Gilham v Ministry of Justice [2019] UKSC 44.

Purpose:

Confirm whether councils have widened whistleblowing eligibility since 2019 to protect non employees (e.g., office holders, ALEO board members), consistent with human rights compliant interpretation highlighted in Gilham Judgement.
Findings will inform comparative governance analysis and recommendations to strengthen protections in ALEO contexts.
Electronic copies and links are sufficient; summaries acceptable for committee/legal rationale.

For this purpose please could you provide:

1.  Current whistleblowing policy:

The latest version (PDF or URL) and the date of last approval/update.

2.  Eligibility definition:

Whether the policy explicitly includes office holders, non executive directors, board members of ALEOs, volunteers, contractors, agency workers, and secondees, in addition to employees and former employees.

If not included, please confirm the groups covered and any exclusions.

3.  Post 2019 changes:

Any policy revisions since October 2019 that widened eligibility or adjusted reporting routes in light of ECHR compatibility or the Gilham judgment.

Copies of relevant committee papers, legal advice summaries, or decision records supporting these changes (redactions acceptable where necessary).

4.  Alternative reporting routes for conflicts:

Whether the policy provides independent or conflict free routes (e.g., Monitoring Officer, Internal Audit, external hotline) where concerns involve councillors or ALEO boards.

If yes, please supply the text or guidance describing these routes.

5.  Training and communication:

Details of any training provided since 2019 to councillors, ALEO board members, or senior officers on whistleblowing eligibility and conflicts.

The date(s) and materials (agenda/slide deck summaries acceptable).

Response 09-01-2026

1. Please see the current policy attached here. Please note that this policy is currently under review.

2. 1.4 It applies to all employees and those employees of contractors working for the Council on Council premises, for example, agency staff, builders, and drivers. It also covers suppliers and those providing services under a contract with the Council in their own premises, for example, care services, early years pre-school providers and other similar activities.

3. Policy currently under review.

4. This is included in the draft updated policy, however, given that this has not as yet been the subject of wider consultation with relevant parties across the organisation, the specific wording cannot be provided at this time.

5. Training and comms incorporated into induction and management training.