Raising Concerns (Whistleblowing)

Appendix 4


Raising concerns (Whistleblowing)


Portsmouth Primary Care Alliance Ltd (PPCA) recognises the hard work undertaken by staff, whether employed, self-employed or sub-contracted, and try to ensure the highest possible standards of service for the benefit of patients, employees, its membership and visitors. When standards are not as would be expected we need to learn and make improvements to address these issues swiftly.

One of the most difficult situations is raising concerns about a colleague’s behaviour, health, or professional performance that may be placing patients at risk. You have a duty to raise concerns when patients may be at risk of harm. Provided you are acting honestly it does not matter if you are mistaken or if there is an innocent explanation for your concern we encourage all staff to discuss concerns with a member of the Management Team or the Directors.

Any concerns that you have regarding patient safety should be raised firstly with the Development Project Manager. Raising concerns “Whistleblowing” relates to concerns for the interests of others or of the practice are at risk. Any concerns relating to you personally and your position need to be raised following the grievance policy. PPCA will, where possible, protect from victimisation and dismissal  in accordance with UK legislation on disclosure of malpractice in the workplace and to take steps to protect to its workers from detrimental treatment or dismissal if they raise concerns in good faith.


PPCA hopes that staff feel confident enough to raise concerns openly so that they can be dealt with fairly and professionally however it is recognised that this may not always be possible. If you wish to raise a concern anonymously it will be difficult to investigate the concern and protect your position.

Once a concern is raised PPCA will investigate the concern and assess what action, if any, needs to be taken. You will be told who is dealing with the investigation, the outcome and whether your assistance in the investigation is required. You can request a full summary of the investigation and its outcome.

If an individual raises a genuine concern and is acting in good faith, even if it is later discovered that they are mistaken, under this policy they will not be at risk of losing their job or suffering any form of retribution as a result. This assurance will not be extended to an individual who maliciously raises a matter they know to be untrue or who is involved in any way in the malpractice.


If you are unable to raise the matter internally or it has not been dealt with properly you can raise your concern with the Wessex Area Team, Oakley Road Southampton, Hampshire SO16 4GX. Telephone number 023 8051 3985


You can seek independent advice or guidance on whether or how to raise a concern at any stage.

The Directors / Management have a specific responsibility to ensure that staff feel able to raise concerns, without fear of reprisals, in accordance with the procedure. All staff are responsible for the success of this policy and should ensure that they take steps to disclose any concerns or suspicion of wrong doing or malpractice at the earliest opportunity.


The term ‘malpractice’ includes but is not exhaustive of:

  • Criminal offences;
  • Breaches of legal obligations (including negligence, breach of contract, breach of administrative law);
  • Miscarriages of justice;
  • Health and safety;
  • Damage to the environment;
  • The concealment of any of the above.


How a disclosure will be handled


All disclosures will be taken seriously and the following procedure will be used. If you have any personal interest in the matter you have raised you must disclose this at the outset. This procedure is not intended to replace the Grievance Procedure, which continues to be the appropriate way to raise personal issues relating to your specific job or employment.


  1. Your disclosure under this policy will be acknowledged in writing confirming that the matter will be investigated.
  2. A suitable person will be identified to manage the disclosure. This will be someone who is in a position to take any necessary action as an outcome.



  1. A suitable individual will be instructed to conduct an investigation into the allegation (they will have had no previous involvement in the matter). We aim to start the investigation within two weeks of the disclosure. The length and scope of the investigation will depend on the subject matter of the disclosure. In most instances, there will be an initial assessment of the disclosure to determine whether there are grounds for a more detailed investigation to take place or whether the disclosure is, for example, based on erroneous information.
  2. You may be asked to provide more information during the course of the             investigation.


  1. The investigation report will be reviewed by the person managing the disclosure.


  1. Appropriate action will be taken – this could involve initiating a disciplinary process, or informing external authorities if a criminal action has been committed. We will endeavour to inform you if a referral to an external authority is about to or has taken    place, although we may need to make such a referral without your knowledge or consent if we consider it appropriate.


  1. If it is found that there is not sufficient evidence of malpractice, or the actions of the       individual(s) are not serious enough to warrant disciplinary action, it may be more      appropriate for the manager to take a more informal approach to dealing with the matter.


  1. You will receive written notification of the outcome of the investigation, though not all the details or a copy of the report.


  1. Possible outcomes of the investigation could be that:


  • the allegation could not be substantiated; or
  • action has been taken to ensure that the problem does not arise again. You will not, however, be given details about the action taken as this could breach the human rights of the person(s) involved.


  1. If you are not satisfied with the response you have received you should raise the matter with the local area office.
  2. If you have asked to remain anonymous, care will be taken to respect this request (see section on confidentiality above).Corrective Action and ComplianceAs part of the investigation into disclosures made under this policy, recommendations for change will be invited from the investigator to enable the practice to minimise the risk of the recurrence of any malpractice or impropriety which has been uncovered. The Directors will be responsible for reviewing and implementing these recommendations in the future and for reporting on any changes required.False DisclosuresPPCA will treat all disclosures of malpractice seriously and protect staff who raise concerns in good faith. However, appropriate disciplinary action will be taken in accordance with the Disciplinary Procedure against any employee or volunteer who is found to have made a disclosure maliciously that they know to be untrue, or without reasonable grounds for believing that the information supplied was accurate. This may result in dismissal.  Other useful organisationsThe General Medical Council (GMC) www.gmc-uk.org As the recognised trade union for UK doctors the BMA is a worthwhile source of information. The BMA has a dedicated webpage regarding whistle blowing providing information, case studies and guidance for members.The Care Quality Commission (CQC)
  3. http://www.gmc-uk.org/guidance/ethical_guidance/raising_concerns.asp
  4. The CQC’s job is to make sure that care provided by hospitals, dentists, ambulances, care homes and services in people’s own homes and elsewhere meets government standards of quality and safety. The CQC has published guidance for workers, for providers of services and a quick guide on how to raise a concern.
  5. British Medical Association (BMA) www.bma.org.uk
  6. The GMC registers doctors to practise medicine in the UK. Its purpose is to protect, promote and maintain the health and safety of the public by ensuring proper standards in the practice of medicine.