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Raising Concerns, Freedom to Speak Up and Whistleblowing Policy and Procedure

We are committed to creating an open and honest workplace where employees feel safe and supported when raising concerns about wrongdoing, misconduct, or poor practice. We recognise that speaking up is essential for maintaining high standards of care, ensuring compliance with legal and regulatory requirements, and safeguarding the well-being of service users and staff.

1. Governance

1.1. This is the Raising Concerns, Freedom to Speak Up and Whistleblowing Policy and Procedure for The Good Place Home Care Services Limited.

1.2. The Good Place Home Care Services Limited will be referred to in this document as "The Good Place Home Care Services Limited","The Good Place","We","Us", or "Our".

1.3. Our registered address is: 186 Wetmore Road, Burton-on-Trent, Staffordshire, DE14 1QZ.

1.4. We can be contacted by:-

1.5. Words importing one gender include all genders, and words in the singular include the plural and vice versa, unless the context requires otherwise.

1.6. Document control sheet:-

MetadataValue
Document fingerprintGOV-2106-V1
Document ownerDean Hill (Nominated Individual)
Document version1
Document statusApproved on 18/03/2026 by the Dean Hill (Nominated Individual)
Document review cycleAnnually or sooner if legislation or guidance changes. Next review planned for March 2027

2. Purpose

2.1. To ensure that everyone working for or on behalf of The Good Place understands their right to raise concerns in the public interest and how to do so.

2.2. To ensure that we fulfil the legal and regulatory responsibilities.

2.3. To support us to meet, and be able to evidence compliance with, the following CQC Single Assessment Framework quality statements:-

3. Scope

3.1. This policy applies to all individuals working for or on behalf of The Good Place, including employees, workers, bank/ agency staff, apprentices/ trainees and most contractors. We also encourage and support volunteers, students and placement learners to use this policy to raise concerns.

4. Policy Statement

4.1. At The Good Place, we are committed to creating an open and honest workplace where employees feel safe and supported when raising concerns about wrongdoing, misconduct, or poor practice. We recognise that speaking up is essential for maintaining high standards of care, ensuring compliance with legal and regulatory requirements, and safeguarding the well-being of service users and employees.

4.2. This policy aligns with the Public Interest Disclosure Act 1998 (as incorporated into the Employment Rights Act 1996) and with the CQC Single Assessment Framework (Well-led: Freedom to speak up quality statement), as well as Regulation 17 (Good governance). It sets out safe, confidential routes to speak up and our commitment to act on concerns without detriment to the person raising them.

4.3. While statutory whistleblowing protection does not usually extend to volunteers or most external job applicants (other than certain NHS roles), The Good Place extends the same zero-retaliation commitment and access to our speaking up channels to volunteers, students and placement learners.

4.4. To qualify for statutory protection, a disclosure must be made in the public interest and the worker must reasonably believe it tends to show one or more of the following:

  • a. A criminal offence;
  • b. A failure to comply with a legal obligation;
  • c. A miscarriage of justice;
  • d. Danger to the health or safety of any individual;
  • e. Damage to the environment; or
  • f. Deliberate concealment of any of the above.

4.5. The worker must also reasonably believe that the information they disclose is substantially true, and that they are raising the concern in the public interest rather than purely for personal reasons.

4.6. A disclosure can be verbal or written. Evidence is helpful but not required to raise a concern.

5. Whistleblowing vs. personal grievance

5.1. Speaking up is about issues in the public interest (for example, risks to people who use services). Concerns that are purely personal employment matters (pay, shifts, interpersonal disputes) should be raised through the Grievance Policy and Procedure, unless they also involve one of the categories above.

5.2. By establishing clear reporting procedures, we ensure that all concerns are properly investigated, addressed, and, where necessary, escalated to external authorities.

6. Encouraging a Culture of Speaking Up

6.1. At The Good Place, we actively encourage employees to voice concerns as soon as possible. We recognise that employees may feel hesitant about raising issues due to fear of reprisal or uncertainty about whether their concerns are valid. To create a culture where speaking up is valued, we:-

  • a. Ensure that all employees are aware of their right to report concerns without suffering negative consequences.
  • b. Provide clear, confidential channels for raising concerns.
  • c. Offer reassurance that reports will be taken seriously and investigated promptly.
  • d. Commit to protecting whistleblowers from victimisation or retaliation.
  • e. We recognise and proactively guard against closed cultures by listening to early warning signs, analysing trends from concerns, and sharing learning openly.
  • f. We will nominate a Speak Up Lead (and, where appropriate, a Freedom to Speak Up Guardian-equivalent) who is independent of line management, visible to employees, and trained to receive concerns.
  • g. Any victimisation or detriment against someone who speaks up (or who helps someone to speak up) will be treated as gross misconduct.
  • h. Ensure that our induction, supervision and ongoing training include information about this policy, examples of concerns that can be raised, and how we respond to them.
  • i. Regularly seek feedback from employees about how safe they feel to speak up, and use this feedback to improve our culture and processes.

6.2. Employees who raise concerns in good faith will never be treated unfairly, dismissed, or subjected to any form of detriment for doing so.

6.3. The Nominated Individual and Registered Manager are accountable for modelling open, compassionate leadership, responding constructively to challenge, and ensuring that people who use our service and their families know how to raise concerns and how their feedback is used to improve care.

6.4. The Speak Up Lead is independent of day-to-day line management structures, has direct access to the Registered Manager and Nominated Individual, and is responsible for:-

  • a. Receiving and signposting concerns raised under this policy.
  • b. Providing advice to employees about speaking up and available routes.
  • c. Supporting the organisation to identify and address cultural or systemic barriers to speaking up.

7. How to Raise a Concern

7.1. If anyone is at immediate risk of harm, call emergency services (999), the police and/ or the Local Authority Safeguarding Team without delay, then inform the Registered Manager as soon as it is safe to do so.

7.2. Employees who witness wrongdoing or have concerns should report them as soon as possible. Concerns can be raised in several ways, depending on the employee’s comfort level and the nature of the issue.

7.3. Concerns about abuse, neglect or serious risk of harm to a person using our service must also be reported under our Safeguarding Adults Policy and Procedure, and may need immediate referral to the Local Authority Safeguarding Team or the police.

7.4. Concerns that are primarily expressions of dissatisfaction about our service from people using the service or their representatives will usually be handled under our Complaints Policy and Procedure. However, employees who believe there is a wider risk to people or wrongdoing in the public interest may raise their concerns under this Raising Concerns, Freedom to Speak Up and Whistleblowing Policy.

7.5. Where to report

7.5.1. The main point of contact for raising concerns at The Good Place is the Registered Manager: Dean Hill.

7.5.2. Concerns can be sent via:-

7.5.3. Concerns can also be sent to the Safeguarding Lead (Dean Hill):-

7.5.4. Speak Up Lead (Linda Caine):-

7.5.5. You can raise a concern with The Good Place or with a prescribed person (such as the CQC) at any time - you do not have to raise it internally first to be legally protected.

7.5.6. Outside organisations:-

8. Informal Resolution

8.1. In some cases, issues may be resolved informally by speaking directly to a line manager or supervisor. If an employee feels comfortable doing so, they are encouraged to discuss their concerns with their immediate superior, who will take appropriate action.

8.2. Informal discussion is optional; if you prefer, you may raise your concern formally or with a prescribed person at any stage.

9. Formal Reporting (Internal)

9.1. If the concern is serious or the employee feels unable to report it informally, they should raise it formally through one of the following channels:-

9.2. You may raise concerns anonymously through any of the channels above. We will review and act on anonymous concerns where possible, but anonymity can limit our ability to investigate and to update you.

10. Formal Reporting (External)

10.1. If an employee believes that their concern has not been properly addressed internally, or if they fear a conflict of interest, they may report their concern to an external authority. This includes:-

10.2. We encourage people to raise concerns internally where they feel safe and able to do so, as this often allows issues to be resolved quickly. However, we recognise that this is not always appropriate or possible. Workers have the legal right to raise a qualifying disclosure with a prescribed person (such as the CQC) at any time, and statutory protection does not depend on raising the concern internally first.

10.3. You can raise a concern with The Good Place or with a prescribed person (such as the CQC) at any time - you do not have to raise it internally first to be legally protected.

11. Handling Whistleblowing Reports

11.1. When a concern is raised, The Good Place follows a structured process to ensure that it is handled fairly and effectively.

11.2. Acknowledgement and initial risk assessment

11.2.1. We acknowledge all reports within five working days. A trained investigator (or the Speak Up Lead) will complete an initial risk assessment to decide immediate safety actions, safeguarding referrals, and whether statutory notifications to external bodies (including the CQC) are required. Where the concern meets the criteria for notifiable incidents under CQC’s Registration Regulations, we will submit notifications without delay, in line with CQC guidance.

11.3. Investigation Process

11.3.1. Where investigation is warranted, we will set clear terms of reference, identify an investigator with appropriate seniority and independence, and gather relevant evidence sensitively and confidentially. We will give the reporter an indicative timescale and provide periodic updates while protecting confidentiality.

11.3.2. Employees who raise concerns will be kept informed of the progress of the investigation, where appropriate, while maintaining confidentiality. Investigations should typically conclude within 28 days; where more time is needed, we will explain why and give a revised timescale.

11.3.3. We will keep clear, accurate and contemporaneous records of concerns raised, risk assessments, decisions made, investigations, actions taken and outcomes. These records will be available for inspection by regulators, subject to data protection and confidentiality requirements.

11.4. Outcome and Action

11.4.1. Once the investigation is complete, appropriate action is taken based on the findings. This may include:-

  • a. Implementing corrective measures to resolve the issue.
  • b. Disciplinary action against individuals found guilty of wrongdoing.
  • c. Reporting findings to external authorities if required.
  • d. Share learning and changes with employees (“you said, we did”) and feed themes into governance and quality improvement.
  • e. Where allegations are not upheld, consider whether system improvements or further training are still warranted.

11.4.2. Whistleblowers will be informed of the outcome, subject to confidentiality considerations, and any further steps that may be taken to address the issue.

12. Learning and quality improvement

12.1. Information from concerns and whistleblowing will be routinely analysed to identify themes, trends and recurring risks relating to safety, quality, equality, diversity and inclusion, and employee wellbeing.

12.2. Themes and learning will be reported into our governance structures, including management meetings and quality reviews, and will inform:

  • a. Updates to risk assessments, care planning processes and safe systems of work.
  • b. Employee training, supervision, and competency assessments.
  • c. Policy and procedure review, including safeguarding, medication, infection prevention and control and complaints handling.
  • d. Workforce planning and support, including steps to address closed or bullying cultures.

12.3. We will share learning and resulting changes with employees, people who use our service and, where appropriate, families and other stakeholders (for example, “you said, we did” updates) in a way that protects confidentiality.

12.4. Senior leaders, including the Nominated Individual and Registered Manager, will regularly review information about concerns and whistleblowing as part of our assurance processes, and will ensure that actions are completed and effective.

13. Protection and Support for Whistleblowers

13.1. We recognise that employees who report concerns may feel vulnerable. The Good Place strictly prohibits retaliation against whistleblowers and will take disciplinary action against anyone found to be victimising or harassing an individual for speaking up.

13.2. Whistleblowers who believe they are experiencing retaliation should report it immediately to the Registered Manager, Speak Up Lead or another senior manager. We offer additional support, including:-

  • a. Confidential counselling services for employees who experience distress as a result of reporting concerns.
  • b. Alternative work arrangements where necessary to protect whistleblowers from harassment.
  • c. Mediation services to address any conflict that arises following a report.
  • d. Detriment includes dismissal, disciplinary action, unjustified negative appraisals, denial of training or opportunities, bullying/harassment, or threats.
  • e. Allegations of victimisation will be investigated swiftly; substantiated cases may result in disciplinary action up to and including dismissal.
  • f. Reasonable adjustments and alternative reporting routes will be offered to ensure people with different backgrounds and protected characteristics can speak up safely.

13.3. Nothing in this policy affects workers’ statutory rights under the Public Interest Disclosure Act 1998 or their ability to seek independent advice, including from Protect (the whistleblowing charity), their trade union, or legal advisers.

14. Confidentiality and Anonymity

14.1. All whistleblowing reports are treated with the highest level of confidentiality. Employees may choose to report concerns anonymously; however, anonymity may limit the organisation’s ability to fully investigate and address the issue.

14.2. We will keep your identity confidential and will not share it beyond those who need to know without your consent, unless we are legally required to do so - for example, where a vulnerable adult may be at risk, a serious crime may have been committed, or another authority must act to ensure safety. Any information shared will be limited to what is necessary.

14.3. Records of concerns will be stored securely, with access restricted on a need-to-know basis and retained in line with our data protection and retention policies, which comply with the UK General Data Protection Regulation (UK GDPR) and Data Protection Act 2018. Where individuals request access to information that identifies a whistleblower, we will carefully balance their rights with our duty to protect people who speak up and any legal restrictions on disclosure.

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While we are not currently regulated, meaning there are some services we cannot currently provide, we are in the process of registering to become a fully regulated service.

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