What is a Privacy Notice?

Oakdale is a 'data controller'. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you regarding how we hold and use your personal information.

How do we collect your personal information?

We may collect personal information directly provided by you or your legal representative at any time you are in contact with Oakdale and we may collect, store and use your personal information whilst you are engaged with Oakdale. We may also collect your personal information from third parties such as the NHS, commissioning authorities or through your private medical insurer.

For what purpose will we use your personal information?

In most cases, we will use your personal information to provide assessment, therapy, treatment or payment purposes. In rare cases, we may need to use your personal information to protect your (or someone else's) interests or if it is in the public interest for us to do so.

Why might we share your personal information with third parties?

We will share your personal information with third parties where required by law, where it is necessary to be able to provide you with assessment, therapy or treatment, to protect your interests (or someone else's interests) or where we have another legitimate interest in doing so.

How long will we use your information?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal information are available in our retention policy.

When might we transfer your information overseas?

We may transfer the personal information we collect about you to countries within the European Economic Area (EEA). We may transfer personal information we collect about you to the United States of America or other parts of the world outside the UK where there has not been an adequacy decision in limited circumstances when a third party supplier has operations in such a country.

What are automated decisions?

Automated decision making takes place when an electronic system uses personal information to make a decision without human intervention. You will not be subject to decisions that will have a significant impact on you based solely on automated decision making, unless we have a lawful basis for doing so and we have notified you.

What is data portability?

The right to data portability allows you to obtain and reuse a copy of your personal data for your own purposes or for us to send the information to a new provider on your behalf (where technically feasible). It allows you to move data, copy data and transfer data in a safe and secure way without affecting its usability.

What are Subject Access Requests?

You have a right of access under the UK General Data Protection Regulation (GDPR). The right of access allows you to obtain confirmation that we are processing your personal data and to receive a copy of that personal data, together with certain supplementary information about how and why it is being used.

Whistleblowing policy.

Whistleblowing policy

Version 5, May 2026. Next review: May 2027.

If you need this document in another format, such as large print, audio or another language, please contact the Governance Team at dpo@oakdalecentre.org.

Our equality impact statement

When following procedures on behalf of Oakdale, all employees and associates are expected to ensure that no one person or group is disadvantaged on the grounds of race, religion or beliefs, age, gender, sexual orientation, gender reassignment, marriage and civil partnership, disability, pregnancy and maternity, caring responsibilities.

Scope

This policy is designed to enable individuals who become aware of wrongdoing at Oakdale, impacting another person or service, to report concerns for proper investigation. It ensures that concerns about wrongdoing or malpractice can be reported without fear of victimisation, discrimination, disadvantage, or dismissal. This policy aims to facilitate the internal resolution of concerns rather than ignoring a problem or relying solely on external disclosure.

This policy does not replace existing procedures:

Concerns related to an employee's own treatment should be raised under the existing grievance or harassment procedures.
Client concerns regarding service provision should be addressed through Oakdale's standard complaints procedures.

Responsibilities

The Clinical Director holds ultimate responsibility for Clinical Governance matters and ensures that any whistleblowing concerns are addressed fairly, thoroughly, and in accordance with this policy.

Managers are responsible for ensuring staff awareness of the policy, its application, and for fostering an environment where concerns can be raised freely without fear of reprisal.

All staff members have a responsibility to raise concerns if they have a reasonable belief that malpractice or wrongdoing has occurred.

Policy statement

Whistleblowing refers to the disclosure of information to an employer or relevant authority by an individual who knows or suspects that Oakdale is responsible for or has participated in wrongdoing. Wrongdoing includes suspected misconduct, illegal acts, or failure to act.

The purpose of this policy is to encourage colleagues with serious concerns about any aspect of Oakdale's operations to come forward and report their concerns.

Employees are often the first to recognise potential issues within an organisation. Whistleblowing is regarded as a positive action that contributes to quality and long-term success. Oakdale is committed to maintaining the highest possible standards of service and ethical conduct across all operations and is also committed to a 'speak up' culture where raising concerns is welcomed and valued.

Who can raise a concern under this policy

Oakdale-employed staff, associates or freelance practitioners.
Employees of contractors working for Oakdale, such as agency staff and tradespeople.
Individuals providing services under a contract or agreement with Oakdale.
Voluntary workers or student placements within Oakdale.

Aims of this policy

Encourage individuals to report serious concerns at the earliest opportunity.
Provide appropriate channels for reporting concerns and obtaining feedback on actions taken.
Ensure responses are provided to concerns and clarify avenues for escalation if necessary.
Offer reassurance that individuals reporting concerns in good faith will be protected from reprisals or victimisation.

Reportable concerns

Serious concerns regarding service provision or the conduct of directors, staff, associates, or others acting on behalf of Oakdale should be reported if they:

Conflict with known standards.
Contravene Oakdale's policies.
Fall below established standards of practice.
Represent improper behaviour.

Examples include, but are not limited to:

Conduct that constitutes an offence or breach of the law.
Disclosures related to miscarriages of justice.
Discrimination based on race, sex, disability, or other protected characteristics.
Health and safety risks to the public and/or employees.
Environmental damage.
Unauthorised use of funds or assets.
Fraud or corruption.
Neglect or abuse of clients.
Other unethical conduct.

Untrue allegations

If a disclosure is made in good faith and is reasonably believed to be true but is not substantiated through investigation, Oakdale will acknowledge the concern and no negative consequences will result. However, frivolous, malicious, or self-serving allegations may lead to appropriate action, including disciplinary measures.

Formal action

If formal action is required following a disclosure, it will be conducted in accordance with relevant internal policies. Any sanctions imposed will be fair and reasonable within the scope of the applicable policy.

Qualifying disclosures

Certain disclosures are classified by law as "qualifying disclosures". A qualifying disclosure refers to information that the reporting individual reasonably and genuinely believes is in the public interest and demonstrates that Oakdale has committed a "relevant failure". This means the concern affects others beyond your personal situation.

These failures may be past, present, or future. For instance, a disclosure qualifies if it relates to environmental damage that has occurred, is occurring, or is likely to occur. Oakdale takes such concerns seriously. Staff members and practitioners must reasonably believe that the disclosure serves the public interest.

Concerns that do not meet the criteria for a qualifying disclosure should be raised under the Oakdale Grievance Policy. If a concern is submitted under the Whistleblowing Policy inappropriately, for example because it pertains to a personal grievance, the receiving manager will confirm that the issue will be addressed under the grievance policy.

Protecting the whistleblower

This policy aligns with the Public Interest Disclosure Act 1998, which protects workers who report concerns in the public interest, provided their disclosures comply with the Act's provisions. Under the Act, Oakdale is prohibited from dismissing or victimising anyone for making a lawful and appropriate disclosure. All colleagues who raise matters of concern under this policy are protected against detrimental treatment, up to and including dismissal, because they have made a disclosure.

Bullying, harassment or any other detrimental treatment afforded to a colleague who has made a qualifying disclosure in good faith is unacceptable. Anyone found to have acted in such a manner will be subject to disciplinary action.

Throughout this process, the whistleblower will have their concerns taken seriously, be given full support from senior management and be assigned a support manager who will be available during the whistleblowing investigation. This will be a different person to the investigating manager. If appropriate, Oakdale will consider temporarily re-deploying the whistleblower for the period of the investigation.

For those who are not employed staff or associates, Oakdale will endeavour to provide appropriate advice and support wherever possible, such as to Freelance Therapists.

In rare cases, a member of staff or associate may have been involved in the wrongdoing being reported. While Oakdale cannot guarantee immunity from disciplinary action, coming forward voluntarily may be considered when determining any consequences.

Confidentiality

All concerns will be treated confidentially, and every effort will be made to protect the identity of individuals raising concerns if requested. However, if disciplinary or other proceedings follow an investigation, it may not be possible to take further action without additional input from the individual who raised the concern. In such cases, support and guidance will be provided should they agree to act as a witness.

Anonymous allegations

This policy encourages individuals to provide their names when raising concerns whenever possible. Anonymity can make it more challenging to protect the position of the whistleblower or provide feedback. While the policy is not ideally suited to concerns raised anonymously, discretion may be exercised when considering such reports.

Factors influencing whether an anonymous concern is pursued include:

The seriousness of the issue raised.
The credibility of the concern.
The likelihood of confirming the allegation from other sources.

Anonymous concerns will be taken seriously where sufficient information is provided.

How to raise a concern

Concerns can be raised via telephone, in person, or in writing. Expressing concerns as early as possible facilitates prompt action. The following details should be provided:

The nature of the concern and reasons for believing it to be valid.
The background and history of the concern, including relevant dates.

While there is no requirement to prove a suspicion beyond doubt, reasonable grounds for concern must be demonstrated to the relevant contact person.

In the first instance

Employees should report concerns, by telephone, in person or in writing, to their line manager or Head of Service. If the concern relates to these individuals, it should be reported directly to the Head of People or HR.
A written summary of the concern should be provided to the Head of People.
Other individuals covered by this policy may contact the Head of People directly with a summary of their concerns through the following channels:
- Email: shannon.blades@oakdalecentre.org
- Letter: Shannon Blades, Head of People Operations, Oakdale, 49 Valley Drive, Harrogate, HG2 0JH
- Telephone: 01423 276 262

If your concern relates to the Head of People

If the concern relates to the Head of People, a Director of Oakdale or the Freedom to Speak Up Guardian can be contacted:

Dr Caroline Falconer, Clinical Director: caroline.falconer@oakdalecentre.org
Richard Carlton-Crabtree, Director: richard.carlton-crabtree@oakdalecentre.org
Lee Clewett, Freedom to Speak Up Guardian: lee.clewett@oakdalecentre.org

There is no requirement to provide any personal information when raising a concern. However, if any personal identifiable information is disclosed during this process, it will be shared only with the Head of People or HR.

What happens after you raise a concern

1. Procedure following a disclosure

The Head of People, or the Director or Freedom to Speak Up Guardian receiving the concern, will acknowledge receipt within seven working days and arrange a meeting with the whistleblower.
An initial investigation meeting will be held within 21 days of receiving the disclosure. The whistleblower may be accompanied by a colleague or union representative. The purpose of this meeting is to gather as much information as possible, including any supporting evidence or potential witnesses.

2. Investigation process

If external reporting is required, for example safeguarding alerts or significant data breaches, the Head of People will consult the Governance Team to ensure compliance with reporting obligations.
The Board of Directors will be informed of the concern, and an investigating manager will be appointed. If the case is particularly complex, an impartial investigator may be assigned.
The investigating manager will conduct a thorough investigation, collecting relevant documentary evidence and witness statements.
A Whistleblowing Concern Investigation Report will be prepared, including conclusions and recommendations, and approved by the Head of People and a Board member.

3. Outcome of the investigation

The investigation manager will communicate to the whistleblower in writing.
Oakdale aims to respond to whistleblowing concerns within three months of the initial report.

4. Escalation process

Raise a concern. Report your concern through the appropriate internal channel.
Acknowledgement. Your concern will be acknowledged within three working days.
Initial meeting. An initial discussion will usually take place within 21 working days to understand the concern.
Investigation. The concern will be reviewed and, where appropriate, a formal investigation will be carried out.
Outcome. You will be informed of the outcome as soon as reasonably practicable. Timeframes will depend on the complexity of the case, but we will aim to conclude matters without unnecessary delay. Independent legal advice may be sought.
If you are not satisfied. You may raise the matter with an appropriate external organisation, as per the government's prescribed list. Employees may submit a formal grievance under the Oakdale Grievance Policy.

Taking action beyond Oakdale with your concern

Concerns raised outside of Oakdale should be directed to one of the prescribed contacts. Public disclosure to any other party may fall outside the protection of the Public Interest Disclosure Act and the scope of this policy.

Confidential information related to Oakdale, clients, or contractors must not be disclosed except to the prescribed contacts listed by the UK government. The official list of prescribed people and bodies for whistleblowing concerns can be accessed here: Whistleblowing: list of prescribed people and bodies

Oakdale is available to assist in identifying the appropriate agency from this list to escalate concerns. Support in this process can be requested if needed. Additionally, an organisation called Speak Up provides guidance on identifying the correct prescribed person or body. Their contact details are:

Telephone: 08000 724 725
Website: speakup.direct/contact-us

Governance and quality assurance arrangements

All information will be handled in accordance with UK GDPR and the Data Protection Act 2018.

The Head of People maintains a register of all concerns raised, along with actions taken and lessons learned. This information is shared with relevant individuals as needed. The policy will be reviewed at least annually.

Patterns and trends in concerns are reviewed by the 'Experience Matters' governance group, which makes recommendations for policy and practice adjustments where required. Lessons learned are communicated to the Senior Management Team and the Board.

The Head of People reviews the register and submits a quarterly report to the Board. This report includes:

A summary of concerns raised.
The department involved.
The post to which the concerns relate, if not confidential.
Any lessons learned.

Employee names will not be included in the report. The purpose of this process is to:

Ensure that Oakdale and relevant departments learn from incidents and implement actions to prevent recurrence.
Maintain consistency in handling concerns across all departments.

The register and quarterly reports will be available for inspection by external auditors or regulators, with confidential details removed. Feedback will be provided where possible, subject to confidentiality and data protection.

All staff will receive awareness training and a copy of this policy at induction and periodically thereafter.