Legislative compliance
As a minimum, all public bodies should:
Review existing procedures
Check that existing organisational procedures do not direct staff to perform actions which might constitute offences under the Public Interest Disclosure Act. Particular procedures that should be reviewed include those concerning:
- the protection and disclosure of confidential information;
- accepting and handling complaints against the organisation;
- how front counter staff should handle calls relating to improper conduct;
- human resources, to ensure that staff are alerted to think very carefully before taking an adverse employment-related action against a person who has disclosed to the Commissioner or cooperated with an investigation;
- providing support for staff who are experiencing emotional stress, and particularly developing a procedure for supporting the welfare of persons who disclose public interest information.
Organise training
Ensure that all employees are aware of their obligations under the Public Interest Disclosure Act, and incorporate this training into induction procedures for new staff. The Commissioner for Public Interest Disclosures welcomes requests to conduct training sessions. You can also direct your staff to undertake online training through this website, and track which of your staff complete the training. All staff need to be aware of their obligations under the Public Interest Disclosure Act, particularly in respect to providing information to the Commissioner. Some of the obligations are counterintuitive, and staff may be at risk of committing an offence while ‘trying to do the right thing’.
Support your managers to manage people
Insist that your managers have or undertake training in managing people, and ensure they have persons they can turn to for advice or support in difficult situations. Make it clear that it is part of their job description to respond effectively and appropriately to workplace conflict. Managers and supervisors are at risk of inadvertently committing acts of reprisal (or of having their actions perceived this way by the discloser).
Guidelines
In the future, the Commissioner for Public Interest Disclosures will issue official guidelines for organisations on how to respond to various issues raised by the Public Interest Disclosure Act, including to protect the welfare of persons who make public interest disclosures.