Schools Topical Audit - Whistleblowing

The Department for Education (DfE) guidance for schools on whistleblowing states that governing bodies of maintained schools are responsible for agreeing and establishing the school's whistleblowing procedure which should be based on the Local Authority procedure.

The DfE guidance also states that the Governing Body should: -

1. minute and record the adoption of their whistleblowing policy and procedure
2. inform every employee of the school's whistleblowing arrangements
3. appoint at least one member of staff and at least one governor who other members of staff can contact if they wish to report concerns.

In Autumn Term 2025, Norfolk Audit Services carried out an audit on whistleblowing arrangements within maintained schools. A sample of 30 schools were assessed via questionnaire, with 5 schools selected for detailed review.

The following risk was covered as part of this audit: -

• Staff are unable to raise whistleblowing concerns or whistleblowing concerns raised are not actioned appropriately

Overall Summary

• Most schools have whistleblowing policies aligned with DfE guidance and NCC standards. Improvements are needed to ensure designated whistleblowing contacts at the school and NCC whistleblowing contact details are identified and included in schools whistleblowing policies.  (See Finding 1). The Whistleblowing policy template available to schools on InfoSpace and the Finance Procedure manual are being updated in line with this
• The schools governance arrangements generally promote transparency although more could be done to identify whistleblowing contacts.  (See Finding 2)
• Staff interviewed demonstrated awareness and confidence in raising concerns.
• Most schools have whistleblowing procedures that are generally well-established and understood.
• The schools demonstrated commitment to promoting transparency and fostering staff confidence in raising concerns.
• Most schools demonstrated good practice in maintaining confidentiality within their whistleblowing procedures. However, improvements may be needed to ensure communications and records are secure. (See Findings 3 and 4)
• Most schools' whistleblowing training is promoted and covered as part of annual safeguarding training, but improvements could be made to cover the wider scope of whistleblowing. (See finding 5)

Detailed findings

Please note recommendations are addressed to the Headteacher as they have overall executive responsibility for the school's activities and are considered by the LA to be the person with overall responsibility to the governing board for the financial management of the school. Headteachers can delegate responsibility for implementation of recommendations but retain ultimate responsibility.

1.Whistleblowing Contacts

Only one school in our sample included named contacts with their direct contact information in their whistleblowing policy with other schools identifying different methods for identifying and communicating designated whistleblowing contacts to staff. The Norfolk County Council Whistleblowing contact details for workers who wish to report concerns directly to the County Council were also not included. The audit also identified that three schools had not appointed both a staff and governor whistleblowing contact as per the DfE Guidance. It should be noted that the Whistleblowing policy template available to schools on InfoSpace and the Finance Procedure manual are being updated in line with this.

Recommendation

Headteachers must ensure:

• At least one named member of staff and one named governor are designated whistleblowing contacts, in line with DfE guidance. These individuals along with their direct contact details should be clearly identified and documented in the school's whistleblowing policy (making use of the updated whistleblowing policy template when available).
• The NCC Whistleblowing contact details are included in their school's whistleblowing policy. We recommend these are included at the top of Appendix 1 alongside the schools designated contacts. These contact details are
  • Email: [email protected]
  • Tel: 01603 22 44 33

2.Lack of Whistleblowing Contact Visibility in Governor Minutes

At 10 of the 30 schools reviewed, whistleblowing contacts were not recorded in their formal records such as governor meeting minutes.

Recommendation

Headteachers must embed the practice of clearly identifying whistleblowing contacts in governor meeting minutes. Doing so reinforces transparency, strengthens governance oversight and ensures that both staff and governors are fully informed of their whistleblowing responsibilities.

3.Confidentiality

At one of the five schools reviewed, it was found that the Chair of Governor's email account designated for whistleblowing matters was accessible by the clerk. This shared access compromises the confidentiality of whistleblowing communications and creates a risk that sensitive information could be viewed by unintended parties.

Recommendation

Headteachers must review and secure whistleblowing channels to ensure that access is strictly limited to the intended recipient. Email addresses used for whistleblowing must be restricted to the whistleblowing contact only, and any administrative support should be provided through separate, non-confidential channels. Implementing these measures will help improve trust in the whistleblowing process and ensure compliance with confidentiality requirements.

4.Record access issues

At two of the five schools reviewed, whistleblowing records may have been accessible to non-designated staff, specifically clerks and administrators. These individuals were not formally assigned whistleblowing responsibilities, yet they may have access to sensitive documentation related to whistleblowing concerns.

Recommendation

Access to whistleblowing records must be strictly limited to authorised contacts only. Headteachers must ensure that governors and designated staff can manage these records independently, without relying on clerks or administrators

5.Whistleblowing Training

Most schools' whistleblowing training is promoted and covered as part of annual safeguarding training. While this approach ensures staff are aware of whistleblowing in safeguarding contexts, it does not fully address other areas where whistleblowing may apply, such as financial mismanagement or non-safeguarding concerns. Although whistleblowing is included within safeguarding training, the framework could be strengthened by introducing more dedicated whistleblowing training that covers a broader range of issues. Expanding awareness beyond safeguarding would strengthen the overall effectiveness of the whistleblowing framework.

Recommendation

Headteachers should look to include whistleblowing guidance on non-safeguarding issues (e.g financial irregularities, fraud, health and safety concerns) in annual training sessions or consider implementing dedicated whistleblowing training to reinforce understanding beyond safeguarding contexts.