SOUTH WEST PUBLIC HEALTH TRAINING PROGRAMME
The intention of this policy is to empower Public Health Registrars to raise concerns as early as possible and to promote a supportive and positive environment where Registrars who have legitimate concerns, are able to raise these without fear of discrimination or reprisal.
All Registrars have a responsibility to understand:
- They have a right and a duty to raise genuine and legitimate concerns;
- The importance of the policy to themselves and the Training Programme
- That when faced with doubts over raising a concern that he/she should always do so;
- That raising genuine concerns does not make them a troublemaker;
- That they will not be asked to prove their concern is true, only that it is honestly raised;
- That it is best to raise a concern at the earliest opportunity;
- That raising genuine but unfounded concerns will not expose them to disciplinary action;
- That deterring anyone from using this policy is a disciplinary offence;
- That bullying, harassing, isolating, or otherwise victimising anyone who uses this policy in good faith, is a disciplinary offence
The Training Programme hopes that most concerns can be resolved on an informal basis with a rapid response. The Training Programme recognises however, that there might be circumstances when matters require to be handled outside these normal channels.
Registrars are assured that any concerns raised through the policy will be treated seriously.
The Training Programme will not tolerate the harassment or victimisation of any individual raising a genuine concern. Instances of harassment or victimisation of a member of staff who has raised a concern will be dealt with in accordance with the Severn PGME and Gloucestershire Hospitals NHS Foundation Trust Disciplinary and/or Harassment & Bullying policies.
Registrars who raise a concern under this policy will not suffer any detriment as a result. Provided the Registrar is acting in good faith, it does not matter if they are mistaken about their concerns.
The Training Programme recognises that Registrars raising concerns may be anxious and so will be fully supported throughout the process. Registrars are able to arrange to speak to someone in private for support and advice.
Concerns raised by Registrars will be treated with respect and confidentiality. However, it should be recognised that it would be unrealistic that all concerns raised can remain entirely confidential. Therefore, a Registrar considering raising a concern should be aware that they may be asked to:
Present evidence to substantiate their concern;
Make a written statement.
Explain their concerns or allegations at any resulting formal proceedings.
The Training Programme will however do its utmost to ensure that Registrars do not suffer as a result of raising a concern in good faith. If a Registrar has requested that his/her identity is not disclosed, but the situation arises where the Training Programme is not able to resolve the concern without revealing their identify, the matter will be discussed with the individual concerned to determine whether and how the Training Programme proceeds.
If the person raising the concern wishes to remain anonymous, it will be much more difficult for the concern to be investigated and for the Training Programme to protect the individual’s position or give feedback. Accordingly, while the Training Programme will consider what action may be justified by an anonymous report, it is unlikely that the Training Programme will be able to handle such reports under this policy.
Whilst the Training Programme is committed to this policy and positively encourages Registrars to raise their concerns, the Training Programme will not tolerate the raising concerns with malicious intention or for personal gains (to get someone you dislike into trouble). Registrars raising concerns that are investigated and found to be of a malicious nature will be treated in accordance with the Severn PGME and Gloucestershire Hospitals NHS Foundation Trust’s Disciplinary Policy.
Handling the matter
The Training Programme will respond promptly and consistently to concerns raised.
Once the concern has been raised, the matter will be considered to assess what action should be taken. This may involve an informal review or an internal inquiry. The individual who raised the concern will be advised who is handling the matter, how they can be contacted and whether further assistance may be needed from them. At the individual’s request we will write to them summarising the concern and setting out how we propose to handle it. Individuals will be asked if they have a personal interest in the matter.
Wherever possible the Training Programme will give as much feedback to the individual as possible; however the Training Programme may not be able to inform the individual of the precise action taken where this would infringe a duty of confidence owed by the Training Programme to someone else.
Procedure for Raising Concern
Registrars who wish to raise a matter of concern should first raise the issue with their educational supervisor. The educational supervisor will acknowledge receipt of the concern and bring it to the attention of the Specialty Tutor in their training location. The educational supervisor will provide an initial written response within 7 working days of a Registrar raising or discussing their concern.
If the educational supervisor is also the Specialty Tutor then the matter will be referred for further investigation to the Head of School/TPD who will identify an appropriate person to investigate the concern, take action and subsequently monitor the action. In these circumstances, the Registrar will be issued with a response at the conclusion of that investigation. The educational supervisor/nominated person investigating the concern will provide feedback to the Registrar who raised the concern so that they know that the matter has been taken seriously by the Training Programme.
If the concerns relate to the actions of their immediate educational supervisor, then Registrars should raise their concern with the Public Health Programme Manager.
Where Registrars believe their educational supervisor has not dealt with their concerns effectively, Registrars should formally raise the matter in writing to the Public Health Programme Manager.
Registrars are asked to put their concerns in writing so that the matter is understood clearly.
After due consideration the Head of School/TPD will give a decision which will include a proposed resolution, in writing, if possible within 7 days of the matter being raised.
Should the individual raising the concern remain dissatisfied, they may refer the matter in writing to the Head of School/TPD who will formally respond within 14 working days.
Should the Registrar wish to raise concern with someone outside the Training Programme, he/she should write in confidence to the Associate Dean at the Severn PGME.