Democracy Spraffa

Item 11 - Whistleblowing Annual Report

North Lanarkshire Council · 30 November 2022
Back to Health and Social Care Integration Joint Board — 30 November 2022 and its agenda

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REPORT 
Item No: 11 
SUBJECT: NHS Lanarkshire Whistleblowing Annual Report 2021/2022
TO: North Lanarkshire Integration Joint Board
Lead
Officer for
Report:
Ross McGuffie, Chief Officer North HSCP  
Author(s) of
Report
Kay Sandilands, Director of Human Resources (NHS Lanarkshire)
DATE: 30th November 2022 
1. PURPOSE OF REPORT 
Update members on the application of the National Whistleblowing Standards 
by NHS Lanarkshire.
This paper is coming to the IJB for: 
For approval  For endorsement  To note 
2. ROUTE TO THE BOARD
This paper has been: Endorsed by the NHS Board. 
Prepared   Reviewed   Endorsed            
3. RECOMMENDATIONS 
The Integration Joint Board is asked to:-
(1) note the NHS Lanarkshire Whistleblowing Annual Report for 2021/20; and
(2) note the assurance received by the NHS Lanarkshire Board that
whistleblowing standards are being followed and learning shared.

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4.  VARIATIONS TO DIRECTIONS? 
5. BACKGROUND/SUMMARY OF KEY ISSUES
5.1 The Scottish Public Services Ombudsman fulfils the role of the Independent
National Whistleblowing Officer (INWO). The aim of the role is to make sure
everyone delivering NHS services in Scotland is able to speak out to raise
concerns, ultimately contributing to ensuring that the NHS in Scotland is as
well run as possible. 
5.2 The INWO developed a set of National Whistleblowing Standards that set out
the high level principles and a detailed procedure for investigating concerns.
An effective procedure for raising concerns (whistleblowing) is:
 open
 focused on improvement
 objective, impartial and fair
 accessible
 supportive to people who raise a concern or are involved in the procedure
 simple and timely
 thorough, proportionate and consistent 
5.3 The National Whistleblowing Standards and Once for Scotland whistleblowing
policy (the Standards) were introduced on 1 April 2021.   The Standards are
applicable across all NHS services.  This means that they must be
accessible to anyone working to deliver an NHS service, whether directly or
indirectly. 
5.4 It is a requirement of the Standards to formally and routinely report
whistleblowing performance to NHS Boards, including the preparation of an
annual report.   
6. CONCLUSIONS
6.1 The NHS Lanarkshire Whistleblowing Annual Report for 2021/20 was
presented to the NHS Lanarkshire Board at its meeting of 31st August 2022.
At that meeting the NHS Board confirmed that it had received assurance that
whistleblowing standards are being followed and learning shared (appended).   
6.2 For the purposes of good governance and transparency, this Annual Report is
being shared with the IJB completeness. 
Yes  No  N/A

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7. IMPLICATIONS
7.1 NATIONAL OUTCOMES
Link(s) to National Health and Wellbeing Outcomes 
People are able to look after and improve their own health and wellbeing and
live in good health for longer 
People, including those with disabilities or long-term conditions, or who are
frail, are able to live, as far as reasonable practicable, independently and at
home or in a homely setting in their community 
People who use Health and Social Care Services have positive experiences of
those services, and have their dignity respected 
Health and Social Care Services are centred on helping to maintain or improve
the quality of life of people who use those services 
Health and Social Care Services contribute to reducing health inequalities 
People who provide unpaid care are supported to look after their own health
and wellbeing, including to reduce any negative impact of their caring role on
their own health and wellbeing 
People who use Health and Social Care Services are safe from harm 
People who work in Health and Social Care Services feel engaged with the
work they do and are supported to continuously improve the information,
support, care and treatment they provide 
Resources are used effectively and efficiently in the provision of Health and
Social Care Services 
7.2 ASSOCIATED MEASURE(S)
None.
7.3 FINANCIAL 
None associated with this report.   
This paper has been reviewed by Finance: 
Yes   No  N/A

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7.4 RISK ASSESSMENT/RISK MANAGEMENT 
Whistleblowing is not currently on the IJB risk register. 
7.5  PEOPLE
7.5.1 All those working in Health and Social Care Partnerships can raise concerns
about NHS services, whoever their employer is.  Any concerns about the
delivery of NHS services must be handled in line with the requirements of
these Standards, and anyone raising a concern through these Standards can
do so to INWO.
7.5.2 If staff do not have confidence in the fairness of the procedures through which
their concerns in respect of NHS services are raised, or do not feel assured
that concerns raised will be acted upon, there is a risk that they will not raise
valid concerns about quality, safety or malpractice. The opportunity to
investigate and address these concerns will have been lost, with potentially
adverse impact on quality, safety and effectiveness of services.  There is also
a wider risk to organisational integrity and reputation, if staff do not believe
they will be listened to and do not feel senior leaders in NHS Lanarkshire are
fulfilling the organisation’s values and promoting a culture of psychological
safety. The activity described within this report contributes to the mitigation of
such risks. 
7.6 INEQUALITIES & FAIRER SCOTLAND DUTY 
EQIA Completed & Fairer Scotland Impact Assessment Form Completed: 
Yes  No  N/A 
8. BACKGROUND PAPERS 
NHS Lanarkshire Whistleblowing Annual Report – April 2021 to March 
2022 (see appendix 1)

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9. APPENDICES
Appendix 1: NHS Lanarkshire Whistleblowing Annual Report – April 2021 to
March   
CHIEF ACCOUNTABLE OFFICER (or Depute)  
Members seeking further information about any aspect of this report, please contact
Ross McGuffie on telephone number 01698 752 591. 
Members seeking further information about any aspect of this report, please contact
the following;
Name: Kay Sandilands, Director of Human Resources (NHS Lanarkshire)
Phone:  01698 752865 
Email: Kay.Sandilands@lanarkshire.scot.nhs.uk

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Appendix 1:
Whistleblowing Annual Report – April 2021 to March 2022 
1. Introduction 
The National Whistleblowing Standards and Once for Scotland whistleblowing policy (the
Standards) were introduced on 1 April 2021.  NHS Lanarkshire’s performance against
the Key Performance Indicators included in the Standards has been reported to the Staff
Governance Committee and the board on a quarterly basis.  In addition to quarterly
reporting boards are also required to prepare an annual report, the contents of which are
outlined in the Standards.   
2. Key Performance Indicators 
2.1      Cumulative total – Whistleblowing Concerns Raised 2021/22 
Quarter Appropriate for
whistleblowing   
Stage 1    Stage 2      Outcome Comments
1 1   0   1              Upheld Action plan
implemented
2    0 n/a n/a           n/a 
3      
2 (1 appropriate for
WB and unnamed.
1 partially
appropriate for WB)
1   1 Both mainly
upheld.
1 complaint was
unnamed and
mainly upheld.  The
second complaint
was dealt with
under 2 procedures
– WB and a
separate HR
procedure.  The
latter complaint was
mainly upheld at
stage 1
4 0 0 0 n/a 
Total 3 1 2   
The Standards require stage 1 concerns to be completed within 5 working days and
Stage 2 concerns to be completed within 20 working days.    
The table below shows the number and percentage of concerns at each stage which
were closed in full within the set timescales of 5 and 20 working days, for 2021/22.  This
reflects any extensions agreed.

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Nos
received
% closed in 5
working days 
Nos
received
% closed in 20
working days
Stage 1  2 100 Stage 2 1 100 
The table below shows concerns raised in 2021/22 where an extension was authorised. 
Concern Nos received Extension authorised As % of all concerns
Stage 1 2 1 50
Stage 2  1 1 100 
3. Analysis of numbers of concerns raised 
Three concerns were raised during 2021/22 and this compares to two during 2020/21,
two during 2019/2020, one during 2018/19, three during 2017/18 and none during
2016/17, so numbers remain fairly constant.  It would be interesting to compare NHS
Lanarkshire’s numbers with those from other Boards but this information is not readily
available, unless the Independent National Whistleblowing Officer (INWO) decides to
publish national numbers, which would be useful for comparison purposes.  
4. Further information on the 3 concerns raised during 2021/22, including
service improvements and shared learning. 
4.1 The first complaint raised in April 2021 was reported to the Staff Governance
Committee in September 2021 and concerned one of the radiology
departments.  Specifically, concerns were raised about staff rest areas, staffing
numbers, management support, enhanced information around incident
reporting and wider sharing of departmental protocols, particularly around out-
of-hours services.   
A detailed action plan was developed as a result of this concern being raised
and staff have been intrinsic to its development. The agreed actions included a
commitment to work on workforce planning, ensuring staff involvement and
feedback on progress; consideration of available space for rest areas;
reviewing management support within the department including senior
management visibility; enhancing information sharing around incident reporting;
wider  sharing of departmental protocols to improve the patient care journey,
particularly out of hours and to develop a departmental action plan which could
be shared with all staff. 
The action plan has been largely monitored through local departmental
management meetings and has also been discussed at pan Lanarkshire
service meetings, which are attended by clinical leads for all departments, the
service manager and team and director and associate medical director. This
has enabled learning and service improvements to be shared across the sites.
The action plan will also be tabled at the acute divisional management team to
log issues and note progress and has been a regular feature at the site
departmental monthly staff meetings.  This has ensured that staff are aware of
the points raised and that outcomes and learning are shared. Specific learning

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and quality improvement projects have been generated around some of the
themes in the action plan and, in addition to local discussion, these projects
have been shared across all of the radiology departments and via the site
clinical governance groups. 
A short life working group has continued ongoing work including use of the
workforce planning tool and an SBAR.  Locums were contracted to work in
radiology to provide additional cover until 8pm and at weekends on an interim
basis.  A staff well-being hub has been established on the three sites supported
by a well-being rep, notice board and signposting. Well-being is a standard item
on monthly staff meetings. Management have been attending safety huddles,
departmental staff meetings and ensuring a presence across departments.
Quality improvement projects have been completed on MRI safety and
radiology patient flow and a safety group established to discuss Datix. 
Overnight Datix incidents are shared and discussed on site daily huddles. The
action plan is a standing agenda item at monthly staff meetings where minutes
of the groups outlined above and updated actions are shared. 
4.2 The second complaint raised concerned cleaning services at one of the acute
hospitals where cleaning services are managed by a private contractor.  The
concern was raised in October 2021 and followed on from a previous and
similar complaint raised in December 2020, which was before the introduction
of the new Standards.  The investigation upheld a number of the issues which
had been identified and concluded by providing eight detailed assurance
recommendations.  These recommendations related to: 
 Appropriate use of equipment
 Cleanliness of equipment
 Staff training in relation to domestic sign off sheets and food hygiene
documentation
 Helpdesk sign off processes
 Process for re-auditing
 Approach to contract management of soft FM services
 Need for a root cause analysis of issues highlighted to identify specific
improvement actions. 
An action plan, based on the investigation report and recommendations, was
developed by the contractor, in conjunction with the Property & Support Services
Division (PSSD). Its aim was to address the issues identified and embed the
necessary changes in the contractor’s approach to service delivery.  An evidence
portfolio to support the implementation of the action plan was compiled and
shared with the management team in PSSD through the ongoing monitoring
process for Soft FM services at the hospital concerned. The learning and
recommendations from the report were also shared with the PSSD team
responsible for delivery of PFI contract management services at both University
Hospital Hairmyres and University Hospital Wishaw, in order to ensure that
learning generated from the issues identified and the subsequent
recommendations were reflected across the estate.

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The implementation of the action plan was monitored through weekly senior level
operational management meetings and also through fortnightly senior
management meetings established by the Director of Planning, Property &
Performance with PSSD and the contractor. These groups continue to meet to
review the performance of the healthcare cleaning service at the hospital
concerned, which is subject to daily auditing by the NHS Lanarkshire Facilities
Management Team auditor.  The Director of Planning, Property and Performance
also presented a report to the Healthcare Quality Improvement and Assurance
Committee (HQAIC) where there was a high level of engagement from Board
members.   
4.3 The third complaint concerned culture and behaviours within one of the
departments of the HR directorate.  Prior to this particular issue being raised
the Head of Service had already commissioned a piece of work following a
decrease in iMatter scores and a mediation session was held in December 2021
which highlighted a number of areas for improvement. 
The subsequent investigation into the whistleblowing concern also made a
number of recommendations on areas to improve the culture and behaviours
within the team.  These formed the basis of an action plan which focussed on
improving communication, clarifying roles, equitable workload and consistency
in application of policies/procedures.  The head of service has held three
sessions with the staff to take forward the action plan and feedback to date
suggests that the culture within the department is improving. The action plan is
fluid and will be amended as required, with the aim of achieving an overall
improvement in relationships within the team. 
Implementation of the action plan is monitored by the HR director on a monthly
basis and staff have been involved in the process throughout and have driven
the development and content of the plan.  Key learning outcomes which have
been shared across the team include the importance of role clarity, regular and
timely communication, two-way feedback and an environment where it is safe
to speak up. These learning outcomes were carefully reviewed with a view to
potentially sharing them across the directorate.  It was concluded that, for
reasons of confidentiality as part of the complaint was dealt with under a
separate HR policy, this would not be appropriate. The complaint was also
reported to the Staff Governance Committee. 
5. Whistleblowing themes, trends and patterns 
The analysis of themes from whistleblowing concerns aids identification of any shared
causes and helps to progress learning and improvement in a targeted manner. The
categories/classification for whistleblowing concerns are listed in Part 2 of the Standards
and are outlined below for information:  
 Patient Safety
 Patient Care
 Poor practice
 Unsafe working conditions
 Changing or falsifying information on performance

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 Fraud
 Breach/breaking any legal obligation
 Abusing authority
 Concealment of any of the above 
Interrogation of the three complaints raised does not initially reveal any obvious thematic
concerns, with each being quite distinct and classification covering a number of the
categories listed above i.e. patient safety, patient care, poor practice, unsafe working
conditions and changing or falsifying information on performance.  However, it should be
noted that, with regard to the second complaint about cleaning standards, a very similar
complaint had previously been raised in October 2020, which was prior to the introduction
of the Standards.  The actions outlined above and the thorough and high level of scrutiny
by the appropriate governance committee (HQAIC) reflect the fact that two very similar
complaints had been received, both of which concerned patient safety. 
6. Independent primary care contractors 
A reporting template and targeted communications were developed for independent
primary care contractors.  Out of those that returned the reporting template, none had
received any whistleblowing complaints.  It is, however, worth noting that a complaint
was received from a GP practice in April 2022 and this will be reported in the quarter 1
report for 2022/23. 
7. Experience of Individuals Raising Concern/s during 2021/22 
The experience of the individual who raised the concern about radiology services was
reported as very positive.  No feedback was received from the other two individuals who
raised concerns.  A further indicator of the satisfaction of those who raise concerns can
be derived from the number of concerns escalated to the INWO and no referrals were
made to the INWO as a result of concerns raised in NHS Lanarkshire. 
8. Communication, Awareness and Training 
Since the soft launch of the Standards at the beginning of 2021 regular items have
appeared in the staff briefing and in the Pulse on-line. Details of confidential contacts
have been publicised and a separate briefing has also been sent to all primary care
contractors, along with supporting documentation to enable independent contractors to
record and report cases. The non-executive whistleblowing champion has presented to
the two Health & Social Care Partnerships and Acute management teams and
presentations have also been made to both the GP and GDP Sub Committees.  Meetings
have also been held with both PFI contractors to confirm that the Standards will be made
available to their staff who provide services to NHS Lanarkshire patients and the non-
executive whistleblowing champion has delivered presentations to the PFI management
teams at University Hospitals Hairmyres and Wishaw.  Managers in PSSD have been
asked to circulate leaflets on whistleblowing for staff who do not have easy access to
email.   
The HR page on FirstPort includes information on whistleblowing, including details of
how to raise concerns via the uMatter email address.  Further communications have
been issued, including items in the staff briefing in September 2021 and January 2022,

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emails about the INWO webinars and a video recorded by the non-executive
whistleblowing champion.  This video appeared with links to social media and the INWO. 
Training on the Standards is available through TURAS via two modules and NES
provides monitoring information on the uptake of the training. To date the training module
for all staff has been completed by 151 people and the module for managers/people
receiving complaints has been completed by 52 people. It is acknowledged that the
numbers completing the training modules are lower than anticipated and directors have
now been contacted about this in a bid to increase the uptake of training. 
9. Confidential Contacts 
There are seven confidential contacts in NHS Lanarkshire, all of whom have completed
the training modules.  Their contact details are regularly publicised in briefings and in the
Pulse on line and they are also available on NHS Lanarkshire’s intranet.  Two of the
confidential contacts are designated for private contractors, including PFIs and one is
designated specifically for independent primary care contractors.  A network for the
confidential contacts has been established to enable them to meet with the Non-
Executive Whistleblowing Champion and the HR Director on a bi-annual basis.  They are
also encouraged to engage with the Scottish Speak Up Network. 
Priorities for 2022/23 
During 2022/23 it is intended to focus on the following areas: 
1. Continuing to publicise the Standards and ways to raise concerns.
2. Broadening awareness across independent primary care contractors and
encouraging more engagement with data reporting requirements.
3. Developing organisational culture to focus on values and behaviours, leadership
and management development, metrics and data and people processes.   The
work on people processes is yet to be scoped but may include capturing concerns
staff may have in relation to the workplace or services such as the use of
whistleblowing procedures.
4. Explore the possibility with the Scottish Government of including reference to
whistleblowing in iMatter or of developing another national survey which would
assist in gauging the level of awareness across the organisation.
5. Use the INWO’s Speak Up week in October to further promote and celebrate
speaking up. 
10. Conclusion 
The Board is asked to note the implementation update and the content of this
performance report and seek assurance that whistleblowing standards are being
followed and learning shared. 
Kay Sandilands
Director of Human Resources
July 2022