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INWO update

The go-live date for the implementation of the National Whistleblowing Standards and the full Independent National Whistleblowing Officer (INWO) service will be 1 April 2021. Read more

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The following information is shared to prepare for implementation of the National Whistleblowing Standards by 1 April 2021.

Arrangements for students and trainees

Student and trainee access to the Standards and the Independent National Whistleblowing Officer (INWO)

Students, trainees, and anyone on apprenticeships and internships working and/or studying within NHS services must have access to these Standards for raising concerns about NHS service delivery.  They must be able speak out by raising concerns over patient safety or malpractice, and they must have access to the support they need to do so.

Students and trainees are often at specific risk of detriment during placements, as they will be relying on managers and mentors for assessment and grading.  They may be deterred from raising concerns if they feel this would impact on their marks, and this concern must be taken into consideration when responding to concerns raised by students.

During their training, most students will be informed of what whistleblowing means and how raising concerns provides an important mechanism for service improvements.  Some will also be informed of the duty they will have to raise concerns, once they are registered professionals.  Their confidence in putting this into practice will vary, depending on a range of factors, including their previous placements and the culture they experience around them where they are working.


Students raising concerns within NHS services

Students and trainees working in an NHS setting should be encouraged to participate fully in the organisation’s learning culture and should be encouraged to use the systems available to all regular members of staff to raise concerns. 

They must have access to information and advice from all the same sources as other staff within the service, including:

  • National Alert Line – 0800 008 6112 or alertline@protect-advice.org.uk;
  • the board’s confidential contact for raising concerns, or other confidential speak up contact;
  • the INWO
  • union representatives
  • professional bodies
  • university representatives (for students)
  • NHS Education Scotland (for trainee doctors and dentists).

They must also be able to raise concerns with:

  • a service manager or team leader
  • a more senior manager if circumstances mean this is more appropriate 
  • a university representative (see below for details)
  • a confidential contact for raising concerns (in some places there may also be speak up ambassadors or advocates).

All NHS boards and service providers must be open to receiving concerns either directly from a student, or through a representative from their course, and must ensure that these concerns are responded to in line with the Standards. 

Students may have concerns that relate to the way their course has been managed or how their placement fits into their wider studies.  Concerns such as these, that relate to their course rather than the delivery of NHS services, should be directed to the complaints procedure in their higher education institution (HEI).  Concerns about NHS services should always be referred to the NHS for consideration, either by the student or via their course advocate, as detailed below. 

(Staff that have NHS as well as teaching responsibilities should raise their concerns through the NHS procedure, as this will provide protection through the Standards.  See our guidance on Governance: NHS board and staff responsibilities for further information.)

In addition to the routes normally available to staff, students can also raise their concerns with a representative on their course.  It may be that information and advice is enough for the student to then raise the concern within the service.  However, if this is not felt appropriate in the circumstances, or if the student does not feel confident that this would achieve the right outcomes for them, they must be able to raise their concern through their course representative or ‘course advocate’.

Each course that provides placements, traineeships or work experience in NHS services must have a named person (such as the course coordinator), who can act as an advocate, and take the concern to the board or primary care service on their behalf.  This person must be fully aware of these Standards, what students can expect when they raise a concern, and who to contact in each of the boards where their students work, in case any concerns are raised.

The course advocate must provide information and advice to students, and discuss the implications of raising the concern either directly or through the advocate.  This discussion must include:

  • consideration of confidentiality issues
  • support available to the student and how to access it
  • details of the procedure and what to expect.

If a student chooses to, they can use the course advocate to raise the concern on their behalf, and can choose whether they then remain anonymous to the board or service provider.  If they choose to be anonymous, all communication must go through the course advocate.  This includes enquiries for further information, updates and a final response at the end of the process.

Trainees that are under a direct contract with NHS Education Scotland (NES) can choose to raise their concern directly with the NHS board they are working for, or through NES, with NES acting in the same way as an HEI,  Trainees must be informed of who they can contact within NES if they want to raise a concern or would like advice or support in raising a concern.

Student concerns should be recorded in the same way as any other concerns.  The detailed information about recording concerns is also applicable to student concerns.

For concerns that are raised by a course advocate rather than by the student, the record should indicate the role of the person bringing the concern, as well as their full contact details, and information about the concern being raised. The name, contact details or any other personal details (including course details) of the student must not be recorded, as this could put them at risk of detriment.

Students raising concerns must have access to the same support as staff do in relation to raising concerns. Their course advocate will be able to provide some support in person.  The advocate will also be expected to be able to advise on support options provided by the board or service provider.  This may, on occasion, mean making special arrangements to ensure access, for example, to counselling which would normally be provided through an employee assistance scheme.

The final decision provided by the NHS service on any concern raised with them must include signposting to the INWO.  This applies equally to student concerns, and , where appropriate, course advocates must take responsibility for passing on this information to the students concerned. 


Updated: January 17, 2020