Public Interest Disclosure Management Plan 2018
Management of Public Interest Disclosures made under the Public Interest Disclosure Act 2010
This management plan has been prepared to comply with s.28 of the Public Interest Disclosure Act 2010 (the PID Act) and Public Interest Disclosure Standard No.1 (the Standard) issued by the Queensland Ombudsman under s.60 of the PID Act.
Under the PID Act, PIDs may be made by employees of a public sector entity and by members of the public. This PID Management Plan should be read in conjunction with the Queensland Ombudsman’s PID Procedure 2018.
Section 6.1.1 of the Standard requires the Queensland Ombudsman to develop, implement and maintain a management program for PIDs about the conduct of officers of the Office of Queensland Ombudsman (the Office) that addresses the following issues:
1. Organisational commitment to encourage internal reporting of wrongdoing
The Ombudsman and senior managers of the Office:
- recognise the important role disclosers play in identifying wrongdoing and thus improving the integrity and performance of the Office and deterring wrongdoing
- are committed to ensuring that PIDs are properly assessed, investigated and dealt with
- recognise the value and importance of providing protection to employees who report wrongdoing using appropriate internal or external channels
- are committed to ensuring that appropriate consideration is given to the interests of persons who are the subject of a PID.
The Ombudsman will take all reasonable steps to protect an employee from any detrimental action by way of a reprisal taken because they have made a PID.
The Office’s organisational commitment to ethical practices and to an effective PID Management Plan is explicitly stated in the Office’s Code of Conduct.
2. Senior management endorsement of the value of PIDs and the proper management of PIDs and disclosers
The Ombudsman and senior managers of the Office recognise that, in order for the Office to have a successful disclosure program, it is critical that managers commit to the implementation of the Office’s PID Management Plan, policies and procedures in relation to disclosures.
Senior managers of the Office encourage any employee who considers that they have witnessed wrongdoing to come forward and make a disclosure. Senior managers of the Office believe that disclosing wrongdoing is in accordance with the Office’s ethical culture, in particular, acting with integrity. It recognises the benefit to the Office of encouraging employees to report wrongdoing.
When employees come forward with information about wrongdoing, managers commit to:
- protecting the dignity, wellbeing, career interests and good name of all persons involved
- protecting the discloser from any adverse action taken as a result of making the disclosure
- dealing with any bullying, harassment, unfair treatment, victimisation or discrimination that results from a disclosure as a breach of the Office’s disciplinary procedures
- responding to the disclosure thoroughly and impartially
- taking appropriate action to deal with wrongdoing
- keeping the discloser informed of progress and the outcome.
Senior managers of the Office also recognise that members of the public may have information about the operations of the Office that meets the criteria for a PID. Members of the public are encouraged to report this information to the Deputy Ombudsman. A PID made by a member of the public will be acknowledged. The discloser will be informed about the outcome of the PID assessment and any action taken as a result of the disclosure.
3. A communication strategy for raising employee awareness about PIDs and the Office’s PID procedures
The Ombudsman recognises that critical to the success of its PID Management Plan is employee awareness of the plan and associated procedures. The Office’s communication strategy involves the following:
- periodically including, in the Office’s internal electronic newsletter, a message from the Ombudsman that reconfirms the Office’s commitment to the PID Act, as well as other information and reminders about the Office’s PID reporting system
- including a PID page on the Office’s intranet
- providing the contact details for the Office’s nominated PID officer in the Office’s internal phone list
- including information about PIDs in the Office’s induction program for new employees
- annual training for employees.
4. A training strategy for employees
The Ombudsman recognises the importance of educating employees on PID issues and ensuring that ongoing training is provided.
As part of the ethics and Code of Conduct training that every employee is required to attend annually, a segment on the operation of the PID Act will be included. This will be formalised in the Office’s training plan. The training will cover:
- how to identify wrongdoing
- how to make a PID
- the support and protection to be afforded to disclosers
- how PIDs will be managed by the Office.
In addition, senior managers of the Office will receive training annually on their obligations in relation to handling PIDs.
5. The appointment of a nominated officer responsible for issues related to the management of PIDs
The Deputy Ombudsman is the nominated officer responsible for issues related to the management of PIDs. The Deputy Ombudsman has:
- direct access to the Ombudsman in relation to PID matters
- delegated authority to appropriately manage PIDs
- access to resources to allow for the proper management of PIDs.
A member of the public or an employee of the Office can make a disclosure to the Deputy Ombudsman by way of:
Attn: PID Coordinator
GPO Box 3314
Brisbane Qld 4001
Phone: 3005 7000 (and ask to speak to the Deputy Ombudsman in their role as PID Coordinator)
6. Ensure that effective systems and procedures are in place for issues arising from PIDs to inform improvements to service delivery, business processes and internal controls
At the conclusion of a PID investigation, the Deputy Ombudsman is responsible for assessing whether any change is needed to the Office’s policies and procedures or internal controls. The Deputy Ombudsman will, within 60 days of the conclusion of the PID investigation, report to the Ombudsman with any recommendation for appropriate change.
7. Provide a mechanism for regular evaluation and monitoring of the effectiveness of PID policies and procedures
The Deputy Ombudsman, as the nominated officer responsible for issues related to the management of PIDs, will conduct an annual review of the effectiveness of the Office’s PID Management Plan and Procedure.