26-27/014

We refer to your request for information (FOI 26-27/014) dated 01 July 2026 which we have handled under the Freedom of Information (Scotland) Act 2002 (FOISA).

You asked

1. “How many incidences of whistleblowing has GTCS recorded in each of the last five financial years (please break down by year, 2021/22,2022/23, 2023/24,2024/25,2025/26)?
2. Does your whistleblowing policy encourage or direct whistleblowers to raise concerns with a "prescribed person" (as defined under the Public Interest Disclosure Act 1998)? If so, please specify which prescribed person(s) are referenced.
3. Does your whistleblowing policy or process guarantee anonymity to individuals who raise a concern? If so, please provide a copy of the relevant section of the policy addressing this.
4. Does your whistleblowing policy include a non-recrimination or non-retaliation provision, protecting whistleblowers from detriment or reprisal as a result of raising a concern? If so, please provide a copy of the relevant section of the policy addressing this.
5. Has your internal whistleblowing policy been subject to any external review, audit, or assessment (by an external body, auditor, regulator, or independent consultant) within the last five years? If so, please provide:
   
   • the name of the body/organisation that conducted the review;
   • the date of the review; and
   • a copy of any resulting report or summary of findings, subject to any applicable exemptions.”

Our response

Please see our response to your queries below.

The number of incidences of whistleblowing recorded in each of the last five financial years.

Please see this information in Table 1 below. Please note this is based on our registration year which runs from the beginning of April to the end of the following March.

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Whether the whistleblowing policy encourages or directs whistleblowers to raise concerns with a "prescribed person" as under the Public Interest Disclosure Act.

Yes. Our policy advises individuals of their right to raise the matter with a prescribed person or body, if internal channels have been exhausted or if the individual has reasonable belief that no action will be taken if they raise the matter internally. The policy provides a link to the Schedule of Prescribed People and Bodies and tells the individual to contact the most appropriate person or listed body, depending on the issue they are raising.

Whether the whistleblowing policy guarantees anonymity to individuals who raise a concern? If so, please provide a copy of the relevant section addressing this.

Yes, please relevant section below:

“You can make the claim anonymously but we may not be able to take the matter further if you haven’t provided sufficient information to investigate. We understand that ‘blowing the whistle’ is a sensitive matter and therefore you can provide your details but request confidentiality, in which case we will make every effort to protect your identity.”

Does your whistleblowing policy include a non-recrimination or non-retaliation provision, protecting whistleblowers from detriment or reprisal as a result of raising a concern? If so, please provide a copy of the relevant section of the policy addressing this.

Yes, please relevant section below:

“GTC Scotland is committed to enabling employees to raise genuine concerns in a safe environment. You will not be at risk of losing your job or suffering any personal detriment as a result of raising a concern provided you have acted in good faith.”‍

‍Has your internal whistleblowing policy been subject to any external review, audit, or assessment (by an external body, auditor, regulator, or independent consultant) within the last five years?

No.

Right to review and appeal

You may request a review of how we have dealt with this information request if you are dissatisfied with this response. This can be done by contacting us at informationgovernance@gtcs.org.uk, describing your original request and explaining the basis for your dissatisfaction. You have 40 working days from receipt of this response to submit a review request.

Once the review process has been completed, if you are still dissatisfied, you have six months in which you can apply to the Scottish Information Commissioner for a decision. See the Scottish Information Commissioner’s guidance on making an appeal for information about how to do this.