Safe Disclosure Policy
|Ref. No.||Executive sponsor||Policy steward||Approval authority||First approved||Last reviewed||Effective date||Next review|
|42.31||Vice President, College Services and CFO||Director, Organizational Development||Executive Council||Mar. 2015||Oct. 19, 2021||Mar. 20, 2021||Mar. 2026|
- Nova Scotia Community College’s Mission of building Nova Scotia’s economy and quality of life through education and innovation is pursued in part through the values of integrity and public accountability. These values require openness and accountability to ensure the effective stewardship of NSCC’s resources, processes and environment.
- The purpose of this policy is to promote the disclosure of improper activity in order to positively impact the reputation, effectiveness, finances and working environment of the College.
- This Policy is directed at the public interest in avoiding Improper Activity and is not intended to resolve employee or student grievances and related complaints that are normally addressed by NSCC's academic and administrative policies or collective agreements. Similarly, this Policy is not intended to replace or supersede any existing NSCC policies.
- This policy applies to all members of the NSCC Community.
- This Policy applies to any behaviour that is connected to and/or may impact the work and services of the College, the work of College employees or the Mission and/or reputation of the College. It applies to behaviour taking place in any physical or electronic sites.
|Discloser||Any member of the NSCC community who makes a report under this policy based on information that they reasonably believe could show that an Improper Activity has been committed or is about to be committed.|
|Good Faith||Refers to the concept of being sincere and without a desire to defraud, deceive, take undo advantage, or in any way act maliciously.|
|Improper Activity||Conduct which includes one or more of Official Misconduct, Maladministration, significant misuse of public resources, or creation of a significant danger to public health or safety. This includes directing or counselling someone to engage in Improper Activity. Improper Activity does not include decisions of policy, business or administration, about which reasonable people might disagree.|
|Investigator||The person or persons charged with conducting the investigation of a Disclosure, namely the Director of Organizational Development, the Director of Internal Audit or their respective designate.
|Maladministration||Failure to act, or conduct intended to cover up an act, in a way that is unlawful, unjust, discriminatory or improper, and which adversely impacts someone's interests in a substantial and specific way, or adversely impacts the brand and reputation of the College.|
|NSCC Community||NSCC community member under this policy, includes but is not limited to the following:
Employee: any person who is employed by NSCC or provides services to
NSCC under an employment contract;
Student: anyone applying to or registered in NSCC programs or
otherwise participating in NSCC courses, programs, events, and
Volunteer: any person performing work for NSCC in an unpaid capacity;
Contractor: any individual or company (and its employees) who provides
services to NSCC under a service contract (i.e., a non-employee employer relationship);
NSCC Community Member: any person working in collaboration with
NSCC for a business or academic purpose or an external community
member, including all graduates and alumni of NSCC;
NSCC Board of Governors: the governing body of the College.
|Official Misconduct||Wrongdoing by a member of NSCC community in carrying out their duties or exercising their authority that may be a criminal offence or is otherwise serious enough that it may justify dismissal if proven. Examples include dishonesty, theft, lack of impartiality when awarding or expending College resources, breach of trust placed in a person by virtue of their position, or misuse of officially obtained information.|
|Protected Disclosure||A disclosure which is made in the good faith belief that it falls within the scope of this Policy.|
|Reprisal||Any retaliatory action or measure taken by a member of the NSCC community against a Discloser that adversely impacts their employment, status or wellbeing, if that action is connected to a Disclosure or was intended to prevent a Disclosure. Examples include: intimidation, harassment, discrimination, threats, etc.|
|Respondent||Any member of the NSCC community alleged to have engaged in an Improper Activity under this Policy.|
|Witness||A person who has information about any alleged Improper Activity.|
NSCC is committed to:
- Promoting the disclosure of improper activity within NSCC, in order to positively impact the reputation, effectiveness, finances and working environment of NSCC.
- Protecting any person who discloses improper activity in good faith from retaliatory action.
- Responding to all Disclosures of improper activity thoroughly, impartially and on a timely basis.
- Providing collaborative, efficient, clear and timely mechanisms and approaches for dealing with Disclosures that arise out of this Policy.
- Protect the dignity, wellbeing, career interests and reputation of all parties involved.
- Taking appropriate action where evidence of improper activity has been found.
- Roles and Responsibilities
- All Members of the NSCC community are responsible for disclosing improper activity in good faith.
- The Board of Governors is responsible for fostering a culture of integrity.
- The President is accountable for oversight of the policy.
- The President and Executive Team are responsible for fostering a culture of integrity and effective stewardship of the public trust.
- The Director, Organizational Development, is responsible for the oversight and application of the Policy and the coordination of NSCC’s response to disclosed information. This includes:
- Ensuring disclosed information is reviewed and investigated in a fair, efficient and transparent manner.
- Maintaining confidential records of Disclosures and responses.
- Developing and implementing procedures and communications to ensure effective administration of the Policy.
- The Director of Internal Audit is responsible for the oversight and application of the Policy and the coordination of NSCC's response to disclosed information in cases where the Director of Organizational Development or a member of Organizational Development is a Respondent.
- NSCC Leaders (AVPs, Principals, Deans, Academic Chairs, Directors and Managers) are responsible for providing advice on policy provisions, receiving disclosures, and addressing and providing assistance in the College review and response to disclosed information.
- It is the responsibility of every Employee to be familiar with and to comply with the provisions of this Policy. This includes adhering to confidentiality obligations and participating in any Procedures taken under this Policy.
- Policy Supports