Freedom to Speak Up Guardian

Pharmacy whistleblowing policies to be updated by September 2017

In November 2016, NHS England published Freedom to speak up in Primary Care – guidance to primary care providers on supporting whistleblowing in the NHS. The guidance is for all providers of NHS primary care services including community pharmacies. It details the principles and actions to apply in primary care to support the raising of concerns by staff about the delivery of primary care services to patients and the management of the matter raised.

The key points for primary care were:

  1. All NHS staff working in primary care should be encouraged to raise a concern, at the earliest opportunity;
  2. NHS primary care providers should be proactive in preventing any inappropriate behaviour, such as bullying or harassment, towards staff who raise a concern;
  3. Each NHS primary care provider should review and update their local policies and procedures by September 2017, so that they align with this guidance;
  4. Each NHS primary care provider should name an individual who is independent of the line management chain and is not the direct employer as the Freedom to Speak Up Guardian, who can ensure that policies are in place and that staff know who to contact if they have a concern.
  5. NHS primary care organisations should build on the work of Being Open by adopting the good practice published in Freedom to Speak Up. NHS England will provide easy access to learning resources and will support a network of Freedom to Speak Up Guardians in primary care.

Contractors should already have a whistleblowing policy (to comply with the Terms of Service) and, therefore, to comply with these new requirements, before the end of September they should (if they have not already):

  1. Review their whistleblowing policies and ensure that the culture of the organisation encourages concerns to be raised and take steps to ensure there is no inappropriate behaviour to somebody who raises a concern; (there is a ‘draft whistleblowing policy at annex A of Freedom to speak up in Primary Care if required)


  1. Nominate a ‘Freedom to Speak Up Guardian.

Nominating a Freedom to Speak Up Guardian

The Devon LPC has agreed to nominate the Chief Officer as the Freedom to Speak up Guardian for independent contractors in its area.  The role will include:

  1. At their request, provide independent and impartial advice to the contractor’s staff on potential whistleblowing issues such as:
  • Poor clinical practice or other malpractice which may harm patients;
  • Failure to safeguard patients;
  • Maladministration of medications or dispensing errors;
  • Untrained or poorly trained staff;
  • Lack of policies creating a risk of harm;

(noting that the first line of advice should be within the contractor)

  1. Access and authority to speak to anybody within the contractor’s organisation; and,
  2. Authority to report a concern externally, if required in accordance with professional standards.

A template to cover nomination for Devon can be viewed here.

For further information, see the PSNC dedicated whistleblowing webpage at: