Responsible: Alan Swindell and Sven Saar
Approved March 2023
To be reviewed March 2026
Policy Rationale and Context.
Waldorf Modern Teacher Education (WMTE) wants to create an environment and culture that is open to criticism and committed to improvement, one in which concerns and complaints*, correctly handled, can make a valuable contribution.
We want to enable students, staff, clients and other stakeholders to raise concerns and make complaints, confident that they will be listened to carefully and responded to promptly, clearly and proportionately.
We want our complaints procedure to be simple, transparent and accountable. Above all, we want people raising concerns or complaints to feel that they have been listened to and that WMTE is always willing to learn.
*A concern is defined as ‘an expression of worry or doubt over an issue considered to be important for which reassurances are sought’.
A complaint is defined as ‘an expression of dissatisfaction however made, about actions taken or a lack of action’
To this end we will ensure that:
Level One: Informal concerns and complaints.
Many concerns and issues are best addressed informally, ideally face-to-face, but even informal solutions can benefit from a brief, written summary. A concluding exchange of emails agreeing on a shared outcome is considered best practice and can be referred to if the concern or issue re-emerge at some future date. Students, staff and other stakeholders should always feel free to raise concerns with an appropriate member of staff. All students have an appointed tutor, who is their usual first port-of-call for most issues, but students should always feel free to approach one of the other course tutors.
Level Two: Formal complaints
If a resolution has not been found via the informal route, you should talk to somebody within WMTE with whom you feel comfortable. Ideally this would be a Course Director, but you may prefer to approach a Core Tutor, or a member of the Community Interest Company or CIC, the body to which WMTE tutors and directors are accountable. Roles, responsibilities and contact details can be found in Appendix One.
You should outline the complaint you wish to make using the attached form (Appendix Two). The person you have approached will either investigate the complaint themselves or find somebody else within WMTE to be `the investigator`, someone who is in a position to do so objectively, having no prior involvement with the issue you are raising.
Please be aware that additional help or advice that may be available to you. For example, Community Legal Advice offers wide-ranging legal advice, and the Independent Complaints Advocacy Service (ICAS) provides advocacy for NHS complainants.
The investigator is expected to:
Level Three: Complaints Panel
If you are dissatisfied with the outcome at Stage 2 and wish to take the matter further, you can escalate the complaint to Stage 3 by requesting that the complaint be looked at again by a Complaints Panel.
The Panel will comprise a minimum of three people who were not directly involved in the matters detailed in the complaint and with one panel member who is independent of the management and running of WMTE. Depending on the context, the Panel may include any combination of: Course Director, Core Tutor, an advocate or speaking partner for you who has been approved by all parties and who may be internal or external to the course, an advocate for any tutor, student or stakeholder against whom a complaint has been made, a non-executive Member of the CIC, a secretary to take minutes.
The Panel will aim to convene a meeting within 15 working days of receipt of a Stage 2 request being referred to them for review. If this is not possible, the Panel will provide an anticipated date and keep you informed. If you reject the offer of three proposed dates, without good reason, the Panel will decide when to hold the meeting and may proceed in your absence and on the basis of any written submissions.
You may bring someone along to the panel meeting to provide support. This can be a relative or friend. Generally, we do not encourage either party to bring legal representatives to the committee meeting. However, there may be occasions when legal representation is appropriate. Representatives from the media are not permitted to attend.
Please be aware that most of our tutors are self-employed, i.e. not employed directly by WMTE. Whilst we remain responsible for their actions when carrying out paid work on behalf of WMTE, we have no wider legal jurisdiction. We do have a duty of care, however, and matters that raise Safeguarding Concerns will be addressed according to WMTE`s Safeguarding Policy.
At least 10 working days before the meeting, the Panel will:
The Panel will not normally accept, as evidence, recordings of conversations that were obtained covertly and without the informed consent of all parties being recorded.
The Panel will also not review any new complaints at this stage or consider evidence unrelated to the initial complaint.
Panel meeting will be held in private. Electronic recordings of meetings or conversations
are not normally permitted unless a complainant’s own disability or special needs
require it. Prior knowledge and consent of all parties attending must be sought before
meetings or conversations take place. Consent will be recorded in any minutes taken.
The Panel will consider the complaint and all the evidence presented.
The Panel can either uphold or dismiss the complaint in whole or in part.
The Panel will provide the complainant with a full explanation of their decision and the reason(s) for it, in writing, within 15 working days.
The response will detail any actions taken to investigate the complaint and provide a
full explanation of the decision made and the reason(s) for it. Where appropriate, it will
include details of actions WMTE will take to resolve the complaint.
The Panel will ensure that those findings and recommendations are sent by electronic
mail or otherwise given to you and, where relevant, the person complained about.
The response will also advise you of next steps.
A written record will be kept of all complaints, and of whether they are resolved at the
preliminary stage or proceed to a panel hearing, along with what actions have been
taken, regardless of the decision.
All correspondence, statements and records relating to individual complaints will be remain confidential.
If the complaint is upheld in whole or in part, the Panel`s recommendations can include any of the following:
If your concern is complex, or cannot be resolved in the ways described above, we can offer the services of independent mediators. Working in consultation with WMTE, the mediators aim to provide a secure, confidential process intended to assist good communication and to
help find appropriate resolution.
Mediation can take place when all those involved agree to it.
Mediators will not retain notes of matters discussed during the process of mediation,
except in the form of any agreed outcomes, which we do in order to ensure that these
can be followed up.
While we would not wish to put a fixed timescale to matters of concern, we would
normally expect any informal concerns to be resolved speedily. If mediation is used,
the entire process would normally be completed within 20 working days. You will be
consulted and your agreement sought for any extension.
Roles, responsibilities and contact details
Contact details for CIC members, Core Tutors and Executive Directors:
Paul White: email@example.com
Jenny Bolsius: firstname.lastname@example.org
Julia Allan: email@example.com
Jenny Wragg: firstname.lastname@example.org
Sven Saar: email@example.com
Alan Swindell: firstname.lastname@example.org
External / Independent:
Jill Tina Taplin, an independent outside adjudicator who is an experienced Teacher Education professional and a member of ASWTE: email@example.com
The Course Directors are individually and jointly responsible for the processes outlined in this policy.
Your relationship to WMTE
Please give details of your complaint, giving details of anyone within WMTE you have already spoken to.
What actions do you feel might resolve the problem at this stage?
Are you attaching any documents, if so, please give details.
Managing serial and unreasonable complaints
There will be occasions when despite all stages of the procedure having been followed,
the complainant remains dissatisfied. In such situations, the WMTE may inform the
complainant in writing that the procedure has been exhausted and that the matter is
WMTE is committed to dealing with all complaints fairly and impartially, and to providing a high-quality service to those who complain. We will not normally limit the contact complainants have with our WMTE. However, we do not expect our students or staff to tolerate unacceptable behaviour and will take action to protect students and staff from that behaviour, including that which is abusive, offensive or threatening.
WMTE defines unreasonable behaviour as that which hinders our consideration of complaints because of the frequency or nature of the complainant’s contact with the WMTE, such as, if the complainant:
• refuses to articulate their complaint or specify the grounds of a complaint or the
outcomes sought by raising the complaint, despite offers of assistance
• refuses to co-operate with the complaints investigation process
• refuses to accept that certain issues are not within the scope of the complaints
• insists on the complaint being dealt with in ways which are incompatible with the
complaints procedure or with good practice
• introduces trivial or irrelevant information which they expect to be taken into
account and commented on
• raises large numbers of detailed but unimportant questions, and insists they are
fully answered, often immediately and to their own timescales
• makes unjustified complaints about students or staff who are trying to deal with the issues,
and seeks to have them replaced
• changes the basis of the complaint as the investigation proceeds
• repeatedly makes the same complaint (despite previous investigations or
responses concluding that the complaint is groundless or has been addressed)
• refuses to accept the findings of the investigation into that complaint where the
WMTE’s complaint procedure has been fully and properly implemented and
Complainants should try to limit their communication with WMTE that relates to
their complaint, while the complaint is being progressed. It is not helpful if repeated
correspondence is sent (either by letter, phone, email or text), as it could delay the
outcome being reached.
When to stop responding
The decision to stop responding should never be taken lightly, but it may be necessary
in the following circumstances:
• WMTE has taken every reasonable step to address the complainant’s concerns
• the complainant has been given a clear statement of WMTE`s position and their options
• the complainant contacts WMTE repeatedly, making substantially the same points
The decision will be made in writing to the complainant.
In response to any serious incident of aggression or violence, we will immediately inform
the police and communicate our actions in writing.
Date: September 2021
Responsible: Course Leaders
Review Date: September 2024
WALDORF MODERN TEACHER EDUCATION (WMTE) intends to be a truly open, accessible and diverse organisation and is committed to the principle of equal opportunities in employment and education regardless of a person’s gender, race, sexual orientation, age, disability or religious belief or other specific factors which result in discrimination.
To achieve this we need to ensure that none of our policies and procedures places any unnecessary barriers for students or staff.
In the event that staff or students are alleged to be in breach of WMTE Equality and Diversity policy, an investigation will be carried out in accordance with agreed procedures. Depending on the outcome, guidance, advice, counselling and training may be offered to ensure compliance. A serious breach of the Equality and Diversity Policy and Procedure may constitute gross misconduct.
WMTE operates within a set of agreed equal opportunities definitions, which can be found as an Appendix to this Policy
WMTE will work actively to make progress in five key areas:
Eliminating any discrimination in relation to tutor or student recruitment and promotion, the purchase of goods and services, and in the content, delivery and management of the curriculum
WMTE will ensure that its equality and diversity policy is publicised as widely as possible to its community, including students, volunteers and staff.
Ensuring that all students, staff and visitors can go about their business in an atmosphere free of intimidation or abuse.
WMTE will review the effectiveness of procedures, so that staff and students feel confident to raise issues of concern about equal opportunities, and to make complaints about discrimination, harrassment or bullying.
Encouraging maximum access to the full range of educational provision of all social backgrounds and cultures.
This includes monitoring patterns of admissions and working to ensure that the admissions process is based only on student needs and aptitudes.
Providing support, wherever possible, to enable individual students of different abilities and needs to progress through the curriculum towards successful achievement.
WMTE will monitor and review the curriculum, and the learning resources used to deliver the curriculum, to ensure that they reflect and promote equal opportunities.
Recognising and reflecting the positive contributions of men and women of different social backgrounds, cultures, religions, abilities, ages and sexual orientation.
The Core Tutors are responsible for ensuring that a policy of equal opportunities is continuously promoted and comprehensively implemented in all aspects of WMTE practice.
The Policy reflects national legislation and guidelines as provided by The Equality Act 2010.
Procedural Monitoring and Evaluation
The Course Leaders will monitor and evaluate the success of this policy, ensuring that it is made available to all staff and students and that it is reviewed at the set review date.
Key performance indicators will include:
Date: March 2023
Responsible: Alan Swindell, Sven Saar (hereafter referred to as course directors)
Date for review: March 2025
Guidance for WMTE tutors and students
If someone discloses that they are experiencing harm, abuse or are feeling vulnerable to radicalisation, or if there are suspicions that someone is at risk of harm, abuse or radicalisation, consider the following guidance.
In the case of a direct disclosure, be supportive
Take what the child or adult says seriously
Promise to keep secrets
Reassure them that it was right to tell someone
Ask them to repeat the story
Explain what will happen next – that you will refer to the course directors
Express any of your own opinions
Write down word-for-word immediately afterwards what was said, including the time, place, and any other observations: sign and date this record
Discuss with anyone else what was told to you, other than with the Principal Safeguarding Officer and other relevant personnel
Pass the referral to the course directors
Start to investigate
Seek support for yourself from the course directors
Contact the alleged perpetrator or other people involved/mentioned
Ask the person to clarify anything you may have misunderstood
Ask closed questions or repeatedly question the individual
Responsible: Course Directors
Updated: March 2023
Next Review: September 2025
WMTE aims to ensure that all personal data collected about staff, students, guest tutors and other individuals is collected, stored and processed in accordance with the Data Protection Legislation which means the Data Protection Act 2018 (DPA2018), the United Kingdom General Data Protection Regulation (UK GDPR), the Privacy and Electronic Communications (EC Directive) Regulations 2003 and any legislation implemented in connection with the aforementioned legislation. Where data is processed by a controller or processor established in the European Union or comprises the data of people in the European Union, it also includes the EU General Data Protection Regulation (EU GDPR). This includes any replacement legislation coming into effect from time to time.
This policy applies to all personal data, regardless of whether it is in paper or electronic format.
This policy meets the requirements of the UK GDPR and the expected provisions of the DPA 2018. It is based on guidance published by the Information Commissioner’s Office (ICO) on the GDPR and the ICO’s code of practice for subject access requests.
It also reflects the ICO’s code of practice for the use of surveillance cameras and personal information.
Any information relating to an identified, or identifiable, individual.
This may include the individual’s:
· Name (including initials)
· Identification number
· Location data
· Online identifier, such as a username
It may also include factors specific to the individual’s physical, physiological, genetic, mental, economic, cultural or social identity.
Special categories of personal data
Personal data which is more sensitive and so needs more protection, including information about an individual’s:
· Racial or ethnic origin
· Political opinions
· Religious or philosophical beliefs
· Trade union membership
· Biometrics (such as fingerprints, retina and iris patterns), where used for identification purposes
· Health – physical or mental
· Sex life or sexual orientation
Anything done to personal data, such as collecting, recording, organising, structuring, storing, adapting, altering, retrieving, using, disseminating, erasing or destroying.
Processing can be automated or manual.
The identified or identifiable individual whose personal data is held or processed.
A person or organisation that determines the purposes and the means of processing of personal data.
A person or other body, other than an employee of the data controller, who processes personal data on behalf of the data controller.
Personal data breach
A breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data.
WMTE processes personal data relating to students, staff, guest tutors and others, and therefore is a data controller.
This policy applies to all staff employed by WMTE, and to external organisations or individuals working on our behalf. Staff who do not comply with this policy may face disciplinary action.
The CIC members have overall responsibility for ensuring that WMTE complies with all relevant data protection obligations.
The course directors (CD) are individually and jointly responsible for overseeing the implementation of this policy, monitoring our compliance with data protection law, and developing related policies and guidelines where applicable. They may delegate the management of specific processes to administration staff.
They are contactable via email: firstname.lastname@example.org
are responsible for:
The GDPR is based on data protection principles that WMTE must comply with. The principles say that personal data must be:
This policy sets out how WMTE aims to comply with these principles.
We will only process personal data where we have one of 6 ‘lawful bases’ (legal reasons) to do so under data protection law:
protect someone’s life
For special categories of personal data, we will also meet one of the special category conditions for processing which are set out in the UK GDPR and Data Protection Act 2018.
We will only collect personal data for specified, explicit and legitimate reasons. We will explain these reasons to the individuals when we first collect their data.
If we want to use personal data for reasons other than those given when we first obtained it, we will inform the individuals concerned before we do so, and seek consent where necessary.
Staff and guest tutors must only process personal data where it is necessary in order to do their jobs.
When staff no longer need the personal data they hold, they must ensure it is deleted or anonymised.
We will not normally share personal data with anyone else, but may do so where:
We will also share personal data with law enforcement and government bodies where we are legally required to do so, including for:
We may also share personal data with emergency services and local authorities to help them to respond to an emergency situation that affects any of our students or staff.
Where we transfer personal data to a country or territory outside the European Economic Area, we will do so in accordance with data protection law.
Individuals have a right to make a ‘subject access request’ to gain access to personal information that WMTE holds about them. This includes:
Subject access requests can be submitted verbally, in writing, either by letter, email to email@example.com
They should include:
When responding to requests, we:
We will not disclose information if it:
would not be in the student’s best interests
If the request is unfounded or excessive, we may refuse to act on it, or charge a reasonable fee which takes into account administrative costs.
A request will be deemed to be unfounded or excessive if it is repetitive, or asks for further copies of the same information.
When we refuse a request, we will tell the individual why, and tell them they have the right to complain to CIC, using the terms set out in our complaints procedure.
In addition to the right to make a subject access request (see above), and to receive information when we are collecting their data about how we use and process it (see section 7), individuals also have the right to:
Individuals should submit any request to exercise these rights to the CD.
As part of WMTE activities, and for the purpose of publicity and assessment, we may take photographs and record images of individuals.
The consent to the use of these images for publicity purposes is assumed upon entry to the course but can be withdrawn at any time, without stating reasons.
When using photographs and videos in this way we will not accompany them with any other personal information about the student.
We will protect personal data and keep it safe from unauthorised or unlawful access, alteration, processing or disclosure, and against accidental or unlawful loss, destruction or damage.
Personal data that is no longer needed will be disposed of securely. Personal data that has become inaccurate or out of date will also be disposed of securely, where we cannot or do not need to rectify or update it.
For example, we will shred or incinerate paper-based records, and overwrite or delete electronic files. We may also use a third party to safely dispose of records on WMTE’s behalf. If we do so,
we will require the third party to provide sufficient guarantees that it complies with data protection law.
WMTE will make all reasonable endeavours to ensure that there are no personal data breaches. Such breaches in a HE context may include, but are not limited to:
Data protection will form part of continuing professional development, where changes to legislation, guidance or WMTE’s processes make it necessary.
CD are responsible for monitoring and reviewing this policy.
All WMTE tutors and staff have some responsibility for their own health and safety as well as that of students and guests and have been requested to read this document in full and inform the Health and Safety Officers of any activities, events, circumstances or particular hazards of which they should be aware under the Health and Safety Acts and Regulations.
The Health and Safety at Work Act 1974 and the Workplace (Health, Safety and Welfare) Regulations 1999 and their associated Approved Code of Practice (ACoP) and guidance, including hygiene requirements, will be complied with at all times.
WMTE students should be able to experience a wide range of activities. Health and safety measures should help them to do this safely, not stop them. We aim to provide a safe learning and working environment for them by ensuring as far as is reasonably practicable that premises and grounds are maintained in a safe condition and provided with safe means of access and egress.
Common sense is used in assessing and managing the risks of any activity. Our health and safety procedures aim to be proportionate to the risks of an activity.
We will endeavour to:
At any time at least one member of staff or a designated student on the premises must have up to date first aid training. Training is provided regularly to ensure enough staff remain qualified at all times.
A student or tutor who is obviously unwell on arrival or who presents symptoms of a contagious disease should not be admitted to the school.
In the event of an accident or sudden illness, the responsible person will:
Updated: March 2023
Responsible: Course Directors
Review Date: September 2025
This policy applies to all WMTE employees, guest tutors and CIC members.
It is important that any fraud, misconduct or wrongdoing by employees or CIC members is reported and properly dealt with. The members will, therefore, respond to all individuals who raise any genuine concerns that they may have about the conduct of others in the school, which are in the public interest. This policy sets out the way in which individuals may raise any concerns that they have and how those concerns will be dealt with.
WMTE expects the highest standards of conduct from all employees and trustees and will treat seriously any concern raised about illegal or improper conduct.
Any matter raised under this procedure will be investigated thoroughly, promptly and confidentially, and the outcome of the investigation reported back to the employee who raised the issue.
No employee will be victimised for raising a matter under this procedure. This means that the continued employment and opportunities for future promotion or training of the employee will not be prejudiced because he/she has raised a legitimate concern.
Victimisation of a worker for raising a qualified disclosure will be a disciplinary offence.
If misconduct is discovered as a result of any investigation under this procedure the matter will be considered under the disciplinary procedure, in addition to any appropriate external measures.
Maliciously making a false allegation is a disciplinary offence.
An instruction to cover up wrongdoing is in itself a disciplinary offence. If told not to raise or pursue any concern, even by a person in authority, employees should not agree to remain silent.
The law provides protection for employees who raise legitimate concerns about specified matters. These are called ‘qualifying disclosures’. A qualifying disclosure is one made in the public interest by the employee who has a reasonable belief that any of the following:
are being, have been, or are likely to be, committed. It is not necessary for the employee to have proof that such an act is being, has been, or is likely to be committed, a reasonable belief is sufficient. The employee has no responsibility for investigating the matter; it is WMTE’s responsibility to ensure that an investigation takes place
Where the concerns are about safeguarding children or young people, the Course Directors or CIC members should be notified. Having been notified, they will be expected to act swiftly and constructively in the investigation of any concerns.
4 When should it be used?
This procedure is for disclosures about matters other than a breach of a contract of tuition or employment.
Where a disclosure is merely an expression of opinion that fails to show that a legal obligation has been or is likely to be breached, it cannot amount to a protected or qualifying disclosure for the purposes of the whistle blowing legislation.
This procedure is not designed to replace or be used as an alternative to the complaints procedure, which should be used where a student or employee is aggrieved about their own situation. Nor should this policy apply where the employee, tutor or student simply disagrees with the way WMTE is run.
People choosing to take action under this procedure must have reasonable grounds for believing the information they have is accurate and not just gossip or rumour.
Any employee employee who makes a protected disclosure has the right not to be dismissed, subject to any other detriment, or victimised, because they have made a disclosure, provided it has not been made maliciously. Any employee who uses this procedure will not be penalised for doing so. WMTE will not tolerate harassment and/or victimisation of any employee raising concerns.
An employee who is not sure whether the conduct they are concerned about does constitute illegal or improper conduct or is unsure about how to proceed may contact the Course Directors or CIC members.
Any suspicion of fraud, corruption or other financial irregularity should be reported to the non-executice CIC members for possible investigation. They are:
Paul White: firstname.lastname@example.org
Jenny Bolsius: email@example.com
Julia Allan: firstname.lastname@example.org
In the first instance, unless the employee reasonably believes a course director to be involved in the wrongdoing, any concerns should be raised with the course directors. If they believe the course director to be involved, then the employee should report straight to a non-executive CIC member (see above).
The investigation may involve the employee and others involved giving written statements. Any investigation will be carried out in accordance with the principles set out above. The employee’s statement will be taken into account and they will be asked to comment on any additional evidence obtained.
Employees who want to use the procedure but feel uneasy about it may wish to consult their Professional Association/Trade Union initially and bring a colleague or Professional Association/Trade Union Representative along to any discussions, so long as the third party is not involved in the issue.
Where anonymity is requested efforts will be made to meet the request where appropriate but that might not always be possible. The earlier and more open the expression of concern the easier it will be to take appropriate action.
The course directors (or the person who carried out the investigation) will then report to the CIC members who will take the necessary action, including reporting the matter to any appropriate department or regulatory agency. If disciplinary action is required this will be taken forward by the CIC members. On conclusion of any investigation the employee will be told the outcome of the investigation and what the next steps will be. If no action is to be taken the reason for this will be explained.
If the employee is concerned that the CIC members are involved in the wrongdoing, have failed to make a proper investigation or have failed to report the outcome of the investigation, they have the option of contacting one of the following:
6 Safeguarding students and vulnerable adults
All employees have a duty to report concerns about the safety and welfare of students. They may be the first to recognise that something is wrong but may not feel able to express their concerns out of fear that this would be disloyal to colleagues, or fear harassment or victimisation. These feelings, however, must never result in a student continuing to be at risk. The safety of students should always be a primary concern for WMTE staff and guest tutors.
Concerns about any of the following should be reported to the course directors:
7 The Law Relating To This Document
Employment Rights Act 1996
Public Interest Disclosures Act 1998
The legislation protecting individuals who makes a protected disclosure applies not only to employees, but also to any person who undertakes to do or perform personally (or otherwise) any work or service for the employer, regardless of the nature of the contractual relationship between them.
A Whistleblowing Policy should establish the procedure for an employee to follow if they have a genuine concern about a colleague’s conduct or the organisation’s practices. The Whistleblowing Policy should make clear what sort of allegations will count as a protected disclosure and should allow for the employee to raise these concerns with a nominated person and set out the steps that the employer will take in response.
A qualifying disclosure means any disclosure of information that in the reasonable belief of the worker is made in the public interest. The requirement that a whistleblower make a qualifying disclosure ‘in good faith’ has been removed. Therefore, while the employer can seek a declaration from the whistleblower that he or she is not knowingly making a false allegations, disciplinary action is likely to be appropriate only where there is clear evidence that the employee has misused the whistle blowing procedure. A consequence of the requirement that a disclosure be made in the public interest is that an employee will generally be precluded from being able to ‘blow the whistle’ about breaches of his or her employment contract.
Section 43J of the Employment Rights Act 1996 provides that a Settlement Agreement made between an employee and employer cannot prevent future protected disclosures.
Any confidentiality obligations in contracts of employment that would prevent an employee making a protected disclosure will be void.
Where a staff member feels unable to raise an issue with their employer or feels that their genuine concerns are not being addressed, other whistleblowing channels may be open to them: