The Procedures below have been organized under the following headings:

1. Confidentiality
2. Steps to Report Wrongdoing
3. Protection from Reprisal or Retaliation

A.  Confidentiality

1. Reports of wrongdoing will be date stamped when received and maintained in separate files. Such files will be treated as strictly confidential, and will be secured and protected from unauthorized access in a location within the People Services Department.
2. The College will make every effort to protect the confidentiality of the process to the extent necessary to conduct an investigation, subject to exceptions authorized or required by law. While every effort will be made to respect the confidentiality of College members, no guarantee of confidentiality can be made given the need to conduct an adequate investigation.
3. All College members are required to refrain from communicating any information received during the course of an investigation and to maintain the confidentiality of the process. Any person breaching confidentiality may be subject to disciplinary action, up to and including expulsion or dismissal from the College.
4. Detailed results of an investigation will not be disclosed or discussed with anyone other than those who have a legitimate need to know.
5. There may be positions (e.g. registered nurse, counsellor, physician) whose professional codes of conduct impose a high degree of confidentiality pertaining to disclosures of wrongdoing made to them in their professional capacities. Such codes or professional standards are subject to common law and statutory exceptions, which may include, but are not limited to the mandatory reporting of child abuse, reporting of risk of serious harm to oneself or others, and when disclosure is required or authorized by law. College members working in these capacities who learn of wrongdoing must, without delay, consult with their supervisor and/or professional association to determine their responsibility to ensure compliance with this Policy, to the extent permissible.

B.  Steps to Report Wrongdoing

6. Reports of suspected wrongdoing must be in writing and include: the name of the College member reporting the wrongdoing, a description of the wrongdoing, the name of the person(s) alleged to have committed or about to commit the wrongdoing; the date(s) of wrongdoing; whether the wrongdoing has previously been disclosed and, if so, to whom, and the response received.

Note: If the report is anonymous allegations will only be acted upon if evidenced collected during the preliminary investigation indicated the disclosure can be adequately investigated and is in the public interest.

7. Reports must be submitted to the Vice President, People Services(henceforth referred to as the Vice President).
8. In the event the alleged wrongdoing involves the Vice President, the Vice President, Administration and International Development, will assume the functions of the Vice President.
9. Upon receipt of a report of wrongdoing, the Vice President will maintain and update a log of the report, ensure that the matter is reviewed promptly and properly, and ensure appropriate action is taken, if warranted.
10. The Vice President will work with the VCC Leadership Team member within whose area of responsibility the matter falls.
11. When the matter involves a VCC Leadership Team member, the Vice President  will work with the President.
12. If the matter involves the President, the Chair of the Board will assume the functions of the VCC Leadership Team member.
13. If the matter to be investigated involves an employee, it will be dealt with in compliance with the relevant terms of the applicable collective agreement and/or College human resources practices.
14. The Vice President  will initiate an investigation of the reported allegation involving, where necessary and on a confidential basis, other individuals within or outside the College with expertise in the substance of the allegation.
15. The Vice President  will determine whether or not the allegation has merit and falls within the jurisdiction of the College and, therefore, warrants action on the part of the College. If the issue falls outside of the jurisdiction of the College and under the jurisdiction of another body, the matter may be referred to that body.
16. If the Vice President  determines that action is required on the part of the College, then they will consult with the College official empowered to take further action. The two parties will agree on the appropriate action to be taken and the College official empowered to take action will proceed to take action.
17. The Vice President  will update the appropriate files and report the outcome of the investigation to the Vice President, Administration and International Development.

C.  Protection from Reprisal or Retaliation

18. College members acting in good faith are protected from retaliation or reprisals for making a report in accordance with this Policy and Procedures.
19. Any acts of retaliation or reprisal against a College member will be dealt with appropriately in accordance with the terms of the applicable College policies, collective agreement and/or VCC’s People Services practices.
20. If an investigation concludes that a College member has made a bad faith report of wrongdoing, they will be dealt with in accordance with College policies, VCC’s People Services practices and/or the terms of the applicable collective agreement.