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Public Interest Disclosure-Protected Disclosures

Sometimes known as whistle-blowing. Most major companies and Public Authorities have policies in place to regulate such disclosures and it is important, before making any Disclosures , or potential disclosures,  that the policy is studied. A detriment suffered by making a disclosure is likely to be much more significant if the person making the disclosure does so under the employer's policy.

Before making any Disclosure the facts should be carefully checked, in so far as possible , given that in some cases , perhaps many cases , there is no open evidence of wrong-doing. Disclosures must have some basis in reasonable fact and should not be used simply to gain some tactical advantage over the employer , for instance as commonly occurs , in response to some disciplinary sanction or dispute, without there  being some real basis for making the disclosure.

The alleged wrong-doing may not actually be occurring, however protection is afforded to the Disclosure if is made in good faith. The burden to show good faith increases if complaints are made outside the organisation.

Detriments caused by Protected Disclosures are classed as discrimination and additional awards can be made against an employer.

 

 

Employees, workers and Contracts of Employment.

The determination of who is , or who is not an employee involves considerable enquiry but there are some simplifications. Most people understand from their own experience how employers behave and so a simple question would be to ask by how much does my "employer" act as a normal employer. For instance:

Factors tending towards employment

- does he provide all the tools and equipment needed,

- does he provide training at his expense,

- does he apply disciplinary sanctions,

- does he provide transport to and from sites.

- does the employee in any way represent the company.

Points tending against employment :

- worker is able to nominate replacements

-worker registered for VAT on his own account.

-worker holds SE6 or other tax certificate which prevents the  employer deducting basic rate tax.

-worker carries out work for others.

-worker is in some other business "on his own account"

-worker can chose when he can work and when not.

-worker provides a substantial part of the equipment needed.

None of the above are exhaustive nor determinative in the sense that the presence or absent of one or another makes or breaks employment , rather all have to be considered together to form a ( horrible word) a "holistic" view of the relationship. Only then can its true nature be ascertained. There are many more examples for and against employment - each case will depend on its own specific facts.

                                                            


 

        Fair Employment Law
 
 
Public Interest Disclosure-Protected Disclosures

Forming The Complaint.

A protected Disclosure occurs if an employee makes a disclosure to his employer , a prescribed person , a Minister of the Crown(i.e a Government Body)  or any other responsible person (with certain limitations), of a matter which the employee reasonably  believes would indicate criminal behaviour or offences are being committed, legal duties and obligations are being avoided, miscarriages of justice are occurring,  Health and Safety is being compromised or that the environment is being damaged (s.43B Employment Rights Act ). Note that there must be some  "Public Interest" - a complaint by an employee that he or she , rather than others, is suffering some detriment remains merely a grievance and the employee must have a reasonable genuine belief that what he discloses is actually occurring, whether or not it  actually is occurring.

Likely defences are that the employee had no reasonable belief, that is to say the disclosure was made on flimsy or unsustainable grounds, the  employee had some financial or material motive in making the claim or simply that there was no genuine belief , reasonable or otherwise or that the Disclosure is made in a manner contrary to the Regulations, that is to say to a person who does not constitute a relevant person for the purposes of the Act. See s.43G & s. 43H .

 

 

Employees, workers and Contracts of Employment.

A number of people at work might be surprised to learn that although they think they are self -employed,  they are more accurately described as being "self taxed" and are in fact subject to a contract of employment and have the right not to be Unfairly Dismissed. Her Majesties Inland Revenue have intervened in many cases to direct employers to class workers in certain industries as employees, but old practices die hard , in particular when the "worker" recognises and enjoys the benefit of NOT being employed. But the test of a contract of employment rests on an ancient concept , that of master and servant , if the master directs the servant to work  and the servant complies by performing personal service in return for pay , then it is likely that some form of service contract exists between them. If there is a high degree of control and direction , a regular expectation of the giving and receiving of work and pay then such a contract is very likely to a contract of service , in other words a contract of employment and the worker is an employee. He or she  has all   employment rights.  It is simply a matter of deciding that in that relationship there exists a certain minimum of mutual obligation between the parties to constitute a contract of employment.

Whilst all employees are workers there are a class of workers who offer personal services ( that is to say they turn up and work personally) but the arrangement between the parties fails to reach the required minimum of mutual obligation necessary to constitute a contract of employment. A tribunal faced with such a case , for instance where a person says he has a contract of employment whereas the employer denies that relationship , must look carefully at all the facts in the relationship , including critically how the agreements were formed in the first place. A worker , rather than an employee, may typically be a person who works sporadically ( albeit for significant periods of time) for an employer but each party has agreed that they should not be bound by any obligation. It can be likened to the old concept of "casual work" - put simply "here is some work , take it or leave it". Or on the other hand the worker may signify to the employer "I'll take the work but I can't say how long I am available". Significantly neither party signs up to any degree of obligation , both approach the relationship at arms length in respect of any mutual obligation. A worker has the right to have holiday pay for the duration of his engagement ( pro -rata), the right to receive wages without deduction ,  SSP subject to the  SSP rules but NOT the right to statutory notice. Significantly a substantial range of rights against discrimination are available. It is the authors view however if the "service agreement" between the parties includes some period or notice,  that can be brought to a tribunal since it arises in a contract concerning "employment".

 




                                                                                                                                  
           

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