Reporting irregularities / “Whistleblowing”

General preconditions

Örebro University firmly believes that any irregularities within our operations must be brought into the light and rectified. We therefore offer different ways of drawing attention to irregularities and wrongdoing, for example via the head of school if anything would happen during a joint project or via the head of department where consultants are hired for certain services. If none of the available routes feel like an option, the online reporting channel we offer may be a more suitable way in. The reporting channel comes under the rules that apply to the university under the act on protection for persons reporting irregularities (2021:890). The act can be read in full, in Swedish, here: https://www.riksdagen.se/sv/dokument-lagar/dokument/svensk-forfattningssamling/lag-2021890-om-skydd-for-personer-som_sfs-2021-890

The reporting channel can be used to inform the university of irregularities and wrongdoing that are in the public interest and that occur or most likely will occur within our operations. If you

  • have been an employee of Örebro University,
  • have had an employment-like status at the university, such as a consultant,
  • have taken part in a joint research project, where the university has decided on your contributions/involvement, or
  • have applied for employment or internship and in that relationship, irregularities within the operations that are in the public interest have in one way or another come to your attention,

it is possible for you to report such irregularities. This is also known as ‘whistleblowing’. The university is then obliged to act on the information given to them and in various ways work to ensure that the irregularities cease.

The reporting channel is to be used for suspicions of irregularities that are in the public interest. In short, these may involve violations of various regulations, external as well as internal. Research misconduct, conflicts of interest, bribes or other situations when somebody makes private gain from their position or office or when somebody’s family members benefit inappropriately are also included. More severe misuse of office and gross deviations from internal or external rules and regulations can be reported, for example, extensive unauthorised use of personal data. The whistleblowing function is, however, not intended for general complaints concerning leadership, salaries, recruitment, operational planning and so on.

The person making a claim

The person wishing to report something is referred to as “the person making a claim”, or in more everyday language “the whistleblower”. If you are making a claim, you have the right of freedom from liability for the report and your personal data are covered by confidentiality. A precondition is, however, that you have reasonable cause to believe that your claim is true – in other words, it cannot be just a rumour. The content of the whistleblower report is, however, not covered by the same secrecy provisions. Read more under the tab “Public access to information and secrecy” below.

Limitations

The protection provided by the act on protection for persons reporting irregularities (2021:890) is in certain aspects limited. These limitations mean that in some cases, freedom from liability no longer applies. When you make a claim, you may not

  • disclose classified national security information, such as information about collaborations with the defence industry,
  • break duties of confidentiality where the right to communicate and publish information is restricted by law, for example disclosing details of somebody’s personal situation if you are working with study guidance,
  • break duties of confidentiality as laid out in the Defence Inventions Act (1971:1078), or
  • commit criminal offences in order to obtain information which you then proceed to report.

Your right to report irregularities and wrongdoing that are in the public interest does not give you the right to disclose documents. In your claim, refer instead to information or documents that may be available to the authority or that the authority in other ways is able to corroborate.

Ways in

To make a claim, you can:

  • Submit it electronically, using the form below
  • Send a letter to
    Internal [CH1] reporting channel/“Whistleblowing”
    Örebro University
    SE-701 82 Örebro

    Mail marked as above will be left unopened for the eyes of the persons appointed recipients of whistleblower reports only.
  • Phone the university switchboard, +46 19 30 30 00, and ask to be connected to a recipient of reports on irregularities that are in the public interest/whistleblowing.
  • Make an appointment to meet in person. Phone up, according to the instructions above, and ask for a meeting in person. You can then agree on a suitable time and place.

A whistleblower report will be handled by the university’s legal officers or, as an exception, the head of HR. These recipients are authorised to act in the university’s place and

  • receive reports and be in contact with the person making the claim,
  • follow up on what has been reported, and
  • provide feedback about the follow-up to the person making the claim.

Only the claims deemed to fall under the act on protection for persons reporting irregularities are handled according to the now current order of procedure.

Reports and other documents upon which the investigation and its closure are based, will be registered in the university records. A claim may lead to labour law action, a police report or a complaint being made with another supervisory authority. It may also lead to the matter being forwarded to the function concerned internally, or that it is closed. If the matter is forwarded to another authority or investigated further internally, the details required for continued investigation are to be handed over to the recipient in question.

More details of how matters are processed can be found in the document “Administrative procedures for handling matters in compliance with the act on protection for persons reporting serious irregularities”/‘Whistleblowing’ 2022/04193” which can be requested from the records office registrator@oru.se.

If you have submitted a whistleblower report, the recipient will contact you in reference to the matter:

  • within seven days with a confirmation that your report has been received, unless you have renounced your right to a confirmation of receipt or if the recipient deems that such a confirmation would disclose your identity,
  • within three months with general feedback on the progress of the case and measures taken, and
  • within seven days of receipt of the report with general feedback on the progress of the case IF the university has, for instance, neglected to confirm receipt of your report.

If the university is obliged to disclose information that may lead to your identity being disclosed, you will also be notified of this, unless by doing so the actual purpose of the information being disclosed is impeded or obstructed (for instance in a police investigation).

A claim made via the reporting channel becomes a public official document. That means that the general public has the right to ask for the details that have been submitted to be disclosed along with any documents added to the case file in the potential ensuing investigation.

Whenever a request to disclose information or documents is made, an examination must be done in compliance with the Public Access to Information and Secrecy Act to determine whether the information is covered by any secrecy provisions. Secrecy applies for information on who has made a claim (the whistleblower). Secrecy also applies for information about other individuals who can be identified through the information provided unless there is no risk of them suffering injury or detriment as a result of the disclosure. Information which has otherwise been provided on the matter is not covered by secrecy unless it is detailed to such an extent that it may disclose the whistleblower’s identity. For the full whistleblower report to be classified as secret, however, is highly unlikely. Secrecy applies for a maximum of 50 years.

It is only those that have been appointed recipients of reports by the university that may have direct access to any personal data in a matter. The recipients may use the personal data only to the extent required for them to complete the duties that they have been assigned.

Under the archiving rules in place, archivists also have access to the matter, including the personal data therein.

Under law, Örebro University is obliged to process personal data when handling claims made in accordance with the act on protection for persons reporting irregularities (2021:890). Örebro University is the controller of the personal data processing that takes place when the reporting channel is used, as well as in any investigations that follow as a result of such a report.

The legal officers within the central administration as well as the head of HR are authorised recipients of whistleblower reports that are made in compliance with the act. Such a report, and any investigations taking place as a result, will be registered in the university records and archived. Therefore, archivists will also have access to the information submitted. In addition, the information may be disclosed if requested under the principle of public access to information, to the extent the information is not covered by secrecy. An examination in compliance with the Public Access to Information and Secrecy Act will be done in each case to determine whether the information is covered by any secrecy provisions.

If a meeting is held in person you may be asked if you consent to the meeting being recorded. If you do not give your consent to being recorded, special minutes will instead be taken to document the meeting. Any recordings will be saved either directly, as an audio file, or as a transcription. If a transcription or minutes are created, you will be given the opportunity to object to the information therein, ask to have information corrected, and approve their content by signing the document.

You have the right to access the data that the university is processing about you. If you believe your personal data to be incorrect, that it should be corrected, or if you want to object to any kind of processing, you need to contact the data protection officer for a discussion of what measures may be taken. It is, however, not possible to delete incorrect personal data that have already been archived.

Örebro University, SE-701 82 Örebro, +46 19 30 30 00

Questions and/or complaints regarding personal data processing can be sent to Örebro University’s data protection officer at dataskyddsombud@oru.se. Alternatively, you can call the switchboard and ask to be connected to the data protection officer. You can also lodge a complaint directly with the Swedish Authority for Privacy Protection, www.imy.se.


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