Safe Disclosure Policy

Context and Purpose

Vancouver Community College (VCC, the College) is committed to promoting a culture of openness, transparency, and accountability. The College recognizes the importance of encouraging employees and others to report any Wrongdoing that may have a detrimental effect on the public interest. The purpose of the Safe Disclosure Policy is to reaffirm the College’s commitment to protecting those who make disclosures in good faith, and to set out safe disclosure procedures in accordance with the Public Interest Disclosure Act (PIDA).

Scope and Limits

This policy applies to all employees, students, the Board of Governors, contractors, and alumni of Vancouver Community College as well as external partners who may have information about Wrongdoing within the institution as defined under PIDA. It also applies to former employees and contractors who were employed or providing contracted work when a Wrongdoing occurred or was discovered. This policy applies to disclosures of Wrongdoing as defined by PIDA and does not replace or substitute existing complaint processes in legislation, College policies, or collective agreements.

Principles

VCC is committed to maintaining the highest standards of ethical conduct and promoting a culture of honesty, transparency, and accountability.
The College is committed to meeting its obligations under the Public Interest Disclosure Act and informing the College community of their rights under the Act.
The College is committed to responding to Disclosures in a timely manner and conducting investigations in accordance with the principles of procedural fairness and natural justice.
The College will prioritize maintaining confidentiality and the protection of privacy for those involved in making a Disclosure or participating in an investigation.
VCC will not tolerate reprisals against any individual who requests Advice, makes a Disclosure in good faith, cooperates in an investigation, or makes complaints about reprisals.
The College will accept anonymous Disclosures and investigate them following the same standards and procedures as a named or identified report where it is possible to do so while maintaining anonymity.
The College will ensure that the Designated Officer(s) are aware of their role(s) and responsibilities under this Policy.
The College will ensure the safe disclosure process is publicly accessible and will publish an annual report of the Disclosures, investigations, findings of Wrongdoing and recommendations made or received under PIDA within the previous year.
This policy and the associated procedures are separate from any criminal or civil proceedings. The College is not responsible for determining violations of criminal or civil law and will fully cooperate in any criminal investigation.

Definitions

Advice: Information that may be requested in respect of making a disclosure or a complaint about a reprisal under this policy.
Designated Officer: A senior executive, or their designate, who receives requests for Advice and receives and investigates public interest disclosures.
Discloser: An individual who makes a report of Wrongdoing under this Policy.
Disclosure: The act of reporting Wrongdoing or improper conduct in accordance with this policy.
Employee: An individual who is currently employed by VCC on a full-time, part-time, permanent, temporary, term, casual or contract basis. For the purpose of this policy, this definition also includes former employees.
Ombudsperson: The BC Ombudsperson appointed under the Ombudsperson Act.
Protection Official: The official who may receive a public disclosure from an individual regarding an urgent risk. In respect of a health-related matter, the provincial health officer. In respect of an environmental matter, the provincial administrator as defined in section 1(1) of the Emergency and Disaster Management Act. In any other case, an appropriate police force.
Reprisal: A measure taken against a discloser or participant in an investigation in response to their report or participation. These measures may include:
a) A disciplinary measure;
b) A demotion;
c) Termination of employment;
d) Any measure that adversely affects the employee’s employment or working conditions, or student’s learning environment or academic outcomes;
e) A threat to take any of the measures referred to here.
Student: A student is a person who is registered in full-time or part-time credit or non- credit courses offered by VCC.
Wrongdoing: Acts or omissions defined under Public Interest Disclosure Act:
a) a serious act or omission that, if proven, would constitute an offence under an enactment of British Columbia or Canada;
b) an act or omission that creates a substantial and specific danger to the life, health or safety of persons, or to the environment, other than a danger that is inherent in the performance of an employee's duties or functions;
c) a serious misuse of public funds or public assets;
d) gross or systemic mismanagement;
e) knowingly directing or counselling a person to commit a Wrongdoing described in (a) to (d).

Related Resources

VCC Policies

Other Resources

College and Institute Act, RSBC 1996, c 52
Criminal Code, RSC 1985, c C-46
Emergency and Disaster Management Act, SBC 2023, c 37
Freedom of Information and Protection of Privacy Act, RSBC 1996, c 165
Ombudsperson Act, RSBC 1996, c 340
Public Interest Disclosure Act, SBC 2018, c 22
ConfidenceLine Tel: 1-800-722-6014
VCC and CUPE Local 4627 Collective Agreement
VCC and VCC Faculty Association Collective Agreement