Whistleblowing guide

OsloMet must comply with applicable laws and ensure that everyone has a satisfactory working and learning environment. We have a responsibility to investigate all reports and to act if censurable conditions are uncovered. Therefore, it is important that you speak up if you discover censurable conditions. Reports should be treated confidentially, and you should not experience negative consequences (retaliation) for blowing the whistle.

Both employees and students have the right to report censurable conditions at OsloMet.

For staff and students

All censurable conditions can be reported. Censurable conditions mean matters that are contrary to legal rules, written ethical guidelines or ethical norms that are widely supported in society, for example conditions that may entail:

• Danger to life or health
• Danger to climate or environment
• Corruption or other financial crime
• Abuse of authority
• Unacceptable learning or working environment
• Breach of personal data security (privacy breaches are reported in a separate deviation channel)

Special for employees

In some cases, you as an employee have a duty to report. This applies to matters relating to defects, or defects that may endanger life or health, as well as if you become aware that harassment or discrimination is taking place in the workplace. In the event of conditions or deficiencies that may endanger life and health, it is important that you notify of this immediately.

Matters that only concern your own employment relationship are generally not covered by the whistleblowing rules, unless they include matters mentioned in the definition above. Matters that concern your own employment relationship should be raised with your manager or manager's manager.

Special for students

We have different ways to speak up:
Circumstances that only apply to your own study relationship are generally not covered by the notification rules, unless they include circumstances mentioned in the definition in the section "What can be reported?" above.

If you are a student and want to speak up about conditions that are not so serious that they fall within the concept of censurable conditions, but which you find challenging, you can contact us through the Si-ifra! channel by sending an e-mail to si-ifra@oslomet.no.

Purely personal circumstances and circumstances that arise outside of teaching and the study programme will generally fall outside OsloMet's authority.

Employees and students can always report internally, and there are no formal requirements for how it should be done. As an employee, you should first try to notify your manager or manager's manager, if the notification concerns matter related to your own employment.

You can report via the whistleblowing form in our whistleblowing channel, which you can find through the yellow button at the top of this page. If you report via the whistleblowing channel, the notification will be received by the administrator in the whistleblowing channel. There are four administrators in the whistleblowing channel, two of whom are employed by the Department of HR and two by the Department of Education.

If the report concerns a potentially censurable condition (i.e. it is defined as a whistleblower in the sense of the law), the administrator sends the report to the relevant members of OsloMet's reception committee. The reception committee consists of the administrator, the central chief safety representative, the head of the whistleblowing committee and a lawyer at the Department of HR. The starting point is that notifications must be managed by the correct line manager.

The Reception Committee follows the rules of the Public Administration Act on impartiality in the handling of cases. This means that the members of the reception committee must not participate in the handling of cases where they are disqualified. If the notification concerns the rector, the handling of the notification must be done by the University Board.

You can also notify OsloMet internally via the safety representative, the students representative, an union representative or a lawyer. It is possible to notify a public supervisory authority, such as the Labour Inspection Authority, the Parliamentary Ombud, the police or the relevant ministry, such as the Ministry of Education and Research. More detailed conditions related to notifying the public can be found in Section 2 A-2 (3) of the Working Environment Act (lovdata.no).  

In OsloMet's Indicative process description for handling notifications (cp.compendia.no), you can read more about the administrator's and the reception committee's procedures for receiving and assessing notifications. 

A whistleblowing report should contain concrete and clear information about the censurable situation. The notice should describe:

• What happened? 
• Who is involved?
• Where did it happen? 
• When did it happen?
• Has it happened multiple times?
• Were there witnesses present?
• If you have previously reported the same relationship to others at OsloMet (e.g. manager or rector), it is important that you inform about this.
• Attach specific examples and evidence/documentation if available.

A whistleblow must always be taken seriously and investigated in accordance with the law. It is possible to report anonymously.

• A notification must be processed within a reasonable time.
• Retaliation is prohibited. This means that you should not experience any kind of negative consequences as a result of having reported the incident. 
• Impartiality is a fundamental principle for the processing of whistleblowing. 
• Those involved in the case shall be given access to the information that concerns themselves in accordance with applicable legislation.
• In the survey, OsloMet will safeguard the basic principles of contradiction.
• Confidentiality must be maintained when processing the report. The identity of the whistleblower and the information in the case must not be known to more people than necessary. 
• The processing of the report must be organised in such a way that the burden on those involved is as small as possible.
• Parties involved have the right to have a support person with them in conversations.

OsloMet has also prepared an indicative process description for handling whistleblowers (cp.compendia.no). This is not absolute, but is intended as an aid in case processing. 

Some reports are processed by OsloMet's Whistleblowing Committee. The committee is chaired by an external lawyer and currently consists of at least two more members:

• external member who is an organisational psychologist or psychologist
• the university's main safety representative or her deputy
• if necessary, the tribunal can be expanded with the necessary professional expertise.

The Whistleblowing Committee deals with reports of a serious nature, and which, for various reasons, cannot be processed in the line at OsloMet. When deciding whether a case should be processed in the line or sent to the committee, OsloMet will place emphasis on the whistleblower's own wishes.

The Whistleblowing Committee shall be advisory and make recommendations to the rector in individual cases.

In consultation with the Whistleblowing Committee, the committe's chair decides whether, or how, a case should be followed up. A case that has been taken up for consideration by the Committee may be closed at any time if, during its work. if the Committee concludes that further investigations by the Committee are not appropriate.

For cases that the Whistleblowing Committee takes up for consideration, a report is prepared and submitted to the rector. The rector decides how the report is to be followed up and informs the parties in the case of his decision.

It is possible to report anonymously in our whistleblowing channel.

If you report anonymously, it is very important that you save the login information you are assigned in the system when the notification is submitted. You need this login information to log into the whistleblowing channel. In the whistleblowing channel, OsloMet can communicate with you about the notification if we need more information. 

You can also report incidents by using your safety representative, trade union or your own lawyer as an intermediary. They can then raise the matter without revealing your identity.

Although it is possible to report anonymously, it is important to be aware that you may be identified either through information in the report itself or in connection with the investigation of the report. Even if OsloMet knows your identity, it must always be treated confidentially, and OsloMet will not disclose your identity unless this is necessary for the processing of the case. 

Often, OsloMet may need more information to be able to follow up the notification. Please note that anonymous whistleblowing may limit OsloMet's ability to follow up or clarify the content of the report, although we will then attempt to communicate through the whistleblowing channel. 

You are always entitled to a fully satisfactory working or learning environment. For employees who blow the whistle, the employer must in particular ensure that the whistleblower has a fully satisfactory working environment.

Retaliation because of whistleblowing is prohibited. Retaliation means negative consequences or sanctions because of your reporting. If necessary, measures appropriate to prevent retaliation shall be provided.

As a whistleblower, you will not necessarily have the right to access the case documents, or the right to information about what is happening in the case. You always have the right to a confirmation that the notification has been received and when the case is closed, you will be notified of this.

Your identity will not be disclosed unless it is necessary for the case to be processed.

You shall be given access to the information that concerns you in accordance with applicable legislation. In the survey, OsloMet will safeguard the basic principles of contradiction.

OsloMet is not permitted to share the information with anyone other than those who have a professional need for the information.

The person who has been notified also has the right to a fully satisfactory working and learning environment. OsloMet has a responsibility to safeguard both the person it has been notified about and others involved.

When the case has been processed, the person who has been notified must be informed that the investigation has been completed.

Privacy statement

This privacy statement describes how we handle your personal data when processingrecieved notifications.

Data controller

OsloMet is the data controller for the processing of personal data described in this privacy statement.

Why do we collect and process personal data?

We collect personal data to investigate whistleblowing in accordance with the requirements of Chapter 2 A of the Working Environment Act and Chapter 4 of the Act relating to Universities and University Colleges.

Legal basis for processing your personal data

The legal basis for processing personal data related to the processing of whistleblowing is Article 6 (1) (c) of the General Data Protection Regulation, cf. paragraph 3 letter b and Article 9 (2) (b), cf. Section 2 A-3 of the Working Environment Act and Section 4-3 b of the Act relating to Universities and University Colleges.

What personal data do we collect and process?

The personal data collected will depend on the content of the individual notification. Most often, we will collect general personal data such as name and contact information, but the scope of personal data is case-dependent. Special categories of personal data may also be collected, if the nature of the case indicates that this is necessary in order to process the report. Special categories of personal data may, for example, be health information or information about trade union affiliation.

What processing do we do with your personal data?

Incoming notifications and associated personal data will be registered in our whistleblowing channel when the notification is submitted, and will then be received by the administrator in the system. OsloMet has four administrators in the whistleblowing channel, two of whom act as deputies.

The notification will then be distributed to OsloMet's reception committee and then the case officer(s), in accordance with OsloMet's routines. The notification will then be processed in accordance with OsloMet's procedures for processing the notification. This may involve assessing the report, obtaining documentation, conducting recorded conversations with the parties involved and writing a report with a conclusion.

Personal data that is subject to the archive legislation will be transferred to OsloMet's archive system, where it will be archived in accordance with applicable regulations.

Where do we obtain your personal data from?

Your personal data will be obtained from notified, relevant documentation related to the whistleblowing case or through conversations with others involved.

Is personal data transferred to others?

If the report is to be processed by OsloMet's Whistleblowing Committee, the information in the notification will be transferred to the external chair of the Whistleblowing Committee.  As of 1 April 2024, the head of the Whistleblowing Committe is Lill Egeland, lawyer at the law firm Simonsen Vogt Wiig. The law firm Simonsen Vogt Wiig is responsible for processing the personal data processed at the law firm. Beyond this, personal data will not be transferred to others.

Security of the processing of your personal data

There is access control in both OsloMet's whistleblowing channel and OsloMet's archive system. For personal data related to whistleblowing, there are strict procedures for access. Only those with an professional need will have access to your personal data.

All data in the whistleblowing channel and in OsloMet's archive system is protected with appropriate security.

How long do we store your personal data?

Personal data related to whistleblowing cases will often be subject to the provisions of archiving legislation. In such cases, the personal data will be archived in accordance with applicable regulations. Data that is not subject to archiving legislation will be deleted when it is no longer required.

See more about rights related to the right of access, correction and deletion and contact information for the data protection officer at OsloMet in other privacy statements. 

Your rights

You have the right to exercise the rights under the GDPR. See more information about your rights in OsloMet's privacy policy.

Contact

Contact person for processing personal data is Julie Dessen.

If you need to talk to resource persons, you can contact your safety representative, your trade union or your local HR unit.

The safety delegate has a duty to notify of circumstances that may lead to an accident or health hazard. The trade union representatives have a duty of confidentiality regarding the conditions you tell us about.

If you need to talk to resource people, you can contact

• The Student Ombudsperson or
• The University Chaplain 

See also more information about OsloMet's support for students at Students support and counselling.