1. The purpose of our procedure
Our procedure outlines how Adelaide University manages disclosures under both the Public Interest Disclosure Act 2018 (SA) (PID Act) and the Corporations Act 2001 (Cth). It ensures that individuals can safely report suspected wrongdoing, knowing they will be protected from reprisal and that their report will be handled appropriately and confidentially.
Please read this procedure in conjunction with our [Governance Policy].
2. Who our procedure applies to
2.1 Inclusions
This procedure applies to members of the Adelaide University community who make a disclosure of suspected wrongdoing.
2.2 Exclusions
This procedure does not apply to disclosures that do not fall within the definition of wrongdoing, such as work or study-related complaints or grievances of a personal nature (e.g., interpersonal conflicts, or dissatisfaction with a grade or performance assessment). Such matters are managed under the appropriate Adelaide University policy and procedure for reporting staff or student grievances and complaints of misconduct.
3. Our public interest disclosure procedure
3.1 Our commitment
Adelaide University does not tolerate wrongdoing and is committed to:
- operating with the highest legal and ethical standards
- requiring all staff and titleholders to behave in a way that is lawful, ethical, and always upholds and is consistent with our [Staff Code of Conduct]
- supporting and protecting disclosers
- handling disclosures made under this procedure thoroughly, impartially and in a confidential manner
- conducting investigations in a fair, confidential and objective manner
- monitoring the outcomes of investigations to ensure the outcome is fair and the response is appropriate
- taking appropriate action against any person found to have engaged in wrongdoing including, where appropriate, notifying external agencies
- taking appropriate action to rectify any confirmed wrongdoing
- ensuring disclosers are aware of how to make a complaint if they believe that their disclosure is not being dealt with appropriately, or if they believe that they are suffering detriment because they made the disclosure.
3.2 How to make a disclosure
3.2.1 How to report
The Integrity Unit is the central and confidential point of contact for disclosures under either the PID Act or the Corporations Act.
A disclosure should, in the first instance, be made to Adelaide University’s Integrity Unit in person, by phone, by email, or via the Integrity Unit’s online reporting form.
A disclosure may also be made in certain circumstances to other individuals or directly to relevant external bodies listed in Annexure 1 (Relevant Authorities and Eligible Recipients under the PID Act and Corporations Act).
If the disclosure concerns the conduct of the Integrity Unit or any of its staff, it should instead be made to the Deputy Vice-Chancellor – Corporate (DVCC).
For the purposes of the PID Act, staff within the Integrity Unit and the DVCC are Adelaide University’s designated Responsible Officers. For the purposes of the Corporations Act, these staff are also authorised Eligible Recipients for protected disclosures made to Adelaide University.
In this procedure, a reference to Integrity Unit includes a reference to the DVCC where the disclosure concerns the conduct of the Integrity Unit or any of its staff.
Anonymous disclosures are accepted, however, the ability to investigate or fully address the issues raised may be limited if further information cannot be obtained from the discloser. Anonymous disclosers are unable to be provided with updates on progress or outcomes.
3.2.2 What to include in the report
A disclosure should include, where possible:
- sufficient information to clearly identify the suspected wrongdoing
- any supporting evidence available, and
- details of those involved, including witnesses.
A person making a disclosure must have reasonable grounds to suspect wrongdoing. Legal protection does not depend on acting in good faith; however knowingly making a false or misleading disclosure, including deliberately omitting or fabricating information, is not protected under either the PID Act or the Corporations Act. Any person who knowingly makes a false or misleading disclosure may be subject to disciplinary action under Adelaide University’s Enterprise Agreement (as amended), relevant policies or procedures, statutory penalties under the applicable legislation, or contractual remedies where applicable.
3.2.3 After a disclosure is made
Once a disclosure has been made, the discloser cannot withdraw the information already provided. However, the discloser may advise that they no longer wish for the matter to be investigated and may decline to provide further information.
A discloser should not discuss the details of their report with anyone who does not have a legitimate need to know, except to seek support or advice from:
- a support person (e.g., a family member, doctor or psychologist)
- a legal practitioner for the purpose of obtaining legal advice or representation, or
- an external body such as the Office for Public Integrity (OPI), Ombudsman SA, or the Police.
3.3 How we respond to a disclosure
3.3.1 Receipt and acknowledgement
The Integrity Unit records a disclosure securely, and acknowledges receipt within five business days, unless the disclosure was made anonymously or no contact details are provided.
The acknowledgement will confirm that the matter has been received and will be reviewed to determine whether it qualifies as a protected disclosure under relevant legislation. The acknowledgement will outline next steps, explain confidentiality and protection provisions, and provide a Disclosure Reference Number (DRN) for use in confidential communication.
The Integrity Unit also confirms with the discloser whether the disclosure has been or will be reported to any other person or agency, as this may affect how the matter is managed.
3.3.2 Preliminary assessment
Within 30 days of receipt of the disclosure, the Integrity Unit reviews the information to confirm whether the disclosure meets the legislative tests for a protected disclosure under either the PID Act or the Corporations Act, and if so, determine the appropriate handling pathway. Within this period, the discloser will be advised of the determination.
If the Integrity Unit determines the disclosure is not protected under the legislation but raises other legitimate concerns, it will be referred to the appropriate internal complaint or grievance process.
The Integrity Unit will take all reasonable steps to respond immediately where there is a potential for serious harm to any person, the public, or the environment, which may include contacting external agencies such as SA Police, SA Ambulance, or the Environment Protection Authority.
3.3.3 Notification to external authorities
As required under the PID Act, the Integrity Unit must notify the OPI of all suspected instances of corruption, misconduct, or maladministration in public administration and provide follow-up outcome reports in accordance with the OPI Directions and Guidelines.
For matters covered by the Corporations Act, the Integrity Unit may refer or report information to relevant Commonwealth regulators when appropriate.
3.4 Protected disclosure pathways
3.4.1. Investigation
Where the Integrity Unit determines that Adelaide University is the appropriate body to handle the disclosure, and has confirmed that an investigation is required, it:
- determines the most appropriate area of Adelaide University to conduct the investigation, having regard to the Enterprise Agreement (as amended) and existing policies and procedures relevant to the subject matter, for example, the [Fraud and Corruption Policy] or [Staff Code of Conduct]
- liaises with the area responsible for managing the investigation to identify a suitably qualified and independent investigator
- ensures the investigation follows principles of procedural fairness and confidentiality, and that all participants are aware of their obligations under the relevant legislation
- maintains secure and confidential records throughout the process, including by only referring to the matter by its DRN throughout the process, except where required by law
- provides the discloser, where contactable, with periodic updates on progress
- ensures that the protections outlined below are applied throughout the process.
Investigations are conducted as promptly as reasonably practicable, with a timeline communicated to the discloser and the discloser kept informed about the progress of the investigation.
3.4.2 Referral
Where the Integrity Unit determines the matter should be referred to another authority (refer Annexure 1), or another authority assumes responsibility for the matter the Integrity Unit will refer the matter to that body. The Integrity Unit will record the reasons for that decision and, where practicable, inform the discloser.
3.4.3 No further action
Where the Integrity Unit determines that no further action is warranted, for example, because the disclosure is trivial, vexatious, lacking sufficient substance, or has already been adequality addressed, it will record the reasons for that decision and, where practicable, inform the discloser of its determination.
3.5 Protecting disclosers
3.5.1 Investigation
Adelaide University takes all reasonable steps to protect disclosers from detriment arising from making a disclosure under this procedure.
Protections are incorporated into the management of each disclosure and adapted to the discloser’s circumstances. At a minimum, the following measures are applied when responding to and handling a disclosure:
- Respond immediately to any report or indication of actual or potential detriment.
- Protect the discloser’s identity by referring to the matter only by its DRN and limiting identifying information to authorised officers who require it.
- Maintain a secure and confidential record of all disclosure details in accordance with this procedure.
- Confirm the type of disclosure and applicable legislation to ensure that the correct legal rights and protections are afforded.
- Ensure all staff involved in managing or investigating disclosures understand their legal obligations and the potential penalties, including imprisonment, that may apply to any person who:
- discloses the identity of a discloser without lawful authority or consent
- subjects, or threatens to subject, a discloser to detriment, or
- acts to hinder or discourage a person from making a disclosure.
- Assess and manage risks to the discloser and others who may be affected by recommending and coordinating appropriate mitigation actions. Where temporary changes to employment or workplace arrangements are required, the Integrity Unit consults with the [Chief People Officer].
- Provide practical and wellbeing support to the discloser, including reassurance of the value of reporting wrongdoing, recommending the discloser contact a support person for professional assistance or support as appropriate, and maintaining regular confidential communication throughout the process.
These protections apply in addition to the statutory protections available under the PID Act and the Corporations Act, which provide immunity from liability, confidentiality of identity, and protection from detriment.
3.6 Recordkeeping
Disclosures received by Adelaide University are recorded in a secure central register maintained by the Integrity Unit. The register records:
- the Disclosure Reference Number (DRN)
- date received
- preliminary assessment outcome
- investigation or referral details
- outcomes or actions taken, including details where no action is taken.
The register forms part of Adelaide University’s disclosures management system, maintained in accordance with confidentiality and recordkeeping requirements under the PID Act and Corporations Act.
3.7 Concerns held by a discloser
If a discloser believes they have been or are being subjected to detriment as a result of making a disclosure, they should immediately notify the Integrity Unit. Where the concern involves or relates to the conduct of the Integrity Unit, the discloser should notify the DVCC. If the concern involves or relates to the DVCC, or if the discloser is not satisfied with the Integrity Unit or DVCC’s response, they may raise their concern directly with the Vice-Chancellor, who is Adelaide University’s Principal Officer under the PID Act.
If the discloser has concerns about the way their disclosure, or a report of alleged detriment, has been handled by Adelaide University, they may raise their concerns with the Executive Director, Integrity Unit, the OPI or Ombudsman SA.
3.8 Reporting
The Integrity Unit prepares an annual report on the operation and performance of the disclosures management system for Council (and other governance committees as appropriate).
4. Who holds a responsibility within this procedure
Refer to the Delegation Policy for all delegations at Adelaide University.
4.1 The [Vice-Chancellor] as Principal Officer under the PID Act is required to:
- ensure appropriate procedures are in place for receiving, assessing and managing disclosures
- ensure there are Responsible Officers designated and trained
- take action on disclosures and complaints of detriment when appropriate.
4.2 The Executive Director, Integrity Unit is required to:
- ensure Adelaide University complies with its obligations under the PID Act, Corporations Act, ICAC Act, and Ombudsman Act in relation to the implementation of this procedure
- provide training and awareness to staff on the identification and management of disclosures
- ensure staff within the Integrity Unit perform their functions as Responsible Officers in accordance with this procedure
- create and maintain confidential records on Adelaide University’s disclosures management system for disclosures received and managed by Adelaide University under this procedure
- collate and record statistics from Adelaide University’s disclosures management system and providing regular reports to senior management and Council
- ensure any recommendations for systems improvements are provided to the relevant business unit for consideration.
4.3 The Responsible Officers are required to:
- advise the discloser of the process and available support
- assess the information as soon as practicable after the disclosure is made and taking such action as is appropriate in the circumstances
- notify the discloser that an assessment has been made and advising them of the action being taken or, if no action is being taken, the reasons why no action is being taken
- apply the relevant law in taking action in response to the disclosure
- listen and respond to any concerns of detriment
- coordinate and provide support to the discloser, including any immediate protective measures needed to safeguard them
- arrange for the investigation of the disclosure, ensuring a report is prepared (including findings, evidence and recommendations) and taking appropriate action where warranted
- advise the discloser of progress and the outcome of any investigation once known
- provide the OPI with information relating to the disclosure where required
- keep confidential records of all aspects of case management of the discloser, including all contact and follow-up action and, in the case of the DVCC, providing this information to the [Integrity Unit] for record-keeping at the conclusion of the investigation.
4.4 Members of the Adelaide University community are required to:
- comply with their legal and ethical obligations and the policies and procedures of Adelaide University
- disclose conduct they reasonably suspect is wrongdoing by making a report under this procedure
- not make false or vexatious reports of alleged wrongdoing
- cooperate with investigations conducted in relation to a disclosure made under this procedure or a relevant law
- support and protect disclosers
- keep a disclosers’ identity and information contained in a disclosure confidential as required under this procedure and by law
- not engage in victimisation or other forms of detriment
- report detriment perpetrated by others to the Integrity Unit.
5. Definitions used in our procedure
Please refer to our Adelaide University glossary for a full list of our definitions.
Detriment means when a person causes detriment including by injury, damage, loss, intimidation, harassment, discrimination, disadvantage, adverse treatment regarding employment or threats of reprisal on the ground that another person has or intends to make a disclosure.
Disclosure means any confidential report of wrongdoing or concerning activity reported in good faith to Adelaide University under this procedure, which the informant reasonably believes to be of public interest. It includes an appropriate disclosure or a report about a reportable matter.
Disclosure management system means the central register used to record all disclosures made to the University and related information and materials and includes this procedure.
Disclosure Reference Number (DRN) is a number used to de-identify communications and ensure confidential record-keeping.
Discloser means a person who makes a disclosure of information under this procedure.
Eligible Recipient is defined in Section 1317AAC of the Corporations Act 2001 (Cth) and includes those entities listed in Table 2 at Annexure 1.
Protective measures include steps that can be taken to reduce the risk of reprisal to an informant by ensuring that the identity of that person is protected while an investigation is conducted and/or arranging for working arrangements to be temporarily adapted (e.g., change to work location) and for supports services to be made available (e.g., Employee Assistance Program).
Public administration has the same meaning as in the Independent Commission Against Corruption Act 2012 and the Ombudsman Act 1972.
Public interest means issues or concerns that affect more than just one person’s private or personal interests, such as corruption, misuse of public resources, unlawful decisions or actions, danger to public health or safety, or danger to the environment.
Public Officers are as defined by the Independent Commission Against Corruption Act 2012 (SA). Most University staff are public officers.
Relevant Authority as defined in Section 5(5) of the Public Interest Disclosure Act 2018 (SA) - refer to Table 1 at Annexure 1.
Wrongdoing has the same meaning as defined under International Standard ISO 37002 Whistleblower management systems – Guidelines. Wrongdoing means conduct (action(s) or omission(s)) by a person or persons connected with the University, which, in the view of an informant, can cause harm, including, but not limited to, the following:
- breach of national, state or international law such as fraud, or corruption including bribery
- breach of the University’s or other relevant code of conduct or breach of the University’s rules or policies
- gross negligence, bullying, harassment, discrimination, unauthorised use of funds or resources, abuse of authority, conflict of interest, gross waste or mismanagement
- actions or omissions resulting in damage or risk of harm to human rights, the environment, public health and safety, safe work practices, or the public interest.
- Wrongdoing or the resulting harm can have happened in the past, be currently happening, or can happen in the future. Potential harm can be determined by reference to a single event or a series of events.
6. How our procedure is governed
This procedure is categorised, approved and owned in line with the governance structure of Adelaide University and the offices and officers listed below.
| Parent policy | [Governance Policy] |
|---|---|
| Policy category | Council |
| Policy owner | Director, Governance Services |
| Procedure owner | Executive Director Integrity Unit |
| Approving authority | Co-Vice Chancellors/Vice Chancellor and President |
| Responsible officer | [TBC] |
| Effective from | 1 January 2026 |
| Review date | [3/4/5 years after date this version is approved, TBC] |
| Enquiries | Interim Central Policy Unit/[Central Policy Unit] staff.policy.enquiries@adelaideuni.edu.au |
| Replaced documents | None |
7. Legislation and other documents related to our procedure
Refer to the Delegation Policy for all delegations at Adelaide University.
| Category | Documents |
|---|---|
| Associated procedures | Student Complaints Resolution Procedure [Staff Complaint Resolution Procedure] [Discrimination Complaints Procedure] Academic Misconduct Procedure |
| Related policy documents | [Fraud and Corruption Policy] Staff Code of Conduct Student Code of Conduct |
| Referenced legislation |
Public Interest Disclosure Act 2018 (SA) |
| External references | Public Interest Disclosure Guidelines issued by the Independent Commission Against Corruption which are accessible online at https://www.icac.sa.gov.au/publications/directions-guidelines |
8. History of changes
| Date approved | To section/clauses | Description of change |
|---|---|---|
| 19 December 2025 | N/A | New procedure |
At the time of writing, Adelaide University’s organisational structure, position titles, and committee names have not been confirmed. Square brackets [ ] indicate placeholders for these details. Brackets are also used to identify policy elements that are subject to further decision-making or confirmation. These will be updated once final decisions are made.