When using the Report and Support tool, LSHTM will aim to keep your information confidential as far as we are able to. Only people dealing directly with your report would usually see a copy.
There are circumstances when we may be required to share your information with others, including outside of our institution. The purpose of this guidance is to provide more information on how we keep your information confidential and how we share it with others.
If you have any questions on confidentiality and your report please contact LSHTM's Legal and Compliance team by emailing legal@lshtm.ac.uk.
1. Anonymous reporting
2. Named reporting (reporting with contact details)
3. Meeting with an Anti-Bullying and Harassment Advisors
4. Other Support
5. Investigation
6. Disciplinary or other formal hearing
7. Litigation
8. Data subject access requests (named reports and anonymous reports)
1. Anonymous reporting
By choosing to report anonymously, you do not wish to be identified as the person reporting; and you do not wish to be contacted by an appropriate advisor.
LSHTM shall respect these wishes and will not take any active steps, nor permit anyone to take active steps on our behalf, with intention of identifying you. Furthermore, information contained in an anonymous report shall still be treated in confidence and disclosed on a ‘need to know’ basis only.
By choosing to submit a report anonymously, however, we are unable to give you direct support in relation to the incident or behaviour.
LSHTM will not generally be able to take steps such as investigating the complaint, initiating disciplinary or other formal proceedings or passing information on to third parties in order to take the report further, unless you have chosen to report with contact details (and you agree to this action).
However, there are certain circumstances in which LSHTM may take steps such as those listed above even where an anonymous report is received (on a 'no names' basis). This is usually where there are concerns for your safety or another person’s safety. Please see our Privacy Notice together with our separate Duty of Care Guidance for further information.
If you choose to report anonymously, the report should not include information relating to you as an individual and from which you would be identifiable. You should also consider whether naming someone else in an anonymous report may also lead to you being identifiable e.g. if you are one a small number of people who reports to a particular line manager or has a particular course supervisor. You are in control of how much or how little information you provide in the report.
To that end, please note, the equality/protected characteristic questions at the conclusion of the anonymous reporting route are optional, as are some of the free text boxes within the form. Those free text boxes that are ‘required fields’ can also be completed with neutral answers (such as ‘Not Applicable’) in order to maintain higher levels of anonymity. .
Even though it may be appropriate to make an anonymous report containing such information in some circumstances. LSHTM encourages any individual who wishes to make an anonymous report not to include names or other information that could be used to identify themselves or a third party.
Information relating to an individual's criminal convictions or past offences (including alleged offences) must not be included in any report, whether submitted anonymously or otherwise.
Information that you provide through reporting anonymously will be used for statistical purposes and to inform prevention work.
For further information, please also see our Privacy Notice.
LSHTM shall respect these wishes and will not take any active steps, nor permit anyone to take active steps on our behalf, with intention of identifying you. Furthermore, information contained in an anonymous report shall still be treated in confidence and disclosed on a ‘need to know’ basis only.
By choosing to submit a report anonymously, however, we are unable to give you direct support in relation to the incident or behaviour.
LSHTM will not generally be able to take steps such as investigating the complaint, initiating disciplinary or other formal proceedings or passing information on to third parties in order to take the report further, unless you have chosen to report with contact details (and you agree to this action).
However, there are certain circumstances in which LSHTM may take steps such as those listed above even where an anonymous report is received (on a 'no names' basis). This is usually where there are concerns for your safety or another person’s safety. Please see our Privacy Notice together with our separate Duty of Care Guidance for further information.
If you choose to report anonymously, the report should not include information relating to you as an individual and from which you would be identifiable. You should also consider whether naming someone else in an anonymous report may also lead to you being identifiable e.g. if you are one a small number of people who reports to a particular line manager or has a particular course supervisor. You are in control of how much or how little information you provide in the report.
To that end, please note, the equality/protected characteristic questions at the conclusion of the anonymous reporting route are optional, as are some of the free text boxes within the form. Those free text boxes that are ‘required fields’ can also be completed with neutral answers (such as ‘Not Applicable’) in order to maintain higher levels of anonymity. .
Even though it may be appropriate to make an anonymous report containing such information in some circumstances. LSHTM encourages any individual who wishes to make an anonymous report not to include names or other information that could be used to identify themselves or a third party.
Information relating to an individual's criminal convictions or past offences (including alleged offences) must not be included in any report, whether submitted anonymously or otherwise.
Information that you provide through reporting anonymously will be used for statistical purposes and to inform prevention work.
For further information, please also see our Privacy Notice.
2. Named reporting (reporting with contact details)
Where you make a named report (also referred to as reporting with contact details) through the Report and Support tool, LSHTM will usually only disclose information to its staff members and only on a ‘need to know’ basis. For example, the report will be shared with the advisor assigned to you.
There are certain circumstances in which LSHTM may take steps such as those listed above even where you do not wish to take your report further. This is usually where there are concerns for your safety or another person’s safety. Please see our Privacy Notice together with our separate Duty of Care Guidance for further information.
LSHTM’s intention is that the content of non-anonymous reports made through the Report and Support tool is not routinely used in investigations and disciplinary processes. This is because the Report and Support tool at LSHTM is intended to provide staff, students and others with a portal to report concerns and to seek support in respect of issues of bullying, harassment, sexual misconduct and other forms of threatening or unacceptable behaviour, but It is not intended to be used as a case management system for recording and managing formal complaints and procedures under the relevant LSHTM policy.
If you want your complaint to be investigated through a formal LSHTM procedure, it may be necessary to submit further information using the appropriate form as part of this process.
In circumstances when disclosure of the initial named report to an investigator or as part of a disciplinary process is necessary, then we will ordinarily notify you prior to disclosure. You will have the opportunity to discuss the reasons for the disclosure and to raise any objections that you would like considered.
There are certain circumstances in which LSHTM may take steps such as those listed above even where you do not wish to take your report further. This is usually where there are concerns for your safety or another person’s safety. Please see our Privacy Notice together with our separate Duty of Care Guidance for further information.
LSHTM’s intention is that the content of non-anonymous reports made through the Report and Support tool is not routinely used in investigations and disciplinary processes. This is because the Report and Support tool at LSHTM is intended to provide staff, students and others with a portal to report concerns and to seek support in respect of issues of bullying, harassment, sexual misconduct and other forms of threatening or unacceptable behaviour, but It is not intended to be used as a case management system for recording and managing formal complaints and procedures under the relevant LSHTM policy.
If you want your complaint to be investigated through a formal LSHTM procedure, it may be necessary to submit further information using the appropriate form as part of this process.
In circumstances when disclosure of the initial named report to an investigator or as part of a disciplinary process is necessary, then we will ordinarily notify you prior to disclosure. You will have the opportunity to discuss the reasons for the disclosure and to raise any objections that you would like considered.
3. Meeting with an Anti-Bullying and Harassment Advisors
Our Anti-Bullying and Harassment Advisors are trained in providing initial advice to you on the various support options available, with a focus on informal resolution.
All of our Anti-Bullying and Harassment Advisors are members of LSHTM staff who have undergone mandatory training in both data protection and information security awareness.
In the event the matter proceeds to a disciplinary hearing, it is possible that your meeting may be disclosed to the disciplinary panel, staff supporting the process, the subject of the complaint and their adviser or representative.
All of our Anti-Bullying and Harassment Advisors are members of LSHTM staff who have undergone mandatory training in both data protection and information security awareness.
In the event the matter proceeds to a disciplinary hearing, it is possible that your meeting may be disclosed to the disciplinary panel, staff supporting the process, the subject of the complaint and their adviser or representative.
4. Other Support
The Anti-Bullying and Harassment Policy details other support options including our HR partners and Student Services. Notes that they take are usually retained as a record and may be included as part of a disciplinary process.
5. Investigation
If you make a named report, you will ordinarily have control over whether or not the matter is investigated by LSHTM, except in limited circumstances, in accordance with our duty of care guidance.
6. Disciplinary or other formal hearing
If an investigation takes place, one of the possible outcomes is that the matter is referred to a disciplinary hearing. As noted above, a copy of the initial report made on this tool will not routinely be included in the disciplinary hearing bundle. However, there may be limited occasions when the original report you have made in this reporting tool is disclosed as part of a disciplinary process. An example might be if the subject of the complaint or their advisers has managed to obtain part of your initial report (e.g. through a Data Subject Access Request - see section 3 below) and has identified information in the initial report that is inconsistent or otherwise conflicts with what you have included in your formal report.
7. Litigation
LSHTM tries to resolve complaints internally using its own processes such as the staff disciplinary and student disciplinary processes.
If a claim is brought against LSHTM or (on rare occasions) against any of its employees then there are specific rules LSHTM has to follow concerning the documents it needs to provide to the individual who has started the litigation. This process of providing documents is called disclosure. A copy of the initial report you have made may be disclosed to the person bringing the claim, also referred to as the claimant.
If a claim is brought against LSHTM or (on rare occasions) against any of its employees then there are specific rules LSHTM has to follow concerning the documents it needs to provide to the individual who has started the litigation. This process of providing documents is called disclosure. A copy of the initial report you have made may be disclosed to the person bringing the claim, also referred to as the claimant.
8. Data subject access requests (named reports and anonymous reports)
Under data protection laws, individuals are able to make a data subject request (DSAR) to obtain data held by LSHTM about them.
If you make a DSAR that includes a request that covers your named report then you will receive a copy of your personal data in your report.
If the subject of your complaint makes a DSAR and the scope of their request covers their personal data in your report, then we are legally required to share this. This legal obligation would arise where you have submitted a named report, but could also arise where you have reported anonymously, but named or clearly identified the subject of your complaint in your report and we have not redacted their name/identifying information due to the incident or pattern of behaviour reported giving rise to a safeguarding risk, in accordance with our duty of care guidance. The subject of your complaint would not be entitled to receive details of your name although it is possible that they may be able identify you when we provide their data. An example of when this might be likely is if a specific event or incident is named in the report and the individual requesting the DSAR is able to infer your identity from this information.
Our data protection team will try to balance our aim of protecting your confidentiality with the other person’s right to receive their personal data. When your personal data is inextricably linked with the personal data of the subject of the complaint then LSHTM will apply the rules around mixed data. These rules can be helpful in allowing LSHTM to protect your confidentiality but they do not provide an absolute guarantee we can keep your report confidential.
In addition to being able to request the personal data in the report, both you and the subject of the complaint can request your personal data in any correspondence and documents (whether electronic or hard copy) created following your initial report that is held by LSHTM.
If you make a DSAR that includes a request that covers your named report then you will receive a copy of your personal data in your report.
If the subject of your complaint makes a DSAR and the scope of their request covers their personal data in your report, then we are legally required to share this. This legal obligation would arise where you have submitted a named report, but could also arise where you have reported anonymously, but named or clearly identified the subject of your complaint in your report and we have not redacted their name/identifying information due to the incident or pattern of behaviour reported giving rise to a safeguarding risk, in accordance with our duty of care guidance. The subject of your complaint would not be entitled to receive details of your name although it is possible that they may be able identify you when we provide their data. An example of when this might be likely is if a specific event or incident is named in the report and the individual requesting the DSAR is able to infer your identity from this information.
Our data protection team will try to balance our aim of protecting your confidentiality with the other person’s right to receive their personal data. When your personal data is inextricably linked with the personal data of the subject of the complaint then LSHTM will apply the rules around mixed data. These rules can be helpful in allowing LSHTM to protect your confidentiality but they do not provide an absolute guarantee we can keep your report confidential.
In addition to being able to request the personal data in the report, both you and the subject of the complaint can request your personal data in any correspondence and documents (whether electronic or hard copy) created following your initial report that is held by LSHTM.
9. Further information
Please contact LSHTM’s Data Protection Officer (dpo@lshtm.ac.uk) for further information in this regard.
If you have any questions about confidentiality please contact LSHTM’s Legal and Compliance Team by emailing legal@lshtm.ac.uk.
For further information on how your personal data is processed by or on behalf of LSHTM in the context of Report and Support, please refer to our Privacy Notice.
If you have any questions about confidentiality please contact LSHTM’s Legal and Compliance Team by emailing legal@lshtm.ac.uk.
For further information on how your personal data is processed by or on behalf of LSHTM in the context of Report and Support, please refer to our Privacy Notice.