(1) This policy establishes a framework at the University of New England (UNE) for reporting and investigating allegations of wrongdoing, without fear of reprisal. (2) This framework sets out: (3) This policy documents UNE’s commitment to building a ‘speak up’ culture by having in place a framework that facilitates public interest reporting of wrongdoing by: (4) All agencies in NSW are required to have a Public Interest Disclosure (PID) Policy under section 42 of the Public Interest Disclosures Act 2022 (PID Act). (5) The University of New England (UNE) takes reports of serious wrongdoing seriously. UNE is committed to building a ‘speak up’ culture where public officials are encouraged to report any conduct that they reasonably believe involves wrongdoing. The integrity of UNE relies upon its staff, volunteers, contractors, and subcontractors speaking up when they become aware of wrongdoing. (6) This policy outlines what members of the UNE community should do if they suspect serious wrongdoing at UNE or other government agencies. (7) This policy should be read in conjunction with the UNE Code of Conduct and associated information. (8) The University of New England (UNE) is committed to: (9) This policy is available in the policy register of UNE’s publicly available website and is brought to the attention of all staff of UNE on their commencement and through regular training. (10) A copy of the policy is also sent to all staff of UNE on their commencement. (11) A hard copy of the policy can be requested from the Governance Directorate. (12) Within this policy: (13) This policy will provide a person who would like to make a report with information on the following: (14) If a person who would like to make, or has made, a report requires further information about this policy, how public interest disclosures will be handled at UNE or the PID Act they can: (15) If a person who would like to make, or has made, a report requires legal advice with respect to the PID Act or their obligations under the PID Act, they may need to seek independent legal advice at an individual’s cost unless prior approval from the Vice-Chancellor is provided. (16) This policy applies to, and is for the benefit of, all public officials in NSW. (17) A public official is defined in section 14 of the PID Act. (18) For UNE this includes: (19) The Vice-Chancellor and Chief Executive Officer (VC&CEO), Disclosures Coordinator (Chief Audit Executive), Disclosures Officers, Chair of UNE Council’s Audit and Risk Committee, and managers within UNE have specific responsbilities under the PID Act. This policy also provides information on how people in these roles will fulfill their responsibilities. (20) This policy does not apply to people who are not public officials, such as: (21) This means that if a person is not a public official, this policy will not apply to their report of serious wrongdoing. There are some circumstances where this can be deemed to be a voluntary PID (see clause 51-55). (22) However, a person who is not within the scope of this policy may still make a complaint to UNE. This can be done by the complaints and grievance processes. (23) This policy is not intended to be used for personal work-related staff grievances. (24) Staff are encouraged to report suspected or possible wrongdoing at UNE. (25) When a public official within the UNE community reports a suspected or possible wrongdoing at UNE, their report will be a PID if it has certain features which are set out in the PID Act. (26) Some internal complaints or internal grievances may also be PIDs, if they have the features of a PID. (27) If an internal complaint or grievance is a report of serious wrongdoing, UNE will consider whether it is a PID. If it is a PID, UNE will deal with it as set out in this policy but will also follow any other applicable and relevant policy such as the Fraud and Corruption Control Policy. (28) A report of suspected or possible serious wrongdoing occurring at UNE will be a PID if it has certain features which are set out in the PID Act. There are three types of PID in the PID Act. These are: (29) This policy applies mostly to making a voluntary PID and how UNE will deal with voluntary PIDs. People who make a mandatory PID or a witness PID are still entitled to protection. More information about protections is available in this policy under the heading ‘Protections’. (30) Voluntary PIDs are most often in mind when people think about public interest reporting and whistleblowing. They involve a public official making a report because they have information that they believe shows, or tends to show, serious wrongdoing, where they are not under a legal obligation to make that report and where it is not an ordinary part of their role to report such wrongdoing. (31) A report is a voluntary PID if it has the following five features which are set out in sections 24-27 of the PID Act: (32) If the report has all five features, it is a voluntary PID. (33) A person making a report is not expected to prove that what they reported happened or is serious wrongdoing. However, a reporter must honestly believe, on reasonable grounds, that the information they are reporting shows or tends to show serious wrongdoing. (34) Even though a person making a report does not have to prove the serious wrongdoing happened or provide evidence, an allegation with no supporting information is unlikely to meet this test. (35) If UNE makes an error and does not identify that a reporter has made a voluntary PID, the reporter will still be entitled to the protections under the PID Act. (36) If the person making a report believes UNE has made an error by not identifying that they have made a voluntary PID, they should raise this with a nominated Disclosures Officer or contact officer for the report. If they are still not satisfied with this outcome, they can seek an internal review, or the UNE may seek to conciliate the matter. A person making a report may also contact the NSW Ombudsman. Further information on rights to internal review and conciliation is found in this document under Part E – Review and Dispute Resolution. (37) Any public official can make a voluntary PID. A person making a report is a public official if: (38) A public official can make a PID about serious wrongdoing relating to any agency, not just UNE. This means that UNE may receive PIDs from public officials outside of UNE. It also means that a UNE staff member can make a PID to any agency, including an integrity agency such at the Independent Commission Against Corruption (ICAC) and the NSW Ombudsman. A list of integrity agencies can be found in Appendix B of this policy. (39) Reports must be one or more of the following categories of serious wrongdoing to be a voluntary PID. This is in addition to having the features set out in Clause 31 of this policy. Serious wrongdoing is defined in the PID Act as: (40) When a person makes a report, they do not need to state to UNE what category of serious wrongdoing they are reporting or that they are reporting serious wrongdoing. (41) For a report to be a voluntary PID it must be made to certain public officials as described below: (42) A person wishing to make a report can also make it to a public official in another agency (meaning an agency other than UNE or another agency that they do not work for) or an integrity agency. These include: (43) If a reporter chooses to make a disclosure outside of UNE, it is possible that their disclosure will be referred to UNE so that appropriate action can be taken. (44) Disclosures to members of parliament (MPs) or journalists are different to other reports. A person can only disclose a report of wrongdoing as a voluntary PID to an MP or journalist in the following circumstances: (45) Investigation period means: (46) If all the above conditions are met, the disclosure from the person making a report to an MP or journalist may be a voluntary PID. (47) A person making a report can make a voluntary PID: (48) A person making a report should provide as much information as possible so that UNE can deal with the report effectively. The type of information a person making a report should include is (a template for written reports can be used): (49) The UNE community is encouraged to report all wrongdoing they become aware of regardless of whether they think it is serious wrongdoing. It is important for UNE to understand what is or what may be occurring. (50) UNE is responsible for making sure all reports are handled appropriately under the PID Act, or if it not a PID, in accordance with relevant policies or other legislation. Even if a report is not a PID, it may fall within another one of UNE’s policies for dealing with reports, allegations, or complaints. (51) The Vice-Chancellor and CEO can, in certain circumstances, determine that a report is a voluntary PID even if the report does not otherwise have all the features of a voluntary PID. This is known as the ‘deeming power’. (52) By deeming that a report is a voluntary PID, it ensures that reporters are provided with protections under the PID Act. (53) If a person is making a report that has not met all the requirements of a voluntary PID, they can refer their matter to Vice-Chancellor and CEO to request that the Vice-Chancellor and CEO consider deeming their report to be a voluntary PID. (54) A decision to deem a report to be a voluntary PID is at the discretion of the Vice-Chancellor and CEO. (55) For more information about the deeming power, see the NSW Ombudsman’s guideline ‘Deeming that a disclosure is a voluntary PID’. (56) If anyone has concerns or questions about this policy or reporting wrongdoing at UNE, they are encouraged to contact the Director Governance and University Secretary at governance@une.edu.au or via phone +61 2 6773 1241. (57) When someone makes a voluntary PID they receive special protections under the PID Act. (58) UNE is committed to taking all reasonable steps to protect anyone from detriment because of having made a PID. UNE is also committed to maintaining their confidentiality as much as possible while the PID is being dealt with. (59) UNE will not tolerate any type of detrimental action being taken against an individual because they have made a report, might make a report, or are believed to have made a report. (60) The maker of a voluntary PID is protected in the following ways: (61) There are other types of reports that are recognised as PIDs under the PID Act, other than PIDs made voluntarily by public officials. (62) Protections for makers of mandatory and witness PIDS are detailed in Table 1 below: (63) If anyone experiences adverse treatment or detrimental action, such as bullying or harassment, they should report this immediately. A person can report any experience of adverse treatment or detrimental action directly to the Disclosures Coordinator, or to an integrity agency. (64) UNE’s Employee Assistance Program (EAP) can be contacted to provide UNE staff with independent and confidential support. (65) A person making a report may also contact the NSW Ombudsman if they have a question about the PID Act or reporting generally. (66) UNE understands that people who make voluntary PIDs may want their identity and the fact that they have made a report to be confidential. (67) Under the PID Act, information tending to identify a person as the maker of a voluntary PID (known as identifying information) is not to be disclosed by a public official or the University. (68) There are certain circumstances under the PID Act that allow for the disclosure of identifying information. These include: (69) UNE will not disclose identifying information unless it is necessary and authorised under the PID Act. (70) UNE will put in place steps to keep the identifying information of the maker and the fact that a report has been made confidential. It may not be possible for UNE to maintain complete confidentiality while UNE progress the investigation, but UNE will do all that UNE practically can to not unnecessarily disclose information from which the maker of the report can be identified. UNE will do this by: (71) It is also expected that the individual making the report will maintain confidentiality. (72) If confidentiality cannot be maintained or is unlikely to be maintained, UNE will: (73) UNE will not tolerate any detrimental action being taken by any person against a person who has made a PID, investigators, witnesses, or the person the report is about. (74) UNE will assess and take steps to mitigate detrimental action from being taken against the maker of a voluntary PID, the person whose conduct is the subject of a PID, investigators and witnesses. (75) UNE will take steps to assess and minimise the risk of detrimental action by: (76) Detrimental action against a person is an act or omission that causes, comprises, involves, or encourages detriment to a person or a threat of detriment to a person (whether express or implied). Detriment to a person includes: (77) Detrimental action does not include: (78) If UNE becomes aware of an allegation that a detrimental action offence has occurred or may occur, UNE will: (79) When a disclosure officer in UNE receives a report which is a voluntary PID, or looks like it may be a voluntary PID, the person who made the report will receive the following information: (80) Once a report that may be a voluntary PID is received UNE will look at the information contained in the report to see if it has the features of a voluntary PID. This assessment is undertaken to identify whether the report is a voluntary PID or another type of disclosure, and to make sure that the right steps are followed. If it is a voluntary PID, UNE will ensure that UNE complies with the requirements in the PID Act. (81) Even if the report is not a voluntary PID, it will still need to be dealt with in a manner consistent with UNE’s complaints handling processes or through an alternate process. (82) If the report is not a voluntary PID, UNE will let the person making the report know that the PID Act does not apply to the report and how UNE will deal with the concerns raised in the report. (83) If the person making the report is not happy with this assessment or otherwise disagrees with it, they can raise it with the person who has communicated the outcome with them or a disclosure officer, request an internal review or request that the matter be conciliated. UNE may, but does not have to, request the NSW Ombudsman to conciliate the matter. (84) UNE may stop dealing with a voluntary PID because it is not actually a voluntary PID (meaning it does not have all the features of a PID). Where this is the case the person who made the report will receive communication outlining: (85) If the report is a voluntary PID: (86) An authorised Disclosures Officer who receives a report of wrongdoing will: (87) Where a report of wrongdoing is about the Vice-Chancellor and Chief Executive Officer it must be forwarded to the Chair of UNE Council’s Audit and Risk Committee for assessment. The Chair will have the power to engage with the Disclosures Coordinator or Chief Financial Officer to obtain funds or resources for investigation as appropriate. (88) Where a report of wrongdoing is about the Disclosures Coordinator it must be forwarded to the Vice-Chancellor and Chief Executive Officer for assessment. (89) The report will be assessed, and a determination made that: (90) Where immediate action is required to protect the safety of people, animals or the environment, the Disclosures Coordinator will enact any relevant emergency management procedures. (91) The Disclosures Coordinator will consult with the Vice-Chancellor and Chief Executive Officer for the purpose of management of reports, including: (92) Where the Disclosures Coordinator determines that the report will be investigated as a voluntary PID under the PID Act or a wrongdoing under the Corporations Act, they will gather preliminary facts to determine whether there may be a case to answer. The Disclosures Coordinator may also delegate the preliminary appraisal to a Disclosures Officer. (93) The preliminary appraisal will be completed promptly to determine what action will be taken to deal with the report of wrongdoing, and the findings will be referred, in order of preference, to: (94) Throughout all preliminary appraisals and investigations, actions will be taken as appropriate to: (95) Where required, advice may be sought from others within UNE, including the Director People and Culture, Director Legal Services or Internal Audit staff, while maintaining confidentiality as far as practicable. (96) Unauthorised investigations by line managers or by any member of staff are prohibited. (97) If, after an investigation, it is found that serious wrongdoing or other misconduct has occurred, UNE will take the most appropriate action to address that wrongdoing or misconduct. This is also known as corrective action. (98) The Vice-Chancellor and CEO will receive the findings of an investigation. Where the Vice-Chancellor has a conflict of interest, the Chair of the Audit and Risk Committee will receive the findings of the investigation. (99) Any recommendations arising from an investigation will be agreed by UNE, and an owner and due date assigned. The owner will receive the action, but depending on circumstances may not receive the report. (100) The Internal Audit Directorate will record and track the implementation of any recommendations that arise from an investigation and report progress to the Audit and Risk Committee. (101) It is a criminal offence under the PID Act and Corporations Act to willfully make a false or misleading statement when reporting wrongdoing. UNE will not support UNE Representatives who willfully make false or misleading reports. Such conduct may also be a breach of the UNE Code of Conduct and result in disciplinary action. (102) UNE is committed to ensuring staff or officers who are the subject of a report of wrongdoing are treated fairly and reasonably. This includes keeping the identity of any person the subject of a report and the allegations or investigation confidential, where this is practical and appropriate. (103) A person who is the subject of the report will be advised of the allegations made against them at an appropriate time (aligned with the assessment process) and before any adverse findings. At this time, they will be: (104) People who make voluntary PIDs can seek an internal review of the following decisions made by UNE: (105) UNE will ensure internal reviews are conducted in compliance with the PID Act. (106) If the person who made the report would like to make an application for an internal review, they must apply in writing within 28 days of being informed of the UNE’s decision. The application should state the reasons why they consider the UNE’s decision should not have been made. They may also submit any other relevant material with their application. (107) If a dispute arises between UNE and a person who has made a report which is, or may be, a voluntary PID, UNE may request the NSW Ombudsman to conciliate the dispute. Conciliation is a voluntary process and will only be suitable for disputes where UNE and the maker of the report are willing to resolve the dispute. (108) UNE must keep full and accurate records with respect to all information received in connection with the PID Act. This ensures that UNE complies with its obligations under the State Records Act 1998. (109) Records of PIDs will be kept confidentially in Content Manager. (110) A register of PIDs will be maintained. (111) Each year UNE provides an annual return to the NSW Ombudsman which includes: (112) The Internal Audit Directorate maintains a register of PIDs and relevant documents in Content Manager and will prepare the Annual Return. (113) The PID Act is captured in the UNE Compliance process. (114) The Vice-Chancellor and CEO has ultimate responsibility for ensuring compliance with the Act and will make, at least annually, enquiries and investigations into compliance. (115) Where non-compliance is identified, the Vice-Chancellor and CEO will require the responsible officer to remediate the item and ensure compliance. (116) Items of non-compliance will be reported to the Audit and Risk Committee. (117) A report will be a protected report under the Corporations Act where it relates to misconduct, an improper state of affairs or circumstances in relation to UNE or its controlled entities, a contravention of or offence under various Commonwealth financial laws, an offence under a Commonwealth law that is punishable by imprisonment for a period of 12 months or more, or represents a danger to the public or the financial system and it is made in accordance with this policy. (118) Reports of wrongdoing that constitute an offence against, or a contravention of, a provision of any of the following Commonwealth financial laws will be protected reports under the Corporations Act: (119) People who can make a protected disclosure under the Corporations Act are: (120) People who have been authorised by UNE to receive reports of wrongdoing that may be protected reports under the Corporations Act are the persons listed in Annexure A to this policy. (121) It is also possible that a report of wrongdoing may be protected under the Corporations Act where the report is made to a journalist, a member of parliament, or an external legal advisor. Any person considering making a report of wrongdoing, that will be protected by the Corporations Act to a journalist, a member of parliament, or an external legal advisor should review the provisions of Part 9.4AAA of the Corporations Act to ensure that their disclosure will meet the necessary conditions for protection. The following is a summary only and should not be used to decide whether to make a report to a member of parliament or a journalist: (122) An emergency disclosure made to an MP, or a journalist may qualify for protection if all the following are met: (123) Where a person reports wrongdoing that is not a PID and not protected by the Corporations Act, UNE will, insofar as is reasonably practicable, keep the identity of the reporter confidential. The identity of a person who makes a report of wrongdoing that is protected under the Corporations Act will be kept confidential by UNE but it may be disclosed if one of the following exceptions applies: (124) A report of wrongdoing that UNE determines is protected by the Corporations Act will be investigated in substantially the same way that a voluntary PID is investigated by UNE (as set out in this policy). (125) UNE will protect and support a person who makes a report of wrongdoing that is a protected report under the Corporations Act in substantially the same way (as set out in this policy) that UNE will protect a person who makes a report that is a voluntary PID. (126) All other wrongdoing or suspected wrongdoing should be reported by UNE Representatives to a supervisor, to be dealt with in accordance with the relevant policies. This might include: (127) Certain people within UNE have responsibilities under the PID Act. (128) The Vice-Chancellor and CEO is responsible for: (129) The Disclosures Coordinator is responsible for: (130) Disclosure officers are responsible for: (131) The responsibilities of managers include: (132) All employees must: (133) Staff can also seek advice and guidance from the Disclosures Coordinator and via the disclosures or whistleblower sections of the websites of the NSW Ombudsman, ACNC or ASIC. (134) The custodian of this policy and principles the Audit and Risk Committee of Council makes this policy. (135) UNE Representatives must observe this policy in relation to public interest and whistleblower disclosures. A failure to comply with this policy may amount to misconduct/serious misconduct and/or unsatisfactory performance. (136) This policy is consistent with the PID Act and with guidelines of the NSW Ombudsman and with the protection of whistleblowers provisions of Part 9.4AAA of the Corporations Act. (137) This policy operates as and from the Effective Date. Previous rules and procedures are replaced from the Effective Date. (138) This policy takes effect pursuant to Section 25 of the University of New England By-law 2005. To the extent this policy conflicts with the University of New England Act 1993 (NSW) (the UNE Act) or UNE University of New England By-law 2005, University of New England Act 1993 (NSW) or University of New England By-law 2005 prevails to the extent of the conflict and this policy must be read down accordingly. This policy operates as a delegation by Council under Section 17 of the University of New England Act 1993 (NSW). (139) UNE will report on statistics of public interest disclosures and whistleblowing to the NSW Ombudsman and yearly in its annual report. (140) Records and communications regarding these matters will be kept securely in UNE’s records management system. (141) Breach of the GIPA Act. A breach of the Government Information (Public Access) Act 2009 (NSW) (GIPA Act) is a failure to properly fulfil functions under that Act. For example, this could include a. destroying, concealing, or altering records to prevent them from being released; b. knowingly making decisions that are contrary to the legislation; or c. directing another person to make a decision that is contrary to the legislation. (142) Corrupt conduct is the dishonest or partial exercise of official functions by a public official. For example, this could include: the improper use of knowledge, power or position for personal gain or the advantage of others; acting dishonestly or unfairly or breaching public trust; or a public official being influenced by a member of public to use their position in a way that is dishonest, biased or breaches public trust. For more information about corrupt conduct see the NSW Ombudsman's Guidelines on what can be reported. (143) Maladministration is conduct that involves action or inaction of a serious nature that is contrary to law, unreasonable, unjust, oppressive, or improperly discriminatory or based wholly or partly on improper motives. For example, this could include a. deciding and/or taking action that is unlawful; or awarding contracts and tenders to private parties that are related by family, friendship, or association. For more information about Maladministration see the NSW Ombudsman's Guidelines on what can be reported. (144) Misconduct is defined in section 9 of the Corporations Act to include fraud, negligence, default, breach of trust or breach of duty. (145) Relative, in relation to a person means the spouse, parent or remoter lineal ancestor, child or remoter issue or brother or sister of the person. (146) Serious and Substantial Waste of Public Money is the uneconomical, inefficient, or ineffective use of resources that could result in losing or wasting public money. For example, this could include a. misappropriation or misuse of public property, or b. the purchase of unnecessary or inadequate goods and services. For more information about Serious and Substantial waste of public money see the NSW Ombudsman's Guidelines on what can be reported.Reporting Wrongdoing at UNE Policy
Section 1 - Purpose and scope
Purpose
Principles
Accessibility of this policy
The policy
Part A - Overview and scope
Scope
Who does this policy apply to?
Who does this policy not apply to?
Part B - How to make a report of serious wrongdoing
Reports, complaints, and grievances
Types of Public Interest Disclosures (PID)
Voluntary PIDs
Who can make a voluntary PID?
What is serious wrongdoing?
Who can I make a voluntary PID to?
Making a report to a recipient outside of UNE
Making a report to a member of parliament or a journalist
What form should a voluntary PID take?
What should I include in my report?
What if I am not sure if my report is a PID?
Deeming that a report is a voluntary PID
Who can I talk to if I have questions or concerns?
Part C - Protections
How is the maker of a voluntary PID protected?
Protections for people who make mandatory and witness PIDs
Protection
Mandatory PID
Witness PID
Yes
Yes
Right to compensation – a person can initiate proceedings and seek compensation for injury, damage or loss suffered because of detrimental action being taken against them.
Yes
Yes
Ability to seek an injunction – an injunction can be sought to prevent the commission or possible commission of a detrimental action offence against a person. For example, an order to prevent dismissal or to require reinstatement.
Yes
Yes
Yes
Yes
Reporting detrimental action
General support
How UNE will protect the confidentiality of the maker of a voluntary PID
How UNE will assess and minimise the risk of detrimental action
How UNE will deal with allegations of a detrimental action offence
Part D - How UNE will deal with reports of serious wrongdoing
How reports will be received and reporters kept informed
How UNE will deal with voluntary PIDs
When a report is not a PID
Where the report is a voluntary PID
Receiving a report
Management of reports
Investigation of reports
What UNE will do if an investigation finds that serious wrongdoing has occurred
Honesty in reporting and sanctions for making false or misleading statements
Rights of persons who are the subject of a report
Part E - Review and dispute resolution
Internal review
Voluntary dispute resolution
Part F - Other University obligations
Record keeping requirements
Reporting of voluntary PIDs and UNE annual return to the Ombudsman
How UNE will ensure compliance with the PID Act and this policy
Part G - Procedures for making and receiving protected disclosures under the Corporations Act
Part H - Roles and responsibilities of UNE staff
Vice-Chancellor and CEO
Disclosures Coordinator
Disclosure Officers
Managers
All employees
More information
Section 2 - Authority and compliance
Section 3 - Quality Assurance
Section 4 - Definitions specific to this policy
Section 5 - Delegations or Powers in the Policy
Role
Power or Delegation
Reference
Vice-Chancellor and Chief Executive Officer
In certain circumstances, determine that a report is a voluntary PID even if the report does not otherwise have all the features of a voluntary PID.
Clauses 51-55
Disclosures Coordinator in consultation with the Vice-Chancellor and Chief Executive Officer
Disclosures Coordinator determines if a report will be investigated as a voluntary PID under the PID Act
Clause 91
Chair of Audit and Risk Committee
Consider reports relating to the Vice-Chancellor and CEO. The Chair will have the power to engage with the Disclosures Coordinator or Chief Financial Officer to obtain funds or resources for investigation as appropriate.
Clause 87
Annexure A
Annexure B
Integrity agency
What they investigate
Contact information
The NSW Ombudsman
Most kinds of serious maladministration by most agencies and public officials (but not NSW Police, judicial officers or MPs)
The Auditor-General
Serious and substantial waste of public money by auditable agencies
Independent Commission Against Corruption
Corrupt conduct
The Inspector of the Independent Commission Against Corruption
Serious maladministration by the ICAC or the ICAC officers
The Law Enforcement Conduct Commission
Serious maladministration by the NSW Police Force or the NSW Crime Commission
The Inspector of the Law Enforcement Conduct Commission
Serious maladministration by the LECC and LECC officers
Office of the Local Government
Local government pecuniary interest contraventions
Email: olg@olg.nsw.gov.au
The Privacy Commissioner
Privacy contraventions
The Information Commissioner
Government information contraventions
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Detrimental action – it is an offence to take detrimental action against a person based on the suspicion, belief or awareness that a person has made, may have made or may make a PID.
Immunity from civil and criminal liability – a person will not incur civil or criminal liability if the person breaches a duty of confidentiality while making a disclosure. This means that legal action cannot be taken against a person for:
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