Last year, the BRC (British Retail Consortium) released Version 8 of the BRC Global Standard for Food Safety. The update included the new clause 1.1.6, which meant that having a "confidential reporting system" (whistleblowing system) in place became obligatory. The BRC Global Standard for Food Safety was updated to reflect the latest thinking in food safety and provides a framework to assist food manufacturers in the production of safe food. The intention is that this will ensure global applicability in line with the Global Food Safety Initiative (GFSI) and encourage the development of a broader food safety culture. In this article, WhistleB explains what to keep in mind when implementing a whistleblowing system in line with the BRC Global Standard for Food Safety.
Confidential reporting system
According to clause 1.1.6 of the BRC Global Standard for Food Safety, companies "shall have a confidential reporting system to enable staff to report concerns relating to product safety, integrity, quality and legality. The mechanism (e.g. the relevant telephone number) for reporting concerns must be clearly communicated to staff. The company's senior management shall have a process for assessing any concerns raised. Records of the assessment and, where appropriate, actions taken, shall be documented."
Based on the main elements of clause 1.1.6, here are some of the near-term actions you can take and questions you can start to consider.
1. Confidential reporting
Does your system live up to the requirements? Is it currently a telephone hotline, email or a digital solution? Does it allow a whistleblower's identity to remain confidential? Can it handle a potential increase in the number of reports received? These are all important questions when assessing your current or envisaged reporting system.
2. Communication to employees
It is critical to encourage internal reporting as far as possible. Communication is a fundamental element in this. Show your employees and others that your organisation is open to whistleblowing, that you value whistleblowing information, and that leaders are committed to listen to and to act on reports received.
2. Case assessment
Do you have competent resources in place for receiving and responding to reports? Think through which roles might be appropriate in your whistleblowing team. This may involve non-operational individuals, such as members of the Board and internal audit as well as managers from a range of functions including Compliance, HR, Sustainability or the CFO.
4. Documentation of case management
Any processing of personal data must be carried out in accordance with the GDPR. Make sure that your whistleblowing system allows archiving or deletion of personal data that is manifestly not relevant for the handling of a specific case without undue delay (GDPR principles of data minimisation and storage limitation). As clause 1.1.6 states, records must be kept of every report received. This should be done in compliance with the GDPR principle of integrity and confidentiality or security. Ensure that your whistleblowing system allows for secure case management, traceability, (automated) record keeping and deletion in line with the GDPR principle of accountability.
What this means for you
BRC Global Standards is a leading brand and consumer protection organisation, used by more than 27,000 suppliers in over 130 countries, with certification issued through a global network of accredited certification bodies. Since 1st February 2019, all audits are being carried out according to the standard's latest version.
Success factors for a trustworthy whistleblowing system
In order to have a trusted and well-functioning whistleblowing service in place, the following elements are key:
- Anonymous reporting should be possible and explained to the potential whistleblower in detail. Data security and data privacy is the number one priority.
- The purpose of whistleblowing, to ensure that the ethical principles in the Code of Conduct are respected, must be communicated by the board and management.
- A well thought-through investigation process needs to be put in place and communicated.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
