How you want to notify is up to you. The Working Environment Act does not decide who an employee shall notify, but the law states that anyone who notifies in line with internal procedures will always have notified in a proper manner.

Below, under the heading "What should a notification contain", gives a detailed description of what should be included in the notification.

Students should notify their study programme leader, the Dean, or the student ombudsman.

If you are an employee, you are encouraged to notify your immediate manager who has personnel responsibilities. If the case cannot be resolved with your immediate manager, you can notify the manager at the level above. You can also notify management via your elected representative, safety representative, a colleague, lawyer or others.

If, for various reasons, you as a student or employee do not wish to take up the conditions in your own faculty/department, you may notify your organisation division by using the notification form. 

It is possible to notify anonymously so that the recipient does not know your identity. However, such whistleblowing will be more difficult for Nord University to process, as we cannot follow up with further questions etc. if needed to the whistleblower. Anonymous whistleblowing can be done through the notificaiton form.

There are no formal requirements to the content of a notification. The notification may be written, oral, open or anonymous. The ability to be able to follow up on a notification depends on how complete the notification is.

The following points should be included in a notification:

• your name (you may also choose to remain anonymous)
  
• your faculty, unit or study programme. This can be omitted in the case of anonymous notification.
  
• the date of the occurrence or violation
  
• the time period, if possible date and time for the violation or observation 
  
• description of the issue
  
• place of the observation or violation
  
• other witnesses or persons who may provide information 
  
• any knowledge of previous cases that have an impact on this case
  
• any information as to whether there has been a previous notification of the same or similar conditions.
  

Who handles received notifications?
In each case a specific assessment will be made in relation to who should be involved in the further processing of the case and the actions to be taken. The number of involved parties will be no more than is deemed necessary.

If the notification form is used, this will be received by Legal Advisor Astrid Haugskott Dahl in the Financial and HR Division, and the Organization Manager. 

Whistleblowing cases are processed and archived in accordance with the applicable regulations. 

Protection of the whistleblower

A received notification should be treated confidentially. Your identity will not be made known to more people than is absolutely necessary for the further processing of the case. If you want your identity to be kept confidential, the proceedings will be arranged such that it is protected. 

If it is necessary for the further proceedings that your identity as whistleblower is made known to those who are to take part in the further investigation of the case, then you will be informed of this and who these individuals are. 

Anyone who uses the notification form will receive a confirmation that the notification has been received. If your identity is known you will receive confirmation that the notification has been received, even if it is notified other than by using the notification form.

When the case has been finally processed by Nord University, you will be immediately notified. You will be notified regardless of whether the follow-up has shown that there have been censurable conditions or not.

The Working Environment Act section 2 A-2 establishes protection against retaliation for a worker who notifies in accordance with The Working Environment Act section 2 A-1.

If the method of notification is not justifiable, an employee who reports a violation is not covered by the protection against retaliation or negative consequences.

Consideration to the person who is the subject of whistleblowing

If Nord University decides to proceed with the case after it has been investigated, the person(s) who are being reported will as a general rule be informed of the notification and the information that Nord University has received. Thus, they will have the opportunity to give their version of the case.

Although the basis of the procedures is internal, you will always have the right to report violations to a superior authority or supervisory or other public authorities. Depending on the content of the notification, this may be the Police, the Norwegian Data Protection Authority, the Norwegian Labour Inspection Authority, the Equality and Anti-Discrimination Ombudsman, the Parliamentary Ombudsman, the Office of the Auditor General Norway, Nokut or the Ministry of Education.

You may also have the right to report violations to the general public. You should be aware that there are more stringent requirements for caution when reporting violations to the general public than internally or to public authorities (see below). 

If you have any questions regarding external violations, please contact Legal Advisor Astrid Haugskott Dahl,  Astrid.H.Dahl@nord.no, Tel. 74 02 26 28. Students may also contact the student ombudsman

In some cases, you will not only have a right, but also an obligation to report violations. It will always be lawful to report violations in accordance with a whistleblowing obligation in law, instruction or regulations. 

An example of a whistleblowing obligation pursuant to law is The Working Environment Act section 2-3 d)   on harassment in the workplace.

 Safety representatives have a special whistleblowing obligation under The Working Environment Act section 6-2 third paragraph.

It is also stated in Ethical Guidelines for the Public Service clause 2.2
in order to implement measures to avoid or limit losses or damages, public officials are required to report to their employer any circumstances of which she or he is aware that could cause the employer, employee or the surroundings to suffer losses or damages. 

For the disclosure to be reliable, you as whistleblower are required to:

• have factual grounds for the criticism
• have been in good faith regarding the factual censurable conditions
• have taken consideration to the employees and the organization in the way you notify
• have assessed whether the issue is of general interest, and the extent to which the information may harm Nord University's reputation.

The notification is unjustified if you do it in a way that is harassing or unnecessarily stressful for the work environment, if the notification could instead be made in a non-stressful manner. 

The notification is also unjustified if you knowingly present groundless allegations directed at colleagues or repeat allegations after the issue has been clarified.

A whistleblower who goes through the official channels, or notifies others at Nord University who have the responsibility or influence in relation to what is being disclosed, is acting in accordance with the law.

You have also always the right to blow the whistle in accordance with obligations arising from law, regulations, agreement, instructions and the like.

Reporting violations to a superior authority or to supervisory- or regulatory authorities, has the same requirements to reliability as internal whistleblowing.

The risk of inflicting injury on Nord University and/or its employees is usually much greater when reporting violations to the general public. The requirement of reliability for whistleblowing to the general public is therefore stricter than for internal whistleblowing or whistleblowing to a superior authority or supervisory bodies, and great care should be exercised when considering whether to report a violation to the public.

Anyone who blows the whistle to the media, via blogs, social media or otherwise makes the information available to the public, should have attempted initially to report internally in the organisation, to a superior authority or to a supervisory body or regulatory agency. 

You should first consider the following three conditions especially carefully when reporting violations to the general public:

• Is there reason to believe that censurable conditions actually exist?
• You should investigate the actual circumstances as thoroughly as possible.
• Is internal reporting, or reporting to a superior authority/supervisory body or regulatory agency possible or appropriate?
  
• Does the general public or others outside the organisation have a justified interest in knowing of the conditions?
  

Praise and criticism related to student life
If you wish to praise or criticize or make suggestions for improvements related to your life as a student you can use this form. Here are all students and staff welcome to let us know about conditions they think are important to follow up. The notifications provided through this form are handled by, among others, by the Learning Environment Committee at Nord University.

Privacy protection

Errors and deviations may arise in connection with all forms of manual or electronic processing of personal data in teaching, research or administration. Anyone who becomes aware of data security breaches, or gets to know that personal data is being processed in violation of the law or applicable procedures should report this. 

There should be a low threshold for reporting deviations. Your reporting is a prerequisite for Nord University to be able to correct errors that have occurred. For deviations linked to privacy protection or data security, you can use a separate notification form. If you notify via this form, your notification will go directly to the data controller. For more information about privacy protection at Nord University, see here. 

HSE for employees

It is important that employees report HSE deviations. According to the Working Environment Act, employees should be actively involved in the implementation of the measures that are initiated to create a good working environment. Reporting deviations is such a measure. For deviations related to HSE for employees, you can usea separate notification form. If you notify via this form, your notification will go directly to the responsible manager.