Whistleblower Policy
Confidential reporting, fair investigations, and zero tolerance for retaliation.
1) Purpose
Digital Safe‑Havens Network (DSN) is committed to lawful, ethical operations. This policy provides safe, confidential channels to report suspected misconduct and assures a fair process without retaliation for good‑faith reports.
2) Scope
Applies to all DSN directors, officers, employees, volunteers, contractors, and partners (“Covered Persons”). Reportable concerns include:
- Fraud, theft, bribery, or corruption
- Violations of law, regulation, or DSN policy
- Data protection or cybersecurity breaches; misuse of confidential information
- Conflicts of interest, financial misstatements, or improper donor/fund use
- Harassment, exploitation, discrimination, or safety risks
3) Reporting Channels
- Email (Confidential): whistleblower@digitalsafehavens.org (monitored by Audit & Finance Chair)
- Alternate: ethics@digitalsafehavens.org (Ethics/COI designee)
- Postal Mail: “Confidential – Whistleblower” to the Board Chair (address available on request)
In emergencies or imminent risk, contact local authorities first.
4) Confidentiality & Anonymity
DSN protects the identity of reporters to the maximum extent possible and permits anonymous reports. Information is shared strictly on a need‑to‑know basis to investigate and address the concern.
5) Good‑Faith Standard
Reports must be made honestly and with reasonable grounds. Knowingly false or malicious reports may result in corrective action.
6) Intake & Investigation Process
- Intake: The Audit & Finance Chair (or designee) logs the report and assesses urgency, scope, and risk.
- Assignment: An impartial investigator or committee is appointed; conflicts are screened.
- Inquiry: Fact‑finding, document review, and interviews are conducted discreetly and promptly.
- Outcome: Findings are documented; corrective actions and learnings are tracked to completion.
- Feedback: When feasible, DSN provides status or outcome summaries to the reporter.
7) Non‑Retaliation
Retaliation against any person who makes a good‑faith report or participates in an investigation is strictly prohibited. Alleged retaliation will be investigated and may result in disciplinary action up to termination or removal.
8) Interim Protections
DSN may implement interim measures—e.g., schedule or reporting‑line adjustments, access controls, or separation—while an investigation is pending.
9) Recordkeeping & Reporting
- All cases are logged with dates, allegations, steps taken, and outcomes.
- Aggregate metrics are reported to the Board (and Audit & Finance Committee) at least annually.
- Records are retained per DSN’s retention schedule and applicable law.
10) External Reporting
Where required by law or contract, DSN may report certain matters to regulators, funders, or law enforcement. This does not prevent individuals from reporting directly to authorities as permitted by law.
11) Governance & Oversight
The Board oversees the policy, ensures independence of investigations, and reviews systemic improvements arising from cases. See also: Conflict of Interest and Code of Ethics.
12) Training & Communication
DSN provides onboarding and periodic refreshers on reporting rights, channels, and protections. Policy changes are communicated across the organization and posted on the website.
13) Effective Date & Updates
This policy takes effect upon publication and will be reviewed at least annually.
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