Establishing what happened.
WHAT TO DO FIRST
Decide who investigates.
WHAT THAT PERSON MUST BE
Independent of those involved Competent Able to act without interference
WHY INDEPENDENCE
Investigation by an interested party is not accepted and it is rarely accurate.
WHAT TO ESTABLISH AT THE OUTSET
What is being investigated What evidence exists Whether anything must be preserved Whether anyone should be suspended pending the outcome
WHY PRESERVATION FIRST
Records and access are altered once an investigation is known about.
WHAT TO PRESERVE
Documents, systems access logs, communications and financial records.
WHAT TO DO ABOUT SUSPENSION
Consider it where the person could interfere or where continued presence is inappropriate.
WHAT TO ESTABLISH
That suspension is not a finding.
WHAT INVESTIGATION INVOLVES
Gathering documents Interviewing those involved and witnesses Establishing facts, not conclusions Recording everything
WHAT TO PROVIDE THE PERSON CONCERNED
The allegations, in sufficient detail to respond An opportunity to respond The right to be accompanied, where applicable
WHY
Fairness is required, and findings made without it are challenged successfully.
WHAT TO AVOID
Deciding before investigating Discussing the matter widely Confronting someone without preparation
WHAT TO PRODUCE
A factual report: what was examined, what was found, and what is concluded.
WHAT TO DECIDE SEPARATELY
The consequence.
WHAT TO CONSIDER
Whether the matter must be reported externally.
WHY
Some findings carry reporting obligations.
WHAT TO ADDRESS
The control failure that allowed it.
