Guidance material

Managing internal investigations

Information for organisations authorised to receive Public Interest Disclosures (PIDs)

If you’re authorised to receive Public Interest Disclosures, or PIDs for short, or if you’re a PID Coordinator, you play a vital role in supporting and protecting potential whistleblowers who speak out against wrongdoing in the public sector.

In some circumstances your organisation may need to conduct an internal investigation into improper conduct.

  • IBAC is Victoria’s independent anti-corruption and police oversight agency. We’re here to prevent and expose public sector corruption and police misconduct, with the overall goal of strengthening integrity within our state.

    IBAC plays an important role in managing and investigating PIDs in Victoria. This includes assessing PIDs and making decisions about what happens next. IBAC also has an important role in providing guidance and education about the PID legislation.

  • You must notify IBAC when you receive a potential PID.

    There may also be circumstances which require you to report a matter to another agency, such as Victoria Police, if you are concerned about serious threats to the life, safety or welfare of an individual.

  • Q. What happens next?

    A. When you notify IBAC of a disclosure, IBAC will assess if it fits the criteria for a PID. We will then take one of three possible actions.

    We will either:

    • investigate the disclosure
    • refer the disclosure to an investigative agency like the Victorian Ombudsman
    • or, if the disclosure does not meet our assessment criteria, IBAC will take no further action.


    Q. When would a public sector organisation be required to conduct an internal investigation into alleged improper conduct?

    A. When IBAC refers a complaint or disclosure received back to a public sector organisation, it typically means that we have determined the organisation is better placed to deal with the matter. The reasons could include that the matter is not deemed serious or systemic corruption or misconduct, that it’s more aligned with the organisation’s area of responsibility, or that it’s more practical for the organisation to handle considering the available resources or expertise.

    IBAC may also decide to refer your notification to other external agencies including:

    • the Victorian Ombudsman
    • the Local Government Inspectorate
    • Victoria Police.


    When managing internal investigations, you should:

    • support the welfare of the discloser(s)
    • continue to make staff aware of public interest disclosure protections and how to report.

    Internal investigations must be carried out with procedural fairness and natural justice. Conflicts of interest should be avoided wherever possible or actively managed.

    Undertake preliminary inquiries to determine whether to pursue the investigation as an internal matter. This should be confidential.

    If you proceed with an internal investigation, hold interviews with all relevant parties to gather information.

    Keep accurate written records of all conversations as part of the fact finding.

    Maintain confidentiality at all times to protect all parties.

    Support the welfare of people you interact with during the investigation.

    Follow the procedures and guidelines of your agency and report outcomes at the end of an investigation.