During your time working with us you’re going to be privy to lots of important and Confidential Information about Wholegrain, our clients, suppliers, and other third-parties as well as personal information about our employees and contractors, especially if you are in a management position. It is therefore imperative that you take care with the Confidential Information that Wholegrain is entrusting you with, as there are consequences on both Wholegrain, and yourself, if care is not taken to the required degree as detailed in this policy.    

This policy applies to all employees and contractors of Wholegrain.  It does not form part of your contract of employment or contract for services and may be amended from time to time.   It should be read in conjunction with our ‘Data Protection Policy’ which references Confidential Information in the context of storing, sharing, and processing of personal, and sensitive, data within Wholegrain. 

Any, and all, personal data used in conjunction with this policy shall be collected, held, and processed in accordance with our ‘Data Protection Policy.’

Definitions and Interpretation

Before we get going, we want to define what we mean by Confidential Information so that we are clear on the parameters.

When we refer to ‘Confidential Information’ we are referring to information or data which could be in written or oral form and is not necessarily highlighted, or indeed obvious, that it is considered as Confidential Information. Whilst the below list is not exhaustive, it aims to give you a clear idea as to what we consider to be Confidential Information. Thus highlighting the areas in which extra care needs to be taken so that Confidential Information is not intentionally, or inadvertently, Shared with others (internally or externally to Wholegrain) where there is no valid or reasonable business reason for doing so.   

So from a Wholegrain perspective, the following is considered as examples of Confidential Information:

  • all information relating to employees, interns, contractors, service providers, staff, advisors, and officers of Wholegrain. Information may include opinions, facts, or actual data (whether that be relating to the individuals personal or professional life) about the aforementioned individuals;
  • all information from our clients and suppliers. This includes information about individuals within our clients and suppliers which may include opinions, facts or actual data relating to their personal or professional life;
  • all information relating to the trading position, business, products, services, affairs, and finances of Wholegrain. This includes, for example, contractual information relating to clients, suppliers and other third parties; marketing plans; information relating to the finances of Wholegrain; our manpower plans and the remuneration paid to our employees, contractors, and officers; information relating to prospects and tenders contemplated, offered, or undertaken by Wholegrain; and any other matters connected with the products/services delivered, marketed, provided, or obtained by Wholegrain; 
  • technical data and know-how relating to Wholegrain, our clients, suppliers, agents, and consultants, for example, product/service designs and specifications; internally developed software/computer systems; ideas and inventions, drawings and plans; research and development; costs, margins, prices; and business methods; e. any incident or investigation relating to Wholegrain’s operations or business, or reports/research commissioned by, or provided to, Wholegrain.
  • any incident or investigation relating to Wholegrain’s operations or business, or reports/research commissioned by, or provided to, Wholegrain.

‘Confidential’ and ‘Confidentiality’ means to keep secret and not to disclose, as well as to use all reasonable endeavours to prevent the use or disclosure by or to any person, of any Confidential Information which comes to your knowledge whilst working with Wholegrain, either during your time working with us or following it.  

There will of course be times when you need to, or believe you need to, make others aware of some Confidential Information that you are privy to.  Before sharing any Confidential Information, ensure that you consider if there is a clear, valid and reasonable business reason as to why the Confidential Information needs to be Shared with each of your intended recipients. If there isn’t one, or you are not entirely sure then don’t Share the information.  If you are unsure then seek guidance from your Line Manager or one of the SLT in the first instance.   

By the way, ‘Sharing’, ‘Shared’ or ‘Share’ means to forward, distribute, disclose, or make known to one or more individuals either within, or outside of Wholegrain. 

Media and Social Media

It goes without saying that employees and contractors are not permitted to speak or give a written statement to the media, or to re/post anything on social media relating to Wholegrain’s business, that of our employees and contractors (current and former), that of our clients and suppliers (current and former), indeed any third-parties that we have, or have had, a business relationship with.  In the event that you are approached by the media or an individual on social media regarding our business, then please refer them to the Managing Director in the first instance.  

Obligation of confidentiality

Just for clarity, the restrictions outlined in this policy apply during your time of working with us, as well as at the end of your employment or contract for services with Wholegrain.  As such they do not carry any time limit to them.


Obviously, none of the above info on confidentiality applies if:

  • any Confidential Information is already in the public domain, otherwise than as a result of direct or indirect disclosure by you in breach of the terms of this policy;
  • any Confidential Information is deemed as a ‘qualifying disclosure’ under the Public Interest Disclosure Act.   Please refer to our ‘Whistleblower Policy aka Confidential Reporting Policy’ for further information.

Additional responsibilities under this policy

In addition to the above, you must not, and without the prior written consent of the Managing Director, allow or enable any Confidential Information:

  • to be copied or reproduced in any form or to be commercially exploited in any way; or
  • to be used for your own purposes or for any purposes other than for the business of Wholegrain or to be used or published by any other person;
  • to be transferred to your own personal e-mail account, regardless of the proposed reasons for doing so;
  • to pass outside of your control unless there is a clear business reason for doing so. 

We may ask you to keep a record of Confidential Information received as well as of the individuals that you have Shared that information with.   

At our request, and at the end of your time working with us, you will be required to return to Wholegrain all Confidential Information in your possession or under your control.  This includes for example, hard copy documents, soft copy documents and recordings, computer discs, memory sticks, portable hard drives, and all other hard and soft materials capable of storing data and information.  We may ask you to confirm in writing that you have returned and or permanently deleted or destroyed all Confidential Information.

Consequences of inappropriately Sharing Confidential Information

We don’t normally lay down the law as that is not our preferred modus operandi however, there can be serious consequences to our ongoing business, relationships and reputation with our employees, contractors, clients, suppliers and other third-parties if we do not carefully manage the Confidential Information that we are privy to.  We think this policy is comprehensive and gives you a clear expectation of what Confidential Information is, why the sharing of it needs careful consideration and your additional responsibilities under this policy.  If any of it is unclear or you require further clarification, then please speak to a member of the SLT in the first instance.  Suffice to say that any breach of this policy could have very serious consequences for Wholegrain with respect to its working relationship with its employees, contractors, clients, suppliers, and other third-parties and ultimately, its long-term success and viability.  Therefore any serious breaches of this policy will be investigated and should culpability be found, then the termination of an individual’s employment/contract for services may occur.