Cases6019373/2025

Claimant v Saxton 4X4 Ltd

3 July 2025Before Employment Judge R S DrakeLondon Eastremote video

Outcome

Other

Individual claims

Automatic Unfair Dismissalnot determined

Interim relief granted on the basis that the tribunal found it likely that a final hearing would determine the claimant was dismissed for making protected disclosures under s103A ERA 1996. The tribunal found the claimant reported GDPR and Data Protection Act breaches to management on 9 and 12 May 2025, and was dismissed on 20 May 2025 without warning or procedure, with evidence of hostile reactions from management following the disclosures suggesting causative link.

Whistleblowingnot determined

The underlying whistleblowing claim formed the basis for the interim relief application. The tribunal found it likely that disclosures made on 9 and 12 May 2025 regarding GDPR and Data Protection Act breaches were protected disclosures made in the public interest, and that these were the principal reason for dismissal days later.

Facts

The claimant was employed from 14 October 2024 to 20 May 2025. On 9 and 12 May 2025 she made verbal reports to management (Mr Neil Mitchell and Mr Alan Austin) about GDPR and Data Protection Act breaches, specifically that confidential legal documentation and employee data were being left unsecured and accessible to staff and the public. Following these disclosures, colleagues made hostile comments including advising her to 'find another job' and that they didn't believe she 'would be coming back'. On 20 May 2025 she was dismissed without warning, disciplinary procedure, or explanation at an unwarned meeting.

Decision

The tribunal granted interim relief, finding it likely that a final hearing would determine the claimant was automatically unfairly dismissed for making protected disclosures under s103A ERA 1996. The tribunal found the disclosures about data protection breaches were likely to be protected disclosures made in the public interest, and that the swift dismissal without procedure or credible alternative explanation, combined with hostile reactions from management, demonstrated a likely causative link between the disclosures and dismissal.

Practical note

Interim relief can be granted where there is a clear temporal and evidential link between protected disclosures and summary dismissal, even at an early procedural stage before the respondent has filed a defence, particularly where dismissal occurs without warning or procedure within days of whistleblowing.

Legal authorities cited

Cavendish Munro Professional Risks Management Ltd v Geduld [2010] ICR 325Taplin v C Shippam Ltd [1978] IRLR 450Ministry of Justice v Sarfraz [2011] IRLR 562Simply Smile Manor House Ltd v Ter-Berg [2020] ICR 570Kilraine v London Borough of Wandsworth [2018] ICR 1850

Statutes

ERA 1996 s.43BERA 1996 s.128ERA 1996 s.103AERA 1996 s.129ERA 1996 s.43A

Case details

Case number
6019373/2025
Decision date
3 July 2025
Hearing type
interim
Hearing days
1
Classification
contested

Respondent

Sector
retail
Represented
Yes
Rep type
lay rep

Employment details

Service
7 months

Claimant representation

Represented
No