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Internal vs external investigation decision sheet

By BION PartnersReviewed General information, not legal advice

A printable sheet to help you decide, and record why, whether a workplace complaint should be investigated internally, internally with external guidance, or by an external investigator. It uses the same five questions as our online self-check.

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General information, not legal advice. Free to use and adapt for your organisation, no sign-up needed. Check it against your own policies, award or enterprise agreement and contracts, and speak with a lawyer about your situation.

The matter

Matter reference
Completed by (role) and date

Five questions

No.QuestionYesNo
1Could the outcome include dismissal or a serious warning?
2Does anyone who would investigate report to, work closely with, or have a personal connection to the people involved?
3Does the matter involve sexual harassment, violence, fraud or a whistleblower report?
4Do you have someone trained in investigations who can give it the time it needs?
5Would you be comfortable defending this process before the Fair Work Commission or a court?

Decision rule: if the answer to any of questions 1 to 3 is yes, or to question 4 or 5 is no, an external investigator is worth considering.

Six factors to weigh

FactorPoints to internalPoints to external
IndependenceThe investigator has no reporting line to, close working relationship with, or personal connection to anyone involved.Risk of actual or perceived bias if handled internally.
ExpertiseSomeone experienced and trained in workplace investigations is available.No one internal has investigation training or experience.
CapacityThe investigator has significant time available alongside their usual role.Investigations are time-intensive and no one can give it the time.
CommunityThe people involved are not closely connected outside work.Regional towns or remote sites where people know each other outside work.
SeriousnessLow-level, straightforward matters, or informal resolution.Serious allegations, possible dismissal, senior respondents, multiple complainants, whistleblower reports.
DefensibilityLow risk of the decision being challenged.Findings may be tested if a decision is challenged.

Decision

  • Internal investigation
  • Internal investigation with external guidance on the allegations, process and report
  • External investigator
  • Another proportionate response (for example informal resolution), because:
Reasons for the decision
Approved by (role) and date

The right response should be proportionate to the seriousness of the allegations. If a matter turns out to be more serious than it first looked, revisit this sheet. See ways to engage us or book a free scoping call.

Sources

  1. Queensland Public Sector Commission: Managing workplace investigations, a practical guide (2024)
  2. Fair Work Act 2009 (Cth) s 387 (AustLII)
  3. Hatch v WesTrac Pty Ltd [2020] FWC 5729

Checked 26 October 2026. Laws and guidance change; check the source before relying on it.

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