1

Schedule of Claims

Key: BC=Ben Craig BB= Beverly Bannister AB=Adam Buckby AM=Anthony Marshall TP=Theresa Peters CG=Carroll Garraway MS=Mick Simpkin TS=Tony Smith
RJ=Ruth Johnson SE=Sue Ely PK=Paul Kelly BA=Bethany Allum SC=Sasha Chaudri LS=Lynn Simpson JR=Jo Robbins BK=Bob Knight AW=Andrea Ward
AD=Amanda Duckett DF=Deborah Francis MW=Marcus Watson CR=Cathy Robinson CO=Cliff Obaseki EP=Ethel Punter JB=Jane Biddlecombe MN= Michelle Naylor
AK= Alexander Khan JP=Jane Puncher CD=Clive Dobbin FH=Fiona Hawkesley JB=John Bacon HH=Hugh Haughian TD=Tanya Davis BBA=Bolanle Balogun
DR.M=Doctor Mason BED= Babcock Education and Skills Ltd

Ms AA Vaughan v Careers Enterprise Ltd and others Case Number: 2318353/2010/N Protected Disclosures
No. Date
of dis-
closure
Dis-
closure
made to
Method of
dis-
closure
Docu-
ment
Loca-
tion/wit
ness
Breach ET1 Para
graph(s)
Detriment

1. 7
th
Sep
2009
BC, AB &
BB.
Written

By e-
mail
N/A Protected disclosure: Failure to safeguard my
confidential, sensitive personal information, as required
by Data Protection Act 1998. (Data Protection Act 1998
S4 (4) and schedule 1): To take measures to prevent
unauthorised processing of data and against accidental
loss: PIDA Detriment: section 43B (1) (b) of the ERA
1996).
4, 5, 6, 7,
8,9,10, 12
17, 23, 24,
25 & 34
The handling of the data protection breach by HR &
management: Failure to follow policy and procedure: a)
My employer did not follow whistleblowing procedure or
offer support following breach and I was told to raise a
grievance. b) I was unduly pressurized by AB (raised
unsubstantiated and potentially defamatory allegations
against me regarding CRB update) and particularly RJ
(HR) on 5
th
November 2009, and dealt with in a wholly
inappropriate manner- singled out from my colleagues to
receive a second follow up e-mail.
2. 13
th

October
2009
BC & BB. Written

By e-
mail
N/A Protected disclosure: Failure to provide a safe place of
work & maintain a safe system of working- Breach of
contractual duties (including mental and physical health,
as required by the UK Health and Safety at Work Act
1974); my workplace fraught with adverse working
conditions resulting in unacceptable levels of stress:
PIDA Detriment: section 43B (1) (d), ERA 1996) and
43B (1) (b) of the ERA 1996).
11, 12, 13,
14, 31 &
44
No support mechanisms in place for me, to make a
tailored intervention and take pro-active steps to
ensure that stress at work didn't become a crisis for
me: i.e. No referral to occupational health, regular one-to-
ones or risk assessments etc. Also relates to disclosure
number 1.
3. 29
th

October
2009
TP-
forwarded
to (BC,
BB & AB)

Written

By e-
mail
N/A Protected disclosure: Failure to provide a safe place of
work and failure to provide and maintain a safe system
for doing work. Breach of contractual duties- Incident at
work whilst alone on duty in a public area: PIDA
Detriment: section 43B (1) (d), ERA 1996) and 43B (1)
(b) of the ERA 1996).
20, 21, 22,
23 & 24
Failure to act/debrief after an incident: Incident report
not followed up, my e-mails were ignored by managers,
risk assessments not reviewed/or in place. Also relates
to disclosures numbers 1 & 2.
2
4. 10
th
Dec
2009 at
16.39 PM
BC,
BB, AB
& my
Union (MS
& CG)
Written By e-
mail
N/A Protected disclosure: I advised management that I
was taking out a grievance against HR for bullying and
harassment, (breach of contractual duties). PIDA
Detriment: Section 100(1)(d) of the Employment Rights
Act (1996) applies in that the circumstances of danger
applied to any danger, including that of harassment by a
fellow worker, not just physical dangers relating to work
premises; and section 43B (1) (d), ERA 1996) and 43B
(1) (b) of the ERA 1996).
30, 31, 36,
37, 38, 40,
41 & 46
Managements handling of grievances: a)
Managements failure to take all reasonable steps to
prevent bullying, harassment and victimization- allowing
AB to continue to have contact with me and permitted him
to handle the grievance that I had taken out against him
and b) the appointing of AM to investigate my grievance.
Also relates to disclosures numbers 1, 2 and 3.
5. 11
th
Dec
2009
BC,
BB
& my
Union
(CG, MS &
TS)
Written By e-
mail
N/A Protected disclosure: I advised management that I
was taking out a grievance against them and HR for lack
of support/health and safety breaches, (breach of
contractual duties). PIDA Detriment: section 43B (1)
(d), ERA 1996) and 43B (1) (b) of the ERA 1996)
44, 47, 48,
49, 50, 51
& 81(q)
Continued lack of support and obstructive behaviour
by management: a) No back to work support
immediately on my return to work (January 21
st
2010), i.e.
no back to work plan/contact with me from management
whilst on long-term sick. b) Managers obstructed me from
accessing current office based risk assessments on
numerous occasions between 10
th
and February 15
th

2010. Also relates to disclosures numbers 1, 2, 3 & 4.
6. 3
rd

February
2010
AM, SE
and my
Union rep
(TS)
Written
and oral
Grievan
ce letter
& oral
represe
ntation
Grie-
vance
hearing
South-
wark
Grievance hearing/letter- protected disclosures:
About the breach of contractual duties set out in 1-5,
including racial discrimination and data protection
breach. PIDA detriment: sections 43B (1) (d), ERA
1996), 43B (1) (b) and 100(1)(d) of the ERA 1996).
46, 52, 53,
54 & 55
AMs handling of my grievance investigation (not fair
and impartial); a) his failure to reach a reasonable
conclusion and b) the unreasonable delays in providing
the grievances outcome. Also relates to disclosures
numbers 1, 2, 3, 4 and 5.
7. 19
th
Feb
2010
PK Written By e-
mail
N/A Protected disclosure- Appeal letter About the breach
of contractual duties set out in 1-6, including racial
discrimination, data protection breach and disclosure
about AMs attempt to conceal information about 43B (1)
(b), (d) : PIDA detriment: sections 43B (1) (d), ERA
1996), 43B (1) (b) of the ERA 1996), 100(1)(d) and (1)
(f) of the ERA 1996).
56, 57, 58,
59 & 60
PKs conduct in relation to my appeal letter: a) his
unlawful refusal to follow the statutory grievance
procedure unless I sent my appeal to him by post and b)
his harassment and victimisation of me in his email to me
dated 20
th
February 2010. Also relates to disclosures
numbers 1, 2, 3, 4, 5 and 6.
8. 22
nd
Feb
2010
My Union,
(TS, MS)
BA, JR &
SC
Written By e-
mail
N/A Complaint against PK: Protected disclosure:
Bullying, harassment and victimization (breach of
contractual duties). PIDA detriment: sections 43B (1)
(d), ERA 1996), 43B (1) (b) and 100(1)(d) of the ERA
1996)
60, 61 &
63
SCs handling of my complaint against PK- a) Not in
accordance with the normal procedures and b) her failure
to replace him- make reasonable adjustments. Also
relates to disclosures numbers 1, 2, 3, 4, 5, 6 and 7.
9. 11
th
March
2010
My Union
(MS, TS,
BK), AW &
AD.
Written &
oral
By e-
mail
Grie-
vances
&
appeal
hearing
South-
wark
Protected disclosure- Appeals and grievances
hearing/letter About the breach of contractual duties set
out in 1-7, including racial discrimination, data protection
breach and disclosure about AMs attempt to conceal
information about 43B (1) (b), (d): PIDA detriment:
sections 43B (1) (d), ERA 1996), 43B (1) (b), ERA
1996), (1) (f) and 100(1)(d) of the ERA 1996).
66, 67, 68,
69, 72, 73,
75 & 76
ADs handling of my appeals and grievances
investigations i.e. a) her failure to reach a reasonable
conclusion) and b) the unreasonable delays in arranging
grievances/appeals & providing grievances/appeals
outcome. Also relates to disclosures numbers 1, 2, 3,
4, 5, 6, 7 and 8.


3
10. 21
st
April
2010 and
19
th
May
2010
My
employer,
ET, AW,
SC, LS,
DF, SE &
my Union
(MS &
TS).
Written &
oral
By e-
mail &
letter
Appeal
hearing
South-
wark
Tribunal claim- 19
th
April and Protected disclosures-
Appeals hearing/Letter-19
th
May About the breach of
contractual duties set out in 1-7, including racial
discrimination, data protection breach and disclosure
about AMs and ADs attempt to conceal information
about 43B (1) (b), (d) : PIDA detriment: sections 43B
(1) (d), ERA 1996), 43B (1) (b), ERA 1996), (1) (f) and
100(1)(d) of the ERA 1996).
81(f),
81(g) &
81(u)
a) Contact made with me by DF via my personal e-mail
address on 2
nd
June 2010 to inappropriately discuss
matters other than my appeal or my well-being and b)
from February 2010, the companys failure to make the
credit monitoring payment that it had promised me in
February 2010, specifically relating to an e-mail from BB
dated 24
th
February 2010. Also relates to disclosures
numbers 1, 2, 3, 4, 5, 6, 7, 8 and 9.
11. The alleged consequences of all these detriments (which are continuing acts) are that I suffered injury to feelings, change in personality, strain on personal relationships, effect on future
employment (i.e. stigma and future health in relation to future loss of earnings), injury to health (i.e. stress related severe depression, panic attacks, insomnia, eating difficulties and muscle
spasms/weakness in arm and the exacerbation of my pre-existing condition- hypertension) and aggravated damages because my complaints of discrimination were handled were in a high-handed,
insulting and oppressive manner. These consequences are also themselves alleged to be detriments, as set out in paragraphs 97, 98, 100, 101, 104, 105 & 106.


Ms AA Vaughan v Careers Enterprise Ltd and others Case Number: 2318353/2010/N Complaints of Discrimination
No. Incident Date Person(s)
Respon-
sible
Loca-
tion
Wit-
ness
Type of
Discrimination
ET Para-
graph(s)
Com-
parator
Protected act relied
upon
Detriment
12. An intimidating and offensive e-mail
was sent to me by the AB regarding
request for credit monitoring, which
managers were copied into.
17
th

Nov
2009
AB Via e-
mail
N/A Unlawful racial
discrimination on
racial grounds
contrary to
section 1 (1) (a),
(b), 1A(c) and
1B(c) of the RRA
1976.
29 & 30 CR N/A I was sent an intimidating and
offensive e-mail from AB in which a) I
was treated unsympathetically and
b) AB tried to deter me from pursing
my grievance, treating me less
favourably than my white colleague
CR.
13. I was sent two letters from AB
regarding my grievances, (including
the one that I had raised against
him).
21
st

Dec
2009
AB, BB &
BC
Via e-
mail
N/A Unlawful racial
discrimination on
racial grounds
contrary to
Section 1 (1) (a),
(b) and 1A(c) of
the RRA 1976.
40, 41 &
42
Hypoth-
etical
N/A Treatment received during 2
nd

period on long-term sick: a) Failure
to handle grievances properly and b)
Intimidation, victimization and
harassment by AB & managements
failure to take all reasonable steps to
prevent bullying, harassment and
victimization.
14. AMs handling of my grievance
investigation: the grievance outcome
statement.
19
th

Feb
2010
AM Via e-
mail
SE &
TS
(GMB)
Unlawful racial
discrimination on
racial grounds
contrary to
55 Hypoth-
etical
Disclosure 6 (written &
oral) detailing
allegations against AB
that would amount to a
AMs handling of my grievance
investigation was not fair and
impartial; a) his failure to reach a
reasonable conclusion and b) the
4
sections 1 (1) (a),
(b), 1A(c) and
2(1) (d) of the
Race Relations
Act.
contravention of the
RRA.
unreasonable delays in providing the
grievances outcome.
15. PKs conduct over the weekend in
relation to my appeal letter: not in
accordance with the normal
procedures.

19
th
&
20
th

Feb
2010
PK Via e-
mail
N/A Unlawful racial
discrimination on
racial grounds
contrary sections
1 (1) (a), (b),
1A(c), 2(1) (d)
and 3A of the
RRA 1976.
57, 58,
59 & 60
Hypoth-
etical
E-mail (appeals letter)
to PK dated 19
th

February 2010
detailing allegations
against AB that would
amount to a
contravention of the
RRA.
PKs conduct in relation to my
appeal letter- a) In his unlawful
refusal to follow the statutory
grievance procedure unless I sent
my appeal to him by post and b) his
harassment & victimisation of me in
his email to me dated 20
th
February
2010.
16. SCs handling of my complaint
against PK. Not in accordance with
the normal procedures.
23
rd

Feb
2010
SC Via e-
mail
N/A Unlawful racial
discrimination on
racial grounds
contrary to
sections 1 (1) (a),
(b), 1A(c) and
2(1) (d) of the
RRA 1976.
60, 61,
62 & 63
Hypoth-
etical
E-mail (appeals letter)
to PK dated 19
th

February 2010
detailing allegations
against AB and e-mail
complaint to SC about
PK that would amount
to a contravention of
the RRA.
SCs handling of my complaint
against PK- a) Not in accordance
with the normal procedures and b)
her failure to replace him- make
reasonable adjustments
17. ADs appeals outcome letter 30
th
March
2010
AM Via e-
mail
N/A Unlawful racial
discrimination on
racial grounds
contrary to
sections 1 (1) (a),
(b), 1A(c) and
2(1) (d) of the
RRA 1976.
75 Hypoth-
etical
Protected disclosure-
Appeals and
grievances
hearing/letter detailing
allegations against AB
that would amount to a
contravention of the
RRA.
ADs handling of my appeals
investigation; a) her failure to reach
a reasonable conclusion) and b) the
unreasonable delays in providing
appeals outcome.
18. ADs grievances outcome letter. 31
st

March
2010
AM Via e-
mail
N/A Unlawful racial
discrimination on
racial grounds
contrary to
Sections 1 (1) (a),
(b), 1A(c) and
2(1) (d) of the
RRA 1976.
76 Hypoth-
etical
Protected disclosure-
Appeals and
grievances
hearing/letter detailing
allegations against AB
& PK that would
amount to a
contravention of the
RRA.
ADs handling of my appeals
investigation; a) her failure to reach
a reasonable conclusion) and b) the
unreasonable delays in providing
grievances outcome.
19. SE contacting CO 2
nd

June
2010
SE Via
tele-
phone
& e-
CO Unlawful racial
discrimination on
racial grounds
contrary to
81(d) &
81(e)
Hypoth-
etical
Tribunal claim &
allegations (written &
oral), against AB at my
grievance hearing on
a) The breach of my privacy and b)
the distressed caused by learning
that my employer was trying to get
rid of me. My employer then later
5
mail sections 1 1A(c)
and 2(1) (a), (b),
(c), (d) of the
RRA 1976.
3
rd
Feb 2010 & PK &
TM at appeals hearing
on 19
th
May 2010 that
would amount to a
contravention of the
RRA.
denied that this topic was even
discussed with CO.
20. DFs contact with me via my
personal e-mail to inappropriately
discuss tribunal case, when I had
just recently been signed off sick with
depression.
2
nd

June
2010
DF Via e-
mail
N/A Unlawful racial
discrimination on
racial grounds
contrary to
sections 1 1A(c),
2(1) (a), (b), (c),
(d) and 3A of the
RRA 1976.
81(f)
81(g)
Hypoth-
etical
Tribunal claim and
allegations (written &
oral), against AB & PK
at appeals hearing on
19
th
May 2010 that
would amount to a
contravention of the
RRA.
Contact was made with me by DF via
my personal e-mail address whilst I
was of sick to discuss matters other
than my appeal or my well-being
(tribunal claim). It was intimidating,
inappropriate and intrusive and
caused me great distress.
21. MWs handling of my complaint
against DF, SE and JB.
2
nd

June
2010
MW Via e-
mail
N/A Unlawful racial
discrimination on
racial grounds
contrary to
sections 1 1A(c)
and 2(1) (a) (b)
(c) (d) of the RRA
1976.
81(h),
81(i),
81(j) &
81(k)
Hypoth-
etical
Tribunal claim/my letter
of complaint dated 2
nd

June 2010 to MW & my
internal grievance
against AB & PK that
would amount to a
contravention of the
RRA.
a) In MWs failure to take my
complaint seriously and investigate it
properly, (did not follow policy and
procedure) and b) failed to
acknowledge breach of privacy and
impact on my health.
22. DFs appeals outcome letter. 4
th

June
2010
DF Via
post
N/A Unlawful racial
discrimination on
racial grounds
contrary to
sections 1 (1) (a),
(b) and 1A(c) and
2(1) (a) (b) (c) (d)
of the RRA 1976.
81(l) &
81(m)
Hypoth-
etical
Tribunal claim and
allegations (written &
oral), against AB & PK
at appeals hearing on
19
th
May 2010 and my
letter of complaint to
MW that would amount
to a contravention of
the RRA.
In DFs handling of my appeals
investigation (undermining of
occupational health
recommendation) i.e. a)in providing
obstructive, evasive and equivocal
responses/failure to address all my
points and answer all my questions
and b) her failure to adhere to
grievance procedure time limits.
23. AWs and managements handling of
my sickness absence, (receipt of
letter putting undue pressure on me
for a re-referral to occupational
health).
22
nd

June
2010
AW, BC &
BB
Via
post
N/A Unlawful racial
discrimination on
racial grounds
contrary to
sections section 1
(1) (a), (b), 1A(c),
2(1) (a) (b) (c) (d)
and 3A of the
RRA 1976.
81(r),
81(s) &
81(t)
Hypoth-
etical
Tribunal claim and
allegations (written &
oral), against AB & PK
at the grievances &
appeals hearing on
11
th
March 2010 that
would amount to a
contravention of the
RRA & two e-mails to
my employer regarding
continued harassment
and victimisation whilst
a) the use of a re-referral to the
companys occupational health
consultants as a means of
intimidation (no consultation) and b)
the appointment of AW to deal with
my sickness absence, when she was
the named contact person on the
ET3- failure to establish my
confidence and trust.
6
on sick leave.
24. From February 2010, the companys
failure to make the credit monitoring
payment that it had promised me in
February 2010, specifically relating
to an e-mail from BB dated 24
th

February 2010.
From
Feb
19
th

2010
BB & My
employer
Via e-
mail
N/A Unlawful racial
discrimination on
racial grounds
contrary to
section 1 (1) (a),
(b), 1A(c) and
2(1) (d) of the
Race Relations
Act.
81(u) Hypoth-
etical
Internal grievance
allegations (written &
oral), against AB & PK
that would amount to a
contravention of the
RRA and my tribunal
claim.
My out of pocket expenses to cover
the cost of credit monitoring from
October 2009.
25. The alleged consequences of all these incidents of discrimination (which are continuing acts) are that I suffered injury to feelings, change in personality, strain on personal relationships,
effect on future employment (i.e. stigma and future health in relation to future loss of earnings), injury to health (i.e. stress related severe depression, panic attacks, insomnia, eating difficulties and
muscle spasms/weakness in arm and the exacerbation of my pre-existing condition- hypertension) and aggravated damages because my complaints of discrimination were handled were in a high-
handed, insulting and oppressive manner. These consequences are also themselves alleged to be detriments, as set out in paragraphs 97, 98, 100, 101, 104, 105 & 106.



Ms AA Vaughan v Careers Enterprise Ltd and others Case Number: 2330171/2010/N Protected Disclosures
No. Date
of dis-
closure
Dis-
closure
made to
Method of
dis-
closure
Docu-
ment
Loca-
tion/wit
ness
Breach ET1 Para
graph(s)
Detriment

1. 21
st
April
& 19
th
May
2010
My
employer,
ET, AW,
SC, LS,
DF, SE &
my Union
(MS &
TS).
Written
& oral
representa
tion
Appeals
letters
and
tribunal
claim
Appeals
hearing
South-
wark
Protected disclosure: Tribunal Claim & Appeals
Letter/Hearing-: About the breach of contractual duties
(including mental and physical health, as required by the
UK Health and Safety at Work Act 1974); racial
discrimination, data protection breach and disclosure
about AMs and ADs attempt to conceal information
about 43B (1) (b), (d): PIDA detriment: sections 43B (1)
(d), ERA 1996), 43B (1) (b), ERA 1996), (1) (f) and
100(1)(d) of the ERA 1996).
79, 80, 81
& 82
In DFs handling of my appeals investigation: i.e. a)
undermining of occupational health recommendation by,
providing obstructive, evasive and equivocal
responses/failure to address all my points and answer all
my questions and b) failing to adhere to grievance
procedure time limits.
2. The alleged consequences of all these detriments (which are continuing acts) are that I suffered injury to feelings, change in personality, strain on personal relationships, effect on future
employment (i.e. stigma and future health in relation to future loss of earnings), injury to health (i.e. stress related severe depression, panic attacks, insomnia, eating difficulties and muscle
spasms/weakness in arm and the exacerbation of my pre-existing condition- hypertension) and aggravated damages because my complaints of discrimination were handled were in a high-handed,
insulting and oppressive manner. These consequences are also themselves alleged to be detriments, as set out in paragraphs 97, 117 & 118, 119, 120, 122 & 123.


7

Ms AA Vaughan v Careers Enterprise Ltd and others Case Number: 2330171/2010/N Complaints of Discrimination
No. Incident Date Person(s)
Respon-
sible
Loca-
tion
Wit-
ness
Type of
Discrimination
ET Para-
graph(s)
Com-
parator
Protected act relied
upon
Detriment
3. The handling of my return to work
following my long-term sickness
absence.
From
21
st

Jan
2010
AB, EP,
BC & BB
N/A N/A Unlawful disability
discrimination
contrary to
sections 3A(5),
(1), 4A(1)(a)(b)
and 55(1),
(2)(b)(c)(d) of the
DDA.
23, 24 &
30
Hypoth-
etical
E-mail to managers
dated 11
th
December
2009 detailing
concerns/complaints
about my work-induced
stress (disability with
sensitivity) and
complaining that
reasonable
adjustments have not
been made.
Lack of support from management
& HR during & immediately after
my first period of long-term
sickness: i.e. Managers failed to
contact me whilst I was off sick for 10
weeks, and as such failed to
implement a back to work plan to
refer me to occupational health in
good time, conduct an adequate
back to work interview and undertake
1-2-1 and risk assessments (office
and individual) in good time.
4. Failure to share my occupational
health report with me in good time.
2
nd

March
2010
BB E-mail
&
Meet-
ting
N/A Unlawful disability
discrimination
contrary to
sections 3A(5),
(1), 4A(1)(a) (b)
and 55(1),
(2)(b)(c)(d) of the
DDA.
28 & 46 Hypoth-
etical
E-mail to Lewisham
team mangers-BB, BC,
TP & EP dated 12
th

February 2010 at
12.22pm about
problems with the
handling of stress in
the workplace & e-mail
to BB & BC at 1.43AM
about the same thing in
relation to me & the
failure to make
reasonable
adjustments.
BBs unreasonably delaying sharing
my occupational health report with
me in good time. This left me feeling
unsupported and my medical
condition was exacerbated. I was
forced to e-mail BC & BB on 12
th

February 2010, to request the
implementation of an individual risk
assessment.
5. Communication via e-mail from AW
regarding the delay in arranging my
hearing. I had previously requested
reasonable adjustments (adhere to
grievance time limits).
3
rd

March
2010
AW & AD N/A N/A Unlawful disability
discrimination
contrary to
section 4A (1) (a)
(b) of the DDA
47 Hypoth-
etical
N/A Failing to adhere to grievance
procedure time limits with regards to
arranging my grievances and
appeals hearing.
6. Communication via e-mail from BB
regarding the lunch hour issue. I had
previously requested reasonable
adjustments (relaxing requirement to
23
rd

March
2010
BB N/A N/A Unlawful disability
discrimination
contrary to
section 4A (1) (a)
49 Hypoth-
etical
N/A BB unreasonably delaying taking
action to address the issue of the
impact of the early lunch hour on my
health, following the initial request
8
take lunch hour at 12.15 PM). (b) of the DDA made in October 2009, which
exacerbated my medical condition.
7. Communications via e-mail from AW
on behalf of DF regarding arranging
grievances and appeals.
15
th
,
19
th
&
20
th

April
2010
AW & DF N/A N/A Unlawful disability
discrimination
contrary to
section 4A (1) (a)
(b) of the DDA
57, 58 &
59
Hypoth-
etical
N/A Failing to adhere to grievance
procedure time limits with regards to
arranging appeals. This
unreasonably delayed the grievance
procedure and exacerbated my
medical condition.
8. Failure to offer alternative options to
reduce my working hours after I
advised my employer that I needed
to reduce my working hours.
From
April
until
May
26
th

2010
BC & BB N/A N/A Unlawful disability
discrimination
contrary to
sections 3A(5),
(1), 4A(1)(a) (b)
and 55(1),
(2)(b)(c)(d) of the
DDA.
67, 68 &
69
Hypoth-
etical
As set out in no.13 & e-
mail to BC & BB dated
3
rd
March 2010
requesting to reduce
my working hours
without financial
impact- (requesting a
reasonable
adjustment).
I was forced to use my annual leave
to reduce my working hours instead
of my employer making a reasonable
adjustment.
9. Communication via e-mail from SE
regarding delay in providing appeal
outcomes.
27
th

May
2010
SE & DF N/A N/A Unlawful disability
discrimination
contrary to
section 4A (1) (a)
(b) of the DDA
62 & 63 Hypoth-
etical
N/A This incident triggered my
breakdown and second period of
long-term sickness absence, (after
enduring ten months of sustained
pressure, stress and anxiety, as a
result of bullying, harassment and
victimisation and my employers
consistent failure to make
reasonable adjustments).
10. The alleged consequences of all these incidents of discrimination (which are continuing acts) are that I suffered injury to feelings, change in personality, strain on personal relationships,
effect on future employment (i.e. stigma and future health in relation to future loss of earnings), injury to health (i.e. stress related severe depression, panic attacks, insomnia, eating difficulties and
muscle spasms/weakness in arm and the exacerbation of my pre-existing condition- hypertension) and aggravated damages because my complaints of discrimination were handled were in a high-
handed, insulting and oppressive manner. These consequences are also themselves alleged to be detriments, as set out in paragraphs 97, 117 & 118, 119, 120, 122 & 123.
NB The incidents and allegations identified in claim number 2330171/2010/N are continuing acts which relate to claim number 2300254/2011B (1-10), which was lodged under the EA in December
2010. The claims detail continuing acts of victimisation, which continued on or after 1 October 2010 and therefore they are also unlawful under the Equality Act 2010 s.111- s.13, s.15, ss20 - ss23,
s26 - s27. At the PHR for this claim which took place on 16 & 17 June 2011, Judge Baron granted a notional amendment, granting me leave to argue this point at the main hearing.



9


Ms AA Vaughan v Careers Enterprise Ltd and others Case Number: 2300254/2011B Protected Disclosures
No. Date
of dis-
closure
Dis-
closure
made to
Method of
dis-
closure
Docu-
ment
Loca-
tion/wit
ness
Breach ET1 Para
graph(s)
Detriment



1. 25 & 26
November
2010
BC & BB. Written

By e-
mail
N/A Protected disclosure: Bullying, harassment and
victimization and breach of contractual duties. PIDA
detriment: sections 43B (1) (d), ERA 1996), 43B (1) (b)
and 100(1)(d) of the ERA 1996)
27-39, 50,
68a-b &
76k, 77
The abuse of the sickness absence / OH process: I
was treated unsympathetically and less favourably than
my colleague CR & prior to bringing legal proceedings & I
was unduly pressurized by my employer and threatened
with disciplinary action.
2. 9
December
2010
AD & BB.

Oral &
Written

By e-
mail
Lewi-
sham
office
BBA
Protected disclosure: Bullying and victimization,
breach of contractual duties, asserting my statutory
rights & a failure to provide a safe place of work &
maintain a safe system of working- (including mental
and physical health, as required by the UK Health and
Safety at Work Act 1974); the failure to undertake a risk
assessment or police its correct use, the failure to act in
accordance with policy and procedure, offer an
alternative role or consider a medical suspension (even
though I was sent home allegedly, on health and safety
grounds): PIDA Detriment: section 43B (1) (d), ERA
1996) and 43B (1) (b) and 100(1)(d) of the ERA 1996)
36e, 38,
41-49, 51,
67a- 67b &
78
Preventing my return to work / abuse of policy &
procedure: i.e. a) I was treated unsympathetically and
less favourably than my colleague CR & prior to bringing
legal proceedings- preventing my return to work (it was
not in accordance with the normal procedures),
stereotypical assumptions about the health safety
implications of my disability were made, a
risk assessment was not undertaken) & b) the refusal to
make reasonable adjustments and accept GP fit note,
the accusation of aggressive behaviour (inc being
humiliated in front of my colleagues).
Also relates to disclosure number 1.
3. 10
December
2010
AD, BB &
BC
Written

By e-
mail
N/A Protected disclosure: The failure to my request for a
reasonable adjustment, the failure to adhere to basic
contract law- (failure to pay me at full rate), the failure to
provide a safe place of work & maintain a safe system of
working. PIDA detriment: sections 43B (1) (d), ERA
1996), 43B (1) (b), the ERA 1996) & TULR (C) A).
36a-d, 39,
52 -59, 70-
72 & 76k
Treatment received between 10 & 21 December 2010:
a) the failure to make reasonable adjustments (inc
paying me at full rate), the refusal to accept the
independent OH report, (ADs e-mail dated 17 Dec was
intimidating and offensive) and b) the instruction to
consent to a re-referral to Medigold or another
independent OH specialist.
Also relates to disclosures numbers 1 & 2
4. 21
December
2010
AK, BB &
BC
Written

By e-
mail
N/A Protected disclosure: Bullying, harassment and
victimization, breach of contractual duties, asserting my
statutory rights & a failure to provide a safe place of
work & maintain a safe system of working- (including
mental and physical health, as required by the UK
Health and Safety at Work Act 1974); the failure to
60- 64 Treatment received following receipt of my e-mail
dated 21 December 2010: a) AKs failure to take my
complaint seriously and investigate it properly
failure/failure to take all reasonable steps to prevent
bullying, harassment and victimization & his failure to
contact me personally and b) the refusal to grant disability
10
undertake a risk assessment or police its correct use,
the failure to act in accordance with policy and
procedure, offer an alternative role or consider a medical
suspension (even though I was sent home allegedly, on
health and safety grounds): PIDA Detriment: Section
100(1)(d) of the Employment Rights Act (1996) applies
in that the circumstances of danger applied to any
danger, including that of harassment by a fellow worker,
not just physical dangers relating to work premises &
section 43B (1) (d), ERA 1996) and 43B (1) (b).
leave retrospectively & re-instate annual leave, the threat
of disciplinary action again and my employers continued
failure to allow me to return to work even though I had
fulfilled my employee responsibilities under the sickness
absence procedure.
Also relates to disclosures numbers 1, 2 and 3.
5. The alleged consequences of all these detriments (which are continuing acts) are that I suffered injury to feelings, change in personality, strain on personal relationships, effect on future
employment (i.e. stigma and future health in relation to future loss of earnings), injury to health (i.e. stress related severe depression, panic attacks, insomnia, eating difficulties and muscle
spasms/weakness in arm and the exacerbation of my pre-existing condition- hypertension) and aggravated damages because my complaints of discrimination were handled were in a high-handed,
insulting and oppressive manner. These consequences are also themselves alleged to be detriments, as set out in paragraphs 25, 26, 51, 60, 62, 82-84, 86-87 & 89a-f.




Ms AA Vaughan v Careers Enterprise Ltd and others Case Number: 2300254/2011B Complaints of Discrimination
No. Incident Date Person(s)
Respon-
sible
Loca-
tion
Wit-
ness
Type of
Discrimination
ET Para-
graph(s)
Com-
parator
Protected act relied
upon


Detriment
6. My employers handling of my
attempt to make arrangements to
return to work.
1 & 2
Dec
2010
BC, my
employer
& BED
Via e-
mail
BB Unlawful disability
discrimination
contrary to s.111-
s.13, s.15, ss20 -
ss23, s26- s27 of
the EA 2010.
27-39,
50, 68a-b
& 76k, 77

N/A or
hypoth-
etical,
CR
Previous 2 tribunal claims,
my request for
reasonable adjustments
& e-mails to BC (BB
copied in) regarding my
protected disclosure 1
made on 25 & 26
November 2010 that
would amount to a
contravention of the EA
2010
The abuse of the sickness
absence / OH process: a) I was
treated unsympathetically and less
favourably than my colleague CR
and/or a hypothetical comparator, I
was unduly pressurized by my
employer and threatened with
disciplinary action &
b) The harassment relating to the
instructions to consent to a re-
referral to Medigold (including
attempting to obtain my consent to a
disclosure of my full medical
records)- the OH process was used
11
as a means of intimidation.
7. The handling of my attempted return
to work on 9 December 2010.
9 Dec
2010
AB, BB,
my
employer
& BED
Via e-
mail &
Lewi-
sham
office
BBA Unlawful disability
discrimination
contrary to s.111-
s.13, s.15, ss20 -
ss23, s26- s27 of
the EA 2010
36e, 38,
41-49,
51, 67a-
67b & 78

N/A or
hypoth-
etical,
CR
Previous 2 tribunal claims,
advice from medical
practitioner & my request
for reasonable
adjustments &
disclosures 1 & 2 (written
& oral) detailing
allegations against AD &
BB that would amount to
a contravention of the EA
2010.
Preventing my return to work /
abuse of policy & procedure: a) I
was treated unsympathetically & less
favourably than my colleague CR
and/or a hypothetical comparator, it
was not in accordance with the
normal procedures, (preventing my
return to work), stereotypical
assumptions about the health &
safety implications of my disability
were made, a risk assessment was
not undertaken) & b) the refusal to
make reasonable adjustments and
accept my GP fit note, the
accusation of aggressive behaviour
(inc being humiliated in front of my
colleagues).
8. The acts / omissions following the
receipt of the independent OH report.

From
10-
21Dec
2010
AD, BC,
my
employer
& BED
Via e-
mail
BB Unlawful disability
discrimination
contrary to s.111-
s.13, s.15, ss20 -
ss23, s26- s27 of
the EA 2010
36a-d,
39, 52 -
59, 70-72
& 76k

N/A or
hypoth-
etical,
CR
Previous 2 tribunal claims,
advice from medical
practitioner & my request
for reasonable
adjustments, & my e-
mails dated 10, 15 & 17 to
AD (BB & BC copied in)
detailing allegations
against AD & BC that
would amount to a
contravention of the EA
2010.
The treatment received between
10 & 21 December 2010: a) the
failure to make reasonable
adjustments, inc not paying me at
full rate & b) the refusal to accept the
independent OH report, (ADs e-mail
dated 17 Dec 2010 was intimidating
and offensive) and the instruction to
consent to a re-referral to Medigold
or another independent OH
specialist.
9. The acts / omissions following the
receipt of my e-mail dated 21
December 2010, in which I had
detailed my request for a reasonable
adjustment.

From
21
Dec
2010
AK, BC,
AD, MN,
my
employer
& BED
Via e-
mail
BB,
AW,
CD
Unlawful disability
discrimination
contrary to s.111-
s.13, s.15, ss20 -
ss23, s26- s27 of
the EA 2010
60- 64 N/A or
hypoth-
etical,
CR
Previous 2 tribunal claims,
my e-mail to AK dated 21
Dec 2010 detailing a
request for reasonable
adjustments & allegations
against AD & BC that
would amount to a
contravention of the EA
2010.
The treatment received following
receipt of my e-mail dated 21
December 2010: a) AKs failure to
take my complaint seriously and
investigate it properly failure/take all
reasonable steps to prevent bullying,
harassment and victimization & his
failure to contact me personally b)
threatened with disciplinary action
12
again & the refusal to grant disability
leave retrospectively/re-instate
annual
10. The alleged consequences of all these incidents of discrimination (which are continuing acts) are that I suffered injury to feelings, change in personality, strain on personal relationships,
effect on future employment (i.e. stigma and future health in relation to future loss of earnings), injury to health (i.e. stress related severe depression, panic attacks, insomnia, eating difficulties and
muscle spasms/weakness in arm and the exacerbation of my pre-existing condition- hypertension) and aggravated damages because my complaints of discrimination were handled were in a high-
handed, insulting and oppressive manner. These consequences are also themselves alleged to be detriments, as set out in paragraphs 25, 26, 51, 60, 62, 82-84, 86-87 & 89a-f.

NB In relation to all three claims, as it is not possible to link a specific incident of discrimination to a specific protected act, (due to the fact that there are so many), the
protected acts relied upon will include but not be limited to those referred to in the Protected act relied upon columns.