Dignity at Work, Bullying, Harassment, and Victimisation Policy

If a student experiences bullying, harassment, or victimisation while on placement, they should first use the host organisation's local systems or policies. They can also seek assistance from the Student Wellbeing Team. Often, students can access the host organisation’s staff policies, which may enable informal resolution.

For placements arranged by the School, we assess workplace policies to ensure they meet legal standards. The School may keep records of any such disclosures to identify and address recurring issues.

Students should inform their School placement tutor, programme leader, or personal tutor if they encounter such issues. The School can then offer support, which might include discussing the situation with the placement supervisor or mitigating any potential influence on the student's final grading.

If no local policy exists (e.g., with small or overseas organisations), a School staff member may provide the host organisation with the School’s Student Bullying and Harassment Procedure to seek an appropriate resolution. Staff can request further guidance on handling such complaints from School officials.

Should a student withdraw from a placement due to these issues, they must still meet work-based programme requirements. While the School will assist in finding alternative arrangements, we cannot guarantee availability. Students wishing to withdraw should consult their School placement coordinator, programme leader, or personal tutor promptly.

Bullying, harassment, and victimisation based on age (excluding under-18s) involves unwanted behaviour related to actual or assumed age. This includes:

• Name-calling, jokes, and offensive language
• Verbal or physical abuse and intimidation
• Assumptions about someone's ability or competence due to their age
• Inappropriate references to age
• Refusal to follow instructions based on the manager’s or lecturer’s age
• Exclusion from social events or meetings due to age

Harassment also covers instances where individuals are targeted because of the age of people they associate with.

Bullying, harassment, and victimisation based on disability involves unwanted behaviour related to a known or assumed disability, impairment, or additional need. Under the Equality Act 2010, a disability is a physical or mental impairment that significantly and persistently affects daily activities. Such behaviour includes:

• Name-calling, jokes, and offensive language
• Verbal or physical abuse and intimidation
• Inappropriate comments or questions about an individual's impairment
• Assumptions that a disability indicates inferiority or lack of intelligence
• Speaking to others rather than directly to the individual with the disability
• Refusal to work or study with, or exclusion of, disabled individuals from social events or meetings

Harassment also includes targeting individuals due to their association with someone who has a disability.

Bullying, harassment, and victimisation related to gender identity or reassignment involves unwanted behaviour towards individuals who are intending to undergo, are undergoing, or have undergone gender reassignment. This includes:

• Name-calling, jokes, and offensive language
• Verbal or physical abuse and intimidation
• Breaching the confidentiality of someone undergoing or who has undergone gender reassignment (which may also be a criminal offence)
• Refusing to recognise a person’s new gender during their transition
• Failing to use a person’s correct name and gender pronouns
• Inappropriate exclusion from facilities matching their self-identified gender
• Intrusive questioning
• Refusal to work or study with, or exclusion from, social events or meetings

Harassment also includes targeting individuals because of their association with someone undergoing or who has undergone gender reassignment.

Bullying, harassment, and victimisation based on race involve unwanted behaviour related to race, ethnicity, national origin, nationality, caste, or skin colour. This includes:

• Name-calling, jokes, and offensive language
• Verbal or physical abuse and intimidation
• Displaying racially offensive material, including graffiti
• Refusal to work or study with, or exclusion from, social events or meetings due to race, colour, nationality, or ethnic origin

Harassment also includes targeting individuals because of the race, colour, nationality, or ethnic origin of those they associate with.

Bullying, harassment, and victimisation based on religion or belief involve unwanted behaviour related to religious beliefs or practices, including non-belief (e.g., atheism or agnosticism) and non-religious beliefs (e.g., Humanism or Pacifism). This includes:

• Name-calling, jokes, and offensive language
• Verbal or physical abuse and intimidation
• Mocking or ridiculing religious or non-religious beliefs
• Ridiculing individuals for wearing religious attire
• Denigrating cultural customs
• Dismissing requests for religious or cultural holiday observances

Harassment also covers targeting individuals based on the religion or beliefs of those they associate with.

Bullying, harassment, and victimisation based on sex or gender involve unwanted behaviour related to an individual’s known or presumed sex/gender. Such behaviour includes:

• Name-calling, jokes, taunts, and offensive language
• Verbal or physical abuse and intimidation
• Making assumptions about someone’s abilities or competence based on their sex/gender
• Inappropriate references to an individual’s sex/gender
• Refusal to follow instructions due to a manager’s or lecturer’s sex/gender
• Refusal to work or study with someone or excluding them from social events because of their sex/gender
• Bullying or harassing someone because they are pregnant (e.g., preventing them from attending antenatal appointments)

Harassment on the grounds of sex/gender also includes targeting individuals based on the sex/gender of those they associate with.

Sexual bullying, harassment, and victimisation involve unwanted behaviour of a sexual nature. This includes:

• Physical acts, such as unwanted touching, groping, invasion of personal space, sexual assault, rape, or indecent exposure
• Verbal harassment, including:
  • Unwanted personal comments or sexual slurs
  • Belittling, suggestive, lewd, or abusive remarks
  • Explicit jokes or innuendos
  • Demands for sexual favours

Non-verbal sexual harassment includes:

• Suggestive looks, leering, and explicit gestures
• Sending sexually explicit emails or social media posts
• Displaying pornographic material on School equipment or premises (see the School's IT Regulations for more details)

Sexual harassment can occur between any gender, including men by women, women by men, or between individuals of the same sex. It can also affect trans and non-binary people.

Bullying and harassment based on sexual orientation (whether gay, lesbian, bisexual, or heterosexual) involve unwanted behaviour such as:

• Name-calling, jokes, taunts, or offensive language
• Verbal or physical abuse or intimidation
• Unwanted or threatened disclosure of someone’s sexual orientation
• Intrusive questioning about personal or sex life
• Inappropriate references to someone’s sexual orientation
• Excluding same-sex partners from social events while including opposite-sex partners
• Refusal to work or study with someone or excluding them from social events due to their sexual orientation

Harassment based on sexual orientation also includes mistreatment of individuals because of the sexual orientation of those they associate with.

For the purposes of this procedure, bullying, harassment, and victimisation are defined as follows:

1.   Harassment: Defined under the Equality Act (2010) as unwanted behaviour related to protected characteristics that undermines dignity or creates an intimidating, hostile, degrading, humiliating, or offensive environment. Harassment can occur from a single incident or repeated behaviour and includes:

• Protected Characteristics: Age, disability, gender identity/reassignment, pregnancy or maternity, race, religion and belief, sex/gender, sexual orientation.
• Examples: Offensive remarks, obscene gestures, unwanted physical contact, and intrusive behaviour via text, email, or social media.
• Perception and Association: Harassment may be based on perceived or actual protected characteristics or association with someone with such characteristics.

2.  Bullying: Persistent, malicious behaviour intended to undermine confidence and self-esteem, often involving misuse of power. Examples include:

• Examples: Intimidation, ostracism, unreasonable workloads, excessive supervision, public humiliation, and obstructive behaviour.

3.  Victimisation: Adverse treatment of individuals due to making or supporting a complaint about discrimination or harassment. Examples include:

• Examples: Exclusion from social events, denial of opportunities, or lowering of assessment results due to complaints.

4.  Appropriate Behaviours: Distinct from bullying, harassment, and victimisation, these include:

• Examples: Following School procedures, merit-based decisions, academic debate, promoting equality, and respecting cultural differences.

What should I do if I fear for my personal safety or the safety of someone else?

Emergencies: If you or someone else is in immediate danger, or if emergency assistance is required: CALL 999. If you are on School premises, you should also call the School emergency number to inform site staff.

If you have concerns for your personal safety or that of others but you/they are not in immediate danger, you can disclose the incident(s) to the Student Wellbeing Team via the School’s Online Disclosure Tool on the AGS. Further information about the Disclosure Response Team and how to disclose an incident to the team can be found in the policies.

If you make an identified disclosure via the Online Disclosure Tool, we will be in touch with safety information. If you make an anonymous disclosure, please carefully read the safety information available on the Online Disclosure Tool.

An identified disclosure will be kept confidential within the Student Wellbeing Team. A student’s information will only be disclosed outside of the team in exceptional circumstances: for example, where there is a legal duty to do so, such as a court order or safeguarding issue, or when disclosure is necessary to safeguard the individual or others. Staff in the Student Wellbeing Team will discuss confidentiality further with you when you first access the service and before you share any additional information.

Should I make an information disclosure or formal report?

The School takes allegations of bullying, harassment, and victimisation very seriously and will seek as swift and just a resolution to each situation as possible.

In dealing with disclosures of bullying, harassment, and victimisation, the School’s focus will be on local/informal resolution wherever possible. This is because, by resolving issues locally, all parties involved in the situation are much more likely to be satisfied with the outcome and matters may be resolved more quickly.

An individual has the option to make a formal report to the School at any stage and is not obliged to pass through the personal and local resolution stages prior to this, although this would be strongly recommended unless the allegation is very serious.

If the allegation is very serious (for example, sexual harassment) or the individual feels too unsafe or uncomfortable to make contact with the person responsible for the behaviour, they should generally pursue a formal report rather than a personal or local/informal resolution.

How can I challenge the person at an informal level?

Some cases of bullying, harassment, and victimisation arise out of misunderstandings, personality clashes, or misplaced humour rather than by deliberate actions. You may find that talking to the person about their behaviour is enough to stop it from continuing. However, this may not always be appropriate – for example, in cases of sexual harassment or any situation where you feel physically unsafe.

If you decide it would be appropriate to challenge the person about their behaviour and would like moral support, ask a friend if they can accompany you to talk to the individual. They may help to calm the atmosphere and to give you more confidence.

Remember that if you do arrange to speak to the perpetrator, you should explain the purpose of your request and arrange a place to meet where you can talk discreetly. If you plan to meet the perpetrator with a friend for support, you should tell them beforehand.

Think about what you are going to say in advance, and practise with someone beforehand if you think this will help. It may be helpful to use specific examples or evidence of the unwanted behaviour. When discussing the situation, try to be clear and specific:

• Tell them exactly what you found unacceptable
• Describe how it made you feel
• Explain what you want them to do – or stop doing – in the future

Be prepared to listen to their side of the story too. They may have interpreted some of your behaviour negatively, and so it can be helpful to have an honest conversation so that you can reach an agreement about how things should change in the future.

Brief notes of the discussion, and copies of any correspondence, should be kept by both parties in the event that follow-up action becomes necessary. The meeting should not be recorded unless everyone has agreed that they are happy to do this.

If the person tries to laugh off your challenge, tell them that you are being serious and make it clear to them that their behaviour is unacceptable and that the School takes bullying, harassment, and victimisation very seriously. Be aware that if you have caught the person off guard, it may be natural for them to be defensive at first. You may need to give them some time to reflect, and their behaviour may still improve even if they cannot see your point of view at first. Remember to stay calm and focused on informing them how their behaviour has made you feel.

If, after speaking to them, their behaviour still does not improve, then you may wish to consider more formal ways of disclosing and reporting the situation.

What should I do if I’m accused of bullying, harassing, or victimising someone else?

The School has a duty to investigate all formally reported incidents of bullying, harassment, and victimisation thoroughly. However, the School also recognises its equal duty of care both to the reporting party and the accused party, and allegations will not be presumed proved until properly investigated using the appropriate complaints or disciplinary procedures.

Students who have been accused of bullying, harassment, or victimisation have a right to be informed if a formal report is made about them and will be given the opportunity to state their own case.

They should take the following action:

• Make sure that they read the Student Disciplinary Policy which sets out what can be expected at each stage of the procedure for dealing with the formal report.
• Avoid contact with the person who has made the accusation, unless this is absolutely necessary, for example on work, teaching, or study matters. If contact would normally be inevitable or unavoidable, the person accused should seek advice from their PAT or Student Wellbeing Team. It may be appropriate to have a third-party present when it is necessary to hold study or work-related meetings.
• Make notes relating to any incidents that have occurred involving the person making the allegation of bullying, harassment, or victimisation and be prepared to respond to questions relating to these incidents.

Students who have been accused of bullying, harassment, or victimisation can also access support and representation from the Student Wellbeing Team, as well as personal and emotional support.

I think my friend is being bullied/harassed/victimised. What should I do?

If you have concerns about how one of your friends is being treated, the first step to take is to talk to them, describe what you have noticed and see how they respond. It may be that they have interpreted events differently and are not bothered by a situation. Alternatively, they may have been avoiding confronting someone and will welcome your support in deciding how to tackle the issue.

It is important that you let them decide what they would like to do, but you can help them by telling them about the different options available. You can point them in the direction of the Student Wellbeing Team if you feel they would benefit from talking to someone about events in more detail. Further information about the Student Wellbeing Team and how to disclose an incident to the team can be found in the policies.

If they want to address the issues informally, you could offer to support them by accompanying them and/or by helping them to rehearse what they are going to say.

If they choose to make a formal report, you may be able to support their case by describing the events that you have witnessed to the investigating member of staff.

If you have concerns for their, or anyone else’s, personal safety, see the question ‘What should I do if I fear for my personal safety or the safety of someone else?’

What do I do if it involves someone who isn’t a School student or member of staff?

All students and staff at the School are expected to abide by the School’s Disciplinary policies and will be subject to disciplinary action where clear breaches are shown, such as in the case of bullying, harassment, or victimisation. This applies both within an academic and a social context.

However, if the perpetrator is someone who is not associated with the School, it can be more difficult for the institution to take action since normal disciplinary policies would not apply. Instead, students may find that these behaviours are covered by other areas of legislation. For example, if bullying, harassment, or victimisation occurs within the workplace, individuals would be covered by employment legislation and any employer policies.

More generally, harassment may be referred to as Hate Crime and can be reported directly to the Police or via a third-party organisation.

If bullying, harassment, or victimisation occurs within private accommodation, the School may not be able to intervene directly, but the Student Wellbeing Team may be able to offer advice regarding contracts and tenancy issues and whether it is possible to sub-let or find housing elsewhere. The team may also be able to provide assistance if you are experiencing issues with your neighbours.

In all these cases, the Student Wellbeing Team can provide practical guidance and support. Further information about the Student Wellbeing Team and how to disclose an incident to the team can be found in the policies.

I’m being bullied/harassed/victimised by School students, but in social situations rather than on my programme. What can the School do?

The School expects students to treat each other, staff members and members of the public with dignity and respect at all times, regardless of whether they are engaged in School activity, on- or off-campus, or online. Therefore, any bullying, harassment, or victimisation incident involving students would fall under the remit of this procedure.

I’m being bullied/harassed/victimised online, by email, text or social media. What can the School do?

Bullying, harassment, and victimisation do not have to be face-to-face; they can also occur through other media including online platforms, text messages, emails, and social media sites. Offensive or degrading comments made through any of these media would fall under the remit of this procedure.

Additionally, the School has rules and regulations about how its IT systems are used. This means that students who are found to have used School computer equipment or networks to distribute offensive materials may also face disciplinary action. Further information can be found in the School’s IT Regulations.

In cases where you notice that comments or remarks have been shared through electronic means, it can be helpful if you record details of what has been shared/said. This can be done by taking copies of social networking pages (by holding down the Ctrl + Prt Scr buttons and then copying this image into a Word document or Paint file), or by keeping copies of text messages and emails.

You can also report the harassment to your internet service provider (ISP) or mobile phone provider as appropriate.

National organisations that provide guidance on online harassment and abuse can be found in Appendix C.

What details should I include in a formal report?

When making a formal report of bullying, harassment, or victimisation to the School authorities under the Student Disciplinary Policy, it is important to provide details about what has happened so that the case can be investigated. One way of collecting this information can be through keeping a diary of events as they happen, which may include things like:

• Date and time
• Location
• What happened
• Your feelings in relation to the incident
• What action do you take
• Names of any witnesses

This can help to ground discussions and may assist the investigation process.

It is also helpful to keep any potential evidence that may help with your case. For example, if the incident(s) involved online harassment, keep hold of any emails, text messages, or social media posts, and include these in your formal report. For further guidance, see the question ‘I’m being bullied/harassed/victimised online, by email, text or social media. What can the School do?.

Students who feel that they have experienced bullying, harassment, or victimisation should be aware that a satisfactory resolution is more likely to be achieved if a formal report is made as soon as possible after the alleged incident(s). If some time has passed since the alleged incident occurred, the School may consider it inappropriate to take disciplinary action.

Are identified disclosures and formal reports of bullying and harassment handled confidentially?

Identified disclosures to the Student Wellbeing Team will be kept confidential. A student's information will only be disclosed outside of the team in exceptional circumstances and ideally with consent from the student. Information will be shared where:

• the individual to whom the information relates has consented
• disclosure is necessary to safeguard the individual or others
• there is a legal duty to do so, such as a court order or safeguarding issue - in which case we may share information with other School staff or appropriate services

Any disclosure of a student’s information will be made with discretion and on a ‘need to know basis. Staff in the Student Wellbeing Team will discuss confidentiality further with the student when they first access the service and before the student shares any additional information.

Where a student makes a formal report to the School authorities, the very nature of bullying, harassment, and victimisation means that, other than in very exceptional circumstances, the reporting party would need to be named during any dealings with the accused party to enable them to understand the full nature of the complaint.

Confidentiality will be respected and maintained by anyone dealing with a formal report of bullying, harassment, or victimisation unless there is an unacceptable risk to the reporting party, another person, or the institution. This aims to protect both the reporting party and the accused party from malicious gossip. It would also be expected that both the reporting party and the accused party would not broadcast the situation unnecessarily as this could adversely affect the outcome of the case.

While it may be appropriate for formal reports to be raised initially by a Student Union representative or other ‘third-party’, it should be acknowledged that progress in resolving the situation could be severely limited unless the reporting party is able and willing to participate in the resolution process.

Individuals making a formal report of bullying or harassment will be protected from victimisation and retaliation.

What kind of disciplinary action will someone receive for bullying/harassing/victimising another student or member of staff?

Students and staff who are found to have bullied, harassed, or victimised other members of the School community (staff, students or visitors) may face disciplinary action in accordance with the student or staff disciplinary procedures, as appropriate.

Details of sanctions for students can be found in the Student Disciplinary Procedure. The School has a separate Staff Disciplinary Policy which outlines how the School will deal fairly and consistently with members of staff who may have breached policies and/or procedures or behaved in an inappropriate or unacceptable manner at work.

If disciplinary action has been taken against someone as a result of my formal report, will I find out?

In cases where disciplinary action is taken against a student or a member of staff, the reporting party will be told that their report was upheld. However, they will not be informed of the details of any disciplinary action taken against the other individual, for this could be deemed as private information under the Data Protection Act 2018. Further information can be found in the School’s Data Protection Policy and Student Privacy Notice.

Complaints of bullying, harassment, and victimisation involving staff, agency staff, governing body members, contractors, or suppliers are managed through the Student Complaints and Academic Appeals Policy. Students should use this procedure to make a formal report. For additional support, students can also contact their Personal Academic Tutor (PAT) or the Student Wellbeing Team.

The following local and national agencies may also be able to provide information and support to students who are experiencing bullying, harassment, or victimisation:

1. Mediation Plus provides impartial and confidential mediation services to residents in Eastbourne, Lewes, and Wealdon), using mediation as a way of resolving disputes. Mediation Plus (mediationhttps://mediation-plus.org.uk/plus.org.uk)
2. National Bullying Helpline is a national organisation that provides information and guidance for adults and children experiencing bullying. Information and advice about all forms of bullying (nationalbullyinghelpline.co.uk)
3. Ditch the Label is a national organisation that provides resources and digital one-to-one support for young people who have concerns about bullying or things that are connected such as body image, mental health, and sexuality. Bullying & Cyberbullying Guides - Advice, Info & Tips | Ditch the Label
4. True Vision is a national organisation that provides information about hate crimes or incidents and how to report it. Stop Homophobic, Transphobic, Racial, Religious & Disability Hate Crime - True Vision (report-it.org.uk)
5. Revenge Porn Helpline: National helpline supporting adults (those over the age of 18) who are victims of image-based sexual abuse. Revenge Porn Helpline - 0345 6000 459 | Revenge Porn Helpline
6. Get Safe Online: National organisation providing information and advice on online safety. Get Safe Online | The UK's leading Internet Safety Website
7. The Samaritans is a national organisation that provides emotional support for people who are struggling to cope, including those who have had thoughts of suicide. They have a 24-hour free and confidential helpline: 116123. Samaritans | Every life lost to suicide is a tragedy | Here to listen

This procedure details how students can disclose, report, and resolve incidents of bullying, harassment, or victimisation. It should be read alongside the School's relevant policies and procedures.

The flowchart below provides a summary of the processes for disclosing, reporting, and resolving such issues:

Disclosures and reports of bullying, harassment, and victimisation involving students are managed through the following process. Personal or informal resolution is encouraged but not always required. Students may bypass stages if needed, particularly in serious cases.

1. Personal Resolution Stage

   • Individuals should first attempt to address the issue directly by making their concerns known to the person responsible. Options include:
     • Speaking directly to the person
     • Writing a letter
     • Discussing the issue with the person in the presence of another student
     • Asking a third party to intervene
     • Blocking unwanted messages or social media interactions
   • Guidance on personal resolution is available in Appendix A: Frequently Asked Questions (FAQ). In cases like sexual harassment or when feeling unsafe, students should skip to local/informal resolution or formal reporting.

2. Local/Informal Resolution Stage

   • If personal resolution is unsuccessful or inappropriate, students should report the issue to the Student Wellbeing Team via the Automated Governance System (AGS). Reports can be made anonymously or with contact details. The Team will respond and offer support.
   • Students may explore informal resolution options, including mediation. While the School does not provide formal mediation services, assistance from someone with mediation skills may be arranged. This stage focuses on finding an informal resolution and does not initiate formal investigation or disciplinary action.

3. Formal Resolution Stage

   • If informal resolution fails or is not suitable, or if a formal report is preferred, students should submit a formal report to the Student Wellbeing Team via the AGS.
   • The School will conduct an investigation and, if necessary, take disciplinary action under the Student Disciplinary Policy. Misconduct may also be addressed through other relevant policies and procedures, with a range of sanctions available.

The Student Wellbeing Team provides comprehensive support for students facing bullying, harassment, or victimisation, including issues such as hate crime, sexual violence, or domestic abuse (recent or historic). Their trained staff offer:

• Safety management support
• Practical assistance
• Referrals to specialist services
• Guidance on making formal reports or complaints

Students can report incidents via the AGS, either anonymously or with contact details. They can also report on behalf of others or disclose witnessed incidents. Staff may disclose incidents on behalf of students, ensuring the student’s consent before identifying them.

The Online Disclosure Tool on the AGS is not for emergencies. For immediate danger, call 999. On School premises, also call the School emergency number +44 (0)203 507 0033.

Students may also consult their Personal Academic Tutor (PAT) for initial support. PATs can discuss issues, assist with disclosures to the Student Wellbeing Team, and provide guidance to both complainants and those accused.

Additional local and national support agencies are listed in Appendix C.