Harassment and Student Safety Policy

This policy sets out how the School protects students from harm and upholds its legal responsibilities, including those under the Equality Act 2010. It describes the School’s approach to preventing, reporting, and addressing harassment and sexual misconduct.

The School expects all members of its community, including external partners, to act with integrity, treat others with respect, and uphold the highest standards of behaviour. Any concerns raised under this policy will be taken seriously, investigated impartially, and resolved through clear and transparent procedures. The School recognises its particular duty of care towards students who may be vulnerable to harm, whether from staff, peers, or others connected with the institution.

The School’s commitment is demonstrated through the following actions:

• Providing clear and accessible reporting routes, including options for anonymous disclosures.
• Ensuring that concerns are investigated promptly, fairly, and with sensitivity.
• Offering dedicated support services to students affected by harassment, sexual misconduct, or related behaviours.
• Delivering training to staff and students on their rights and responsibilities in this area.
• Upholding lawful freedom of speech, while ensuring appropriate measures are in place to protect individuals from harm.
• Prohibiting the use of non-disclosure agreements (NDAs) in cases involving harassment or sexual misconduct.
• Regularly reviewing the effectiveness of this policy to ensure it remains aligned with legal obligations and best practice.

The School affirms that it does not use NDAs to silence individuals who raise concerns about harassment, sexual misconduct, or safeguarding.

This policy reflects the School’s commitment to safeguarding the wellbeing, safety, and education of its community.

Where reports of harassment or sexual misconduct indicate potential safeguarding risks, cases will be triaged under safeguarding protocols in parallel with the disciplinary processes outlined in this policy.

The purpose of this policy is to establish a clear and consistent framework for preventing, reporting, and responding to harassment, sexual misconduct, bullying, victimisation, and abuse of power within the School. This policy sets out the School’s expectations for the conduct of its students, staff, external partners, and others and explains the procedures in place to protect individuals from harm.

The policy aims to promote a culture of dignity, respect, and equality, where inappropriate behaviours are neither tolerated nor ignored. It ensures that any concerns raised will be addressed promptly, fairly, and sensitively, and that appropriate support will be provided to those affected. It further outlines the School’s commitment to safeguarding lawful freedom of speech within its academic community, while ensuring the wellbeing and safety of individuals are appropriately protected.

Through this policy, the School affirms its dedication to maintaining the highest standards of behaviour, protecting the welfare of its students and staff, and fulfilling its legal and moral responsibilities to provide a safe and inclusive learning and working environment.

This policy applies to all students enrolled on the School’s programmes of study, whether on a full-time, part-time, blended, or flexible online basis. It applies across all modes of course delivery. It also applies to all members of staff, including academic and professional services staff, casual workers, contractors, agency workers, and visiting speakers. In addition, the policy extends to volunteers, governors, and any other individuals acting on behalf of the School, including external placement partners.

The policy applies to all activities connected to the School, whether these take place on School premises, online, during placements, fieldwork, or social and extracurricular events, or in any other context where individuals are acting in connection with their roles at the School. It governs conduct between students, between staff and students, between staff members, and in relation to third parties whose actions may impact the School’s community.

Conduct that occurs off-site or in private settings may fall within the scope of this policy where it has a bearing on the safety, wellbeing, or experience of students or staff in their connection to the School.

The School recognises its responsibilities under the legal and regulatory frameworks which govern higher education providers in England. This policy is informed by those obligations and reflects the standards and expectations placed upon the School as part of its duty to safeguard the wellbeing, rights, and educational experience of its students.

The School’s approach is shaped by the Equality Act 2010, which protects individuals from discrimination, harassment, and victimisation on the grounds of protected characteristics. This legislation underpins the School’s commitment to fostering an environment where all students and staff are treated with dignity and respect, and where equality of opportunity is actively promoted.

Additionally, the School acknowledges its responsibilities under safeguarding legislation, including obligations to protect students who may be at risk of harm due to abuse, neglect, or exploitation. These duties extend beyond legal compliance and form a core part of the School’s commitment to ensuring a safe and supportive learning environment.

This policy has been developed in alignment with the regulatory framework that governs the higher education sector in England. These include standards relating to the protection of students from harassment and sexual misconduct, the promotion of freedom of speech within the law, and the upholding of students’ rights to fair and transparent procedures.

The School recognises its obligations in relation to data protection law, ensuring that information relating to cases of harassment, sexual misconduct, and safeguarding is handled lawfully, fairly, and securely in accordance with the General Data Protection Regulation (GDPR) and the Data Protection Act 2018.

For the purposes of this policy, the following terms are defined to ensure clarity and consistency in understanding across the School community. These definitions reflect established legal standards, sector guidance, and good practice within higher education.

Harassment is defined as unwanted conduct which is related to a protected characteristic, such as age, disability, gender reassignment, race, religion or belief, sex, or sexual orientation, and which has the purpose or effect of violating a person’s dignity, or creating an intimidating, hostile, degrading, humiliating, or offensive environment for them. Harassment can occur through a single act or repeated behaviour and may be verbal, non-verbal, physical, written, or via electronic means, including social media.
Harassment may be obvious or subtle, and the impact on the individual is central to determining whether conduct constitutes harassment, regardless of the intention of the person responsible.

Sexual misconduct refers to any unwelcome behaviour of a sexual nature which is committed without consent or has the effect of making a person feel uncomfortable, intimidated, or humiliated. This includes, but is not limited to, sexual harassment, sexual assault, sexual violence, stalking of a sexual nature, the sharing of sexual images without consent, and any coercive or exploitative sexual behaviour.

Sexual misconduct may arise in the context of staff-student or student-student relationships, and the School recognises the particular responsibilities it holds to address and prevent abuse of power within such relationships.

An intimate personal relationship is a relationship that involves physical intimacy and/or romantic or emotional closeness beyond the boundaries of a professional or academic connection. This includes, but is not limited to, sexual relationships, romantic partnerships, and relationships characterised by strong emotional intimacy which may affect impartiality, professional judgement, or create a real or perceived conflict of interest.

Bullying is defined as offensive, intimidating, malicious, or insulting behaviour, or an abuse of power that undermines, humiliates, denigrates, or injures an individual. Bullying may be persistent or an isolated incident, and can be verbal, non-verbal, or physical. It may occur face-to-face or through digital communications, including social media.

Victimisation occurs when an individual is treated unfavourably because they have made a complaint or allegation of harassment, bullying, or sexual misconduct, supported someone who has made such a complaint, or participated in an investigation or disciplinary process relating to these matters. Victimisation is unlawful under the Equality Act 2010 and is taken seriously by the School.

Abuse of power refers to situations where an individual uses their position of authority or influence within the School to intimidate, coerce, manipulate, or otherwise disadvantage another person. Such abuse may manifest within professional or academic relationships, and may involve exploiting vulnerabilities or exerting undue influence for personal or professional gain.

Safeguarding refers to the measures in place to protect the health, wellbeing, and human rights of individuals, ensuring they live free from abuse, harm, and neglect. Within the context of this policy, safeguarding primarily relates to the protection of students who may be at risk due to their age, disability, mental health, or other factors which make them vulnerable.

Freedom of speech is the legal right to express one’s views and opinions within the boundaries of the law. The School upholds freedom of speech as a fundamental principle of academic life but balances this right with its duty to protect students and staff from harm, including from unlawful speech such as hate speech, harassment, or incitement to violence.

Reporting refers to the act of notifying the School about an incident or concern covered by this policy. Reports can be made by individuals directly affected, by witnesses, or by those acting in support of someone who has experienced unacceptable behaviour. Reports may be submitted formally or informally, and individuals may choose to remain anonymous.

The complainant is the person who makes a report or raises a concern under this policy, alleging that they have experienced harassment, sexual misconduct, bullying, victimisation, or abuse of power.

The respondent is the person against whom a report or complaint has been made under this policy.

The School is committed to ensuring that all members of its community have access to clear, accessible, and effective routes for reporting concerns related to harassment, sexual misconduct, bullying, victimisation, or abuse of power. The School recognises that individuals affected by such behaviours may find it difficult to come forward and, as such, strives to provide a reporting process that is supportive and transparent.

Reports may be made by students, staff, or third parties who have witnessed, experienced, or been informed of conduct falling within the scope of this policy. Individuals may choose to report incidents formally or informally and may do so anonymously.

Where appropriate, individuals are encouraged in the first instance to seek support and advice from their Personal Academic Tutor (PAT), a member of the Student Success Team, or a trusted member of staff. These individuals can offer guidance on the reporting process and available support services. An informal approach may, in some cases, lead to resolution through discussion, mediation, or agreed actions without the need to invoke formal procedures. However, the decision to proceed informally or formally remains entirely with the person raising the concern.

It is important to note that informal discussions will not usually lead to disciplinary action unless the matter is subsequently escalated through formal reporting channels.

Formal reports can be made through the School’s designated reporting platform, the Automated Governance System (AGS), which provides a structured, secure, and confidential route for submitting concerns. This system allows individuals to:

• Identify the nature of the concern (e.g., harassment, sexual misconduct, bullying, safeguarding, victimisation).
• Clarify whether they are reporting on behalf of themselves or another person.
• Opt to report anonymously if preferred.
• Provide relevant details, including the identities of those involved, the nature and location of the incident, and any supporting information.
• Indicate whether they wish to be contacted for follow-up.

They may also initiate a report by contacting Personal Academic Tutors (PATs), a member of the Student Success Team, or a trusted member of staff. The details of the report should be entered into the AGS via the same reporting platform to enable it to be logged and tracked.

Upon such submission, the report is automatically directed to the Director of Student Services, who has oversight for triaging reports, ensuring appropriate action is taken, and maintaining oversight of case management.

Where a report indicates an immediate risk to an individual’s safety, the School will take urgent action to safeguard those involved. This may include referrals to external agencies or activating internal safeguarding protocols.

The Director of Student Services will assess the nature of the concern, including risks, and determine the appropriate route for handling the matter. This may involve referral to:

• The Student Success Team for matters involving student wellbeing or support.
• The Student Disciplinary Procedure for allegations concerning student conduct.
• The Staff Disciplinary Procedure via the People team for concerns involving staff.
• Safeguarding Leads where the report involves issues of safety, wellbeing, or vulnerability.

All reports will be handled promptly, with acknowledgment of receipt provided within two working days.

Where a formal investigation is warranted under a policy or practice, an impartial investigator will be appointed as per that policy or procedure. This individual will be appropriately trained and will have no prior involvement in the matter. The investigation will follow a structured process, including:

• Issuing a written investigation plan to all parties, outlining timelines, process stages, and rights of representation.
• Gathering evidence, including documentation, witness statements, and digital records where relevant.
• Conducting interviews with the complainant, respondent, and any witnesses, ensuring support is offered throughout.
• Preparing a findings report with recommendations for next steps.

Investigations will be conducted in accordance with the principles of natural justice, ensuring fairness, transparency, and sensitivity to all parties involved.

Following the conclusion of any investigation, the outcomes will be communicated to both the complainant and the respondent in writing, outlining the findings, any actions to be taken, and the rationale for decisions made. Both parties will be advised of their right to appeal through the School’s established appeals processes.

Where a case is upheld, outcomes may include disciplinary action ranging from warnings to exclusion (for students) or dismissal (for staff), as appropriate to the severity of the conduct.

The School recognises that some individuals may prefer to report concerns anonymously. While the School accepts anonymous reports through AGS, it should be noted that anonymity may limit the ability to investigate fully or to provide feedback on outcomes. Nonetheless, all anonymous reports are logged, reviewed, and considered for any safeguarding or risk-related actions required.

The School has a dashboard to track submissions and produce key data for continuous improvement. All reports and related documents will be maintained securely within this case management system, with access strictly limited to those with a legitimate role in handling the matter. Records will be retained in line with data protection law and the School’s Data Protection Policy.

Through these detailed procedures, the School aims to ensure that all concerns are addressed fairly, consistently, and with due regard for the wellbeing of all individuals involved.

Upon receipt of a formal report through the Automated Governance System (AGS) or through direct communication with a member of staff, the matter will be referred without delay to the Director of Student Services. An acknowledgement of receipt will be provided to the complainant within two working days, confirming that the matter is being reviewed and outlining the next steps.

The Director of Student Services will conduct an initial assessment to determine the nature and seriousness of the report, including an immediate risk assessment. These assessments will consider whether there are any immediate safeguarding concerns requiring urgent action and whether the report falls within the scope of this policy.

If the matter relates to staff conduct, it will be referred to the School’s People team under staff disciplinary procedures. If it concerns student conduct, it will proceed under the procedures outlined below.

Where a report includes allegations of criminal behaviour, the Director of Student Services will assess whether it is appropriate or necessary to refer the matter to the Police. Where a Prevent duty issue arises, the Director of Student Services will discuss it with the School’s Prevent Lead. This decision will take into account the wishes of the complainant, any immediate risks identified, and the School’s safeguarding and other obligations.

Where a formal investigation is required under a policy or procedure, the Director of Student Services will appoint an impartial and appropriately trained member of staff to act as the Investigating Officer under that policy or procedure. This individual will have had no prior involvement in the matter and will be responsible for gathering evidence, interviewing parties involved, and preparing a formal report of findings.

Both the complainant and the respondent will be notified in writing of the decision to conduct a formal investigation. This communication will outline the scope of the investigation, the process to be followed, the expected timelines, and the support available to them. Both parties will be reminded of their right to be accompanied to any meetings and their right to representation where applicable.

The Investigating Officer will conduct the investigation in a fair, sensitive, and objective manner. The investigation will typically include the following steps:

• An initial meeting with the complainant to gather detailed information about the allegations and to clarify any areas requiring further exploration.
• An initial meeting with the respondent to outline the nature of the allegations and to allow them the opportunity to respond.
• Meetings with any relevant witnesses, as identified by the complainant, respondent, or through the course of the investigation.
• The collection and review of documentary or digital evidence, such as emails, messages, or social media content, where relevant.
• The preparation of written notes following each meeting, which will be shared with the individuals concerned for confirmation of accuracy.

All meetings will be conducted in private, with a neutral note-taker present to ensure accurate records are kept. The individuals involved may be accompanied by a colleague, friend, or representative from the Students’ Representative where applicable.

Upon completion of the investigation, the Investigating Officer will compile a detailed report setting out the facts established, the evidence considered, and any findings in relation to the allegations made. This report will be submitted to the Director of Student Services for review.

Where the findings indicate that the allegations are substantiated and disciplinary action may be warranted, the case will proceed through the appropriate disciplinary process. This may include:

• Referral to the Student Disciplinary Panel in cases of serious misconduct.
• Immediate imposition of sanctions by the Investigating Officer for cases, within their delegated authority, if a policy or practice allows.

Where the findings indicate that the allegations are not substantiated, the complainant and respondent will be informed of this outcome in writing, with reasons provided.

Both the complainant and the respondent will receive written confirmation of the investigation outcome. This communication will include:

• A summary of the findings.
• Any action the School proposes to take.
• Information on the right to appeal, the grounds for appeal, and the process to be followed as defined in relevant policies and procedures.

The School will take appropriate steps to protect the confidentiality of those involved, while ensuring transparency of process and outcome to the extent necessary.

Appeals against the outcome of an investigation or any disciplinary action imposed will be handled in accordance with the School’s appeal procedures.

Details of the appeals process will be provided alongside the outcome letter.

Investigations will normally be concluded within twenty-one working days from the date of appointment of the Investigating Officer. Where this is not possible due to complexity or availability of evidence, the individuals involved will be informed of revised timescales and reasons for any delay.

Disciplinary panels, where required, will normally be convened within thirty working days of the completion of the investigation. Outcome letters will be issued within seven working days of the panel decision.

Records of all investigations, outcomes, and any disciplinary actions taken will be maintained securely by the Director of Student Services. Access to these records is restricted and will be managed in accordance with data protection legislation and the School’s Data Protection Policy.

Records will be retained for the duration of the individual’s enrolment or employment, and for a period thereafter as set out in the School’s retention schedule. Aggregated, anonymised data on cases will be reported to governance bodies to inform oversight and continuous improvement.

The School is committed to providing comprehensive, accessible, and effective support to all those affected by issues covered under this policy, including harassment, sexual misconduct, bullying, victimisation, abuse of power, or related safeguarding concerns. In particular, the School recognises that such experiences can have a profound impact on a student’s wellbeing, mental health, academic engagement, and overall experience of higher education. Supporting students is a central pillar of the School’s approach to prevention, intervention, and resolution.

The School’s support mechanisms for students are designed to offer early intervention, ongoing assistance, and specialised guidance where required. These services operate in close coordination with the reporting, investigation, and disciplinary procedures outlined in this policy, ensuring that students are supported holistically throughout any process they may engage with.

The School’s Personal Academic Tutoring (PAT) system plays a fundamental role in providing academic and pastoral support to students. PATs serve as a regular, proactive point of contact, helping students navigate both academic challenges and personal issues that may impact their studies. PATs are trained to recognise signs of distress or vulnerability and are able to offer guidance, escalate concerns appropriately, and signpost students to further support where necessary.

Where a student discloses concerns relating to harassment, sexual misconduct, or related behaviours within the PAT relationship, the PAT will ensure the student is informed of the reporting mechanisms available, including informal and formal routes, and will support the student in accessing additional services as needed.

The Student Success Team offers an additional layer of support for students requiring assistance beyond their PAT. This team provides advice, practical support, and access to wellbeing services, including those related to mental health, disability, and safeguarding. The Student Success Team works closely with academic staff, PATs, and external agencies where appropriate, ensuring a coordinated and student-centred approach to support.

Students who engage with the reporting processes outlined in this policy will be offered ongoing contact with the Student Success Team throughout any investigation or disciplinary process.

The School is committed to supporting the mental health and wellbeing of its students, recognising the interconnectedness of mental health, academic success, and personal safety. Students have access to a range of wellbeing resources, including:

• Initial consultations with wellbeing advisers.
• Referral to counselling and specialist support services where appropriate.
• Practical guidance on managing stress, anxiety, and the impacts of trauma.
• External support services through partnerships and signposting arrangements.

The School’s approach to mental health support is guided by its Student Mental Health Policy, which sets out the principles, responsibilities, and pathways available to ensure that students can access timely and appropriate help.

The School recognises its safeguarding responsibilities under legislation and institutional policy. Safeguarding concerns are triaged by the Designated Safeguarding Lead, who ensures that appropriate measures are taken to protect students from harm. This may include the development of individual safeguarding plans, liaison with external safeguarding partners, and ensuring that any concerns are integrated into the School’s broader support structures.

Safeguarding is embedded within the School’s reporting, monitoring, and governance processes, ensuring that any risk identified through this policy’s procedures is appropriately addressed.

The School also has a Prevent Lead.

In addition to the support services provided internally, the School maintains comprehensive signposting to external organisations offering specialist assistance in areas such as harassment, sexual misconduct, mental health, and legal advice. This information is made available through the School’s website, handbooks, and Student Success Team.

Students are encouraged to access these services as needed, recognising that external providers may offer independent and confidential support beyond the scope of the School’s internal provision.

Support provided to students is monitored by the Director of Student Services and the submission dashboard, enabling oversight of individual cases, emerging trends, and areas for enhancement. Feedback from students who engage with support services also informs continuous improvement, ensuring that the School’s approach remains responsive, effective, and aligned with sector best practice.

Regular review of support mechanisms is conducted by the Director of Student Services at the Executive Committee level, in collaboration with the Student Success Team, PAT coordinators, safeguarding leads, and academic leadership, with outcomes reported to the Executive Committee and Governors.

Through these integrated support structures, the School demonstrates its commitment to safeguarding the wellbeing of its students and ensuring that those affected by harassment, sexual misconduct, or related behaviours receive the support they need to continue their studies safely and successfully.

The School is committed to maintaining clear, professional boundaries between staff and students in order to safeguard the integrity of the educational environment and to protect both parties from potential conflicts of interest, abuse of power, and perceptions of impropriety. The School recognises that the nature of academic and pastoral roles may bring staff and students into close professional contact. Therefore, clear expectations regarding conduct and boundaries are essential to maintaining trust, fairness, and respect within the School community.

This section should be read in conjunction with the School’s Staff and Student Relationship Policy, which sets out in detail the principles, expectations, and procedures governing professional conduct in this area.

In line with the School’s policy, staff must not enter into any intimate, romantic, or sexual relationships with students. This prohibition applies in all circumstances and is absolute, regardless of any perceived consent.

Such relationships undermine professional boundaries, create inherent conflicts of interest, compromise fairness and impartiality, and expose both parties to potential allegations of misconduct or exploitation.

Where a pre-existing personal relationship exists between a member of staff and a student — for example, where a staff member and student are related or share a domestic arrangement — the staff member is required to declare this to their line manager and People team. This ensures that appropriate measures can be put in place to avoid any conflicts of interest or perceptions of bias. Such measures may include adjusting academic supervision arrangements, reassigning assessment responsibilities, or placing restrictions on involvement in disciplinary or complaints processes.

Failure to declare such relationships may be treated as a disciplinary matter.

All staff are expected to maintain professional boundaries in their interactions with students at all times. This includes:

• Communicating with students through appropriate, professional channels.
• Avoiding behaviour that could be construed as favouritism, undue familiarity, or over-involvement in a student’s personal affairs.
• Being mindful of the power imbalance inherent in staff-student relationships and acting with integrity to protect students’ welfare and the reputation of the School.

Staff must ensure that any concerns about inappropriate behaviour, whether by colleagues or students, are reported promptly through the appropriate channels.

Staff receive training on maintaining professional boundaries as part of their induction and ongoing professional development. This training reinforces the expectations set out in this policy and the Staff and Student Relationship Policy, ensuring that staff are aware of the risks associated with breaches of professional conduct and the potential consequences for themselves, the students involved, and the institution.

The School monitors compliance with these expectations through its governance structures, including regular review of disciplinary cases, feedback mechanisms, and staff appraisals. Any breaches of these provisions are taken seriously and may result in disciplinary action, up to and including dismissal.

By maintaining these clear boundaries, the School ensures that its academic and professional environment remains fair, respectful, and free from undue influence or exploitation.

The School recognises that prevention is a critical element of safeguarding students and staff from harassment, sexual misconduct, bullying, victimisation, and abuse of power. The School is committed to ensuring sufficient financial, staffing, and training resources. As such, the School is committed to delivering structured, mandatory, and role-appropriate training to both students and staff as part of its wider approach to fostering a safe, respectful, and inclusive academic community.

These training provisions are designed to ensure that all members of the School community understand their rights and responsibilities, recognise unacceptable behaviours, and are aware of how to report concerns and access support. This training also supports the School’s legal and regulatory obligations, including those relating to safeguarding, freedom of speech, the Equality Act 2010, and duties of care under health and safety law.

The training outlined in this section is embedded within the School’s broader governance and operational frameworks, as outlined in the School Handbook and Staff Handbook. These handbooks confirm the School’s expectations for professional conduct, safeguarding, dignity and respect, and student responsibilities. They outline the requirement for staff and students to engage with relevant training as part of their duties within the School community.

Students are required to engage with mandatory training covering harassment, sexual misconduct, safeguarding, freedom of speech, and related topics as part of their induction to the School. This is delivered through:

• Online e-learning modules, accessible within two weeks of enrolment.
• In-person workshops during induction week, focusing on consent, bystander intervention, and respect.
• Annual refresher training to reinforce key messages and update students on any changes in law, policy, or best practice.
• Targeted training for student leaders, societies, volunteers, and others with specific roles of responsibility.

Training content covers definitions of unacceptable behaviour, reporting routes (including AGS), the role of Personal Academic Tutors (PATs), and available support services. It also addresses lawful freedom of speech and the distinction between offensive views and unlawful conduct.

All staff are required to complete safeguarding, harassment, sexual misconduct, and freedom of speech training within their first month of employment. This is delivered through:

• Mandatory online e-learning as part of the induction process.
• Role-specific training within three months for those in positions of heightened responsibility, such as PATs, Student Success Team members, safeguarding leads, and investigators.
• Annual refresher training to ensure knowledge remains current and aligned with sector best practice.
• Advanced training for senior managers, People professionals, disciplinary panel members, and compliance staff, focusing on investigation procedures, safeguarding law, and freedom of expression protections.

Staff training is managed and monitored by the People team, with completion rates tracked and reported to the Director of Operations.

Completion of all mandatory training is monitored through People systems (for staff) and Student Services systems (for students). Non-compliance is followed up through line management for staff and through engagement strategies for students. Completion rates are reviewed termly and reported to the Executive Committee by the Director of Operations and Governors as part of the School’s governance assurance processes.

Training content is reviewed annually by the People team in consultation with Prevent and Safeguarding Leads, and the Student Success Team to ensure alignment with current legislation, regulatory expectations, and sector best practice. Feedback from participants informs ongoing enhancement to ensure training remains engaging, effective, and relevant.

This structured, mandatory training framework ensures:

• Legal and regulatory compliance across all areas covered by this policy.
• A consistent understanding of rights, responsibilities, and reporting processes.
• Reinforcement of the School’s values of respect, inclusivity, and accountability.
• Protection of lawful freedom of speech within the bounds of safeguarding and wellbeing duties.
• Assurance to regulators and stakeholders of the School’s commitment to prevention and education.

The School recognises that the handling of personal data in connection with allegations of harassment, sexual misconduct, bullying, victimisation, and safeguarding concerns requires the utmost care, diligence, and compliance with data protection legislation. This includes adherence to the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and institutional policies including the School’s Data Protection Policy and Student Privacy Notice.

All personal data processed under this policy is handled in accordance with the School’s Data Protection Policy. Data is processed lawfully, fairly, and transparently, with safeguards in place to protect the confidentiality and rights of individuals involved.

Information provided during the reporting, investigation, and disciplinary processes is treated with strict confidentiality. Access is restricted to those directly involved in managing the case, including relevant members of staff within the Student Success Team, People team, and senior leadership as necessary. Confidential information will not be disclosed to third parties except where required by law, where necessary to protect the health or safety of individuals, or with the express consent of the individual concerned.

The School upholds the principles of data minimisation and purpose limitation, ensuring that only data strictly necessary for managing the concern is collected, processed, and retained. Sensitive personal data, including information relating to safeguarding, mental health, and allegations of sexual misconduct, is handled with enhanced protections and is subject to additional controls.

Where data is processed in connection with safeguarding or criminal matters, further restrictions apply in line with statutory obligations and guidance from the Information Commissioner’s Office (ICO).

All reports of misconduct, safeguarding concerns, and investigations are recorded securely within the School’s Automated Governance System (AGS), which serves as the institutional platform for case management and compliance monitoring. This system enables the tracking of cases from initial report through to resolution, including recording key milestones such as investigation outcomes, disciplinary decisions, and time to resolution. Records include:

• The nature of the concern reported.
• Dates of reports, meetings, investigations, and decisions.
• Outcomes of investigations and disciplinary processes.
• Support provided to individuals involved.
• Any follow-up actions or safeguarding measures.

Data is stored in accordance with the School’s retention schedules and data protection principles. In general, records relating to student conduct are retained for six years after the conclusion of proceedings, unless there is a clear and lawful reason to retain them for longer. Records relating to safeguarding or criminal matters may be retained in accordance with statutory requirements.

The School’s Data Protection Officer oversees data management practices, ensuring compliance with legal obligations and institutional policy. Any requests for access to personal data, correction of inaccuracies, or objections to processing are managed in accordance with the rights of individuals as set out in the Data Protection Act 2018 and UK GDPR.

Data is stored securely within systems that are access-controlled and protected by appropriate technical and organisational measures. Staff handling such data receive regular training on data protection obligations, confidentiality, and information security, consistent with the School’s policies and procedures.

Breaches of confidentiality or data protection related to the handling of misconduct or safeguarding matters are treated seriously and may result in disciplinary action.

This section operates in conjunction with:

• The School’s Data Protection Policy, which sets out the overarching framework for data governance.
• The Student Privacy Notice, which explains how student data is collected, used, and protected.
• The School Handbook and Staff Handbook, which outline responsibilities for data security, confidentiality, and privacy.
• Institutional IT and Governance policies regarding data storage, access, and retention.

A controlled dashboard monitors the management of cases covered by this policy, including compliance with data handling standards. Reports in accordance with the Data Protection Policy are provided to the Executive Committee to ensure transparency, accountability, and continuous improvement in safeguarding privacy and data security.

Through these measures, the School demonstrates its commitment to protecting the privacy of individuals while fulfilling its legal and ethical responsibilities to investigate and address serious misconduct effectively.

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.

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, call 999. If you are on School premises, also notify staff immediately.

Non-Emergencies

If you are concerned about your safety, or the safety of someone else, but there is no immediate danger, you should disclose this via the Online Disclosure Tool on the AGS. You can submit either an identified or anonymous disclosure.

The Student Success Team will review identified disclosures and provide appropriate safety information and support.

Identified disclosures are treated confidentially within the Student Success Team. Information is only shared externally in exceptional circumstances, for example where there is a safeguarding concern, a legal obligation (such as a court order), or where necessary to protect the individual or others. Confidentiality will be discussed with you prior to sharing further information.

Should I Make an Informal Disclosure or a Formal Report?

The School takes all concerns about bullying, harassment, victimisation, and related behaviours seriously and is committed to resolving matters swiftly, fairly, and sensitively.

Where possible, concerns should be resolved locally and informally, as informal resolution is often quicker and may lead to outcomes more satisfactory to all parties. However, individuals may make a formal report at any time and are not required to attempt informal resolution first, particularly where the concern is serious (e.g., sexual harassment) or if they feel unsafe or uncomfortable.

Informal Resolution – Challenging Inappropriate Behaviour

Some concerns may arise from misunderstandings, personality differences, or unintended conduct. In some cases, explaining the impact of someone’s behaviour can lead to resolution. However, this approach is not appropriate in all situations, particularly where safety is a concern.

If you feel able to raise the issue informally:

• Choose a neutral, private setting.
• Be clear and specific about what behaviour was unacceptable, how it affected you, and what you want to change.
• Consider having a friend present for support.

Keep a brief written record of the conversation in case further action becomes necessary.

If behaviour does not improve, you should consider submitting a formal report through the AGS.

What If I Am Accused of Bullying, Harassment, or Victimisation?

All formal reports are investigated under this policy and the Student Disciplinary Procedure or Staff Disciplinary Procedures as appropriate. Allegations are not presumed proven until a proper investigation has been conducted. Both the complainant and the respondent will receive appropriate information and support.

If you are the subject of a formal report:

• Review this policy and the relevant disciplinary procedures to understand the process.
• Avoid unnecessary contact with the complainant.
• Keep a record of any relevant incidents or communications.
• Seek guidance from your PAT and the Student Success Team.

Support is available for both parties involved through the Student Success Team.

How Can I Support a Friend Who May Be Affected?

If you are concerned about a friend:

• Speak with them and listen to how they feel about the situation.
• Encourage them to explore the options for disclosure or reporting.
• Offer to accompany them if they wish to challenge behaviour informally or make a report.
• Direct them to their PAT, Student Success Team or relevant support services.

What If the Behaviour Involves Someone Outside the School?

If the individual responsible is not a member of the School community, the School’s disciplinary procedures will not apply. However:

• If the issue occurs within a placement or employment setting, the School’s  policies may apply.
• Harassment may be a criminal matter (e.g., hate crime) and can be reported to the Police.
• The Student Success Team can offer further guidance.

Bullying, Harassment, or Victimisation in Social Settings

The School expects students to behave with respect both within and outside of academic settings. Incidents that occur socially but involve members of the School community fall within the scope of this policy.

Online, Email, Text, and Social Media Harassment

Harassment can take place through electronic means. The School’s Student Disciplinary Procedure and IT Regulations apply where School systems are misused. Students should preserve evidence of any offensive messages (e.g., screenshots).

External reporting options also include ISPs, mobile providers, and specialist organisations.

What Information Should I Include in a Formal Report?

A formal report should clearly outline:

• Dates, times, and locations.
• A description of the incident(s).
• Your response and any witnesses.
• Supporting evidence (e.g., emails, screenshots).

Prompt reporting is encouraged to support effective resolution.

Confidentiality of Disclosures and Reports

Identified disclosures are kept confidential within the Student Success Team, shared externally only where required for safeguarding, legal obligations, or significant risk.

In formal reports, identification of the complainant is normally necessary for a fair investigation. Confidentiality is maintained by all parties involved, except where necessary to protect individuals or the School.

No party should discuss an ongoing case publicly, as this may undermine the process.

Disciplinary Action for Bullying, Harassment, or Victimisation

Where breaches of this policy are proven:

• Students may face sanctions under the Student Disciplinary Procedure.
• Staff may face action under HR disciplinary procedures.

Sanctions range from warnings to suspension or exclusion for students, and warnings to dismissal for staff.

Will I Be Told the Outcome?

You will be told whether your report was upheld. However, details of sanctions imposed on another party are confidential and will not be shared.