PREVENT DUTY POLICY
1.0 INTRODUCTION
1.1 Vale Training Services Ltd is required under the Counter- Terrorism and Security Act 2015 (“the Act”) to ‘have due regard to the need to prevent people from being drawn into terrorism’ (“the Prevent Duty”).
1.2 Under section 29, it must have regard to guidance issued by the Home Secretary. The Prevent Duty Guidance for higher education institutions in England and Wales came into effect on 18 September 2015 following approval by Parliament.
1.3 This document sets out how the Company complies with the Prevent Duty.
1.4 The Company takes seriously its responsibility to ensure the safety and wellbeing of students, staff and the wider community and as part of this wishes to do all that it can to prevent any member of the Company community from being drawn into terrorism.
1.5 The Company also has a responsibility to protect academic freedom and general freedom of expression.
1.6 The key member of staff responsible for ensuring that the Company complies with the Prevent Duty is the Deputy Vice-Principal (Academic Affairs), liaising with the BIS regional Prevent Co-ordinator and other local and regional partners.2.0 SCOPE
2.1 The Prevent Policy applies to all staff, students and visitors of the Company.
2.2 The Company will liaise and work with the Pearson Company Students Association (“the PCSA”) with regards the implementation of this Policy.3.0 RISK ASSESSMENT AND ACTION PLAN
3.1 As required by the Prevent Duty, the Company will devise and maintain an assessment of the risk of our students being drawn into terrorism. The Risk Assessment is devised and maintained by the Deputy Vice-Principal (Academic Affairs).
3.2 The Risk Assessment will be reviewed at least annually by the Executive Group and changes to the risk will be reported to and considered by the Executive Group.
3.3 The Risk Assessment and Action Plan will be reported to the Governing Body at least annually.
4.0 EXTERNAL SPEAKERS
4.1 The following applies to all events that utilise any Company resources or are in any way branded or affiliated to the Company. It includes events held off site.
4.2 Higher Education providers have a duty under the Education (No. 2) Act 1986 to secure freedom of speech for its employees, students and visiting speakers. However in complying with the Prevent Duty the Company will not:
· Provide a platform for any proscribed terrorist organisation or encourage terrorism in any way;
· Allow gender or religious segregation at any event it organises or at events held on its premises.
4.3 The Company expects that speakers shall:
· Not act in breach of the criminal law.
· Not incite hatred or violence or any breach of the criminal law.
· Not encourage or promote any acts of terrorism or promote individuals, groups or organisations that support terrorism.
· Not spread hatred and intolerance.
· Not discriminate against or harass any person or group on the grounds of their sex, race, nationality, ethnicity, disability, religious or other similar belief, sexual orientation or age.
· Not defame any person or organisation.
· Not raise or gather funds for any external organisation or cause without express permission of the Company.
· Present ideas and opinions, in particular those that may be contentious or potentially offensive, in the spirit of academic debate, being open to challenge and question.
· Follow the Company’s policy on and instructions relating to health and safety.4.4 Staff and students who wish to invite an External Speaker must therefore consider the following before making an invitation or any advertisement of an event:
· Question 1: Has the speaker previously been prevented from speaking at the Company or another University or similar establishment or previously been known to express views that may be in breach of the Counter-Terrorism and Security Act 2015 Act?
· Question 2: Does the proposed title or theme of the event present a potential substantial risk that views/opinions expressed by speakers may be in breach of the Act?
· Question 3: Is the proposed speaker/theme likely to attract attendance from individuals/groups that have previously been known to express views that may be in breach of the Act?
4.5 If any the answers to any of the above questions are ‘Yes’ then the organiser must refer the matter immediately to the Deputy Vice-Principal (Academic Affairs) and no invitation or advertisement may be made until confirmation has been provided in writing from the Deputy Vice-Principal (Academic Affairs) that the event may proceed.
4.6 Students wishing to book Company space for events must do so through the Student Services office. Requests will go to the Head of Student Services who will consider the above questions, referring to the Deputy Vice-Principal (Academic Affairs) where necessary. The Deputy Vice-Principal (Academic Affairs) will keep a record of all referrals and any action taken. Where an organiser disagrees with the decision, then they may refer it to the Principal. The decision of the Principal is final.
5.0 SECURITY SENSITIVE RESEARCH
5.1 The Company currently has no plans for students or staff to be engaged in security sensitive research. In the event that it were to be proposed then a full ethical review would be required before approval via Academic Board.
6.0 STAFF TRAINING
6.1 The Company will carry out training on a regular basis for all relevant staff so that they can recognise those who are vulnerable of being drawn into terrorism and potential signs of radicalisation. It will include an explanation of how to handle appropriately and sensitively any concern that may emerge.
6.2 The Company will utilise external sources of training, information and guidance such as:
http://course.ncalt.com/Channel_General_Awareness/01/index.html as well as developing its own internal training and guidance for staff.
6.3 The Prevent Duty will be highlighted in key induction and training events for relevant new or visiting staff.
6.4. Information about this Prevent policy will be included in Student Handbooks and information events held for students during Welcome Week.7.0 FAITH FACILITIES
7.1 The Company is a secular organisation and does not provide prayer facilities. Student Services maintains a list of local faith facilities. There is a quiet room at the 190 High Holborn site. The Company does not have a Chaplaincy.8.0 IT NETWORKS
8.1 The Company considers it unacceptable for its IT networks to be used in any way that supports, promotes or facilitates terrorism. Students must not use the Company IT infrastructure to create, download, store or transmit unlawful material, or material that is indecent, offensive, defamatory, threatening or discriminatory.
8.2 The Company has implemented web filtering on its Wi-Fi and academic networks.
8.3 The Company has considered the costs and likely benefit of implementing active monitoring of use of its networks with a view to detecting attempts to access prohibited sites. As a result of this consideration, it has concluded that the likely benefit or risk mitigation does not warrant the introduction of active monitoring. This position will be kept under review.9.0 ESTATE
9.1 Staff responsible for the security of the buildings which the Company permanently occupies are made aware of the Company’s obligations under the Prevent Duty through staff training sessions.
9.2 In general, the security of the Estate is maintained by:
9.2.1 24 hour security staffing;
9.2.2 Random bag searches by approved Staff.
10.0 COMMUNICATIONS
10.1 The Company will not permit material supporting terrorism to be displayed within the Company premises and will remove any such material if it is found. The Company may also take action under its Student Disciplinary Code.
10.2 Likewise, the Company will seek to ensure that its printed and electronic communications do not contain or support terrorist material or material likely to encourage terrorism and will investigate immediately if any such instances are raised.11.0 SOCIAL MEDIA
11.1 Any branded (i.e. using the Company logo, or formally associated with the Company) social media applications or platforms (e.g. Facebook) will be monitored by the Marketing Department. Action will be taken by the Company to remove any posts etc. that do not comply with the spirit of this policy and the Act and disciplinary action may be taken.12.0 ROLES & RESPONSIBILITIES
12.1 All members of staff should be aware of the Company’s responsibilities under the Prevent Duty and of the measures set out above to comply with it. Members of the Company community who are concerned about a student or member of staff who might be at risk of being drawn into terrorism should report this to their line manager or to the Deputy Vice- Principal (Academic Affairs).13.0 CONCERNS ABOUT INDIVIDUAL STUDENTS OR MEMBERS OF STAFF
13.1 Where a staff member or student has a concern regarding an individual student or another staff member, then they may report it confidentially to the Deputy Vice-Principal (Academic Affairs). Alternatively, they may report it to their own line manager or the line manager of the staff member about whom they have concerns. The line manager will then refer the matter to the Deputy Vice-Principal (Academic Affairs). The Deputy Vice-Principal (Academic Affairs) will then consider the information and any evidence and:
13.1.1 Determine that there is no risk and the matter will not be taken any further or
13.1.2 Contact the student to discuss the matter confidentially within 5 working days or
13.1.3 Raise the matter confidentially with the Company’s local Prevent Duty partners (Channel Police Practitioner or Department for Education adviser) for advice and guidance and possible referral to the Channel scheme, or
13.1.4 Immediately refer the matter to the Police because there are serious and immediate issues of safety to the student/staff member or others, and/or there is evidence to suggest a criminal act may be committed or has been committed. This decision would be taken only in the most serious of circumstances and only in conjunction with the Principal, or a Vice Principal or the Academic Registrar.13.2 In considering radicalisation staff should consider the following:
13.2.1 The individual’s views have become increasingly extreme regarding another section of society or government policy
13.2.2 They have been observed downloading, viewing or sharing extremist propaganda from the web
13.2.3 They have become withdrawn and focused on one ideology
13.2.4 The individual has become increasingly intolerant of more moderate views
13.2.5 The individual has expressed a desire/intent to take part in or support extremist activity If any of the above is ‘yes’ then there is a potential for cause for concern.
14.0 In addition
14.0.1 The individual has changed their appearance, their health may have suffered (including mental health) and they have may become isolated from family, friends, peers or social groups.
This does not in itself indicate radicalisation but may be linked to the points above. It may however indicate a cause for concern in terms of the individual’s pastoral care more generally.
15.0 DISCIPLINARY ACTION
15.1 The Company has procedures (Student Disciplinary Code) that provide a mechanism for dealing with alleged misconduct by students that is unlawful, intimidating, threatening or brings the Company into disrepute.
15.2 The Company has policies and procedures in place as part of its line management and human resources infrastructure to deal with any alleged misconduct by staff.
16.0 CREATION OF DELIVERY/ACADEMIC PARTNERSHIPS
16.1 Where the Company creates a partnership with another organisation it will conduct due diligence on that organisation and in so doing affirm that it would comply with the Company Prevent Duty obligations as well as the general aims and principles of the Company. Due diligence is conducted by the Academic Affairs Office in conjunction with the Review and Enhancement Committee and Executive Group. SHARING OF INFORMATION
16.2 Where there is a concern regarding a student or staff member then information may be shared both internally and externally. Internally, information will be shared with relevant senior managers, Programme Leaders, Personal Tutors and Support Staff as deemed appropriate by the companies senior director.
16.3 Externally, information may be shared with Local Channel Prevent Co-ordinators, the Police or other agencies as deemed necessary and in accordance with the Data Protection Act.17.0 MONITORING OF POLICY
17.1 The Governing Body will receive annually a report on the implementation of this Policy. Where this Policy is changed as a result of a serious incident then the Company will report the matter to HEFCE.
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