In implementing this duty, we are also conscious of our commitments to free speech, academic freedom, human and equal rights, and the appropriate management of information.

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1. Introduction

   1.  Purpose
      The School is required under the Counter-Terrorism and Security Act 2015 to ‘have due regard to the need to prevent people from being drawn into terrorism’. 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. This document sets out how we are complying with the Duty.

   2.  Scope
      The Prevent Policy applies to all staff and (where relevant) students of the School. In the context of this policy, the term students is intended to include apprentices.

2. Prevent Policy

   1. Approach

      1.  The School welcomes the Government’s intention that the Prevent Duty is implemented ‘in a proportionate and risk-based way’ and that it should not create large new burdens on institutions. We therefore intend to implement our legal responsibilities as part of our existing policies and procedures, which we also consider to be the best way of ensuring a joined-up approach. 

   2. We take seriously our responsibility to ensure the safety and wellbeing of students, staff and the wider community and as part of this would wish to do all that we can to prevent any member of the School community from being drawn into terrorism. We also value the principles of academic freedom and general freedom of expression and have a statutory duty to protect them. 

3.  Leadership

   1.  The School takes seriously at the highest levels the need to prevent terrorism occurring in our community. The Chief Compliance Officer has been identified as the member of senior management responsible for ensuring that the School complies appropriately with the Prevent Duty, in liaison with other key stakeholders within and beyond the School.

4. Risk Assessment and Action Plan

   1.  As required by the Prevent Duty, we carry out assessments of the risk of our students being drawn into terrorism. This risk assessment is reviewed at least annually by the School’s management. Where any significant risk is identified we will consider what action might mitigate the impact/likelihood of that risk crystallizing, and if necessary include it in the School’s Prevent Action Plan.

5. External Speakers

   1. The Code of Practice on Freedom of Expression (School Regulation 18) has been updated to reflect the Prevent Duty. It sets out how we will ensure that we meet the different legal requirements on us, not least the duty under the Education (No. 2) Act 1986 to secure freedom of speech within the law. Under the Code of Practice, where the views expressed constitute views that risk drawing people into terrorism, or are shared by terrorist groups, permission must be sought by the staff or student organiser from the Chief Compliance Officer. Due diligence is carried out where required and we will share information with other institutions if appropriate about any particularly problematic event that comes within the remit of Prevent.

   2. In complying with the Prevent Duty the School will not: - Provide a platform for any proscribed terrorist organisation or encourage terrorism in any way; - Allow gender segregation at any event.

   3. In conjunction with the School’s Code of Practice, the Students’ Union has its own complementary procedures in place in relation to events organised by its societies where external speakers will be participating.

6. 2.5 Security Sensitive Research

   1.  The School recognises that the research and study of terrorism is valid and valuable, and that staff and students should be able to undertake this without risk of prejudice. It is therefore acknowledged that certain staff (and exceptionally students) will have need to access material which supports terrorism as part of their work. In such cases it is incumbent on the responsible member of academic staff to ensure via the School’s normal ethical review processes that material is only accessed that is appropriate for the research or other work being carried out and that its use will not encourage terrorism in any way.

7.  Staff Training

   1. 2.6.1 We 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. For those with whom any specific concerns will be raised (primarily staff in Student Support and Safeguarding), differentiating the risk of radicalisation from other issues will be covered in more detail, together with the opportunities and requirement to share information confidentially where needed. Our approach will be to support vulnerable students in whatever circumstance they find themselves, recognising that radicalisation could occasionally be occurring when certain behaviour is manifest but that other explanations will usually apply.

8.  Pastoral Care

   1. 2.7.1 Pastoral care is available to students in a variety of ways. Specialist support is provided through Student Success. All students have a personal tutor. 

9.  Communications

   1. We will not permit material supporting terrorism to be displayed within School premises and will remove any such material if it is found. Likewise, we will seek to ensure that the School’s printed and electronic communications (including its website) do not contain or support terrorist material or material likely to encourage terrorism and will investigate immediately if any such instances are raised. It is acknowledged that there will be legitimate reasons to display materials relating to terrorism as part of legitimate teaching and research activities, and this should be declared under the process described in paragraph 2.5.1 above.

10. 2.10 Information Sharing

    1. The School is aware of the Channel process and of the opportunities for informal and formal sharing of information with relevant authorities. We will use these when we consider it is necessary and appropriate to do so in the interests of preventing people from being drawn into terrorism. Information sharing will only take place with external authorities when this is consistent with the provisions of the Data Protection Act.

11.  Roles and Responsibilities

    1. The School Executive Board is responsible for providing assurance of the School’s compliance with the Prevent Duty, for approving the Prevent Policy, and for approving the School’s annual accountability.

12.  All members of staff should be aware of the School’s responsibilities under the Prevent Duty and of the measures set out above to comply with it. Members of the School community who are concerned about a student who might be at risk of being drawn into terrorism should report this to their line manager or to Student Success. Concerns about members of staff who might be at risk of being drawn into terrorism should be reported to the Director.