Prevent duty compliance: Preliminary self-assessment report

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Prevent duty compliance: Preliminary self-assessment report
As submitted to the HEFCE by the deadline of 22 January 2016.
Name of provider………University of Warwick…………………………UK Provider Reference Number………………………….
Authorised by (name, position)………………………………………………………………………………………………………………………………………..
Signature………………………………………………………………………………………………….Date……………………………………………………….…
(a) Arrangements for senior management and
governance oversight of the implementation
of the provider’s Prevent duty obligations and
engagement with Prevent partners (PDG
paragraphs 16 and 17, HEG paragraphs 16 to
18).
A
 The University’s compliance with the Prevent duty guidance is managed
by a bespoke working group, chaired by the Deputy Registrar and
attended by relevant colleagues including: the Head of Student Support
Services, the Head of Security Services, the University Senior Tutor,
representatives from Human Resources, the Senior Wardens from the
Residential Life Team, the University’s Legal Adviser, the Librarian and
representatives from the University’s incident management and business
continuity functions.
 Recommendations made by this group regarding the University’s
approach to implementing the guidance (including new or revised
regulation, policy and practices) are reviewed and approved by the
Steering Committee. The Steering Committee (which is responsible for
overseeing both the University’s strategic development and the
operational business of the University) meets at least fortnightly, is
chaired by the Vice-Chancellor, and attended by the Senior Management
Team, the President of the Students’ Union, and representatives of the
Senate.
 The University’s governing body (the Council) has overall accountability
for compliance with the Prevent duty. The Council has received updates
on the Prevent Duty and has undertaken discussion on the topic as a
strategic item of business. The Council considers reports on the key
developments approved by the Steering Committee, and will be
responsible for statutory returns to HEFCE.
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 The Registrar and Chief Operating Officer, the Deputy Registrar and the
Head of Security Services maintain close links with Prevent partners,
particularly the Police and the BIS Regional Prevent Coordinator. The
University has access to two Police Officers and a Police Community
Support Officer, who have an active presence on campus, are visible at
University events and are available to the campus community for advice
and guidance.
 The Head of Security Services acts as the Single Point of Contact
(SPOC) in this regard, reporting to the Deputy Registrar. Through the
SPOC and the members of the working group, the University engages
with both internal and external stakeholders, inclusive of: University
departments and service areas, the Students’ Union, the Police, local
authorities, the NHS Safeguarding Team, and the BIS Regional Prevent
Co-ordinator. This enables the provision and receipt of information as
appropriate in order to support vulnerable individuals as part of the
overall support framework (as detailed in section (f) below).
 The SPOC liaises with the BIS Regional Prevent Co-ordinator on a
regular basis and also attends meetings of local partnership groups.
Additionally, a number of colleagues on the working group are members
of various external networks (such as AUCSO, NAMSS and HEBCoN),
allowing the institution to benefit from the sharing of best practice and
resources across the HE sector.
 The Deputy Registrar, Head of Security Services, Head of Institutional
Resilience, Head of Student Support Services and the Learning and
Development Adviser have all attended sector and non-sector events
regarding the new Prevent Duty including those organised by the
Leadership Foundation, external conferences and events organised
directly by HEFCE. This has been beneficial in sharing practice and
clarifying expectations.
(b) Prevent risk assessment (HEG
A
 A risk register to comply with the statutory duty has been compiled which
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paragraphs 19 and 20).
(c) Action plan in response to that risk
assessment (HEG paragraph 21).
(d) Arrangements for engaging with and
consulting students on the provider’s plans for
implementing the Prevent duty (HEG
paragraph 16).
assesses where and how members of the University community could be
at risk of being drawn into terrorism. A contextual statement prefaces the
document and notes the campus location, characteristics and
demographics of the University along with the breadth of pastoral support
available at the University. The risk register is kept under review by the
working group and will be reviewed termly or as the need arises. The
Prevent Risk Assessment was approved at the meeting of the
University’s Steering Committee on 11 January 2016.
A
 An action plan has been developed both in response to the risk
assessment and to ensure compliance with all aspects of the Prevent
duty guidance. The working group monitors progress against the action
plan and updates it accordingly. The Prevent Action Plan was approved
at the meeting of the University’s Steering Committee on 11 January
2016
A
Through the
University’s
existing
governance
and
representative
systems
 Student representation in the University’s governance system is
embedded within the University through representatives of the SU being
formal members of the majority of University Committees. This includes
formal representation at the Steering Committee, the Senate and the
Council (see item (a) above). Such forums have and continue to present
the opportunity for these representatives to input into the University’s
plans for implementing the Prevent duty.
 The Warwick’s Students’ Union has a formal mandate through an All
Student Meeting motion which was passed in November 2015 not to
engage with the Prevent agenda beyond its legal obligations or where it
is seeking to safeguard a member.
 The University has positioned its approach to the Prevent duty through its
existing student welfare and safeguarding processes. The University has
a very strong relationship with SU officers and staff, and continues to
work closely with them on matters such as student welfare and
safeguarding as part of usual business.
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 The SU recognises its obligations with respect to external speakers and
has in place robust processes for such consideration. SU officers were
also closely involved in the recent development of an enhanced process
for external speakers that will enable the University to take a more
streamlined approach to this topic.
(e) Training appropriate staff about Prevent
(HEG paragraphs 14, 15 and 22 to 24).
A/B
As part way
through the
training
programme but
awaiting further
details of other
HO approved
training
materials being
available.
Expected to be
completed by
Spring Term
2015/16,
pending
availability of
further training
options.
 A number of the University’s front line pastoral staff have undertaken
WRAP training in the past in previous iterations of the programme.
 All members of the Prevent working group received the WRAP for HE
training from the BIS Regional Prevent Co-ordinator in September 2015.
A number of members have also undertaken the JISC online version of
the training to trial that package and three have additionally undertaken
the “Train the Trainer” programme.
 The Head of Security Services (who is also the SPOC) has undertaken
the ‘Train the Trainer’ training. 50% of Security Services staff have
completed the WRAP training, with the remainder due to receive it from
the Head of Security Services or the Regional BIS Prevent Coordinator
by the end of February 2016.
 The Regional BIS Prevent Co-ordinator provided WRAP training for
members of the Residential Life Team (wardens and resident tutors for
on-campus accommodation) on 20 October 2015. This training session
also included some colleagues from Student Support, Disability Services,
Counselling Services, Mental health Services, the Library, the Research
Exchange and PG Hub and Security services. 123 colleagues attended
this event in total.
 A further session has been scheduled for 11 February 2016, which will
include staff from the above groups who were not able to attend on the
previous date, along with a range of other colleagues such as HR
Advisers, senior Accommodation Office colleagues, senior members of
campus and commercial staff and International Student Advisers.
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 Completion of the training is recorded on the relevant colleague’s HR
record. The residential life team who operate in a voluntary capacity, and
are therefore not employed in their wardenial capacity, have their specific
programmes or training recorded by the Senior Wardens.
 The University is investing in a new HR system which will enhance
processes available to flag the training requirement against relevant job
roles, as a means of ensuring new staff in these posts are identified as
requiring the training; in the meantime such processes will be manual.
 The further groups of relevant staff who would benefit from training have
been identified through the action plan. We understand from our BIS
Regional Prevent Co-ordinator that there may be a short version of the
training imminent which we are advised would be more appropriate to
give a general awareness to larger populations such as cleaning and
maintenance staff so await further details of this package with interest.
(f) Arrangements for sharing information
internally and externally about vulnerable
individuals, where appropriate (HEG
paragraph 23).
(g) Policies and procedures for approving
B
The University
is participating
in work
regionally to
update existing
arrangements
through the
regional group
Expected to be
completed by
Spring Term
2015/16,
subject to the
work of the
regional group.
B
 The University is committed to providing a safe, supportive and positive
environment for all members of its community. There is a documented
referral pathway for student support issues which sets out how cases of
concern and support in relation to student welfare are identified and
referred within the University. The pathway diagram is an open
document, available for all staff and students. The document is also
referred to in staff training. Policies to record the approaches
underpinning the document are in the process of being developed.
 The University is already party to an information sharing agreement with
regional partners and also abides by its obligations under the Data
Protection Act 1998. The agreement is currently being reviewed by all
statutory partners, in light of the prevent duty. The University is involved
in this discussion.
 The University already has in place an external speaker process and very
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external speakers and events on campus
(HEG paragraphs 7 to 15).
Pending
approval of a
revised
Regulation 29
and external
speakers
approval form
at the meeting
of the Senate
on 27 January
2016




good links with the SU on this topic.
A further streamlined process for the request and approval of external
speakers at University events is in the process of being approved. This
enhanced process has been developed as a result of a recent rapid
improvement event to bring together representatives from the different
areas of the University, including the SU, who may be involved in
organising and approving such events.
All requests will be submitted via a single online form, which is then
reviewed by Security Services and the Students’ Union.
Under current processes and also going forward, any event deemed to
be of high risk is referred to the Head of Security Services, and onwards
to the Deputy Registrar for a final decision.
This process covers the University’s obligations to protect free speech as
well as the safety and security of events per se and is not solely confined
to the consideration of the Prevent agenda although it encompasses this
duty.
(h) Code of practice for ensuring freedom of
speech within the law on the provider’s
premises, including (if applicable) those of the
students’ union (if not covered in the external
speakers and events policies) (HEG
paragraph 8).
B
Pending
approval of a
revised
Regulation 29
and external
speakers
approval form
at the meeting
of the Senate
on 27 January
2016
 University Regulation 29 on ‘Meetings etc on University Premises’ was
issued by the Council in pursuance of its duties as laid down in Section
43 of the Education (No.2) Act 1986, with a view to providing such
safeguards as are reasonably practicable to ensure that freedom of
speech within the law is secured for members, students and employees
of the University, and for visiting speakers. Regulation 29 is being
updated in light of the prevent duty and will progress through the
University’s governance system to Council for consideration and
approval.
(i) Arrangements to protect the importance of
academic freedom (if not covered in the
external speakers and events policies) (HEG
paragraph 8).
B
Pending
approval of a
revised
Regulation 29
 This is covered by Regulation 29 (as above).
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and external
speakers
approval form
at the meeting
of the Senate
on 27 January
2016
(j) Policies and procedures for approving
branded events taking place off campus (if not
covered in the external speakers and events
policies) (HEG paragraph 12).
B
Pending
approval of a
revised
Regulation 29
and external
speakers
approval form
at the meeting
of the Senate
on 27 January
2016
 This is covered by the external speaker process referred to above which
forms part of Regulation 29 (as above).
(k) Arrangements for sharing information
about external speakers with other providers,
where legal and appropriate (if not covered in
the external speakers and events policies)
(HEG paragraph 14).
A
 Where legal and appropriate, the Head of Security Services would
consider this as part of his process. Such information would be conveyed
via higher education networks, best-practice sharing with colleagues at
other HE institutions, and liaison with the BIS Regional Prevent Coordinator. The information sharing agreement as referred to in section (f)
may also be used depending on the nature of the issue. The University
operates within the requirements of the Data protection Act 1998.
A/B
Some
underpinning
policies in the
process of
being drafted
 As outlined in section (f) above, the University is committed to providing a
safe, supportive and positive environment for all members of its
community. The documented referral pathway for student support issues
illustrates the joined up nature of the constituent elements of the support
framework. Student Support Services provides dedicated support for a
wide range of personal and welfare issues, inclusive of a counselling
(l) Arrangements for ensuring sufficient
pastoral and chaplaincy support for all
students (including arrangements for
managing prayer and faith facilities) (HEG
paragraphs 25 and 26).
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Expected to be
completed by
Spring Term
2015/16.
service, a mental health and wellbeing team, a student funding team and
a disability services team.
 To ensure that the University is able to continue to provide an
appropriate level of student support, a review of the future strategic
needs of Student Support Services is planned for late January 2016.
 The University Senior Tutor is supported by a network of personal tutors
in departments in providing advice on academic-related matters. The
Senior Tutor works closely with Student Support Services to ensure that
students are offered appropriate pastoral support.
 All students who have accommodation on campus are provided with an
excellent network of support from the Residential Life Team. The
Residential Life team work and live alongside students within the Halls of
Residences and are a key part of the University’s welfare and support
network.
 Security Services are on hand 24 hours a day throughout the calendar
year to ensure a safe and welcoming campus environment. The duties of
Security officers extend beyond the protection of the built environment;
other services encompass a wide range of welfare and personal safety
matters, including the provision of pastoral care for vulnerable or
distressed members of the University community.
 The Students’ Union Advice Centre provides information, advice and
advocacy for students on a breadth of issues including financial hardship,
personal issues, immigration matters, housing problems and academic
concerns.
 The University Chaplaincy, located at the centre of campus (with multifaith prayer rooms also available elsewhere on site) is open to all
members of the University community, of any or no faith.
 Christian (Catholic, Anglican, Free Church), Jewish and Muslim
8
Chaplains, meet students and staff socially and pastorally, and are a
valued part of the University’s Welfare network (see section (f) above).
There are regular services for all Christian denominations and
congregational prayers for Muslims for all five daily prayers.
 The Chaplaincy is open every day in term time, between 09:00 - 22:30,
but staff /student cards are needed for access outside normal office
hours (09:00 - 17:00) and during vacation times. The Islamic Prayer Halls
are open 24/7 and staff /student cards are required for access.
 The University has continued to invest in its faith facilities which have
consistently rated highly in the International Student Barometer survey
(96.4% satisfaction rating in the 2014 wave).
 The University liaises closely with the chaplains through the Deputy
Registrar, the Head of Student Support and the Head of Security
Services. The day to day lead for liaison is the Director of Strategic
Programme Delivery (as a direct report to the Deputy Registrar) along
with a Pro Vice-Chancellor who has the link to the chaplaincy as one of
their accountabilities.
 The chaplaincy has a dedicated and on-site administrator who
coordinates the wide range of activities in the chaplaincy and supports
the chaplains in their work.
(m) Policies for the use of the provider’s
computer facilities (hardware, software,
networks, social media), to include
consideration of filtering arrangements and of
academic activities that might require online
access to sensitive or extremism-related
material (HEG paragraphs 27 and 28).
B
Pending
approval of a
revised
Regulation 31
at the meeting
of the Senate
on 27 January
2016
 University Regulation 31 governs the use of University computing
facilities. Whilst it already covers use for unlawful or offensive activities, it
has now been revised to contain explicit reference to the Prevent duty.
The revised regulation is due to be considered by the Senate on 27
January 2016.
 All users of the University’s computing facilities sign up to an acceptable
use policy (governed by Regulation 31), at the point of enrolling or
signing an employment contract with the University.
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 A research governance structure is in place, with local research ethics
committees considering projects which may require access to securitysensitive research material. The University’s Research Governance and
Ethics Committee, reporting to the Research Committee, has oversight of
these processes and has recently considered and reconfirmed its
approaches in light of the Prevent duty. Research Governance and
Ethics issues receive oversight from a Pro Vice-Chancellor.
 All externally funded research projects are processed by a central
research support service (RIS), so any concerns regarding research
content can be identified and referred to the relevant research ethics
committee. The Director of RIS has reviewed approaches in light of the
prevent duty.
 IT Services are able to retrospectively monitor the historic usage of
computing facilities in the event that a concern is raised regarding an
individual user. Pre-emptive filtering arrangements are not considered to
be a proportionate need at this time, noting that such filtering is not a
mandated requirement of the Prevent duty however the University will
keep this under review pending any further developments in the sector.
 Relevant student-facing staff, as identified in the action plan, will
undertake the WRAP training to raise awareness of how to refer any
concerns that may arise.
(n) Arrangements for engaging with students’
unions and societies, which are not subject to
the Prevent duty but are expected to
cooperate with their institution (HEG
paragraph 29).
B
Work is
ongoing to
refresh the
University’s
formal
agreement with
the Students’
Union more
 Student representation in the University’s governance system is
embedded within the University through representatives of the SU being
formal members of the majority of University Committees. This includes
formal representation at the Steering Committee, the Senate and the
Council (see item (a) above). Such forums have and continue to present
the opportunity for these representatives to input into the University’s
plans for implementing the Prevent duty.
 The Warwick’s Students’ Union has a formal mandate through an All
10
generally.
although
practical
working
relationships on
wellbeing
matters
continues to be
strong.
Expected to be
completed by
Summer Term
2015/16.
Student Meeting motion which was passed in November 2015 not to
engage with the Prevent agenda beyond its legal obligations or where it
is seeking to safeguard a member and has elected not to be part of the
working group as a result.
 The University has positioned its approach to the Prevent duty through its
existing student welfare and safeguarding processes. The University has
a very strong relationship with SU officers and staff, and continues to
work closely with them on matters such as student welfare and
safeguarding as part of usual business.
 The SU recognises its obligations with respect to external speakers and
has in place robust processes for such consideration. SU officers were
also closely involved in the recent development of an enhanced process
for external speakers that integrates several processes into a more
streamlined approach.
Note: Paragraphs referred to are found in the statutory Prevent guidance: ‘Revised Prevent Duty Guidance for England and Wales’ (PDG) and
‘Prevent Duty guidance for higher education institutions in England and Wales (HEG).
Rating scale:
A
Policies and processes have been documented. They have been reviewed, updated, approved in last three months, and are active. They
fully satisfy the Government’s ‘Prevent’ duty guidance.
B
Policies and processes have been documented. They have been reviewed, updated, approved in the last year, and active. They may
satisfy the Government’s ‘Prevent’ duty guidance.
C
Policies and processes have been documented, but need to be reviewed against the Government’s ‘Prevent’ duty guidance.
D
Policies and processes have been drafted, but not yet approved.
E
Policies and processes have not been prepared yet.
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