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. 1 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 2 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. 3 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. 4 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 5 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). 6 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). 7 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. 9 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. 11 12