Title: Prevent Policy Document Type: Policy Version: 1.0 [February 2016] Publication date: February 2016 Author: Student Support Office Approved by: Executive Committee February 2016 For review by the College Registrar: February 2017 Prevent Policy – Version February 2016 New College of the Humanities 1 NCH PREVENT POLICY 1. SUMMARY 1.1 New College of the Humanities (NCH) has a number of key obligations laid out in law. They have always included the necessity of reporting criminal activity to the police. NCH now also has an obligation to comply with the Government’s Prevent Duty. NCH acknowledges that a university also has an obligation to promote freedom of speech. This policy will balance NCH’s commitment to free speech and debate and the requirement for a Prevent Duty. To ensure compliance with this policy, the College has appointed a Prevent Officer and a Deputy Prevent Officer. 2. CONTEXT AND LEGAL REQUIREMENTS 2.1 The College’s policy will be consistent with the full Prevent Strategy outlined here: https://www.gov.uk/government/publications/prevent-duty-guidance 2.2 The full CONTEST strategy outlined by the Government can be found here: https://www.gov.uk/government/publications/counter-terrorism-strategy-contest 2.2.1 As part of the CONTEST strategy, Prevent aims to ● Respond to the ideological challenge of terrorism and the threat faced by the UK from those who promote it ● Prevent people from being drawn into terrorism and ensure they are given appropriate advice and support ● Work with a wide range of sectors (including education, criminal justice, faith, charities, the internet and health) where there are risks of radicalisation which need to be addressed 2.3 Definitions 2.3.1 The College will follow relevant definitions laid out in the law of England and Wales and Government Policy. 2.3.2 Terrorism is defined in the Terrorism Act 2000 as: the use or threat which: involves serious violence against a person; involves serious damage to property; endangers a person’s life (other than that of the person committing the act); creates a serious risk to the health or safety of the public or section of the public; or is designed seriously to interfere with or seriously to disrupt an electronic system. The use or threat of such action must be designed to influence the government or an international governmental organisation or to intimidate the public or a section of the public and be undertaken for the purpose of advancing a political, religious, racial or ideological cause. 2.3.3 Extremism is defined in the Prevent Strategy as: vocal or active opposition to fundamental British values, including democracy, the rule of law, individual liberty and mutual Prevent Policy – Version February 2016 New College of the Humanities 2 respect and tolerance of different faiths and beliefs. We also include in our definition of extremism calls for the death of members of our armed forces. 2.3.4 Violent extremism defined in the Prevent Strategy as: the endorsement of violence to achieve extreme ends. 2.3.5 Radicalisation is defined in the Prevent Strategy as: the process by which a person comes to support terrorism and forms of extremism leading to terrorism. 2.3.6 The Channel process is a programme which focuses on providing support at an early stage to people who are identified as being vulnerable to being drawn into terrorism. The programme uses a multi-agency approach to protect vulnerable people. More information about Channel can be found here https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/425189/C hannel_Duty_Guidance_April_2015.pdf. 2.3.7 New College of the Humanities is a Relevant Higher Education Body (RHEB) requiring a Prevent Policy. 2.4 The College will continue to work with a range of external organisations. In relation to this policy these will include, but not be limited to: HEFCE, QAA, Local authorities, BIS, the Police and security services, NUS training providers and specialist external advisers. NCH will also work with the Regional Prevent Coordinator. 2.5 Encouragement of terrorism and supporting of proscribed terrorist organisations are criminal offences. RHEBs must not provide a platform for these offences to be committed. This means that events must not be held on the premises unless NCH can guarantee that extremist views will be challenged as part of the same event. There must be mechanisms put in place to assess and rate the risks associated with any events planned on the premises or that are affiliated with, funded by or branded as NCH. There must be clear guidance as to when an event can proceed and what action may take place to mitigate any risk relating to the remit of this policy. 2.6 NCH will have a risk based approach to preventing terrorism. To comply with the Prevent duty, NCH must have procedures and policies in place which match the expectations set out by the Government. These policies must apply to all staff, students and visitors. There must also be policies and procedures in place for the management of all events on College premises. 2.7 NCH has policies relating to the use of their IT equipment which include specific reference to the statutory duty. 2.8 NCH will set out what is expected from the Student Union and Student Societies in relation to the Prevent duty. Prevent Policy – Version February 2016 New College of the Humanities 3 2.9 This policy will be published on the NCH website and will be reviewed periodically or in response to changes in Government policy. 3. POSSIBLE SIGNS OF RADICALISATION 3.1 The Government does not specify what the signs of radicalisation are; it is likely that the most obvious sign of radicalisation will be extreme change in behaviour and this will vary from case to case. Below is a short list of the possible indicators for RHEBs to look out for. This list is not exhaustive. 1. Changes in ideology or faith 2. Narrowing of political views 3. Adoption of “Them” and “Us” mentality 4. Isolation from friends and family 5. Fervent public expression of strong anger or grievance about perceived injustice. 6. Attendance at certain rallies or meetings The following NCH policies may help staff to identify any relevant changes in behaviour. ● ● ● ● ● NCH Welfare Policy NCH Attendance Policy NCH College Life Statement NCH Complaints Policy Student Union Honour Code 3.2 These policies are available on the NCH website. 4. IMPLEMENTATION OF THE PREVENT DUTY 4.1 Speakers and Events NCH holds events, public meetings and lectures which may be led by an external speaker. A member of NCH staff will be in attendance at these meetings. Any events held by the Student Union or Student Societies are approved by Student Support. Any student who wishes to host an event at College must complete a form stating the details of the event. Students are asked to provide the following details: ○ The speakers details ○ The member of staff on duty 4.1.2 Students are also informed that they must include Question and Answer time during the session and that they must take attendance at the event. Before confirming an event, Student Support will conduct a search on the speaker to minimise the risk of hosting an extreme speaker. Student Support will reject any request to host an event during which they feel they cannot safeguard the students. 4.2 Internet Access NCH has implemented changes to its firewall. Sites which fall under a category in the following list are not accessible to anyone on the NCH network. Prevent Policy – Version February 2016 New College of the Humanities 4 ○ ○ ○ ○ Violence/Hate/Racism Weapons Illegal Skill/Questionable Skills Hacking/Proxy Avoidance Systems This list has been provided by NCH’s internet service provider. For the full list of sites and definitions, please see http://www.sonicwall.com/content-filtering-services/content-filtering-ratingscategories.aspx. Anyone needing to use a blocked website for academic purposes should contact the Director of Operations. 4.3 Student Welfare Teaching and Student Support staff will consider the College’s Prevent obligations alongside other welfare duties in the normal course of the teaching programmes. NCH students has weekly tutorials and termly meetings with their Head of Faculty. Any concerning behaviour may be picked up during this time. Students are also provided with a personal tutor and are encouraged to use them as a point of contact if they have any welfare concerns. Attendance is strictly monitored and registers are taken at every teaching event. Any student who misses a certain number of events is given the opportunity to attend a meeting with their Course Leader. During this meeting, students and staff may express any concerns they have. The Student Support Office is an open office and encourages students and staff to drop in to communicate any worries they have on an ad hoc basis. Students are also encouraged to book meetings with the Student Wellbeing Coordinator to discuss any issues they are having. 4.4 The Student Union and Student Societies play an important role in safeguarding against radicalisation. NCH will work with the student body to fully implement this policy. This work will range from looking out for fellow students to reporting extreme behaviour. The NCH Student Union has an honour code which all students sign upon joining the College. This outlines how students are expected to create an environment where debate can thrive and look out for other members of the College. 4.5 Training Training will be given to members of staff who have a direct relationship with students. This means that Student Support, Heads of Faculty and Personal Tutors receive training in the first instance. The Workshop to Raise Awareness of Prevent (WRAP) should be undertaken by the people listed above. Further training can be given to anyone who may need it. This training will help members of NCH understand the behaviours outlined in 3.1 and the context in which these behaviours may occur. 5. ESCALATION IF A STUDENT OR STAFF MEMBER SHOW SIGNS OF RADICALISED BEHAVIOUR 5.1 Any member of NCH (student or staff member) may express concerns about any member of NCH (student or staff member) potentially being drawn into violent extremism based on information received or behaviour observed. Prevent Policy – Version February 2016 New College of the Humanities 5 5.2 Within NCH there are already mechanisms for counselling, guidance and pastoral care. These are set out in the policies referenced in section 3. Changes in behaviour are likely to be identified using the current processes and staff will be able to respond appropriately. Staff are also encouraged to use the free counselling service offered by the College if they have any concerns. 5.3 There may be circumstances where NCH identifies someone who is in need of intervention under the terms of this policy. If this happens, the following steps will followed. 5.4 If a student or member of staff is worried that a student is becoming radicalised or is radicalising others, this must be reported to the Student Wellbeing Coordinator. The Student Wellbeing Coordinator will pass this on to the Deputy Prevent Officer if appropriate. The Deputy Prevent Officer and/ or the Prevent Officer will investigate the matter. 5.5 If a student or member of staff is worried that a member of staff is becoming radicalised or is radicalising others, this must be reported to the Master, the HR Manager or the COO. They will pass this on to the Deputy Prevent Officer if appropriate. The Deputy Prevent Officer and/ or the Prevent Officer will investigate the matter. 5.6 Once any available information and substantive evidence has been gathered, this will be considered by the Deputy Prevent Officer, in discussion with other members of NCH staff where relevant. At least three of the following must be in attendance at the meeting: HR Manager, Master, COO, Deputy Prevent Officer, Prevent Officer, Personal Tutor, Head of Faculty, Registrar. The investigation and any evidence found will be recorded on Highrise or on the staff file. 5.7 A decision will be made as to the seriousness of the case. Four potential outcomes are likely at this stage: 5.7.1 No further action is required and this will be recorded on Highrise or on the staff file. The Prevent Officer, the relevant Heads of Faculty, Personal Tutor (students only), the Student Wellbeing Coordinator (students only), the Registrar (students only), the HR Manager (staff only), the COO (staff only) and the Master will be informed where relevant. 5.7.2 There is substance to the case but at this stage only internal action is required. The exact nature of the intervention required will be determined by discussion between the Deputy Prevent Officer, the Prevent Officer, the Registrar (students only), the HR Manager (staff only), the COO (staff only) and the Master. Actions and a review date will be agreed. This will be recorded in Highrise or on the staff file. Heads of Faculty, Personal Tutor and the Student Wellbeing Coordinator will be informed where relevant. At the review, the case will be assessed again and the appropriate actions taken. 5.7.3 NCH may choose to refer the person to the Channel process as an action point. This is a voluntary safeguarding process. Should NCH refer someone to the Channel process, the Deputy Prevent Officer or the Prevent Officer will attend the relevant meetings. 5.7.4 A referral to the police is required because there are serious and immediate safety issues to the student, staff member or others, and/or there is evidence to suggest a Prevent Policy – Version February 2016 New College of the Humanities 6 criminal act may be committed or has been committed. This decision will only taken be in the most serious circumstances and only following discussions between the Deputy Prevent Officer, the Prevent Officer, the Registrar (students only), the Head of HR (staff only), the COO (staff only) and the Master. 5.8 If concerns are raised about any of the members of staff involved in the above process, they will be excluded from it. 5.9 NCH will handle personal data in accordance with the Data Protection Act (1998) and the specific requirements relating to Prevent as prescribed by Law. 5.10 Contact with the Regional Prevent Coordinator is the responsibility of the Prevent Officer and Deputy Prevent Officer. The Prevent Officer and Deputy Prevent Officer will be responsible for coordination with relevant bodies in the event of the College having concerns. 5.11 The Prevent Officer and/ or Deputy Prevent Officer will also: ● Attend any training or conferences required to keep up to date on Prevent matters ● Meet regularly to discuss any matters arising ● Keep the Prevent Policy up to date ● Liaise with the relevant monitoring bodies Prevent Policy – Version February 2016 New College of the Humanities 7