PREVENT POLICY
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NCH Prevent Policy
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SUMMARY
1. New College of the Humanities has a number of key obligations laid out in law. They have always included the necessity of reporting criminal activity to the police. From 18th September 2015, the College must also report activities outlined in this document to the Regional Prevent Coordinator. This document identifies our policies with regard to this obligation.
CONTEXT AND LEGAL REQUIREMENTS
2. The full CONTEST strategy outlined by the Government can be found here.
3. As part of the CONTEST strategy, Prevent aims to:
3.1. Respond to the ideological challenge of terrorism and the threat faced by the UK from those who promote it
3.2. Prevent people from being drawn into terrorism and ensure they are given appropriate advice and support
3.3. 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
4. The full Prevent Strategy outlined by the Government can be found here.
5. Definitions
5.1. 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.
5.2. 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 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.
5.3. Violent extremism defined in the Prevent Strategy as: the endorsement of violence to achieve extreme ends.
5.4. 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.
6. Under Section 26(1) of the Counter-Terrorism and Security Act 2015, “specified authorities” have a due regard to prevent people from becoming involved in terrorism. As a Relevant Higher Education Body (RHEB), New College of the Humanities is subject to the duty.
7. 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. Our Regional Prevent Coordinator is Kat Cooper ().
8. Encouragement of terrorism and supporting of proscribed terrorist organisations are criminal offences. RHEB’s must not provide a platform for these offences to be committed. This means that events must not be held on the premises unless the College 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 the College. 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.
9. It is important to have a risk based approach to preventing terrorism. To comply with the Prevent duty, the College 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.
10. RHEBs must also have policies relating to the use of their IT equipment which include specific reference to the statutory duty.
11. RHEBs must have clear policies relating to Prevent and the Student Union and Student Societies. These policies must set out what is expected from the Student Union Student Societies in relation to the Prevent duty.
12. This policy will be published on the College website and will be reviewed periodically or in response to changes in Government policy.
POSSIBLE SIGNS OF RADICALISATION
13. 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.
13.1. Changes in ideology or faith
13.2. Narrowing of political views
13.3. Adoption of “Them” and “Us” mentality
13.4. Isolation from friends and family
13.5. Fervent public expression of strong anger or grievance about perceived injustice.
13.6. Attendance at certain rallies or meetings
14. The following College policies may help staff to identify any relevant changes in behaviour.
14.1. Student Welfare Policy
14.2. Student Attendance Policy
14.3. Student Complaints Policy
15. These policies are available on Moodle and on the main NCH website. .
HOW PREVENT POLICY IS PUT INTO ACTION
SPEAKERS AND EVENTS
16. NCH holds events, public meetings and lectures which may be led by an external speaker. A member of NCH staff is usually in attendance at these meetings. Any events held by the Student Union or Student Societies are approved by Student Support or the Master. 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:
16.1. The speakers details
16.2. The member of staff on duty
17. 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 that they feel they cannot safeguard the students during.
INTERNET ACCESS
18. The College has implemented changes to the firewall. This means sites which fall under a category in the following list are not accessible to anyone on the College network.
18.1. Violence/Hate/Racism
18.2. Weapons
18.3. Illegal Skill/Questionable Skills
18.4. Hacking/Proxy Avoidance Systems
19. This list has been provided by the College’s internet service provider. For the full list of sites and definitions, can be found here.
20. Anyone needing to use a blocked website for academic purposes should see Appendix 1.
STUDENT ENGAGEMENT
21. The College has an engaged student body and works closely with the students to continually improve engagement. The College encourages students to debate complex ideas and issues. Students are closely supervised during their time here and have more one to one contact hours than at many other universities through 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 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 Head of Faculty. 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.
TRAINING
22. Guidance from the Government suggests training should be given to help people identify potential signals that a student has become radicalised or is radicalising other students. Training is 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) programme will be one tool made available to the people listed above. Further training can be given to anyone who may need it.
ESCALATION IF A STUDENT OR STAFF MEMBER SHOWS SIGNS OF RADICALISING BEHAVIOUR.
23. Any member of the College (student or staff member) may express concerns about any member of the College (student or staff member) potentially being drawn into violent extremism based on information received or behaviour observed.
24. Within the College, 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.
25. There may be circumstances where the College identifies someone who is suspected as being involved in terrorist-related activity. If this happens, the following steps will followed.
26. A person will only be referred to the Police if there is an immediate threat of violence.
27. If a student or member of staff is worried that a student is becoming radicalised or is radicalising others, this must be reported to Student Wellbeing Coordinator. The Student Wellbeing Coordinator will pass this on to the Prevent Officer if appropriate. The Prevent Officer will investigate the matter.
28. 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 HR and Operations Manager or the COO. The HR and Operations Manager or the COO will pass this on to the Prevent Officer if appropriate. The Prevent Officer will investigate the matter.
29. Once any available information and substantive evidence has been gathered, this will be considered by the Prevent Officer, in discussion with other members of the College staff where relevant. The investigation and any evidence found will be recorded on Highrise or on their staff file.
30. A decision will be made as to the seriousness of the case. Three potential outcomes are likely at this stage:
30.1. No further action is required and this will be recorded on Highrise or on their staff file. The relevant Heads of Faculty, Personal Tutor (students only), the Student Wellbeing Coordinator (students only), the Registrar (students only), the HR and Operations Manager (staff only), the COO (staff only) and the Master will be informed.
30.2. 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 Prevent Officer, the Registrar (students only), the HR and Operations 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. The relevant Heads of Faculty, Personal Tutor and the Student Wellbeing Coordinator will be informed. At the review the case would be assessed again and the appropriate actions taken. Where necessary, the College will refer the person to the Channel process as an action point. Should the College refer someone to the Channel process, the Prevent Officer will attend the relevant meetings
30.3. A referral to the police is required because there are serious and immediate safety issues to the student or others, and/or there is evidence to suggest a criminal act may be committed or has been committed. This decision will only be taken in the most serious circumstances and only following discussions between the Prevent Officer, the Registrar (students only), the HR and Operations Manager (staff only), the COO (staff only) and the Master.
31. In accordance with the Data Protection Act, personal data on students will only be passed to the relevant authorities, in the instance that a request for information is made, with a police warrant. The College will only pass on student information if action is required in accordance with point 31.2 or 31.3. In sharing such information with external parties, the College will share only sufficient and relevant information in order to allow the concern to be appropriately followed up. The College will keep confidential records of the information shared. These will be kept in accordance with the Data Protection Act (1998).
32. Contact with the Regional Prevent Co-ordinator is the responsibility of the Prevent Officer who will be responsible for coordination with relevant bodies in the event of the College having concerns.
33. The Prevent Officer will also:
33.1. Attend any training or conferences required to keep up to date on Prevent issues.
33.2. Keep the Prevent Policy up to date
ACADEMIC EXCEPTIONS TO REVIEW EXTREMIST MATERIAL ONLINE
34. Should an academic wish to review extremist material online (which ordinarily would have been blocked by the NCH provider, Pioneer), they should complete a form which the College provides on the staff intranet.