· Web viewThe Counter Terrorism and Security Act 2015, Section 26, has established a ‘Prevent Duty’. The University, as a ‘Relevant Higher Education Body (RHEB) in ... Universities

Prevent Duty Risk Assessment and Action Plan

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INTRODUCTION

Prevent Duty

The Counter Terrorism and Security Act 2015, Section 26, has established a ‘Prevent Duty’. The University, as a ‘Relevant Higher Education Body (RHEB) in the terms of the Act, must demonstrate it has “due regard, in the exercise of its functions, to the need to prevent people from being drawn into terrorism”.

The Prevent Duty is part of the Government’s counter-terrorism strategy to:

1. Respond to the ideological challenge of terrorism and the threat faced from those who promote it;2. Prevent people from being drawn into terrorism and ensure that they are given appropriate advice and support; 3. Work with sectors and institutions where there are risks of radicalisation that need to be addressed.

The Act places a statutory duty on ‘those judged to have a role in protecting vulnerable people and/ or our national security’. Universities also have a Public Sector Equality Duty to foster good relationships between people with ‘protected characteristics’ and those with none and to encourage diversity and equality on campus. To draw together these ‘duties’ the University has incorporated the Prevent Duty within its broader Equalities Duty.

In accordance with the requirements of the Prevent Duty the University has undertaken a risk assessment and produced an action plan to demonstrate how it will comply with the Act. Policies and procedures are being reviewed and updated making clear reference to how the University would respond to any identified risk.

Risk Assessment

The Government ‘Prevent Duty Guidance: for higher education institutions in England and Wales’ (July 2015) states that Institutions ‘will be expected to carry out a risk assessment … which assesses where and how their students might be at risk of being drawn into terrorism’ (paragraph 19). ‘We would expect the risk assessment to look at institutional policies regarding the campus and student welfare, including equality and diversity and the safety and welfare of students and staff’. The risk assessment should also assess ….’the physical management of the university estate including policies and procedures for events held by staff, students or visitors and relationships with external bodies and community groups who may use premises, or work in partnership with the Institution’ (paragraph 20).

The University has based its risk assessment on the local risk level as determined by the Counter Terrorism Unit.

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Brighton and Hove City Council, as part of its Prevent Duty, has formed a Prevent Board which is a multi-agency forum for the sharing of information between a range of partner organisations. As a member of this forum, the University is kept advised of the current risk status. The advice to the University is that it is ‘low risk’ at the present time.

In its Risk Assessment the University has attempted to look at how and where students might be drawn into terrorism. The Action Plan, attempts to mitigate identified risk and will be revised should the level of risk vary. It should be seen as a ‘living’ document.

Action Plan

The Action Plan identifies those areas in which the University is required to demonstrate compliance as identified by the Government in its ‘Prevent Duty Guidance: for higher education institutions in England and Wales’ (July 2015) and by the Higher Education Funding Council For England (HEFCE) in its guidance ‘The Prevent Duty Monitoring Framework for the higher education sector’ (November 2015/32). The Action Plan identifies the actions that need to be taken to be fully compliant with the Prevent Duty.

The Equalities and Diversity Committee will oversee the delivery of the Action Plan through a Steering Group. Council, as the ‘responsible body’ will receive regular updates on progress against the Action Plan.

Monitoring Compliance

The University Council is the ‘responsible body’ within the University. The Higher Education Funding Council (HEFCE) is responsible for monitoring compliance.

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Risk AssessmentThe Government’s Prevent Duty Guidance requires the University to identify ‘where and how’ students might be at risk of being drawn into terrorism. As with the rest of the population, students may be ‘radicalised’ or drawn into terrorism through a variety of routes and for a range of reasons, ranging from concerns about geopolitics; global conflicts and humanitarian crises; as well as other issues such as animal rights. Researching issues may lead students to web sites, social media groups and organisations whose methods of achieving their stated aims may include acts that would be defined as terrorism or non-violent extremism. The University is aware that this will continue to be a potential ‘risk’ which it attempts to mitigate by encouraging students to explore and research current events and world issues in an environment that encourages open debate and critical thinking and which fosters informed decision making.

The University is aware that staff are potentially as at risk as students and the Risk Assessment therefore includes all members of the University Community.

University of Sussex Risk Analysis December 2015

Potential Risk Probability

Impact Overall Risk Level High/Medium/Low

Students being drawn into terrorism

The effectiveness of the University’s policies regarding:1. The physical management of the University

2. Student welfare

1

2

1

5

5

5

Low

Low

Low

Production and dissemination of radical, extremist or terrorism-related material or internet resources:

1 5 Low

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Use of University IT systems and networks for production and disseminationConcerns about materials posted on University propertyUse of University-related or hosted social networking sites for extremist/radical or terrorism related discussionresearch activity, non-authorised, giving cause for concern

2

2

5

5

Access to University campus by external influencers; unauthorised speakers or disseminators of literature

4 5 High

Public image and Reputational damage 3 5 High

Risk estimates

Probability 1-5

Impact 1-5

Action Plan

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Prevent DutyVulnerability/risk area as identified in the Act

Specific requirement Actions taken or required to be taken

Timeframe Mitigation - actions linked to identified risk and to ensure compliance

Responsibility

LeadershipDefined as:Council;University Executive Group;SPOCPSGHoS

Single Point of Contact (SPOC) appointed for operational delivery of Prevent-related activities.

Leaders required to:1. Attend training, and

establish or use existing mechanisms to understand risk of radicalisation.

2. Ensure staff understand the risk and build capabilities to deal with it

3. Communicate to staff/students about Prevent Duty, including

Director of Student Services appointed as SPOC. SPOC to keep senior leadership informed and engaged to ensure oversight of statutory duty.

All leaders have been briefed and aware of their responsibilities.

Training to be delivered once sector programme has been developed.

Through ongoing briefing/training

In place and ongoing

To be completed by January 2017 and then ongoing

OngoingTraining modules agreed

Annually: in first term of academic year

Prevent Steering Group to be established to ensure leadership responsibilities identified and shared. In place

Identify and deliver training Senior leaders have attended Prevent Duty training (Aug 2016)

Training plan draft submitted to HEFCE for approval

Draft comms for students for approval ongoing

University Executive Group

HR and SPOC

HR and SPOC

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Responsibility

student and staff unions

4. Monitor staff attendance at training and overall implementation of Prevent Duty

Ongoing

SPOC and Head Comms

H.R.SPOC(report any issues arising to Steering group)

Partnerships1. Productive cooperation

with Local Prevent BoardThe SPOC represents the University as a member of the Board

In place – meetings held regularly throughout year.

SPOC

Regular engagement with Prevent Partners

Productive cooperation with:1. Local Prevent Board

2. HEIs in region

3. BIS and HEFCE Prevent coordinators

4. Students ‘Union

Ongoing contact to maintain updates on local risk (Counter Terrorism Local Profile)

Throughout the year

Termly, as a minimum

Termly as a minimum

Termly and as

Maintaining dialogue about approach to Prevent Duty

In place and ongoing

SPOC

SPOC

SPOC

SPOC

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Responsibility

5. Campus partners delivering services Partners need to be

kept informed of actions that they are required to undertake

part of Steering GroupTermly

Policies and referral pathways to be shared/discussedFor action

HR, Estates andFacilities and SPOC

Staff training Identify appropriate training package for staff

Some key staff, including Student Services and Security have undertaken earlier iterations of the WRAP training programme. This programme currently being reviewed nationally.

SPOC briefed Equality and Diversity Committee to ensure that university’s Prevent-related training is

Identified from May 4th 2016 when training package made available Training package identified July 2016

Steering group to identify levels of training required across institution.

In progress – confirm roles

HR and Steering GroupSPOC and BIS coordinator identifying most appropriate training packagesCompleted

Equality and Diversity Committee to receive reports on attendance at trainingongoing

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Responsibility

underpinned by unconscious bias training which is already offered by Staff Development.

Pastoral care/student welfare/ equality /diversity

Ensure there is: 1. Sufficient welfare,

pastoral and chaplaincy support for students.

2. Guidance and policy regarding use of prayer rooms and other faith related spaces.

Regular review of policy and procedures in the area of student engagement: academic advising, staff training.

Review current policies and procedures

April 2016, and annually in November when bids for additional budgets are made.

April 2016 and annually thereafter

Gap analysis of existing activity/policy to identify areas requiring reference to Prevent Duty and/or review and training. Current action

Director of Student Services

Governance and Director of Student ServicesFor action

Sharing Information internally and externally about vulnerable individuals where appropriate

1. Robust procedures required for sharing information, internally and externally, in relation to vulnerable people

The University is developing an ‘Engagement Framework’ to bring together existing policy and procedures to

June 2016 – implementation for September 2016/17

University has informed HEFCE that the cause for concern procedures are ‘currently being reviewed and

PVC Teaching and Learning, Student Engagement Working Group, Academic Advising Implementation Group.

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Responsibility

Sharing information about external speakers with other providers where legal and appropriate

Ensure that Freedom of Speech and external speakers and events policy incorporates this clearly and transparently.

ensure they are robust, transparent and readily accessible. In the interim existing policies to be updated to reflect Prevent Duty

July 2016 for local approval – to HEFCE by Sept (see below)

updated’. For further action

Rights of individuals are fully protected, and staff should understand local level agreements for sharing information across services, external and internal.for action

Estates and Facilities with SPOC; Governance, HR.

Events and external speaker policy and protocol

1. Required to have policies and procedures in place for managing events on campus and the use of

Review current policy to ensure:

1.Clarity of process to

July 2016 Update university policy to reflect Prevent Duty. Draft submitted

Governance

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Responsibility

Freedom of Speech and Academic Freedom

premises which apply to staff, students and visitors.

1. Balance legal duties with duty to protect student and staff welfare

facilitate transparent risk assessment and decision making.

2. Freedom of speech and academic freedom are upheld notwithstanding Prevent Duty measures.

July 2016Draft submitted HEFCE Sept

Freedom of Speech policy to be updated to reflect new contractual obligations between university and partners in Estates and Security etc Action completed

Keep USSU informed and ensure transparent communication Ongoing

Governance

SPOC

Internet safety and IT

1. Policies to contain specific reference to Prevent Duty

Useage policies to refer to Prevent Duty

Completed Ensure text in regulations refers to IT policy, and

Director of IT Services, Registry/Governance

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Responsibility

2. Consideration should be given to use of filters as part of overall strategy

Review policies for staff/students researching sensitive or extremism-related issues

policies/guidance on research ethics, access to security-sensitive online materials, and privacy for staff and students

Relationship with the Students’ Union and SU societies

Required to have policies in relation to student union activities on campus, and any online activity directly related to the University in the specific context of the Prevent Duty.

1. Review protocol for holding events, promoting activities both on and off campus premises that are ‘badged’ as University of Sussex events.

2. Offer training for staff and encourage engagement with

July 2016

All key staff to have completed training by

USSU to consider how this is reflected in any of their policies on Freedom of Speech and room usage in accordance with the their requirements as laid out by the Charities Commission.For action

Maintain opportunities to develop

Steering Group, SPOC, USSU General Manager and Sabbatical Officers

SPOC

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Responsibility

Prevent Duty January 2017 and an ongoing programme thereafter

communication and consultation with permanent staff and sabbatical officers in USSUAsk USSU to ensure that their ‘No Platform ‘policy is clearly articulated. Ongoing

Updated August 3rd 2016 – as version 1.2 Updated to reflect submission to Hefce of draft FoS Code of Practice and External Speakers/Events Procedures Sept 2016 Version 1.1. submitted to Hefce on 1st April 2016 Risk assessment reviewed by SPOC Dec 2016 prior to latest submission to HEFCE : no change identified

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Documents

· Web viewThe Counter Terrorism and Security Act 2015, Section 26, has established a ‘Prevent Duty’. The University, as a ‘Relevant Higher Education Body (RHEB) in ... Universities