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Implementing the new Prevent statutory duty: understanding expectations and ensuring compliance

PREVENT Cardiff Metropolitan University

The Counter Terrorism and Security Bill 2015

Guidance & Instruction for specific authorities on the duty to have due regard to the need to prevent people being drawn into terrorism (Dec 2014)

A risk-based approach to the Prevent duty• Establish or use existing mechanisms for

understanding the risk of radicalisation• Ensure staff understand the risk and build

capabilities to deal with it• Communicate and promote the

importance of the duty• Ensure staff implement the duty effectively

Working in partnership

Prevent depends on effective partnership. To demonstrate effective compliance with the duty, universities must demonstrate evidence of productive cooperation, in particular with Prevent co-ordinators, the Police and other authorities; to include multi-agency forums

Partnership II• Active engagement from Vice Chancellors, senior

management and prevent partners are a requirement • Due to size and complexity, there is a requirement for cross

disciplinary working (in Cardiff Mets case the Equality and Diversity Committee) but with a single point of contact (Prevent Coordinator) for operational delivery of Prevent-related activity

• Universities are to have regular contact with their Higher Educational Prevent coordinators who will advise on Duty of Care, risk and appropriate response. In South Wales this is actioned by the SWCRWG

Risk Assessment• Universities are expected to risk assess points of vulnerability

which might expose students to risk of being drawn into terrorism. Such duty extends into non-violent extremism, which can create an environment that promotes or popularises views that terrorists exploit

• Risk assessments should include student welfare, equality and diversity and the safety and welfare of students and staff

• The physical management of the university estates including policies and procedures for events held by staff, students and visitors should also be included in such assessments

• Conflict Zone students required monitoring and specific support packages

Sharing information

The Prevent program must not involve any covert activity against people or communities. Universities may need to share information to ensure, for example, that a person at risk of radicalisation is given appropriate support (Channel)Information must be shared and assessed on a case by case basis and is governed by legislation. To ensure the rights of individuals are fully protected, it is important that information sharing agreements are in place at local levelWhen considering sharing personal information, that universities should take account of the following:

SI Requirements• Necessity and Proportionality: Personal information should

be shared where it is strictly necessary to the intended and proportionate to it. Key to determining the necessity and proportionality of sharing information will be the professional judgement of the risks to the individual or the public

• Consent: wherever possible the consent of the person concerned should be obtained before sharing the information about them

Student Union• The Bill requires that the Student Union works in conjunction

with the University with regards to Prevent which is governed by the University Prevent Policy

• The Student Union is to have clear polices stating which activities are, and are not, permitted by students and this is to include on-line activities and student societies

• The student union has a duty to challenge extremist concepts that legitimise terrorism

• Student Union staff are to be included in the university Prevent training process and have a voice in it’s formation

• All society (and other) speakers MUST to be cleared using the RAG/SPOE system and the Prevent Coordinator is to consider sharing speaker information via the HO/HE Prevent Co-ordinator (Continued)

Speakers & Events

University are required to have polices which govern speakers and events. This is to include:

• A minimum 30 day period of notification using the SU formatted protocol or direct referral to the Prevent Coordinator where appropriate (Conferences & Academic) for RAG/SPOE & ‘Inform’ assessment

• Advanced notice of the content of the event including topic outline and sight of presentations etc. may be required

• A clear risk assessment and referral process for controversial events

Monitoring and Enforcement

• Universities must comply with this duty and will be expected to maintain appropriate records to show compliance with their responsibilities and provide reports when requested

• Where a university is not complying with the duty, the Prevent Oversight Board may recommend that the Secretary of State use the power of direction under section 23 under the Act

• An inspection regime will be implemented for universities

Training

There is a requirement that staff have training in relation to Prevent. Such training needs to be university specific but should also be tiered: Senior Management, Student Services, International Welfare Teams, Student Union, Security and Reception staff need bespoke training at a much higher level to include ‘risk’ briefings

Content

Training will include:• Awareness of the threat • An understanding of extremist ideologies that can be used to

draw students and staff into terrorist support or membership• An understanding of vulnerability to radicalisation and the

process of grooming and recruitment• An understanding of the internal referral process within the

university and the key role of the Channel program• Staff should be aware of both the local risk assessment but

also of the needs of international students, particularly the support requirements of those from conflict zones

Prevent TrainingT1: E - module Basic information for all staff

T3: Specialist ProvisionKey staff –fully Prevent trained (to include RB)

T4: Senior Management: Reputational integrity

Tier 1-4

Online risk

• The act requires that the university has policies detailing what is and is not permissible; these policies should contain specific reference to statutory duty

• The duty requires that the university considers filtering as a means of restricting access to harmful material including material that may draw students into terrorism

• Universities should adopt UUK’s recommendations on recording extremist-related research

Prayer room & faith based events• Prayers rooms are to be managed by prayer room protocol

covering use, speakers, materials, timings and sharing agreements

• All Cardiff Met prayer rooms are multi-faith, although provision is specific to individual faith requirements under equality legislation. Single sex prayer rooms are permitted under legislation

• There is a requirement under the act for specific & adequate prayer room provision for the student population

• Prayer rooms and faith based events managed by the multi-faith Chaplaincy and are integral to the university Prevent program

• Off Campus faith / cultural based events which include, or affect, students are to be managed and risk assessed

Pastoral & Chaplaincy Care

As part of the universities duty of care, it is expected that there be sufficient chaplaincy and pastoral support for all students according to the needs of the particular university, this is seen as a key element of compliance with the duty

Recommended Action Points

Attendance

The adoption of strict attendance monitoring to identify missing or ‘trafficked’ students at a very early point

Chaplaincy Provision

The adoption of an Arabic competent chaplain to specifically address the needs of our Muslim students

Policy Adoption

The adoption (with annual review) of the Prevent Policy in Cardiff Met (LSC)

Recommended Action Points

Staff Training

The adoption of an e-module staff training process with HR & routine senior staff training and ‘Risk’ briefings

Chaplaincy/HO Linked Research Hub

The continuation of research investigating on-line recruitment to Jihadist groups

On-line Filters

Review filtering and other options regarding Prevent sensitive on-line security

Radicalisation Contact Risk Points

Speaker (Student Society)

Conference speaker

E-contact (Grooming)

Prayer Room contact/use

International Ambassadors

Fresher's Fair

Unauthorised access to sites

Student Cells (Including Socs)

Off Site/LSC/ Trafficking

Key Internal Working Relationships

Prevent Team

Student Services/Chaplaincy

Security & Reception DLT’s

I/O Welfare & Complance

Personal Tutors

Prescribed Reporting Route

Pro-Vice Chancellor

• VCB

• Governors

Dean of Students

• Pro-Vice Chancellor

• Prevent Coordinator

PREVENT Coordinator

#UUKSDWifi Network: Woburn House Conference CentrePassword: pplyfr

Implementing the new Prevent statutory duty: understanding expectations and ensuring compliance