Prevent

Senior management and governing bodies engagement with and understanding of institutional responsibilities in respect of Prevent under Office for Students and Ofsted (higher apprenticeships.)

Risk

The organisation fails to ensure appropriate governance and senior leadership oversight is in place in relation to Prevent.

Actions taken

1. Prevent is covered as a standing item in the CONTEST Strategy Group with representation from key academic and professional services. This is chaired by the University Secretary and Registrar for governance and oversight, reporting into the University Executive Board.
2. In addition to receiving updates (as appropriate), the Governing Council approves the Prevent Accountability Return and action plan in November each year.
3. The University has regular contact with external stakeholders for the purposes of Prevent.
4. All members of Governing Council have received safeguarding and Prevent training.
5. Safeguarding, inclusive of Prevent, is a regular agenda item at Skills Committee and Governing Council.

Further actions required

1. Continue to ensure policy and action is informed by liaison with internal and external stakeholders.
2. Continue to update UEB, GC and the wider student and staff community, and maintain representation and contact with local stakeholders and groups as appropriate.
3. Ensure that Prevent is not confined to events and speakers. To ensure risk assessment and action is taken on a wider scale in terms of educating students and staff about Safeguarding and Prevent and supporting them to access the relevant support as and when required.

The University has a clear understanding of the local and national risks related to extremism and radicalisation.

Risk

The organisation does not access available intelligence leading to a failure to develop a comprehensive action plan and effectively support vulnerable individuals.

Actions taken

1. Local and national risks through membership and participation in the Regional HE Prevent Network, liaison with Prevent Police & provision of the annual Counter Terrorism Local Profile (CTLP) as well briefings to Contest Board.
2. The University is further appraised of local and national updates through the regular liaison with the East Midlands Regional Prevent Coordinator who is also a member of the Contest Group.
3. Staff are briefed on local risk to students and the support needs of international students, particularly those from conflict zones through regular updates via Derby Daily, Managers updates and through the Local Safeguarding Officer network.

Further actions required

1. Not applicable

• Staff and students are aware of the webpages which contain guidance on Prevent
• Staff and students are aware of the benefits of community cohesion and the potential damaging effects of extremism on community relations
• Staff and students understand what is meant by the terms radicalisation and extremism and know how to share concerns about radicalisation and extremism
• All students have access to support and guidance to address any issues they may be facing whilst studying at the University
• A coordinated approach is taken to the support of students who may be vulnerable to violent extremist radicalisation
• The University’s response to the Prevent duty is guided by our institutional values of inclusiveness, integrity and community
• The University provides safe spaces internally for discussion and debate

Risk

1. The organisation does not make available appropriate training and awareness leading to staff and students failing to report concerns.
2. Community relations suffer as a consequence of the University not having due regard to the Prevent Duty.
3. The organisation does not provide effective welfare and pastoral support which results in learners (and staff) being unsupported and the risk of vulnerabilities being exploited.
4. Implementation of Prevent policies result in discriminatory and/or disproportionate outcomes.

Actions taken

1. The Head of Student Services has put in place a Risk Management Tool to help assess, plan and mitigate risk for students and staff.
2. Student Services Teams continually monitor access and waiting times to pastoral support services.
3. Reporting mechanisms, forms and guidance in place for all staff and students and visible on our external webpages.
4. Commitment in place to triage any student in crisis immediately via Student Services Teams.
5. Local Safeguarding Officer (LoSO) model in place to ensure a cohesive culture around Prevent and Safeguarding across our campus.
6. Collaborative approach to support via Chaplaincy, Student Services, Halls and Union of Students.
7. The University has in place a ‘Cause for Concern’ process led by the Director of Student and Academic Services that is an internal ‘multi-disciplinary service’ approach to supporting some of the most vulnerable students at risk of non-completion or leaving the University.
8. Student Services are members of Derbyshire Adults and Children's Safeguarding Board. 

Further action required

1. Continue to develop strategic and operational student services plans that ensure the ongoing delivery of excellent student services and support.

• The Union of Students (UoS) is aware of the risks of radicalisation and extremism and are able to support students appropriately
• All are aware of and adhere to the External Speakers Procedure
• On/Offsite events/trips are assessed for the risk under the framework of the Prevent Duty
• UoS is aware that, as registered with the Charity Commission, they are subject to charity laws and regulations, including those relating to Prevent Duty
• The rights to Freedom of Speech and Academic Freedom are respected and balanced with legal duties
• UoS members consulted on approach to Prevent

Risk

• Extremist organisations are given a platform to radicalise young people because the organisation has ineffective processes in the place for vetting speakers and events
• Inappropriate or extremist materials are shared with learners (face to face or via weblinks) because insufficient checks are made of external speakers and materials that they promote or share

Actions taken

1. All clubs and societies must complete an Event form and External Speakers request form for each event taking place as per the Union External Speakers Policy. A risk assessment is then completed to assess any potential risk or impact of the event going ahead.
2. External Speaker Policy followed for societies who wish to invite external speakers to events, including a booking form and risk assessment which aligns with University processes.
3. UoS has access to appropriate Prevent training.
4. F2F Prevent induction training to Full Time Officers delivered by Regional Prevent Coordinator annually.
5. UoS is represented in CONTEST group.
6. UoS as of 24/25 attends the Regional Prevent Meetings.

Further actions required

1. Continue to ensure the UoS are integrated into the broader work of the University.
2. All advisers, officers and society coordinator will have access to Prevent training and this will further be built into the induction. 

• Staff understand the reasons for the implementation of the Prevent Strategy and what the Universities' responsibilities are
• Staff receive training that helps develop critical thinking skills around the power of influence and confident in managing discussions about controversial issues
• Staff are aware of what they should do in the event of any concerns being raised in relation to this duty

Risk

• Staff are not aware of the factors that make people vulnerable to radicalisation and terrorism and are unable to recognise the signs of vulnerability and therefore are unable or unwilling to refer concerns
• Leaders and staff feel unable or unwilling to challenge extremist narratives
• Staff are unclear on how to deal with or refer concerns resulting in individuals not being supported and potentially radicalisation remaining unchecked
• Heavy staff turnover in the University means that monitoring Prevent training completion and keeping staff up to date may be a challenge

Actions taken

1. Prevent training is incorporated into the 'keeping students and staff safe' and the 'how we work' e-learning module, and is mandatory for all new staff.
2. Training is reviewed annually to ensure it is up-to-date and relevant.
3. Completion rates are tracked and reported to the CONTEST group.
4. The Safeguarding and Complex Case Officer in Student Services ensures regular communications in Derby Daily around Prevent.
5. Forms and guidance on UDO, Staff iD and main website.
6. F2F sessions delivered for student-facing colleagues with continuation as new staff are hired. In addition F2F sessions are organised for staff who are non-PC users.
7. Assurance of relevant clearance/checks in place ahead of commencement of employment (eg. DBS, List 99) as part of our safer recruitment policy.

Further actions required

1. TCI will maintain delivery of training including for new staff and repeat training for existing staff.
2. TCI will ensure continued close liaison with Student Student Services, Prevent Coordinator and other stakeholders to ensure all training is up to date and supporting our community and Prevent duty.

• DS&S Colleagues receive appropriate Prevent awareness training
• All areas including staff and students will receive appropriate training to stay safe online and adhere to policies around general usage covering what is and is not permissible, whilst also containing specific references to the statutory duty
• Use filtering as a means of restricting access to harmful content. Consideration should be given to the use of filters as part of the institutions strategy to prevent people from being drawn into terrorism
• Students and Staff understand the risks attached to accessing terrorist and extremist material online and understand the institution’s duty and process in these areas
• Any references to the institutions online are picked up quickly and referred for action if they have links to terrorist/extremist material
• The University has appropriate monitoring arrangements in place to also include any relevant University social media accounts (Facebook, Twitter etc.)

Risk

• Extremist organisations are able to radicalise students online and encourage them to commit acts of violence or incite others to commit acts of violence as ‘lone actors’
• Learners (and staff) are able to access unlawful radicalising material which promotes proscribed terrorist groups
• The University experiences reputational damage due to references made online to the University in relation to links to terrorist/extremist material

Actions taken

1. Internet is provided by JISC and web filtering services are in place to reduce possibility of the inappropriate content being accessed by University staff and students.
2. DS&S operate best in class web filtering services (currently CheckPoint) on the University’s internet feeds which automatically blocks and records attempted access to inappropriate web content.
3. A weekly report of all attempted access to inappropriate web content is sent to representatives in BLC and the Head of Governance & IT Portfolio with any issues raised to the Academic Registrar.
4. Further restrictive web filtering policies are in place for all Under 18 learners and an exception report is sent weekly to Operational Manager - Learner Journey at BLC.
5. DS&S have representation at the CONTEST group.
6. External Relations monitor social media for any evidence that a student or staff member is inciting hate rhetoric or terrorism and raise the alarm should any threat direct or indirect be aimed at the University.

Further actions required

1. DS&S will continue to review all policies and procedures annually to ensure compliance and best practice

• The University works with partners that place the same level of importance on the Prevent Duty as the University
• Our partners understand that Prevent is everyone's business

Risk

• Our partners may not have the same level of management overview and compliance commitment to the Prevent Duty as the University of Derby
• The organisation does not have robust processes in place to protect work-based students from the risks of radicalisation

Actions taken

1. We identify whether partners register directly with OfS. If partners do register with OfS, we seek confirmation of this and note their direct accountability for Prevent Duty. If partners do not register with OfS we require them to comply with our Prevent duty and to evidence this in regular reporting and show due regard to Prevent requirements.

Further actions required

1. Continued monitoring of Partner relationships and approaches to ensure our Prevent duty is not undermined.
2. Monitoring and evaluation of partner feedback.

• Students and staff working on sensitive or extremism-related research to be aware of policies and procedures relating to Prevent
• Students, academics and university research administration understand the process for carrying out security-sensitive research.
• Students and colleagues feel protected and secure if carrying out legitimate security-sensitive research
• Advise the Academic Board on issues associated with research ethics, and advise on the implications of developments for research governance at the University

Risk

• College researchers are in breach of research ethics governing research using human subjects, including online

Actions taken

1. University’s Research Ethics Policy and Code of Practice in place to ensure continued adherence to our Prevent duty coupled with the Ethics Monitor system.
2. All research involving human subjects must receive ethical clearance from the University.

Further actions required

1. Continual Review of Process and Policy and sharing good practice into and from college Ethics Committees into UREC.

• Staff and students are aware of the policies and procedures in place relating to booking of external events and speakers
• Suitable policies and procedures are in place to identify, assess and manage events
• Policies and procedures in relation to events and speakers take into account freedom of speech and other related legal and regulatory requirements

Risk

• Lack of oversight and controls over Events and/or speakers hosted on campus which risk drawing staff and/or students into terrorism

Actions taken

1. The Events Operations Manager liaises with the Regional Prevent Co-ordinator to help ensure thorough understanding the Prevent Duty and are supportive of the enhancements made to the events risk assessment tool.
2. The University has a Code of Practice on Freedom of Speech.
3. The University has controls and procedures in place to support the code of practice by way of an event approval request form.
4. The University has balanced its legal duties in relation to ensuring freedom of speech and academic freedom, and also protecting student and staff welfare through its Code of Practice on Freedom of Speech.

Further actions required

1. Adoption and implementation of revised Code of Practice on Freedom of Speech which will reflect the non-implementation of the Higher Education (Freedom of Speech) Act 2023 and will remain a solid guiding framework for the University on free speech issues. Governing Council will consider this revised Code on 22 November 2024.