The Higher Education Funding Council for England (HEFCE), as the body given responsibility by the Home Office for monitoring compliance with the Prevent duty in the higher education sector in England, has now announced how it will perform this responsibility. Full details can be found at the links to the HEFCE website below: the following is a summary.
The monitoring framework consists of two stages – an initial assessment in 2016 to ensure that Higher Education Institutions have policies that are fit for purpose, followed by ongoing monitoring thereafter.
The initial assessment begins with a self-assessment form that HEIs must submit by 22nd January 2016. The sample form in Annex C suggests this is an assessment of the organisation’s preparedness to perform the various duties contained in the Home Office Guidance, from D (no arrangements prepared yet) to A (arrangements in place, reviewed, approved and operating). Where responses are B, C or D an estimate of when A will be reached is required. Where a paragraph is considered not to apply (response E) a justification is required.
During the spring and summer of 2016 (deadlines vary depending on the HEI’s status) further evidence must be provided, consisting of copies of the organisation’s risk assessment, action plan and policies for external speakers and events. If not already covered by those documents, an additional report is required summarising arrangements for senior management oversight, student engagement, staff training, information sharing (about vulnerable individuals and external speakers), pastoral and chaplaincy support, use of computer facilities, engagement with student unions. Organisations may also provide statistics as evidence that these processes are in operation.
In the ongoing monitoring stage, from 1st December 2016, Governing Bodies will need to provide an annual report, including statistics, as evidence of continuing activity. HEIs will also be reviewed on a five-year cycle to check that their arrangements are up to date.
A non-statutory advice note contains a list of questions to help HEIs develop their risk assessment, action plan, policies and processes. Most of these refer to policies and processes, but there are five questions specific to IT systems:
- Do IT policies set out what is and is not acceptable use of the provider’s systems for both research and non-research purposes?
- Do IT policies include arrangements for managing the provider’s ‘branded’ websites or social media to ensure they are not used to promote extremist material or activities?
- What factors were taken into account when considering whether and how to use filtering to limit access to harmful content?
- Is there a process for identifying and dealing with breaches of IT usage policies?
- What arrangements does the provider have in respect of websites and social media operated by students’ unions or societies
UCISA’s Model Regulations for the use of institutional IT facilities and systems may well be relevant to these discussions.