Policies & Key Documents

Prevent Policy

Introduction

This Policy sets out the Prince’s Foundation’s School of Traditional Arts approach to comply with the Counter Terrorism and Security Act (2015) and the Prevent Duty Guidance for Higher Education Institutions in England and Wales (2019). Part 5 of the Counter Terrorism and Security Bill (2015) placed specific obligations on universities to “have due regard to the need to prevent people from being drawn into terrorism”. This is known as the “Prevent Duty”. The aim of the Prince’s Foundation’s School of Traditional Arts Prevent Policy is to recognize this responsibility and to create and maintain a safe, healthy and supportive learning and working environment for all its students and staff.

Scope

This Policy applies specifically to the staff and students of the Prince’s Foundation’s School of Traditional Arts (PFSTA) and has been drafted to comply with the requirements of the Office for Students. In due course the Policy will be updated so that it applies to the staff, students, contractors of the Prince’s Foundation as a whole.

Policy objectives

The Prince’s Foundation recognises that all members of staff have a duty under the Counter Terrorism and Security Act (2015) to have due regard to the need to prevent people being drawn into terrorism and to act positively to report concerns. The purpose of this policy is to:**

  • Make it clear that properly thought through policies and procedures are in place that are followed and applied
  • Gain assurance that procedures are clear and able to be implemented
  • Ensure an awareness of the Prevent Duty within the Prince’s Foundation’s School of Traditional Arts including trustees, staff and students
  • Set out clear guidance on events which include external speakers
  • Set out clear guidance available to all on the use of faith-related facilities
  • Clarify PFSTA’s approach to its external communications in relation to Prevent
  • Reiterate guidance on the use of information technology on the premises and for the use of research in curriculum areas

Policy owners, approval and oversight

The Policy is overseen and reviewed by the Education Committee. It is ultimately approved by the Board of The Prince’s Foundation.

The Policy is owned by the Chief Operating Officer who has responsibility for overseeing the Policy’s effective implementation and compliance. The Director and the Registrar of the Prince’s Foundation School of Traditional Arts shall assist the COO in ensuring this Policy is implemented effectively.

Equality and Diversity

This policy recognises the importance of providing for and celebrating the cultural, religious and ethnic diversity of its staff and students. It requires all staff, students and visitors to respect the Foundation’s values, be sensitive to the diversity of the Foundation community and to show respect to all sections of that community.

Audience

The Prevent Policy applies to everyone working at or attending the Prince’s Foundation School of Traditional Arts including staff, students, volunteers, contractors, visitors, consultants and those working under self- employed arrangements.**

Application

The implementation of the Policy requires the Foundation to:

  • Monitor and assess risks within activities undertaken by the Prince’s Foundation’s School of Traditional Arts (the “Risk Assessment”); and
  • Provide a clear framework to structure and inform our response to concerns (the “Action Plan”)

These will be compiled with assistance from the DfE Prevent Coordinator for London. The advice from the FE/HE Regional Prevent Coordinator for London is that the Risk Assessment and Action Plan should be compiled with detailed consideration and consultation undertaken within the organization. The proposal is that the Education Committee reviews the Risk Assessment and Action Plan at its next meeting.

Training

A key requirement is to ensure that members of staff receive appropriate information and training. All members of PFSTA staff are expected to be aware of the Prevent Duty and to know what their responsibilities are in relation to it, including in particular knowing how to raise a matter of concern. See Section 4.0 which will give behaviour indicator examples to help you recognize a concern. Staff will require training to ensure a comprehensive understanding of, and compliance with, the Prevent Duty. For key staff, such as those with a particular student-facing role, training will be organised. The DfE Prevent Coordinator for London has been approached and he has confirmed that he can offer this training. Training will be arranged at least once a year for key staff.

Review cycle

The Policy will be updated to include all aspects of The Prince’s Foundation in due course; and this Policy was re-presented to the Board of Trustees and was approved at the Board meeting (1st October 2020).

Thereafter the Policy will be reviewed on an annual basis by the Education Committee and any amendments sent to the Board of Trustees for approval.

Local Authority Prevent contact:

Hackney Prevent Coordinator – tracey.thomas@hackney.gov.uk Websites:

https://www.gov.uk/government/publications/channel-guidance https://www.gov.uk/government/publications/prevent-duty-guidance https://www.officeforstudents.org.uk/publications/prevent-duty-framework-for-monitoring-in- higher-education-in-england-2018-19-onwards/

https://www.safecampuscommunities.ac.uk/

E-Learning:

https://www.elearning.prevent.homeoffice.gov.uk/ https://www.safecampuscommunities.ac.uk/prevent/

The Prince’s Foundation School of Traditional Arts: Prevent Policy

  1. Approach
    1. The Prince’s Foundation takes seriously its responsibility to ensure the safety and wellbeing of students, staff and the wider community, and as part of this would wish to do all that it can to prevent any member of the School of Traditional Arts community from being drawn to terrorism. The Prince’s Foundation School of Traditional Arts (PFSTA) aims to provide a safe, inclusive and supportive environment, conducive to work, learning, research and the enjoyment of a positive experience to all. Through this, the PFSTA aims to ensure vulnerable individuals are safeguarded from radicalisation and being drawn into violent extremism and terrorism.**
    2. PFSTA welcomes the Government’s intention that the Prevent Duty is implemented in a proportionate and risk-based way and that it should not create large new burdens on institutions. PFSTA intends to implement its legal responsibilities as part of existing policies and procedures, to ensure a joined-up approach. In doing this PFSTA will actively involve the students and will continue to consult them should any changes to this policy be required in the future.**
    3. PFSTA values the principles of academic freedom and general freedom of expression and recognises it has a statutory duty to protect them. Preventing vulnerable individuals from being drawn into terrorism is a safeguarding issue and the Foundation’s policies and procedures in place to help safeguard staff and students also take into account the Prevent requirements. [See Safeguarding Policy p.3&4]**
  2. Leadership
    1. PFSTA takes seriously the need to prevent terrorism occurring in its community. The Chief Operating Officer has been identified as the member of senior management team responsible for ensuring that PFSTA complies appropriately with the Prevent Duty. The Registrar of the School will assist in this by ensuring that staff and students are made aware of the general requirements of Prevent but in ways that ensure they remain sensitive to the cultural, religious and ethnic diversity of the PFSTA community.
    2. The Education Committee and the Academic Board are responsible for providing the Board of Trustees with assurance of PFSTA’s compliance with the Prevent Duty. The Board of Trustees is responsible for approving the Prevent Policy and for approving PFSTA’s annual accountability and monitoring return to OfS in compliance with the ongoing conditions of the Foundation’s registration
  3. Channel
    1. Channel is a multi-agency approach, which is led by the local authority (not the police or security service) to help support individuals who are identified as vulnerable for a variety of reasons. It is a programme focussed on providing support at an early stage to people. This includes those that are identified as being vulnerable to being drawn into terrorism. Channel aims to ensure that vulnerable adults of any faith (or none), ethnicity or background receive support before their vulnerabilities are exploited by those that would want them to embrace terrorism, and before they become involved in criminal terrorist activity.**
  4. Potential Behaviour Indicators
    1. The following behaviours can work as a guideline to help members of the Foundation community identify possible radicalisation. However, any or all do not always mean someone is being radicalised, with the exception of joining an extremist group and visiting extremist websites which is a concern but would be more of an action rather than behaviour.**
  • Increased social isolation.
  • Approval of the use of violence to support an idea or cause.
  • Racial intolerance or discriminatory behaviour towards people of different ethnicities. Unwilling to engage with people who are different. Becoming abusive to people who are different.
  • Sympathising with extremist groups and ideologies. Joining or trying to join an extremist organisation.
  • Visits to extremist websites. Accessing extremist online content. Increased internet/social media usage. Changing online identity. Having more than one online identity.
  • Becoming increasingly argumentative with friends and family. Changes in a person’s circle of friends and disinterest in old acquaintances.
  • Glorifying violence or advocating extreme messages.
  • Embracing conspiracy theories.
  • Feeling persecuted.
  • Being secretive and reluctant to discuss their whereabouts.
  1. Internal and External Referral Process
    1. The internal referral process will start with reporting any concerns to the line manager. If the line manager feels the matter is of concern, he/she will report to the Registrar/Director of the School.**
    2. Staff should not ignore their concerns but check what they have noticed. They could speak to the student directly or talk to colleagues to see if they share their concerns. If, after checking, the staff member identifies a potential matter of concern, or one is referred to them, they should contact their line manager as soon as possible for advice. This should always be their first step. They should not carry out an investigation themselves. Even if they have doubts as to whether a matter is relevant or not, they should always seek advice. Staff with the appropriate training will be able to assess if the matter requires further investigation or not.**
    3. The staff member’s line manager will carefully and sensitively consider the available evidence to assess whether the concern is genuine. He/She may seek further information from the staff member or others to verify the information provided or to help assess the level of vulnerability and welfare of the person. At this stage, the line manager will filter out any concerns that are established to be misinformed.**
    4. The case will be referred to the Registrar and Director of the School for a full assessment of risk and consideration of any further action. Regardless of this assessment, the Registrar and Director of the School will inform the Chief Operating Officer who will decide, in consultation with the Registrar and Director of the School, whether it is necessary to seek external referral.**
  2. In deciding whether there is a case for referring a concern outside of the Foundation, consideration is to be given to the following questions:**
  3. Is it appropriate and proportionate to share the information with outside agencies because there is, on the balance of probabilities, a serious risk posed by the individual to the wider public or to that individual?**
  4. By making the referral, is the intention to protect the individual from criminal exploitation, grooming (being drawn into terrorism) or self-harm?**
  5. Is the Foundation under a specific legal obligation to make the referral?**
  6. No member of staff is expected to make a judgement about whether someone is at risk of being drawn into terrorism or not. This is the responsibility of those key staff identified as key to the addressing of the Prevent duty. However, all members of staff have a responsibility to report internally any matters of concern, so that an appropriate assessment can be undertaken by key staff.
  7. Once the concern has been raised to the level of the Chief Operating Officer, it will be decided whether the concern should be referred through the Channel programme. The Channel referral process requires that concerns should be passed on to the Foundation’s Safeguarding Lead, who may consult with the local Prevent Officer (Police/Local Authority).
  8. If further action is considered appropriate, screening by the police Channel Coordinator might take place, followed by a preliminary assessment by the Local Authority’s Prevent Lead and Police Channel Coordinator.
  9. If further action is considered necessary, the next step might be the creation of an assessment and action plan by the local Multi-Agency Channel Panel, and subsequent implementation of that plan, which would be aimed at re-engaging the individual and preventing radicalisation. Channel is about safeguarding adults from being drawn into committing terrorist-related activity. It involves early intervention to protect vulnerable people and divert them away from the risk they face before illegality occurs. The framework for referral, review and action is not intended to criminalise individuals, but to set a course to avoid precisely that. An individual’s engagement with the Channel programme is entirely voluntary at all stages.
  10. Risk Assessment and Action Plan
    1. As required by the Prevent Duty, PFSTA will develop an Action Plan which sets out the implementation of the Policy. This will include, but is not limited to:
  11. Implementing training procedures for staff responsible for Prevent Duty
  12. Ensuring all staff and students are aware of Prevent reporting procedures
  13. Establishing staff development sessions to inform and provide more information on the Prevent Duty
  14. Embedding briefing on Prevent Duty during induction of new staff members
  15. Raising student awareness of Prevent Duty and ensuring staff handbook is up to date
  16. As required by the Office for Students, PFSTA will carry out assessments of the risk of its students being drawn into terrorism. The risk assessment will be reviewed at least annually by the Education Committee. Where any significant risk is identified, PFSTA will consider what action might mitigate the impact/likelihood of that risk crystallising, and if necessary include it in the Foundation’s Prevent Action Plan.**
  17. PFSTA Events and External Speakers
    1. PFSTA is aware that it has a duty under the Education (No 2) Act 1986 to secure freedom of speech within the law. However, where the views expressed constitute views that risk drawing people into terrorism, or are shared by terrorist groups, permission to proceed must be sought by the organiser from the Policy owner. The Policy owner maintains the right to decide not to proceed with the event or external speaker, should doing so constitute a risk of compromising PFSTA’s commitment to the** Prevent Duty.**
    2. The MA Senior Tutor will work with Open Programme staff to make suggestions to book non-curricular external speakers and will work together to carry out due diligence on the speaker before forwarding this information for final approval to the Director of the School. PFSTA will share information with external organisations if appropriate about any event as described in 4.1 which comes within the remit of Prevent.**
    3. External speakers will be made aware of their responsibility to abide by the law by the staff member who booked the speaker including that they:
  18. must not incite hatred, violence or call for the breaking of the law
  19. are not permitted to encourage, glorify or promote any acts of terrorism including individuals, groups or harmony
  20. must not spread hatred and intolerance in the community and thus aid in disrupting social and community harmony
  21. must seek to avoid insulting other faiths or groups, within a framework of positive debate and challenge
  22. are not permitted to raise or gather funds for any external organisation or cause without express permission of the Director of the School.
  23. The staff member booking the speaker is responsible for checking all external speakers’ details, group links and other connections including: any links with extremist or terrorist organisations; has previously spoken at another institution on a topic that has caused fear or intimidation; is accepted in mainstream as being highly controversial; is likely to cause harm to a specific group of staff and students; has links to any person or group that has been connected with any controversy of a negative or positive nature; has a significant profile and may attract a following that could create crowd control and health and safety issues and is from a political party during an election period.
  24. In complying with the Prevent Duty PFSTA will not:
  25. Provide a platform for any proscribed terrorist organisation or encourage terrorism in any way
  26. Allow gender segregation at any event.
  27. If the booker suspects that the external speaker has extremist or terrorist links, he/she must inform the Chief Operating Officer who will inform the external Prevent Coordinators and police.
  28. In order to promote balanced and respectful debate the Foundation will consider any of the following in order to mitigate any potential risk to the Foundation:
  29. having an independent chairperson to facilitate an event and make sure a range of viewpoints can be heard;
  30. filming events to deter the use of unlawful speech;
  31. have additional staff in place to provide security;
  32. ticketing an event to prevent non-student violent protest;
  33. reviewing any promotional materials before the event; or training staff on how to facilitate well-balanced debate.
  34. Permission to use Foundation premises for events will only be granted to staff who undertake to comply with instructions in relation to the location, arrangements for and conduct of such activities, including adequate stewarding and control of entry. The details of such arrangements are agreed in each individual case.
  35. Staff responsible for infringements of or departures from these procedures may be subject to Foundation disciplinary procedures.
  36. Staff members must follow the agreed protocol when using the Foundation’s brand for off-site events. All publicity using the Foundation’s name must be agreed by the Director of the School prior to its publication. No events shall be booked off campus in the Foundation’s name where an external speaker is present without the consent of the Director of the School.
  37. Staff and Student Training and Awareness
    1. PFSTA will ensure appropriate training for all relevant staff so that they can recognise those who are vulnerable of being drawn into terrorism and potential signs of radicalisation. It should include an explanation of how to handle appropriately and sensitively any concern that may emerge. PFSTA have been in contact with the FE/HE Regional Prevent Coordinator for London who has agreed to give training workshops and will consult with him about the relevant training needed. PFSTA will look to have workshops on Teams so that several staff members at different venues and those working from home can join. Workshops can also be recorded on Teams so that staff members who were unable to join could watch the video at a later date.**
    2. All members of staff should be aware of PFSTA’s responsibilities under the Prevent Duty. Members of PFSTA’s community who are concerned about a student or member of staff who might be at risk of being drawn into terrorism should report this to their line manager.**
    3. PFSTA works closely with the Student Representatives in ensuring that it provides excellent support for its students. Through regular contact with the Student Representatives via the Registrar PFSTA will ensure that students are consulted on an ongoing basis on how its Prevent Duty is implemented. There are several staff/student meetings such as the Student Forum, Course Board of Study, Research Degrees Committee and Academic Board. This policy will be included in the staff and student handbooks and the policy will be submitted for discussion at the staff/student meetings.**
  38. Pastoral Care and Faith Facilities
    1. PFSTA is a small institution so pastoral care is made available through various staff members. All students will have access to a personal tutor, student representative, Registrar and Director of the School.**
    2. PFSTA is aware of its responsibilities under The Equality Act 2010 and the inclusion of Religion and Belief as a protected characteristic. PFSTA is committed to providing opportunities for staff and students to balance their faith requirements with the competing demands of work and study.** PFSTA seeks to ensure that appropriate provision is made for those of any faith (or those without faith) to access appropriate

facilities for pastoral care and for religious purposes. The provision of adequate facilities to allow groups to observe their faith are an important element of PFSTA’s Prevent approach. The culturally diverse nature of the Foundation must be actively celebrated and promoted to counter the threat of radicalisation from external influences.**

  1. PFSTA has a dedicated prayer space on the top stairwell on the 4th floor, and if unavailable, students are also encouraged to pray in their studio spaces as they may wish.** The average number of students using the prayer spaces every year is around 6 or 7 students so students if they wish are encouraged to have a rota for use of the 4th floor. However, many of the students are comfortable to pray in the studio space. All PFSTA owned and managed facilities fall under the auspices of the health and safety policy and will be subject to the usual requirements including no-smoking, adherence to evacuation procedures, fire risk assessments and so forth.

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  1. As outlined in the student handbook regulations, all students enrolling at the PFSTA agree to a range of standards of acceptable behaviour and this applies to their conduct in PFSTA’s prayer spaces.
  2. IT facilities and access to social media
    1. All computer usage must comply with the provisions of the Counter-Terrorism and Security Act 2015. The Foundation will take all action required by the Act and follow any guidance issued under section 29 of the Act to meet its duties. Such action may include, but not be limited to, monitoring computer usage and reporting any use which the Foundation considers necessary pursuant to the Act to the relevant authorities.
    2. As a student or member of staff, they may have a legitimate reason to access extremist or terrorist-related materials for teaching and research purposes. If researchers access such material without informing the Foundation or if they do not adequately protect the material or if they circulate it to others, this action or lack of action could be open to misinterpretation by the authorities. This may put the researcher at risk of investigation or prosecution under counter-terrorism legislation.
    3. In order to protect the researcher from such occurrence, they are advised to inform their tutor that they intend to access and/or store material and give an indication of the purpose of accessing/storing the material and the duration of that access/storage. The tutor will inform the IT Manager so that they have adequate information in case the Foundation is asked to explain access to particular websites by an external authority. The tutor will not take any other action but will retain information so the researcher is protected should they ever be questioned by authorities.
    4. Any material must be kept secure in the same way that they might protect sensitive personal information i.e. not storing on a personal computer or laptop, not using the material for any purpose other than the purpose for which it was collected and not sharing the material with others unnecessarily.
    5. PFSTA considers it unacceptable for its IT networks to be used in any way that supports, promotes or facilitates terrorism. PFSTA takes the challenges presented by social media very seriously. If any misuse of the Foundation’s branding on social media accounts is discovered, then action will be taken. The Foundation will block access to specific websites, network resources and IP addresses that provide or facilitate access to extremism materials in relation to the Foundation’s Prevent duty. There is an IT policy in

the student handbook which the Registrar has been working with the DfE Officer to expand and amend to include the use of social media and Prevent issues. The Foundation will look into filtering as a means of restricting access to harmful content, and will consider the use of filters as part of our overall strategy to prevent people from being drawn into terrorism.

  1. Communication
    1. PFSTA will not permit material supporting terrorism to be displayed within PFSTA premises and will remove any such material if it is found. Likewise, PFSTA will seek to ensure that its printed and electronic communications (including its website) do not contain or support terrorist material or material likely to encourage terrorism and will investigate immediately if any such instances are raised. Permission needs to be granted by the Director of the School and Registrar for students and staff to distribute leaflets both within the Foundation or handing out leaflets outside the Foundation premises.**
  2. Information Sharing
    1. PFSTA is aware of the Channel process and of the opportunities for informal and formal sharing of information with relevant authorities. PFSTA will use these when considering it is necessary and appropriate to do so in the interests of preventing people from being drawn into terrorism. Information sharing will only take place with external authorities when this is consistent with the provisions of the Data Protection Act and does not amount to an agreement to share personal data on anything other than a needs based and case by case basis.
  3. Academic Freedom
    1. As set out in PFSTA’s Academic Freedom Policy, the ability of students and staff to research, teach and debate any topic will not normally be fettered unless, on a case by case basis, a specific threat is identified.
  4. Related Policies and Procedures
    1. The following policies and procedures in the staff handbook and the student handbook are related to the Prevent Policy:
  5. IT Policy & Social Media Policy
  6. Academic Freedom
  7. Freedom of Speech

14,2 As this policy has now been approved, this policy will be included in the staff and student handbooks for 2020.

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