1. Introduction
1.1 Purpose
The Institution is required under the Counter-Terrorism and Security Act 2015 to ‘have due regard to the need to prevent people from being drawn into terrorism’. Under section 29, it must have regard to guidance issued by the Home Secretary. The Prevent Duty Guidance for Higher Education Institutions in England and Wales came into effect on 18 September 2015 following approval by Parliament. This Policy outlines our responsibilities and practice under the Prevent Duty.
1.2 Scope
The St George’s, University of London Prevent Policy applies to:
- All staff whose normal place of work is on the Institution’s premises and those working remotely
- All registered students of the Institution (whether on campus or learning remotely)
- St George’s, University of London Students’ Union (SGSU) and associated sabbatical officers
- Activities of the Institution’s staff and students taking place away from the Institution’s premises (and online) fall within the policy’s scope if the activities are perceived to be affiliated with the Institution e.g. through funding or branding.
2. Roles and responsibilities
2.1 The Council has overall responsibility for ensuring that the Institution is showing due regard to the Prevent Duty and for signing off St George’s, University of London’s (SGUL) annual Prevent Report that is submitted to the Office for Students (OfS) as part of the annual accountability statement.
2.2 The Institution’s named Prevent Lead is the Deputy Chief Operating Officer. The Deputy COO works closely with the Dean for Student Welfare and Support who is the Academic Lead for Prevent.
2.3 The Campus Good Relations Group (CGRG) are responsible for ensuring that the Institution is compliant with the Prevent Duty. The Group reviews the Institution’s Prevent Policy on an annual basis and submits to the Executive Board to approve and recommend to Council for approval. The Executive Board will report to Council on an annual basis.
2.4 The Institution’s Prevent Panel are responsible for reviewing concerns raised against students regarding Prevent and deciding whether or not to refer this concern to Channel1. The Panel shall consist of the Deputy COO and the Dean for Student Welfare and Support, with the ability to seek advice from the CGRG.
2.5 All staff should be aware of the Institution’s responsibility under the Act and the measures employed to comply with the Prevent Duty.
2.6 The Institution’s Prevent Lead and/or Prevent Administrator have a duty to notify the Office for Students as soon as possible of: any significant changes of circumstances affecting the provider’s Prevent responsibilities (such as a change in Prevent Lead or changes to core policies); or any Prevent-related serious incidents.
3. Policy and procedure
3.1 Identification, Support and Referral / Raising Concerns
If any member of staff or of the student body has a concern that a student has been radicalised, or is in the process of being radicalised, they should report this to the Dean for Student Welfare and Support in the first instance. In the absence of the Dean for Student Welfare and Support, the Deputy Dean of Students or the Personal Tutor Coordinator should be contacted. The diagram below shows the process following the identification of a concern regarding radicalisation.
3.2 Staff Training
In compliance with the Prevent Duty, the Institution provides Prevent training to all staff as good practice, but ensures that key staff, which in this context SGUL defines as staff with welfare responsibilities (such as Personal Tutors and Student Services Staff), have mandatory training. SGUL is also committed to ensuring that Senior Leadership Staff and those involved in the Prevent Policy undertake Prevent Training This includes, but is not limited to: Council, the Vice Chancellor’s Advisory Group, Campus Good Relations Group, and SGSU staff and sabbatical officers.
Compliance with completing training (initial, and refresher every two years) amongst these groups is monitored by the Prevent Administrator, and reported termly to the Prevent Lead who will report this to the CGRG. Training is provided in an online format via the Learning Management System ‘MyTraining’.
The online training module is included in the Institution’s induction training package and all staff members are required to complete this.
3.3 Events and External Speakers and Visitors
The Institution’s duty to secure freedom of speech within the law (as per Section 43 of the Education (No. 2) Act 1986), must be balanced with the Institution’s responsibilities under Prevent Duty to prevent people within its community from being drawn into terrorism. The Institution holds an “Events and External Speaker and Visitor Policy” which facilitates this balance.
This policy is hosted on the SGUL and SGSU websites.
3.4 IT Networks
The Institution’s IT Conditions of Use Policy and the IT Conditions of Use: guidance on core regulations, apply to use of all IT facilities and reflect the institutions responsibilities under the Prevent Duty. These documents are reviewed and approved by the Executive Board.
The Institution does not apply web filtering but the IT system is in “Monitor mode” whereby access is logged. Only instances where there is a cause for concern, will reports be generated from the logs and shared with the appropriate person for further investigation. Detail of the individuals authorised to release such information are given in the Information Sharing Policy for Security-related Data.
Where legal and with the appropriate ethical approval, the Institution has procedures to approve and manage valid activities involving the creation, access or storing of sensitive material for valid research purposes. Such access requests should be discussed with the Joint Research and Enterprise Service in the first instance.
3.5 Risk Assessment and Action Plan
In compliance with the Prevent Duty, the Institution holds a “Prevent Risk Register” by way of a risk assessment and action plan for the risk of our students bring drawn into terrorism. This document is maintained by and reported to the CGRG.
3.6 Faith Facilities
The Institution has a diverse community and both the Institution and SGSU is committed to creating a campus environment characterised by good relations between all its staff and students and to the promotion of tolerance, mutual understanding and inter-faith dialogue. Integration between all faith groups is encouraged through the multi-faith and quiet contemplation room. This is an onsite space which can be booked and used by any students and staff, of faith or not, to observe prayers or have some quiet time. The Protocol for the multi-faith and quiet contemplation room can be found on the SGUL and SGSU websites.
As per the Protocol, any external guests must be formally invited and will be subject to web and other security checks. Any external speakers are required to abide by the Institution’s Events and External Speaker Policy.
4. Related policies
Events and External Speakers and Visitors Policy
IT Conditions of Use Policy
Information Sharing Policy for Security-related Data
Protocol for the multi-faith and quiet contemplation room
1 Channel is a government programme which focuses on providing support at an early stage to people who are identified as being vulnerable to being drawn into terrorism.