1. Purpose and Scope

1.1 Purpose

1.1.1 Our policy sets out how the University is responding to its statutory duty to due regard to the need to prevent people from being drawn into terrorism.

1.1.2 In implementing this duty, we are also conscious of our commitments to free speech, academic freedom, human and equal rights, and the appropriate management of information.

1.1.3 The University 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: England and Wales (2003) is statutory guidance, which was issued on 7 September 2023 under Section 29 of the Counter-Terrorism and Security Act 2015 and came into force in December 2023. It replaces the 2015 guidance which came into force in July 2015.

The aim of Prevent is to stop people becoming terrorists or supporting terrorism.

The objectives of Prevent are to:

• tackle the ideological cause of terrorism
• intervene early to support people susceptible to radicalisation
• enable people who have already engaged in terrorism to disengage and rehabilitate

This Policy sets out how we are complying with the duty.

1.2 Scope

1.2.1 This Prevent Policy applies to all staff, students and other members of the University, and those working for or with the University. (In the context of the Policy, the term students is intended to include apprentices.) In addition, the policy highlights specific duties required of identified individuals and bodies within the University.

2. Definitions

2.1 This Glossary of Terms sets out the terms relevant to the Prevent duty guidance 2023.

3. Roles and Responsibility

3.1 Leadership

3.1.1 The University takes seriously at the highest levels the need to prevent terrorism occurring in our community. Our Policy has been approved by Council. The University Secretary & Registrar has been identified as the member of senior management responsible for ensuring that the University complies appropriately with the Prevent duty, in liaison with the DfE Prevent Regional Co-ordinator, South West and other key stakeholders within and beyond the University. An annual report on Prevent is made to the University Executive Board and Council.

3.2 University Executive Board and Council

3.2.1 The University Executive Board is responsible for providing Council with assurance of the University’s compliance with the Prevent duty. Council is responsible for approving the Prevent Policy and for approving the University’s annual Prevent Monitoring Accountability and Data Return to the Office for Students in compliance with the ongoing conditions of the University’s registration.

3.3 Members of the University Community

3.3.1 All members of the University community should be aware of the University’s responsibilities under the Prevent duty and of the measures set out above to comply with it. Members of the University community who are concerned about a student who might be at risk of being drawn into terrorism should report this to the Director of Student Support and Safeguarding. Concerns about members of staff who might be at risk of being drawn into terrorism should be reported to the Deputy Director of Human Resources.

4. Prevent Policy

4.1 Approach

4.1.1 The University welcomes the Government’s intention that the Prevent duty is implemented ‘in a proportionate and risk-based way’. Our approach has been to embed our legal responsibilities wherever appropriate as part of our framework of policies and procedures, which we consider to be the best way of ensuring a joined-up approach. In doing this we actively involve the Students’ Union and the campus trade unions and will continue to consult them should any changes to this Policy be required in the future.

We take seriously our responsibility to ensure the safety and wellbeing of students, staff the wider community and as part of this would wish to do all that we can to prevent any member of the University community from being drawn into terrorism. We also value the principles of academic freedom and freedom of speech and have a statutory duty to protect them under the Higher Education (Freedom of Speech) Act 2023.

4.2 Risk Assessment and Action Plan

4.2.1 As required by the Prevent duty, we carry out assessments of the risk of our students and staff being drawn into terrorism. This risk assessment is reviewed at least annually by the University Executive Board. Where any significant risk is identified we will consider what action might mitigate the impact/likelihood of that risk crystallising, and if necessary include it in the University’s Prevent Action Plan

4.3 External Speakers

4.3.1 The University’s Code of Practice on Freedom of Speech and Academic Freedom and Regulation 18 (Freedom of Expression) fulfil the requirement in the Prevent duty for universities to have policies and procedures in place for the management of external speakers and events on campus and use of the University’s premises. It sets out how we will ensure that we meet the different legal requirements on us, not least the duty under the Higher Education (Freedom of Speech) Act 2023 to secure freedom of speech within the law. Under the Code of Practice and Regulation 18, where the views expressed constitute views that risk drawing people into terrorism, or are shared by terrorist groups, permission must be sought by the staff or student organiser from the University Officer authorised by Council to act on its behalf (see Regulation 18) . Due diligence is carried out where required and we will share information with other institutions if appropriate about any particularly problematic event that comes within the remit of Prevent. Those undertaking the due diligence on external speakers will receive appropriate training.

4.3.2 In complying with the Prevent duty the University will not:

• provide a platform for any proscribed terrorist groups or organisations or encourage terrorism in any way;

• allow gender segregation at any event.

4.3.3 In conjunction with the University’s Code of Practice, the Students’ Union has its own complementary procedures in place in relation to events organised by its societies where external speakers will be participating.

4.4 Security Sensitive Research

4.4.1 The University recognises that the research and study of terrorism is valid and valuable, and that staff and students should be able to undertake this without risk of prejudice. It is therefore acknowledged that certain staff and students will have need to access material which supports terrorism as part of their work. In such cases it is incumbent on the responsible member of academic staff to ensure via the University’s normal ethical review processes that material is only accessed that is appropriate for the research or other work being carried out and that its use will not encourage terrorism in any way. This may include the use of an electronic and/or physical ‘safe room’ (as is already required by some funders for some security-sensitive research). For the protection of the individual and the University, access to security sensitive information is registered in advance using the University’s ethics review process.

4.5 Staff Training

4.5.1 The University has developed a Prevent Training Plan which was approved by the University Executive Board in May 2023.

Our approach is to support vulnerable students and staff in whatever circumstance they find themselves, recognising that radicalisation could occasionally be occurring when certain behaviour is manifest, but that other explanations will usually apply. For this reason, our approach to Prevent is embedded in our broader Safeguarding Policy. The aim of the Prevent Training Plan is to ensure that all staff know how to escalate concerns where they have concerns that staff or students may be at risk of radicalisation.

4.6 Pastoral Care

4.6.1 Pastoral care is available to students in a variety of ways. Specialist support is provided through Student Support and Safeguarding. The University’s Student Support Service offers a range of support services that students can access if they need support and guidance, including emotional or wellbeing support, counselling and mental health, disability support, money management and international student advice.

Undergraduates and taught postgraduate students are assigned and Academic Advisor when they join the University.

The Students' Union provides welfare support through its Advice and Representation Centre.

4.7 Faith Facilities

4.7.1 The University 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 Chaplaincy Centre on campus offers support for people of all faiths and none. There is a chapel within the Chaplaincy Centre. The University also has a Muslim Prayer Room, a Hindu faith space and space for its Sikh and Jewish communities. Our procedures for accessing prayer spaces on campus are available via the Chaplaincy Centre.

4.7.2 The University of Bath Interfaith Forum (UBIF) is a public forum open to staff and students of different faiths.

4.8 Information Sharing

4.8.1 The University is aware of the Channel process and of the opportunities for informal and formal sharing of information with relevant authorities. We will use these when we consider 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 relevant data protection legislation.

4.9 IT Networks

4.9.1 We consider it unacceptable for our IT networks to be used in any way that supports, promotes or facilitates terrorism. We have referenced Prevent in our IT Acceptable Use Policy and will keep under regular review the possible use of filters as a means of restricting access to content covered by the Prevent duty as part of our risk assessment process and in discussion with other universities. Social media services provide avenues for the distribution and accessing of extremist material, and the University takes the challenges presented by social media very seriously. If any misuse of the University’s branding on social media accounts is discovered then action will be taken in accordance with the terms and conditions of the relevant platform.

4.10 Communications

4.10.1 We will not permit material supporting terrorism to be displayed within University premises and will remove any such material if it is found. Likewise, we will seek to ensure that the University’s 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. It is acknowledged that there will be legitimate reasons to display materials relating to terrorism as part of legitimate teaching and research activities, and this should be declared under the process described in paragraph 4.4.1 above.

4.10.2 We will ensure key staff are familiar with organisations that the government has proscribed and the symbols used by proscribed organisations.

4.11 Students' Union

4.11.1 The University works closely with the Students’ Union in ensuring that we provide excellent support to our students. This includes the various matters covered by this Policy. Students’ Union staff [and Officers] will participate in the Prevent training being provided by the University and are very aware of their duties as charitable bodies. There is close collaboration with the Students’ Union in relation to any controversial event proposed by one of its societies. Through regular contact with the Students’ Union we will ensure that students are consulted on an ongoing basis on how we are implementing the Prevent duty. Information for students about organising an event that involves an external speaker or an event which may be controversial is available on the Students’ Union and University websites.

5. Related Policies and Procedures

5.1 The following policies and procedures are related to the Prevent Policy.

• Safeguarding Policy
• Code of Practice on Freedom of Speech and Academic Freedom
• Regulation 18, Freedom of Expression
• Register of need to access material which supports terrorism
• Ethics Review Process
• Supporting Students in Distress Guidance
• IT Acceptable Use Policy
• Regulation 10.3, Computing Facilities
• IT Security Best Practice

6. Document control information