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Preventing and Responding to Student Harassment And Sexual Misconduct

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  4. Preventing and Responding to Student Harassment And Sexual Misconduct

This webpage summarises LSBU’s policies and procedures relating to the preventing of and response to student Harassment and Sexual Misconduct, including intimate personal relationships between staff members and students.

This webpage is the ‘single comprehensive source of information’ required by the Office for Students.

What is harassment & sexual misconduct?

Harassment is defined by the law in:

The Protection from Harassment Act 1997 which defines harassment as a course of conduct (i.e. two or more instances of verbal or non-verbal conduct and/or speech) which alarm or cause distress, which the person knows or ought to know amounts to harassment.

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The Equality Act 2010 which says that a person harasses another if they engage in unwanted behaviour related to a relevant protected characteristic (age, disability, gender reassignment, race, religion or belief, sex, sexual orientation) and the behaviour has the purpose or effect of violating the other person's dignity, or creating an intimidating, hostile, degrading, humiliating or offensive environment for that person.

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Examples of behaviour that is unacceptable include:

  • derogatory or discriminatory jokes, comments, nicknames or “banter” based on someone’s protected characteristic
  • pestering, spying or stalking, including following, monitoring, watching or spying on someone, in person or online
  • intimidating, coercive or threatening actions and behaviour, including shouting, screaming or swearing at someone, and invasion of personal space
  • isolating, ostracising or deliberately excluding someone
  • physical assault or threats of physical assault

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Not all behaviour that some may consider offensive would be considered harassment, particularly when balanced against the right to freedom of speech within the law, academic freedom and tolerance for controversial views in educational contexts or environments.

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For example, it is unlikely but not impossible that the following would be considered to amount to harassment even if experienced as deeply offensive:

  • course materials, including but not limited to books, videos, sound recordings, and pictures
  • statements made and views expressed by a person as part of teaching, research or discussions made about any subject matter which is connected to course content
  • lawful views expressed by a speaker at an event or debate within the University setting.

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Support is available to students who feel offended or distressed by incidents, regardless of whether they would be considered harassment. Students are encouraged to tell us about any incident they are concerned about, regardless of whether the incident is formally reported for investigation or whether any investigation finds that the incident amounts to harassment. See the ‘support available’ section for more information.

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Sexual Misconduct is a broad term that encompasses any unwanted or attempted unwanted behaviour of a sexual nature. Sexual misconduct can be committed by a person of any gender, and it can occur between people of the same or different genders. It can occur between strangers or acquaintances, including people involved in an intimate or sexual relationship.

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Examples of behaviours that are unacceptable include but are not limited to:

  • Rape or threats of rape
  • Sexual Assault or threats of sexual assault
  • Engaging or attempting to engage in any non-consensual sexual acts including physical, verbal or online conduct of a sexual nature
  • Breach of the Staff - Students Intimate Relationship Policy

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You can find further information on myAccount:

And on Report + Support:

Staff and Student Relationships

To ensure appropriate conduct between LSBU staff and students, we require transparency, accountability, and strict adherence to ethical standards, as described in the Staff – Students Relationship Policy.

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Key definitions:

Intimate Relationship: A relationship that includes, or has the potential to include, romantic, sexual, or deeply personal connections between individuals. This encompasses dating, cohabitation, sexual relationships, or any other close personal involvement that may compromise professional boundaries

Close Personal Relationship: A relationship that goes beyond professional or academic interactions, including familial or financial ties that may influence decision-making or create conflicts of interest. This is likely to include after-hours meetings either on or off campus, dining out, having beverages together or making suggestions for the same.

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Strictly Forbidden Relationships

Any intimate relationship between a staff member and a student is strictly forbidden if the student is:

  • Under 18 years of age
  • Over 18 years of age but considered vulnerable or at risk

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Mandatory Declarations (for permitted relationships)

Any close personal relationships or intimate relationships between LSBU staff and students are strongly discouraged. Any such relationship that already exists, is developing or is likely to develop, must be declared by the staff member involved to the Senior Business Partner. LSBU will ensure that in these situations, the staff member has no professional responsibility for the student.

For clarity, a relationship that has any of the following characteristics must be declared:

  • Any form of dependence, whether emotional, practical, financial or otherwise, and whether the student appears dependent on the member of staff
  • Favouritism towards any student (which might include, for example, preferential treatment in assessment or access to opportunities)
  • Any romantic or sexual conduct, including dating, living together, and any form of sexual relationship

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If a close personal or intimate relationship already exists before both people are members of the LSBU community, the staff member must disclose this. Disclosure must happen either when the staff member begins their employment, or when the student enrols, depending on which person joins the institution second.

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Reporting Inappropriate Conduct

Any staff member whoobserves or is subjected to inappropriate behaviour (e.g. flirtation or suggestions of a relationship) must report it immediately to the senior Business Partner.

If a student has a concern about inappropriate behaviour in breach of this policy, or is concerned about a misuse of power, authority or a conflict of interest, they are encouraged to tell LSBU. See ‘Reporting Harassment and Sexual Misconduct’ section.

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Consequences

For staff, failure to disclose a relationship or engaging in prohibited conduct is likely to lead to disciplinary action, which could include dismissal.

Students will never face disciplinary consequences for reporting a genuine concern, or for engaging in a close personal or intimate relationship with a member of staff that is consensual.

Reporting Harassment and Sexual Misconduct to LSBU

A)There are different ways of informally and formally reporting an incident of Harassment or Sexual Misconduct to LSBU and these are outlined in full in the Student-Harassment-Bullying-and-Sexual-Misconduct Policy-2023

Informal reporting – this means telling us something happened and potentially accessing support, but not requesting an investigation by LSBU.

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  1. Report + Support

    Anyone can informally report an incident of Harassment, Sexual Misconduct, Hate, Bullying, Domestic Violence or Discrimination via Report + Support.

    You can report on behalf of yourself or someone else.

    If you report on behalf of yourself, you can choose to report anonymously or to include your contact information. If you include your contact information, you will be offered specialist support from LSBU. More information about this is in the below ‘support available’ section.

    If you report anonymously, we won’t be able to offer any individual support because we won’t know who you are, but we will monitor all reports for trends, and take measures to respond where appropriate, for example by providing training or increasing security.

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  1. Informing a member of staff

If you inform a member of staff at LSBU about a relevant incident (including in person, via email, by raising an enquiry on MyAccount, or any other way), the staff member will signpost you to Report & Support where you can log the incident and/or access information about support available.

The staff member will be required to log the incident too, but can do this without your personal details if you don’t want to access further support and if there isn’t an immediate risk to anyone’s safety. If there is an immediate risk, the staff member will be required to contact emergency services and/or share information with the Mental Health & Wellbeing Team to ensure there is a risk assessment and that all parties involved have access to appropriate support.

Formal Reporting – this means requesting that LSBU investigates what happened.

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If a member of the LSBU community behaves in a way that you believe is Harassment or Sexual Misconduct and you want LSBU to investigate it, you can formally report that person using the following procedures:

A) Formally reporting a student

  1. Select ‘My Enquiries and Requests’
  1. Select ‘Add new enquiry’
  1. Select ‘General enquiry’
  1. Choose ‘Report an incident (Student Disciplinary)’ as the topic.
  1. Fill in the form with all the relevant information, then press ‘Submit.’

These formal reports will be reviewed in line with the Student Disciplinary Procedure.

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B) Formally reporting a member of staff, third party, or visitor

  1. Select ‘My Enquiries and Requests’
  1. Select ‘Add new enquiry
  1. Select ‘Complaint’ as the nature of enquiry
  1. Fill in the form with all the relevant information, then press ‘Submit.’
  1. These formal reports will be dealt with as a complaint under the Student Complaints Procedure. Where the Reported Party is a member of staff this may include referral to, and investigation under, the Staff Disciplinary Procedure.

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If you have accessed support from an SLO (see section below’, they can submit a formal report on your behalf if you wish for them to do so.

Support available to LSBU students

Students who have experienced Harassment or Sexual Misconduct at any time in their lives can access support and advice from LSBU.

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Online information:

Support information is available on the LSBU Report and Support pages and on myAccount, myLSBU and the LSBU website. You don’t need to log an incident in order to access the information on any of these platforms.

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Specialist support:

Student Liaison Officers (SLOs) are trained members of LSBU staff, usually based in Student Services, who can provide students a safe and confidential space for informal reporting, as well as information about options for formal reporting and accessing additional support.

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SLOs will never pressure you or judge you. By accessing this support, you are not committing yourself to any course of action. You can access SLO support regardless of whether you choose to make a Formal Report.

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SLO support is also available to students who are reported for Harassment or Sexual Misconduct. This will always be a different SLO to that of the reporting student.

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You can access SLO support by:

  1. logging an incident on Report + Support and including your contact details. This information will be received directly by and only by the Mental Health & Wellbeing Team where the SLOs are based.
  1. raising a ‘wellbeing’ enquiry on myAccount – this will be reviewed by the Student Life Helpdesk and passed to the Mental Health & Wellbeing Team. You do not need to include any details about the incident and can simply request an SLO appointment in the enquiry.
  1. emailing studentwellbeing@lsbu.ac.uk – this will be reviewed by the Student Life Helpdesk and passed to the Mental Health & Wellbeing Team. You do not need to include any details about the incident and can simply request an SLO appointment in the enquiry.

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SLOs offer:

  • Priority, non-emergency, one-to-one, appointment-based support in person, by telephone or on MS Teams.
  • Secure and accurate record keeping
  • Appropriate and accurate information about external and internal reporting options and support options
  • Practical support to maximise your chances of remaining and succeeding in study. This might include:
    • A supporting statement which can be used for Extenuating Circumstances claims, so that you don’t need to re-explain or disclose confidential or traumatising information to another team
    • Support to get reasonable adjustments to study and assessments put in place you having to re-explain or disclose confidential or traumatising information to another team.
  • Risk assessment and management, escalating where necessary if action needs to be taken to reduce the risk of further harm occurring (see section 7 and 15).
  • Support during an internal investigation under the Student Disciplinary Procedure or the Staff Disciplinary Procedure
  • As requested by you the student, referrals to, and if required and deemed appropriate, payment for, specialist external and/or therapeutic support
  • As requested by you the student, liaison with:
    • Individual members of the course team
    • Relevant individuals regarding suitability of placement location
    • Halls of residences
    • Specialist external services, for example an ISVA (Independent Sexual Violence Adviser), a SOLO (Sexual Offences Liaison Officer) or a Police Victim Care Officer, to ensure that internal and external support are aligned (without duplicating or replacing external specialist support)

How we handle information

We will always handle information we receive or obtain in connection with potential or actual incidents of Harassment or Sexual Misconduct sensitively and fairly.

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We recognise the importance of privacy and will only share information on a need-to-know basis. Normally, information will only be shared with your consent. In cases where information needs to be shared without your consent, we will always seek to inform you first. Times when information may need to be shared include:

  • To ensure a formal report can be appropriately considered and investigated;
  • To ensure that any students who have reported an experience or who are alleged to have committed misconduct receive appropriate support;
  • To safeguard members of the University community;
  • To comply with our duties and/or the law

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All personal data is recorded and held in accordance with current data protection legislation and retained in line with the University’s Record Retention Schedule. Full details about information sharing can be found in the below policies:

  • Staff – Student Intimate Relationship Policy

Investigations at LSBU

We always strive to ensure investigations undertaken and decisions made by LSBU are credible and fair. Full details of these processes can be found in the LSBU Staff Disciplinary Policy and Procedure October 2023 and the Student Disciplinary Procedure.

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Any student who is directly affected by a decision made following a Formal Report of alleged harassment or sexual misconduct will be provided with relevant information about the decision and the reasons for it.  This information could include:

  • what steps were taken to investigate the Formal Report;
  • a summary or high-level description of the evidence made available to the decision-maker(s), or a copy of that evidence;
  • who made the decision(s);
  • what measures may be put in place to prevent the issue that led to the Formal Report happening again.

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The University will never use non-disclosure agreements (NDAs).

How we ensure students understand our approach

    • You are sent a link to this web-page and asked to read it as part of your mandatory enrolment process each year
    • We tell you about our approach during your first-year mandatory induction talks
    • During the 25-26 Academic Year, students who don’t attend the in-person workshop will be enrolled on an e-learning course.  We will be evaluating the efficacy of the e-learning during the 25-26 academic year.

Training for staff

We are currently developing an e-learning for all staff which will ensure they understand how to respond to student disclosures of Harassment or Sexual Misconduct. All current staff will need to complete this by 31st December 2025 and then again every 2 years as part of the ongoing compulsory training. All new staff will complete the e-learning during probation and then again every 2 years.

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Student Liaison Officers have all completed the Sexual Violence Liaison Officer Development Programme with Lime Culture.

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We are currently reviewing the training for members of staff involved in investigating incidents of Harassment & Sexual Misconduct and are committed to ensuring they receive specialist training as soon as is practically possible.

Other steps to protect students

We are committed to continuing to evaluate and develop our approach to preventing and addressing Harassment and Sexual Misconduct. This includes:

  • Using available data, including informal and formal reports, to understand trends and adapt our approach accordingly
  • Utilising relevant data to increase visibility of our approach and the impact. For example, we will circulate information internally about the percentage of students who report anonymously vs with their contact details; the percentage of students who are offered support after disclosing an incident; and the percentage of students who take up the offer of SLO support.
  • Evaluating the training delivered to students and staff and updating them where appropriate
  • Consulting with our Student Wellbeing Panel and the Students’ Union to inform ongoing developments to our approach

In this section

  • Preventing and Responding to Student Harassment And Sexual Misconduct
  • Prevent