3.6 Disclosure

Disclosure, for the purposes of this Policy and Procedure, involves an individual choosing to tell someone about their experience of sexual harassment or sexual misconduct.

3.7 Discrimination

The Equality Act 2010 states that it is against the law to treat any person unfairly or less favourably on the basis of a protected characteristic. The 9 protected characteristics are: age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race (including ethnic origin, nationality and colour), religion or belief, sex and sexual orientation.

3.8 Grooming

Grooming can be defined as a gradual process that someone in a position of power uses to manipulate someone to do things they may not be comfortable with and to make them less likely to reject or report abusive behaviour. Grooming will initially start as befriending someone and making them feel special and may result in sexual abuse and/or exploitation.

3.9 Harassment

Harassment under the Equality Act 2010 is unwanted conduct related to a relevant protected characteristic that has the purpose or effect of violating a person’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for that person. The unwanted conduct can be physical, verbal or non-verbal. See appendix 1 for specific examples.

p style=”color: #000000; font-size: 16px; font-weight: 500; font-family: Roboto;”>3.10 Reporting

Reporting is the sharing of information with a staff member of the College regarding an incident of bullying, harassment or sexual misconduct experienced by that individual for the purposes of initiating the investigation process set out in this Policy and the accompanying procedure.

3.11 Reported Party

The Reported Party is the person(s) whose behaviour it is alleged amounted to an incident of sexual harassment or misconduct.

3.12 Reporting Party

The Reporting Party is the person(s) who witnessed or is the subject of the alleged incident of sexual harassment or misconduct.

3.13 Sexual misconduct

Sexual misconduct is a form of harassment involving unwanted conduct of a sexual nature. It includes any behaviour, such as verbal, non-verbal, physical, or digital that is sexual in nature and violates a person’s dignity or creates an intimidating, hostile, degrading, humiliating, or offensive environment It can include:

• sexual harassment
• sexual harassment through digital channels
• sexual violence
• Intimate partner violence
• sexual assault
•  rape
•  distributing private and personal explicit images or video footage of an individual without their consent
•  grooming
•  coercion or bullying with sexual elements
•  sexual invitations and demands
•  sexual comments
•  sexual non-verbal communication
• creation of atmospheres of discomfort
• promised resources or advancement in exchange for sexual access See appendix 1 for specific examples.

3.14 Stalking

Following a person, watching or spying on them or forcing unwanted contact with the victim through any means, including social media. The effect of such behaviour is to curtail a victim’s freedom, leaving them feeling that they constantly have to be careful. In many cases, the conduct might appear innocent (if it were to be taken in isolation), but when carried out repeatedly, it may then cause significant alarm, harassment or distress to the victim.

3.15 Victimisation

Treating someone less favourably because they have made a claim or complaint of discrimination, or helped someone else to make a complaint (under the Equality Act), or made a disclosure (whistleblowing) under the Public Interest Disclosure Act 1998, or in either case the affected person is believed to have made or helped make, or is believed that they may make or help make, a complaint or disclosure.

4. Roles and Responsibilities

4.1 Institutional Commitment

The College is committed to promoting a culture of safety, dignity and mutual respect. The College recognises that preventing and addressing sexual harassment and misconduct requires shared responsibility, proactive leadership and transparent systems. The College will:

• Ensure that effective policies, procedures and safeguarding mechanisms are in place.
•  Provide training and resources to raise awareness and promote appropriate behaviour.
•  Offer responsive, trauma-informed support services.
•  Establish clear lines of accountability and oversight.

4.2 Responsibilities of Senior Leadership

Senior leaders (e.g. the Directors, Principal, Academic Board, Designated Safeguarding Lead – DSL):

• Set the tone for institutional values and lead by example.
• Ensure adequate funding and staffing of welfare, HR and safeguarding services.
• Monitor compliance with the policy and regulatory frameworks (e.g. OfS Condition E6).
• Receive and review anonymised data on sexual harassment and misconduct trends.

4.3 Responsibilities of HR

HR plays a central role in:

• Supporting staff who experience or are accused of misconduct.
• Supporting staff who experience or are accused of misconduct.
• Supporting staff who experience or are accused of misconduct.
• Supporting staff who experience or are accused of misconduct.
• Ensuring compliance with employment law and disciplinary procedures.

4.4 Responsibilities of the DSL

The DSL has oversight of safeguarding issues, including sexual harassment and misconduct. Responsibilities include:

• Triaging student cases and conducting or overseeing investigations.
• Coordinating risk assessments and interim protection measures
• Liaising with external agencies, including police and university partners.
• Advising on complex safeguarding situations and ensuring consistency

4.5 Responsibilities of Student Welfare and Support Team

The team provide the front line of student-facing support. They must:

• Receive and respond to disclosures in a compassionate and timely manner.
• Guide students through informal and formal reporting options.
• Support awareness training and induction.
• Signpost students to internal and external support (e.g. counselling, legal aid).
• Monitor opt-out requests for training and alternative delivery.

4.6 Responsibilities of Line Managers and Academic Supervisors

Managers and supervisors are responsible for:

• Ensuring staff and students under their remit are aware of the policy.
• Ensuring staff and students under their remit are aware of the policy.
• Ensuring staff and students under their remit are aware of the policy.

4.7 Responsibilities of All Staff and Students

Every individual has a duty to:

• Actively contribute to a safe and respectful environment.
• Complete all mandatory training.
• Model appropriate, professional behaviour.
•  Report incidents or concerns promptly.
• Support peers and colleagues who may be affected by misconduct.
• Disclose criminal convictions before employment or enrolment and during their time at the College.

4.8 Responsibilities of Partner Universities

For students on franchised programmes with partner universities:

• Lead formal investigations in serious cases.
• Provide mandatory training on sexual harassment and misconduct awareness to all their registered students
• Provide outcome updates where permitted.

5. Staff–Student Personal Relationships

5.1. Overview

This section sets out the College’s institutional policy stance on intimate personal relationships between staff and students. The College is committed to maintaining a professional, respectful and safe academic environment. To uphold the integrity of teaching, learning and student support, the College prohibits personal relationships of a romantic, sexual, or intimate nature between staff and students currently enrolled at the institution.

5.1.1 This stance is grounded in safeguarding principles and designed to prevent conflicts of interest, abuses of power, or the perception of preferential treatment. It applies regardless of age or consent.

The is part of the College’s wider safeguarding and misconduct framework and is included in the single comprehensive source of information available to students and staff.

5.2 Prohibited Conduct

Any romantic, sexual or intimate relationship between a staff member and a currently enrolled student is strictly prohibited.

This prohibition applies to all categories of staff (academic, administrative, temporary and visiting) and to all enrolled students.

5.3 Pre-Existing Relationships

5.3.1 Where a pre-existing relationship exists (e.g. a staff member’s partner enrolls as a student), the staff member must disclose this immediately to their line manager and HR.

5.3.2 HR will implement a formal conflict-of-interest management plan, which may include adjustments to teaching, assessment, supervision or reporting lines.

5.4 Breach of Policy

5.4.1 Any failure to declare a pre-existing relationship, or any attempt to conceal or misrepresent the nature of a relationship, will be treated as misconduct and subject to disciplinary action.

5.4.2 Allegations or disclosures of staff–student relationships will be investigated confidentially and sensitively by the HR department or the DSL, depending on the context. Investigations will follow safeguarding principles.

5.4.3 Students who knowingly engage in such a relationship may be referred to the Student Disciplinary Panel in accordance with the Student Code of Conduct.

5.5 Further Guidance

Guidance and support are available from HR, Student Welfare and Support Team, or the DSL.

This policy position will be communicated clearly during induction and embedded in ongoing staff and student training

6. Promoting a Safe and Respectful Environment

6.1 Mandatory Training Participation and Opt-Out Process

As part of the College’s duty to promote a safe and respectful academic environment, all students and staff are expected to complete mandatory training on sexual harassment and misconduct awareness.

6.2 While participation is mandatory, students can request to opt out under specific circumstances.

• Opt-out may be granted where the reason is deemed reasonable on personal, cultural, medical, or psychological grounds. Valid reasons may include: a prior traumatic experience related to the training content; cultural or religious sensitivities; diagnosed mental health conditions; accessibility issues or neurodiversity that necessitate a different delivery format
• Students who wish to opt out must complete and submit an Opt-Out Request Form to the Student Welfare and Support Team no later than five working days before the scheduled session.
•  Each request will be reviewed jointly by the DSL and the Head of Student Welfare and Support.
• Students will be provided with a minimum of 10 working days’ notice prior to any mandatory training session.

6.2.1 Alternative Briefing Requirement

Where an opt-out is approved, students are required to complete an alternative briefing, which ensures all students maintain an understanding of their rights, responsibilities and the institutional support available to them.

6.2.2 Non-participation without formal opt-out approval will be treated as a breach of institutional policy and subject to appropriate follow-up.

7. Procedure for Reporting and Investigation

7.1 Informal Resolutions

7.1.1 Overview

The College recognises that some individuals affected by Sexual harassment or misconduct may prefer to seek an informal resolution, particularly in cases where the behaviour is isolated, non-threatening, and not considered serious. Informal resolution is always voluntary, non-disciplinary, and led by the wishes of the person affected. Facilitated options will only proceed with informed consent from all involved parties and after safeguarding suitability is confirmed.
Informal resolution does not prevent the affected individual from choosing to submit a formal complaint later. The College will still be required to act, even if informal resolution is requested, if there are serious safeguarding concerns or a risk to others.

7.1.2 Options for Informal Resolution

Students and staff can initiate informal resolution through the following contact points:

Students: Personal Tutor, Student Welfare and Support Team, or DSL

Staff: Line Manager, Human Resources (HR), or trade union representative

Where appropriate, informal resolution may involve:

• A facilitated conversation or mediation between the parties.
• Clarification of boundaries and expectations.
• Issuing of a No Contact Agreement or mutual behaviour commitment.
•  In some cases, supported apologies or agreement to attend training or reflective learning.

The Student Welfare and Support Team and HR will support students and staff in identifying and arranging an appropriate pathway.

7.1.2.1 Individuals can access initial support or request informal resolution using multiple reporting channels maintained by the College, including:

• Online reporting forms (anonymous or named)
• Email to Student Welfare and Support Team
•  Safeguarding email contact
• Drop-in sessions with Welfare Officers (term time)
• Telephone support
• In-person meetings with designated staff

7.1.2.2 These options are listed in full on the single comprehensive source of information on the College website and are available to students and staff seeking informal advice or resolution without initiating a formal complaint.

7.1.3 Responding to Concerns about one’s own Behaviour

Where a student or staff member is informed that their behaviour has caused discomfort or could be perceived as bullying, harassment or sexual misconduct, they are expected to:

• Listen respectfully and without defensiveness.
• Acknowledge the feedback and reflect on its impact, regardless of intent.
•  Avoid retaliatory behaviour, including dismissive or minimising language.
•  Seek advice if unsure how to respond constructively.
• Where the concern appears serious, the individual receiving the feedback escalates the matter to their line manager or HR (staff), or their personal tutor or Student Welfare (students), to determine whether the matter should be moved into a formal process.

7.1.4 When Informal Resolution is Not Appropriate

Informal resolution is not suitable where the alleged behaviour includes:

• Sexual assault or criminal behaviour,
• Persistent, threatening or escalating harassment,
•  Power imbalances that may compromise fairness (e.g. staff–student relationships),
•  Safeguarding risks to the individual or others.

In such cases, the College will provide support and guidance to the discloser on accessing formal procedures and will act on its duty of care to escalate the matter accordingly.

7.2 Formal Complaint procedure

7.2.1 This procedure sets out how formal complaints regarding sexual harassment and misconduct are made and managed.

7.2.2 Student Reporting

Students who have experienced or witnessed sexual harassment or misconduct must report this to the Student Welfare and Support Team or DSL.

Students submit formal complaints via:

•  The secure online reporting form on the Single Source of Information on College website
•  Email to Student Welfare and Support Team
•  Direct contact with a member of the Student Welfare and Support Team
  Reports are triaged and risk-assessed by the Head of Student Welfare and Support and/or the DSL.

7.2.3 Staff Reporting

Staff report incidents of sexual harassment and misconduct using the secure online report form or, where relevant, safeguarding procedures. The following reporting options are available:

• Line Manager
•  Human Resources (HR)
•  DSL, for safeguarding concerns or when the reported party is a student
•  Online reporting form, accessible via the single comprehensive source of information on the College website.
•  Email reporting
•  In-person meetings, with trained HR, Welfare or Safeguarding Officers
•  Telephone support, via the confidential helpline

7.2.3.1 HR is responsible for identifying the correct policy route (grievance, misconduct, safeguarding), documenting the referral, and supporting the staff member throughout the process.

7.2.4 Partner University Escalation and Case Triage

All cases involving sexual harassment and misconduct are triaged by the College and managed as follows:

• Lower-level concerns, including those suitable for early intervention or informal resolution, are handled internally by the College in line with existing processes.
• Serious or complex cases are escalated to the relevant awarding partner (e.g. Leeds Trinity University and Plymouth Marjon University) and are investigated in accordance with their own policies and student conduct frameworks.
• Students will be clearly informed about who is handling their case and the applicable procedures.

7.2.5 Reports involving non-members of the College community are submitted to:

• Student Welfare and Support Team (students)
•  Line Manager or HR (staff)

The DSL or HR assess the complaint and engages relevant third parties, their organisations, College Security, or the police where necessary.

7.2.6 Complaints by Third Parties or the Public

Any third party or member of the public who experiences sexual harassment or misconduct by a College student or staff member during College activity, reports directly to the Principal.
Reports are submitted via email:
The email address is monitored by the Principal and DSL.
All third-party reports are referred to the appropriate process: disciplinary, safeguarding, or external investigation

7.2.7 Multiple Reporting Channels

The College ensures reporting is accessible, confidential and responsive through the following channels:

•  Secure online form (anonymous or named)
• Email
•  In-person reports via Personal Tutors, HR or Welfare Officers
•  Term-time drop-in sessions with trained welfare staff
•  Telephone helpline

All channels are available in the single comprehensive source of information on the College website.

7.3 Anonymous Reporting

7.3.1 Anonymous disclosures are submitted via a secure online form on the College website. No personal details are required unless voluntarily provided. Anonymous reports will not in themselves trigger proceedings, but they will inform risk assessments, environmental investigations, or safeguarding action where credible risks are identified.

7.3.2 Data will be monitored and utilised in annual institutional reviews to inform decision-making and continuous improvement and shared with university partners in accordance with their policies and procedures.

7.4 Safeguarding Considerations

Where the person affected is considered an adult at risk, the College has a statutory safeguarding duty. Such reports must be escalated immediately to the DSL, and the case will be handled in accordance with the College’s Safeguarding Policy.

7.5 Timeframes for Reporting

There is no time limit for reporting incidents. However, delayed reporting may affect the availability of evidence. Complaints will be managed under the policy in effect at the time of reporting.

7.6 Investigations and Timelines

7.6.1 In cases involving serious or complex allegations involving students registered with a partner university, the partner institution is responsible for conducting the formal investigation in accordance with its own policies. The College will cooperate fully and ensure alignment with the partner’s regulatory, safeguarding and procedural requirements.

7.6.2 All formal complaints of sexual harassment or misconduct are investigated in a fair, impartial, and timely manner, in line with the College’s commitment to safeguarding, natural justice and OfS Condition E6.

The investigation process follows these structured steps:

1. The case is assigned to a lead investigator based on the nature and parties involved. The DSL oversees student cases, while HR manages staff cases. Where appropriate.

2. The case lead reviews the complaint to confirm scope, assess safeguarding risks, determines interim protective measures and decides if referral to the partner university or external authorities (e.g. police) is necessary.

3. Both the Reporting and Responding Parties receive written confirmation of:

•  The scope of the complaint
• The name of the appointed investigator
•  The expected timeline and process

4. The investigator conducts interviews, collects witness statements, reviews written and digital evidence and compiles a report. Both parties may nominate witnesses and submit supporting evidence.

5. The report is reviewed by the appropriate decision-maker or panel (e.g. HR Manager or DSL). A determination is made on the balance of probabilities.

6. Both parties are informed of the outcome in writing. The Reporting Party is told whether the complaint was upheld and any protective actions. The Responding Party is informed of any sanctions imposed.

7. Either party may appeal within 10 working days of the decision. Grounds include procedural error, new material evidence, or a disproportionate outcome. Appeals are reviewed independently by staff with no prior involvement in the original decision or investigation.

7.6.3 Investigations will conclude within 30 working days of receipt of a formal complaint. Where this is not achievable, both parties will be informed of delays and provided with progress updates.

7.6.4 To ensure impartiality:

• Investigators and decision-makers must not have prior involvement in the case.
• All individuals involved must declare conflicts of interest.
•  Both parties may be accompanied to meetings by a support person.

7.7 Environmental Investigations

7.7.1 Where there are a number of reports concerning sexual harassment and misconduct, the College will conduct an environmental investigation with staff and/or students within a department or faculty to understand the behaviours in more detail, and identify and target appropriate support and interventions.

7.7.2 An environmental investigation will involve agreed terms of reference with the department, and interviews and/or focus groups with students and/or staff to ascertain the key concerns and possible solutions.

7.7.3 The introduction of environmental investigations is intended to ensure effective resolution of complaints and prevention of future unacceptable behaviours.

8. Support, Interim Measures and Protection Against Retaliation

8.1 Support Entitlement

The College is committed to providing comprehensive and timely support to all individuals affected by incidents of sexual harassment and misconduct. This includes:

• Reporting Parties (individuals who disclose or report an incident)
• Responding Parties (individuals accused of the behaviour)
• Third Parties (e.g. witnesses, bystanders, or those indirectly impacted)
  Support is available regardless of whether a formal complaint is submitted. All students, staff and visitors engaged in College-related activities are eligible for support services.

8.2 Access to Support Services

8.2.1 Information about support is available via the single comprehensive source of information. This includes:

• Mental health and counselling services
• Academic or workplace adjustments
•  Safeguarding referrals
•  Pastoral support or line manager guidance
•  Signposting to external organisations such as:
•  Rape Crisis
•  Revenge Porn
•  National Bullying Helpline
•  Mind
• The Survivors Trust
• SupportLine
• Samaritans
• NHS self-help Guides
• Victim Support
• Citizen’s Advice

8.2.2 Staff receiving a disclosure must respond sensitively, escalate concerns appropriately, and refer individuals to relevant support services.

8.3 Interim Measures and Risk Management

8.3.1 Where a formal complaint is submitted, or safeguarding concerns are identified, the College will convene an Interim Measures Panel (IMP) to:

• Assess risks and needs for all parties
• Put in place proportionate, protective measures to maintain safety, fairness, and continuity
• Recommend tailored interventions for Reporting and Responding Parties, as well as affected third parties

8.3.2 Measures include:

• No-contact agreements
• Adjustments to timetables, teaching or supervision
• Temporary changes to working
  environments
• Academic or welfare support
• Access to remote or anonymous counselling tools
• Temporary suspension (used only when necessary and proportionate)
• The IMP will be chaired by a senior manager or director. Membership will ensure:
• Appropriate expertise and impartiality
• Gender and ethnic diversity where practicable</li
• Completion of safeguarding, sexual misconduct and trauma-informed training.

8.3.3 Panel composition will be shared with both the Reporting and Responding Parties to ensure transparency and allow for any conflicts of interest to be raised. Third parties may be informed where appropriate and lawful.

8.3.4 All interim measures and associated risk assessments will be reviewed regularly and adapted as circumstances evolve. Affected individuals will be informed of changes and provided with reasons. All decisions will be managed in accordance with GDPR, safeguarding obligations and confidentiality protocols.

8.4 Protection Against Retaliation

8.4.1 The College strictly prohibits any form of retaliation against individuals who disclose, report, or support a report of sexual harassment or misconduct. This includes retaliation by staff, students, or third parties associated with the College.

8.4.2 Retaliation is defined as any adverse treatment or disadvantage suffered as a result of engaging in the reporting or investigation process. This includes, but is not limited to:

•  Academic or professional disadvantage
•  Exclusion from learning or social environments
• Verbal abuse, intimidation, or threats
• Pressure to withdraw a complaint or to remain silent
•  Negative treatment by peers, staff, or supervisors

8.4.3 The College will treat any such behaviour as a serious disciplinary matter. Allegations of retaliation will be investigated promptly and independently and will result in disciplinary action under the relevant student or staff conduct procedures.

8.4.4 Where there is a risk of retaliation, the College will implement protective measures, such as academic adjustments, no-contact directives, changes to timetables, or temporary separation of parties. These measures will be proportionate and reviewed regularly.

8.4.5 All students and staff are encouraged to report suspected retaliation to the Student Welfare and Support Team, DSL or HR. These reports will be handled sensitively and in accordance with the College’s safeguarding and investigation procedures.

8.5 Outcome of a formal complaint/disciplinary case

8.5.1 The Reporting Party will be told whether their complaint has been upheld or not, and whether the Reported Party has been dismissed or expelled.

8.5.2 If the complaint is not upheld or the Reported Party is not dismissed or expelled, information will be shared with the Reporting Party to minimise any adverse effects in accessing their work or study environment, where possible, but there may be limits to the information about the consequences to the Reported Party that can be shared with the Reporting Party.

8.5.3 Where the Reporting Party is told the outcome, they will be asked to respect confidentiality with regards to the outcome.

9. Police Investigations and Judicial Proceedings

9.1 Where criminal investigations and/or judicial proceedings are ongoing, or are likely to commence in respect of a disclosure or report, the College will continue its own investigation and any disciplinary action, subject to the circumstances of the case and police advice.

9.2 Where, following police advice or otherwise, the College decides not to undertake its own investigation until the case has concluded, the College reserves the right to review this decision and to initiate its own investigation and/or disciplinary action at a later stage in or on completion of the criminal investigation and/or judicial proceedings.

9.3 A decision by the Police or Crown Prosecution Service (or other law enforcement agency) to take no further action in relation to a criminal matter, or an acquittal at a trial, does not preclude or negate the outcome of the University’s investigation and/or disciplinary action. Where the trial has completely exonerated the subject of the complaint and it has been found that the Reporting Party has made a false or misleading complaint, the University may revisit any disciplinary sanction issued to the Reported Party and may consider disciplinary action against the Reporting Party.

9.4 An internal investigation is focused exclusively on whether a breach of this policy, and/or other applicable obligations or policies, has occurred. The internal process may therefore be considering different issues from a Police investigation or criminal prosecution. This is why it may, depending on the circumstances, be possible to proceed with an internal investigation at the same time as a criminal process.

9.5 Where a student or staff member is convicted of a criminal offence or accepts a Police caution in relation to behaviour that falls within the scope of the College’s policies, they must declare this to the College. The conviction/caution will be taken as conclusive evidence that the behaviour took place, and no further investigation shall be required by the College. Appropriate measures will be taken (if they have not already) under the respective Student Disciplinary Procedure and Staff Disciplinary Procedure.

9.6 Where the College is delivering higher education programmes on behalf of a partner university, and a criminal investigation or related disclosure involves a student enrolled on such a programme, the College will notify the partner university without delay. In accordance with the partnership agreement, the formal investigation and resolution of serious cases will be led by the partner university. The College will provide all necessary cooperation and support to ensure alignment with the partner’s policies, safeguarding duties and regulatory responsibilities.

10. Protection Against Misuse of the Policy

10.1 Victimisation and Non-Retaliation Assurance

For detailed guidance on the College’s prohibition against victimisation and retaliation, see Section 8.4 Protection Against Retaliation.

10.2 False or misleading complaints

Submitting a complaint that is not in good faith or providing false or misleading information in any investigation of complaints is prohibited. If a complaint is found to be false or misleading, it will be dealt with in accordance with the Student or Staff Disciplinary Procedures.

11. Safeguards for Academic Expression

11.1 The College upholds academic freedom as a core principle of higher education and recognises its legal obligation to protect lawful freedom of speech and academic expression under the Higher Education (Freedom of Speech) Act 2023.

11.2 Academic content or discussion, when relevant and delivered respectfully within the context of teaching, research, or scholarly debate, is presumed not to constitute harassment or sexual misconduct.

11.3 However, this presumption does not extend to content or delivery methods that:

• Are not directly relevant to the academic subject
•  Are delivered in a deliberately provocative, discriminatory, or targeted manner
•  Cause serious and foreseeable harm without academic justification.

11.4 The College will assess complaints involving academic content on a case-by-case basis, balancing the protection of academic freedom with its legal duties under the Equality Act 2010 and OfS Condition E6 to maintain a safe and inclusive learning environment.

12 Confidentiality, Record-Keeping & Data Sharing

12.1 Confidentiality

12.1.1 Confidentiality is essential when handling allegations of sexual harassment and misconduct. The Reporting Party, Responding Party, third parties and staff managing the process must only share information on a strict ‘need-to-know’ basis.

12.1.2 The College will not, under any agreement or procedure, prevent a student from sharing their experience of harassment or sexual misconduct. This right is protected unless the student explicitly requests confidentiality.

12.2 Record-Keeping

Information related to a complaint involving a student or staff member is documented in the individual’s personnel record, including the outcome and any supporting documentation generated during the investigation. Records will be retained in accordance with College’s records retention schedule and will be subject to audit by the Quality Team.

12.3 Data Sharing

12.3.1 The College will protect the confidentiality of those reporting harassment or sexual misconduct, but may share information internally or with safeguarding or legal authorities where necessary to protect individuals or meet statutory obligations.

12.3.2 The College ensures full compliance with GDPR and the Data Protection Act 2018. All personal data collected in relation to harassment or sexual misconduct cases will be:

• Collected and processed under lawful bases, including legal obligation, public task and safeguarding interests
•  Stored securely in encrypted and access-controlled systems
•  Accessible only to designated staff with a direct safeguarding or investigatory role
•  Retained only for as long as necessary, in line with the College’s Records Retention Schedule
•  Subject to regular review and audit to ensure data accuracy, security and appropriate use.

12.4 Data Collection, Analysis and Reporting

12.4.1 The College is committed to the systematic collection, analysis and reporting of data relating to sexual harassment and misconduct to monitor the effectiveness of this policy and inform institutional improvements.

12.4.2 All formal complaints, informal resolutions and anonymous reports will be logged in a secure central register, maintained by the DSL and HR. Records will include case type, outcome, follow-up actions and, where known and relevant, protected characteristics such as sex, race, disability, or sexual orientation.

12.4.3 Anonymised data from the central register will be reviewed termly to identify patterns, repeated concerns and areas of institutional risk. Data will be disaggregated, where appropriate, to ensure equitable outcomes and inform targeted interventions.

12.4.4 An annual data report will be submitted to the Academic Board and Senior Leadership Team. This report will include analysis of:

• Case volumes and types
• Average time from complaint submission to outcome notification
•  Patterns across departments or demographics
•  Actions taken
• Recommendations for improvement

12.4.5 The College will use these findings to:

• Inform policy and procedural updates
• Develop targeted staff and student training
•  Improve support services and implement preventative safeguarding interventions

12.4.6 In addition to safeguarding-related information sharing outlined in Section 12.3, the College will cooperate fully with requests from the OfS, partner universities, or other relevant regulatory or safeguarding authorities to share anonymised data or case analysis, in line with OfS Condition E6 and applicable legal requirements.

12.4.7 To promote transparency and institutional accountability, the College will publish an anonymised annual report summarising the number and nature of reports received, key themes, outcomes and actions taken. This summary will be shared with students and staff through appropriate internal communications and made available to the OfS.

12.4.8 In accordance with partnership agreements, the College will provide anonymised annual reports to university partners detailing the number of sexual harassment and misconduct cases reported, case outcomes and actions taken. Interim data will be shared upon request. These reporting expectations will be formalised within the SLA with and reviewed annually to ensure alignment with regulatory requirements and good practice.