Prevent monitoring and the detailed submission
On the 1st April 2016, HEFCE-funded institutions are required to make a detailed submission in response to the Prevent duty. Michaela Boryslawskyj looks at the recent advice note from HEFCE issued on 16th February.
Last week we received an update from HEFCE on the Prevent Duty and their monitoring arrangements; this served as a timely reminder that the date (for HEFCE funded providers, at least) for the detailed Prevent submission will soon be here, so it seemed an appropriate time to share my views on the four items covered by the update.
HEFCE are communicating updates via the preventmonitor-hefce@jiscmail.ac.uk list; if you are the Prevent Lead at your institution, HEFCE have asked that you subscribe to this list, but it is also available to those who are simply interested in developments in this area.
Self-assessment outcome
Institutions were required to submit a self-assessment of their compliance with the requirements of the Prevent duty by 22nd January 2016; HEFCE have confirmed they received a submission from every institution they expected to provide one, and their findings were reported at sector level to Government, but HEFCE do not intend to publish the findings more widely.
Limited information on the findings (again at sector level) was imparted at the Leadership Foundation Event I recently attended in London; whilst this was helpful there arguably may have been some benefit in slightly more detailed information having been published which, whilst not identifying individual institutions, would have enabled the sector to get a feel for common issues/concerns and gauge their approach and progress towards compliance prior to the detailed submission.
Following the self-assessment exercise, HEFCE have commenced a wider engagement process and institutions can expect contact (either via a call, or a visit) from their HEFCE Prevent Adviser.
HEFCE advice note
HEFCE have updated the advice note they first published in November 2015 to clarify and provide additional information on franchising and third-party arrangements, visiting lectures and speakers visiting as part of academic provision, the institutional approach to Prevent, the Channel Process and chaplaincy and pastoral arrangements.
It is particularly helpful that the revised note clarifies that ‘sufficient chaplaincy and pastoral arrangements’ does not require the provision of chaplaincy support on campus, or for all faiths, but that where an institution does not offer this on campus, it ensures alternative arrangements are in place, which would include signposting to religious provision in the local area.
The advice note also further considers in what circumstances, and how, institutions will share information about speakers with other institutions, questioning whether informal arrangements are already in place and sufficient?
Potentially the AHUA network could promote the informal sharing of approaches, or information. At present there is limited information available on the safe campus communities website and institutions may feel that they are making decisions in isolation, despite assurances from the HE Prevent co-ordinators that they would offer support and advice in such circumstances. The note suggests that the information which might be shared will already be in the public domain, which may help allay concerns around data protection and privacy issues, although these would have to be considered on a case by case basis.
Detailed evidence submission
HEFCE funded institutions will need to submit detailed evidence by 1st April 2016 of the steps taken to comply with the Prevent duty. HEFCE intend to issue a circular letter in early March 2016 to confirm the arrangements for this process, which will involve submission through HEFCE’s extranet.
As has been a common theme throughout this implementation process, HEFCE will not be issuing templates for the detailed evidence submission and are leaving it to institutions to ‘decide how best to demonstrate compliance in their own context’.
Much emphasis has been placed on the importance of context, proportionality and a risk-based approach, but it may have been helpful for more templates/guidelines to have been produced to inform the sectors’ approach, which would have included a template risk register and action plan, since there is a danger that highly individualised responses will prove a challenge in terms of monitoring and enabling comparisons of levels of compliance.
Voluntary data submission
Alongside the detailed evidence submission, HEFCE are requesting that institutions provide the following data on a voluntary basis:
‘Channel’ Programme
- Number of people considered for referral;
- Number of people referred; and
- Number of people accepted onto the Channel Programme.
Events and Speakers
- Number of events and speakers referred to the highest level for approval.
Staff training
- Number of staff who received Prevent-related training, with an indication of the nature of the training, including where different categories of staff received different training.
After this detailed submission, HEFCE will require an annual Prevent Duty report which will be built into the annual accountability returns process, the first report being due on 1st December 2016.
Members may be reassured that HEFCE have advised the data will be used to show trends at national, regional and sector level and not used, or interpreted at an individual institutional level (unless there is a case which implies a serious issue).
Given the continuing media focus on the Prevent duty and freedom of speech at universities and the previous naming and shaming of institutions, there may be reticence in volunteering such detailed information to HEFCE; in the face of this concern, HEFCE advocate the importance of volunteering such information at this stage to enable them to address any issues before the data return becomes mandatory.
It is a dim and distant memory so I may have confused the message with the passage of time, but I’m sure I recall somebody, somewhere at some point saying the implementation of this duty should not result in any additional work for institutions.
As we approach what is perhaps the most intensive phase of HEFCE’s monitoring, that message doesn’t seem to be ringing true for members who have been attending various training sessions, compiling dedicated action plans and risk registers reviewing policies and collaborative provision arrangements. Hopefully once the detailed submission phase has been completed and the duty is embedded into the annual reporting process the burden will ease somewhat.
