Prevent Policy

Introduction

1. Northeastern University London’s (the University) implementation to the Prevent Duty is one of safeguarding.
2. Section 26 of the Counter-Terrorism and Security Act 2015 (CTSA 2015) places a duty on the University, in the exercise of their functions, to have ‘due regard to the need to prevent people from being drawn into terrorism’.
3. The Revised Prevent Duty Guidance: for England and Wales is issued under section 29 of the CTSA 2015 and states that the University must have regard to this guidance when carrying out the duty.
4. The University has formed a Prevent Duty Review Group which is responsible for the effectiveness and implementation of its Prevent Policies and related procedures. The Terms of Reference can be viewed here.

Purpose

5. Since 18 September 2015, the University must report activities outlined in this Policy to the Regional Prevent Coordinator. This Policy identifies how the University complies with its obligation under the UK Government Counter-Terrorism Strategy (CONTEST).6
6. Prevent remains one of the key pillars of CONTEST, alongside the other three ‘P’ work strands:
   1. Prevent: to stop people becoming terrorists or supporting terrorism.
   2. Pursue: to stop terrorist attacks.
   3. Protect: to strengthen our protection against a terrorist attack.
   4. Prepare: to mitigate the impact of a terrorist attack.

Scope

7. This Policy applies to students and learners registered at the University, those undertaking work related learning programmes, and visitors to the University. This Policy also extends to University employees working  on university business e.g., professional placements, visits to apprentice’s place of work, widening participation and recruitment activities in local schools.

Definitions

8. Staff refers to any person who is employed by the University.
9. Terrorism is defined in the Terrorism Act 2000 as: The use or threat which: involves serious violence against a person; involves serious damage to property; endangers a person’s life (other than that of the person committing the act); creates a serious risk to the health or safety of the public or section of the public; or is designed seriously to interfere with or seriously to disrupt an electronic system. The use or threat of such action must be designed to influence the government or an international governmental organisation or to intimidate the public or a section of the public and be undertaken for the purpose of advancing a political, religious, racial or ideological cause.
10. Extremism is defined in the Prevent Strategy as:  the promotion or advancement of an ideology based on violence, hatred or intolerance, that aims to:
    1. negate or destroy the fundamental rights and freedoms of others; or
    2. undermine, overturn or replace the UK’s system of liberal parliamentary democracy and democratic rights; or
    3. intentionally create a permissive environment for others to achieve the results in (1) or (2).
11. Violent extremism defined in the Prevent Strategy as ‘the endorsement of violence to achieve extreme ends.’
12. Radicalisation is defined in the Prevent Strategy as ‘the process by which a person comes to support terrorism and forms of extremism leading to terrorism.’
13. Extreme Right-Wing Terrorism (ERWT) describes those involved in Extreme Right-Wing activity who use violence in furtherance of their ideology. These ideologies can be broadly characterised as Cultural Nationalism, White Nationalism and White Supremacism. Individuals and groups may subscribe to ideological tenets and ideas from more than one category.
14. Having due regard in relation to section 26 Counter-Terrorism and Security Act 2015, means that specified authorities should place an appropriate amount of weight on the need to prevent people becoming terrorists or supporting terrorism when they carry out their usual functions.
15. Ideology is a set of beliefs, principles, and objectives to which an individual or group purports to adhere and attempts to instil in others to radicalise them towards becoming terrorists or supporting terrorism. There are several concepts or ‘tools’ that often feature in terrorist and extremist ideologies, including: narrative, propaganda, grievances, and conspiracy theory.
16. Interventions are tailored packages intended to divert people away from extremist activity at the earliest opportunity and support their disengagement with terrorist ideologies where they have been involved in terrorism or terrorist-related activity.
17. Islamist terrorism is the threat or use of violence as a means to establish a strict interpretation of an Islamic society. For some this is a political ideology which envisions, for example, the creation of a global Islamic caliphate based on strict implementation of shari’ah law. Many adherents believe that violence (or jihad as they conceive it) is not only a necessary strategic tool to achieve their aims, but an individual’s religious duty. In the UK the Islamist terrorist threat comes overwhelmingly from those inspired by, but not necessarily affiliated with, Daesh and/or al-Qa’ida, but they operate within a wider landscape of radicalising influences as set out in the government’s response to the Independent Review of Prevent. Islamist should not be interpreted as a reference to individuals who follow the religion of Islam.
18. Left Wing, Anarchist and Single-Issue Terrorism (LASIT) encompasses a wide range of ideologies. It includes those from the extreme political left-wing as well as anarchists who seek to use violence to advance their cause in seeking to overthrow the State in all its forms.
19. Online radicalisation describes situations where the internet is believed to have played a role in a person’s radicalisation pathway. The internet can play two broad roles in radicalisation (offering mechanisms often unavailable to people offline). These are: exposure to extremist and terrorist content and socialisation within ‘likeminded’ networks. Often this is facilitated by highly permissive environments online.
20. Permissive environment may be characterised as being tolerant of  behaviour or practices strongly disapproved of by others, such as an environment where radicalising ideologies are permitted to flourish. Radicalisers create and take advantage of permissive environments to promote or condone violence and to spread harmful ideologies that undermine our values and society. Permissive environments can exist both online and offline. Permissive online environments can contribute to online radicalisation.
21. Prevention in the context of this document means reducing or eliminating the risk of people being radicalised or becoming involved in terrorism.
22. Radicalisation is the process of a person legitimising support for, or use of, terrorist violence.
23. Susceptibility is complex and unique to a person’s circumstances. Within Prevent, susceptibility refers to the fact that a person may be likely or liable to be influenced or harmed by terrorist and extremist ideologies that support or radicalise people into terrorism. Please see the ‘susceptibility to radicalisation’ section of the Prevent duty guidance 2023. As set out in the Prevent duty guidance, a person’s susceptibility may be linked to their vulnerability (see vulnerability below), but not all people susceptible to radicalisation will be vulnerable. There may be other circumstances, needs or other underlying factors that may make a person susceptible to radicalisation but do not constitute a vulnerability.
24. Terrorist-related offences are those (such as murder) which are not offences in terrorist legislation (TACT 2000), but which are judged to be committed in relation to terrorism.
25. Vulnerability describes the condition of being in need of special care, support, or protection because of age, disability, risk of abuse or neglect.

Responsibilities

26. The University acknowledges that it has a number of key obligations laid out in law. These obligations are enumerated in the University’s policies and procedures, including the Code of Practice on Freedom of Speech and Managing External Speakers Policy, which govern the University’s approach to the holding of extra-curricular meetings and events and the hosting of external speakers.
27. The University will:
    1. Uphold the legal duties imposed upon the University.
    2. Remain true to the mission and vision of the University.
    3. Continue to work with a range of external organisations including, but not limited to: OfS, QAA, ESFA, OFSTED, local authorities, DfE, the police and UK Government security services, NUS training providers, and specialist external advisers.
    4. Follow its Code of Practice on Freedom of Speech.
    5. Follow its Safeguarding Policy and Support to Study Policy for supporting students who may be vulnerable or experiencing difficulties.
    6. Follow its process for reporting a concern of a vulnerable individual who may be radicalised as illustrated in Appendix B.
    7. Ensure all learners, staff and visitors are provided a lanyard and an ID pass to be worn at all times whilst on campus.
    8. Have an Acceptable Use Policy for Students (IT) which complies with CONTEST.
    9. Ensure any decisions taken by the University are proportionate to the risk of terrorism and radicalisation in the local area and sector; and tailored to reflect and respond to local threats.
28. The full CONTEST strategy outlined by the Government can be found here. As part of the CONTEST strategy, the objectives of Prevent are to:
    1. Tackle the ideological causes of terrorism.
    2. Intervene early to support people susceptible to radicalisation
    3. Enable people who have already engaged in terrorism to disengage and rehabilitate.Respond to the ideological challenge of terrorism and the threat faced by the UK from those who promote it.
    4. Prevent people from being drawn into terrorism and ensure they are given appropriate advice and support.
    5. Work with a wide range of sectors (including education, criminal justice, faith, charities, the internet and health) where there are risks of radicalisation which need to be addressed.
29. The full Prevent Strategy outlined by the Government can be found here.

General Principles

Managing Risk

30. The University manages the risk by accounting for local risk and threat that is proportionate to its size and provision.

Speakers and Events

31. The University holds events, public meetings and lectures which may be led by an external speaker. The Principal Organiser of the speaker or event will follow the Code of Practice on Freedom of Speech, Events Policy, Campus Security Policy and Managing External Speakers Policy alongside this Prevent Policy as applicable.

Internet Access

32. The University will continue to manage its internet access and take action to block unapproved access to sites which fall under a category in the following list.
    1. Violence/Hate/Racism
    2. Intimate Apparel/Swimsuit
    3. Nudism
    4. Pornography
    5. Weapons
    6. Adult/Mature Content
    7. Cult/Occult
    8. Drug/Illegal Drugs
    9. Illegal Skill/Questionable Skills
    10. Sex Education
    11. Gambling
    12. Alcohol/Tobacco
    13. Hacking/Proxy Avoidance Systems
33. Anyone needing to use a blocked website for academic purposes should see: Academic Exceptions to Review Extremist Material Online or contact the Prevent Officer.

Student Engagement

34. The University recognises that the Student Union and Student Societies play an important role in safeguarding against radicalisation, by ‘looking out’ for fellow students, reporting extreme behaviour and contributing to the development of University policies. 
35. The University has a procedure for reporting concerns about a vulnerable individual, and all staff and students receive training in this procedure. The procedure is outlined in Annex A: Process for reporting a concern of a vulnerable individual flowchart. 
36. Attendance is monitored and registers are taken at teaching events. (Undergraduate Student Attendance Policy and Academic Engagement Policy). For apprentices, there will be regular reviews of progress with the learner and employer.

Training

37. Guidance from the Government suggests training should be given to help people identify potential signals that a student has become radicalised or is radicalising other students. 
38. Staff training shall be proportionate to the risk of terrorism and extremism in the local area.
39. All staff receive initial training during induction.
40. Student representatives and key members of the student union receive initial training on the commencement of their post. 
41. Key members of staff are identified and receive proportionate training that is tailored to their particular roles within the University. 
42. Employers of apprentices are provided with Prevent guidance.

Recognising Possible Signs of Radicalisation

43. The Government does not specify what the signs of radicalisation are; it is likely that the most obvious sign of radicalisation will be extreme change in behaviour, and this will vary from case to case. This list is not exhaustive.
    1. Changes in ideology or faith.
    2. Isolation from family and friends.
    3. Talking as if from a scripted speech.
    4. Unwillingness or inability to discuss their views.
    5. Narrowing of political views.
    6. A sudden and disrespectful attitude towards others.
    7. Adoption of “Them” and “Us” mentality.
    8. Fervent public expression of strong anger or grievance about perceived injustice.
    9. Increased levels of anger.
    10. Increased secretiveness, especially around internet use.
    11. Travelling for long periods of time but is vague about where they are going.
    12. Buying or storing large amounts of chemicals for no obvious reason.
    13. Attendance at certain rallies or meetings.

Process for Reporting a Concern of Radicalisation

44. Any member of the University ( learner or staff member) or an employer¹ may express concerns about another member of the University (student or staff member) potentially being drawn into violent extremism based on information received or behaviour observed. 
45. Within the University, there are mechanisms for counselling, guidance and pastoral care. Changes in behaviour are identified using the current processes and staff are able to respond appropriately. 
46. There may be circumstances where the University identifies someone who is suspected as being involved in terrorist-related activity. If this happens, the following steps will be followed, as per the flowchart: Annex A: Process for reporting a concern of a vulnerable individual.
    1. If a member of the University believes that another member of the University is involved in terrorist activity, then this must be communicated to the police. 
    2. If a member of the University is concerned that a student or apprentice is becoming radicalised or is radicalising others, this must be reported in the first instance to the Prevent Officer (PO). The PO will investigate the matter.
    3. If a member of the University is worried that a member of staff is becoming radicalised or is radicalising others, this must be reported to the Human Resources Director (HRD)  in the first instance. The HRD will pass this on to the PO if appropriate. The PO will investigate the matter.
    4. The PO will investigate, gather more information and discuss the case with all relevant internal and external parties. The outcome will be recorded on their student record or on their staff file.
47. Three potential outcomes are likely at this stage:
    1. Stage 1: No further action is required and this will be recorded on their student support/apprentice record or on their staff file as set out above. 
    2. Stage 2: There is some substance to the concern but at this stage only internal action is believed to be required to support the vulnerable student. The exact nature of the intervention required will be determined by the PO in consultation with Student Support and Development (students only), the DHR (staff only), and the CEO. The PO will secure the explicit consent for actions from the DRO (staff) and the CEO, who will determine the actions to be taken, the date of next review, and the periodicity of review as necessary. This will be recorded on the student/apprentice or staff file. The relevant members of staff involved in any support or intervention will be informed. The case will be reviewed regularly and at a minimum on a monthly basis. Where it is felt by the PO and CEO there is a Prevent issue beyond that which the University can support, the vulnerable student the University will refer the person to the Channel process (Annex B: Referral and Channel Process). Should the University refer someone to the Channel process, the PO will attend the relevant meetings when required.
    3. Stage 3: There is an immediate threat of criminal activity or to the safety of an individual or other party. In this case the PO will liaise with the police immediately.
48. All staff, to the extent permitted by law, will support the Police in their work.
49. Any requests for information from the Police will be authorised by the Executive Committee (ExCo) or in the event of an emergency, the CEO or, in their absence, the Associate Vice President for Student Engagement and Academic Services.   
50. When considering a request, the University will meet the requirements of the Data Protection Act 2018 (DPA), UK General Data Protection Regulation (GDPR) and the  equitable principle of confidentiality that a person who has received information in confidence cannot take unfair advantage of it, and must not make use of it to the prejudice of the person who gave the information, without obtaining their consent; and must satisfy itself that there is a lawful duty to disclose and there is a sufficiently important reason to disclose.  
51. In accordance with the DPA, personal data will only be passed to the relevant authorities, where the University is satisfied that the University’s Responsibilities have been satisfied. In sharing such information with external parties, the University will share only sufficient and relevant information in order to allow the concern to be appropriately followed up. The University will keep confidential records of the information shared. These will be kept in accordance with the DPA.
52. Contact with the Regional Prevent Coordinator is the responsibility of the PO who will be responsible for coordination with relevant bodies in the event of the University having concerns.
53. The PO will also:
    • Attend any training or conferences required to keep up to date on Prevent issues.
    • Keep the Prevent Policy and Code of Practice on Freedom of Speech up to date.

Reporting, Monitoring, and Reviewing

54. The PO will report to the Executive Committee (ExCo) statistical information relating to Prevent on an annual basis. The PO will be supported in their work by the Prevent Duty Review Group (PDRG) which will include members of professional staff, faculty and Students Union. The PDRG will help to ensure that all areas of the University are engaged with Prevent and any issues with the policy or processes are identified and resolved promptly.
55. ExCo will report to Northeastern London Board statistical information relating to Prevent on an annual basis.
56. ExCo will monitor the data and make recommendations as appropriate.
57. ExCo will review the policy and procedures for their effectiveness and the PO will implement the recommendations as instructed with the help of the PDRG.

Version History

Annex A: Process for Reporting a Concern of Radicalisation

Annex B: Referral and Channel Process (Information Only)

This Flowchart Must Be Used in Conjunction With the Statutory Guidance for Channel Panel Members and Partners of Local Panels*

*Channel Duty Guidance: Protecting people vulnerable to being drawn into terrorism

Footnotes

^{[1] The term ‘employer’ refers to the employer of an apprentice who are on an apprenticeship programme at the University.}