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Procedures and Policies

Prevention of sexual misconduct policy

Last updated: 18 June 2025

1. Introduction

1.1. The University is committed to providing a safe and inclusive environment that helps to promote wellbeing and success regardless of background. We believe that acts of sexual misconduct and violence are unacceptable.

1.2. We aim to create an inclusive University where everyone is treated fairly and with respect, where we feel valued and have a sense of belonging; a culture where it is safe to speak up and speak out and where we are empowered to grow and realise our full potential.

1.3. Sexual misconduct / violence is not tolerated at the University of Gloucestershire and allegations will be taken seriously, considered carefully and acted upon appropriately.

1.4. The University maintains a single source of information which sets out the full range of policies and procedures on subject matter relating to incidents of harassment and sexual misconduct and is available here.

1.5. This policy should not stop or delay any report to the police that you think is necessary. To report a crime in an emergency dial 999, for the reporting of non-emergency incidents dial 101 or report anonymously via Crime Stoppers on 0800 555 111.

2. Purpose and scope

2.1. The purpose of this policy is to promote a culture where sexual misconduct is not tolerated and where allegations of such behaviour are dealt with fairly and without fear of discrimination or recrimination.

2.2. This policy is for all students enrolled at the University of Gloucestershire. It covers guidance for students who are experiencing, previously experienced or have been accused of sexual misconduct, or if they have knowledge of such an incident having taken place within the University community.

2.3. A separate policy exists, Dignity and Respect at Work, Harassment and Bullying Policy, for members of staff – available on Staffnet.

2.4. The policy covers allegations of sexual misconduct towards students by another student, or allegations of sexual misconduct towards a student from a member of staff, or allegations of sexual misconduct towards a member of University staff by a student.

  1. If you are a student at a partner institution and your complaint is related to another student at that institution, you should follow the relevant procedures within your institution.
  2. If you are a student at a partner institution and your complaint is related to a member of staff at that institution, you should in the first instance pursue your complaint in accordance with the partner institution’s procedure.
  3. If you are a student on placement and your complaint relates to a member of staff at placement, you should contact your placement/link tutor and Student Services at the University in the first instance.

2.5. Sexual misconduct may:

  1. be a single incident or a pattern of behaviours
  2. have occurred on, or off campus, in the UK or abroad, in person or via telephone, email, social media, online activities or other forms of communication.

2.6. As defined by the Office for Students; sexual misconduct relates to all unwanted conduct of a sexual nature, including, but not limited to:

  1. Sexual harassment
  2. Sexual assault
  3. Rape
  4. Physical unwanted sexual advances
  5. Intimidation, or promising resources or benefits in return for sexual favours
  6. Unwanted conduct which creates an intimidating, hostile, degrading, humiliating or offensive environment
  7. Distributing private and personal explicit images or video footage of an individual without their consent

3. Preventative approaches and action

3.1. The University’s commitment to the prevention of sexual misconduct is evidenced through its approaches to creating a culture in which students can flourish;

  1. Clarification to all members of the University community in their own responsibilities and levels of expectations in creating a safe and inclusive environment at the point of enrolment,
  2. The establishment, monitoring and review of appropriate policies and procedures,
  3. Ensuring appropriate training for staff and students in understanding their own responsibilities and approaches,
  4. Regular messaging, through a variety of formats, to all students and staff,
  5. Ensuring ease of access, confidence and consistency in reporting routes,
  6. Ensuring sensitive, timely and appropriate investigation of formal reports.

    3.2. Student expectations are explicit from the point of enrolment throughout their studies and students are directed towards the Student Code of Conduct to remind them of their responsibilities regarding their actions as a student of the University of Gloucestershire.

    3.3. The University’s Personal Relationships Policy for staff sets out the expectations and obligations of all staff with respect to personal relationships between students and staff.

    3.4. University staff receive training identifying, addressing and preventing sexual misconduct and in how to refer students in need of support appropriately to Student Centres and other services. Relevant Student Support and Wellbeing staff and Dignity Advisers undertake bi- annual training on receiving disclosures of sexual misconduct and appropriate referral routes.

    3.5. The University works in conjunction with the Students’ Union on sharing messages and campaigns relating to the prevention of sexual misconduct and both MyGlos and StaffNet  promote key messages throughout the year.

    4. I have experienced sexual misconduct, what should I do?

    4.1. If you feel you are experiencing or have previously experienced sexual misconduct do not feel that is your fault or that you have to put up with it. The University’s primary concern is that you should receive appropriate support, assistance and confidential advice.

    4.2. We encourage anyone who experiences or witnesses acts of sexual misconduct to approach the University at the earliest opportunity that feels comfortable to do so. Early disclosure of unwanted behaviour means incidents can be described in detail and witnesses are better able to recall what they observed. Whilst there is no time limit, if you wish to informally resolve orformally report an incident to the University and/or the police, we would encourage you do this as soon as possible after it has happened.

    4.3. We appreciate that approaching the University may feel daunting, or you may feel uncertain as to what would happen to you and the information you disclose. By talking with trained staff at the University, they can explain processes to you and make sure you are aware of the full range of support available to you. We can also link you with other organisations such as Gloucestershire Rape and Sexual Abuse Centre (GRASAC) if you would prefer to talk to someone external to the University about your options.

    4.4. When thinking about how you wish to address the sexual misconduct, the University will support you to make your decision. You are central to determining the preferred pathway and the University will offer support for you throughout any process you chose to follow.

    4.5. Any information you share with the University will be treated confidentially, however, in exceptional circumstances, we may have to disclose relevant details but we would make every effort do this with the knowledge and agreement of the individuals involved. Examples of these exceptional circumstances are:

    1. Where there is risk of harm to self or others to protect your vital interests
    2. Where we are required by law to disclose information e.g. prevention of terrorism, serious crimes or child protection issues

    4.6 You can choose to withdraw any disclosure or report you make of inappropriate behaviour at any time.

    What should I do if I observe an incident of inappropriate behaviour?

    5.1. If you witness acts of inappropriate behaviour, including sexual misconduct, it is helpful if you:

    1. where possible, and you feel comfortable and it is appropriate to do so, intervene at the time of the interaction
    2. encourage the targeted individual (or group) to seek appropriate support and guidance
    3. where appropriate to do so, encourage the perpetrating individual to seek appropriate support and guidance
    4. offer appropriate support yourself for example by volunteering to provide an accurate statement regarding what you have witnessed
    5. report the incident(s) to the appropriate member of staff (most likely Student Centres in the first instance).

    6. Who should I contact for advice?

    6.1. If you have experienced, witnessed or been complained about in terms of sexual misconduct you may need help and support. It is important you talk to someone you trust.

    6.2. Within the University support is available primarily through Student Centres. The Student Centre staff have been trained in receiving disclosures of sexual misconduct and can talk to you about your options for support, and options for addressing the inappropriate behaviour. Or you may wish to consider;

    1. Dignity Advisers – staff who work to promote respectful attitudes and behaviour at University. They can offer advice and support to anyone experiencing inappropriate behaviour
    2. School/Department Staff – Personal Tutor/Module Tutor/Senior Tutors can offer initial advice on how to access Student Centres
    3. Housing Support Team or your local Residential Support Adviser
    4. Chaplaincy
    5. Students’ Union Advice Service

    6.3. Any contact will be treated as confidential (within boundaries identified in 4.5 of this policy) to discuss your concerns and options available to you. The primary role of anyone supporting you is to listen, provide independent support and guidance regarding the range of options available.

    6.4. Student Support and Wellbeing staff can also talk to you about your options for reporting the incident for university action including the University’s Investigatory Procedures for Student Matters and Disciplinary Procedures for Student Matters, which may be implemented as a result of any breach of the Student Code of Conduct. You will then be able to make an informed decision about how you wish to proceed. Staff will also talk to you about whether you wish to report the incident to the police.

    6.5. University staff will treat any matters you raise in confidence within the remit of legal responsibilities and the needs of potentially investigating the allegations.

    7. What support is available?

    7.1. Student Support and Wellbeing staff can offer support directly or can refer you to internal services including Student Centres, University Counselling Service and Dignity Advisers, along with any other support services that may be relevant to your circumstances.

    7.2. Student Support and Wellbeing staff can also give you information and help to access external sources of support. The University has well established links with our local Sexual Assault Referral Centre (Hope House), Gloucestershire Rape and Sexual Abuse Centre and Victim Support services. Staff can also advise on national sources of support, online resources and helplines which may be helpful for you (for further information see Appendix 1: Contacts and Sources of Further Information).

    7.3. If you wish to make a report to the police and do not feel able to do so on your own, Student Support and Wellbeing staff can provide support with this.

    7.4. Student Support and Wellbeing can support you through whichever process you would like to follow, and the information you provide will be treated sensitively and with respect.

    7.5. Further information on the wider range of support services available at the University (including Dignity Advisers and counselling), along with information available from external providers can be accessed from the University website.

    8. Disclosing and addressing sexual misconduct incidents

    8.1. The University takes all allegations of sexual misconduct seriously. It is important that the matter is dealt with in a timely manner, sensitively, confidentially and effectively for everyone involved.

    8.2. When discussing their situation with a staff member listed in 6.2, students will be given information on all options available to them including;

    1. Receiving advice and support (as listed in 7)
    2. Making no formal report of the incident(s) and taking no action
    3. Seeking informal action to address behaviour
    4. Formally reporting the incident(s) to the University for investigation
    5. The University undertaking action to safeguard students’ situations whilst an investigation is underway
    6. Reporting incident(s) to the Police for investigation

    8.3. The options listed above are available to all students and do not need to be followed in any particular order. Formal options can be instigated directly without the need for informal resolution to be undertaken. However, the University will pause any action (formal or informal) that the Police advise may compromise any Police investigation. The University adheres to “Guidance for Higher Education Institutions: How to handle alleged student misconduct which may also constitute a criminal offence” (Universities UK / Pinsent Masons, 2016).

    8.4. Whilst the University encourages informal local resolution wherever possible, it is not always appropriate, especially when a student has experienced an act of sexual misconduct. Students can obtain advice from the contacts listed in 6.2 for the different options available to address incidents.

    8.5. Where an incident is identified as a breach of the Student Code of Conduct or viewed as an act of gross misconduct, the formal process may be invoked directly.

    8.6. Should students prefer, disclosures of acts of sexual misconduct can be made using the University’s online reporting tool which is available to enrolled students via the student intranet (MyGlos). The site has information on support options, internal and external to the University, and enables students to make a disclosure which is sent directly to Student Services staff. Students can choose to report incidents anonymously or they can choose to disclose information about themselves to enable Student Support and Wellbeing staff to contact them to offer support and talk through options for addressing the inappropriate behaviour. Where the report is made anonymously, the University will be unable to take action related to individuals, nor provide tailored advice to those reporting. However, anonymous information received will build intelligence, and be used to monitor issues across the University to inform future decisions.

    8.7. To report an incident of sexual misconduct where the perpetrator is a member of staff, you are advised to raise the concerns with someone listed in 6.2 or report using the online reporting tool mentioned above. Where a complaint is received, staff will be subject to the processes for employees of the University (see Dignity and Respect at Work Harassment and Bullying Policy (Staff)).

    8.8. Anonymised requests for advice can be received from personal email addresses (if you would rather not be identified by using your student email address), and students can access advice from the University website on support and reporting options.

    9. Informal routes

    9.1. Informal options are available to address incidents where it feels appropriate to do so. We recognise that it is not appropriate in every case, particularly around sexual misconduct. However, where you feel comfortable with this approach, informal options are available. Sometimes people are not aware that their behaviour has been viewed as inappropriate or unwelcome and an informal discussion can improve understanding and help agreement to be reached to change behaviours.

    9.2. Outcome of informal procedures

    Whichever of the informal methods chosen, the aim is to agree a way forward without further inappropriate behaviour. If the outcome of informal methods is unsatisfactory, or informal methods do not feel comfortable, or are not appropriate in the circumstances, then the formal procedures can be invoked.

    9.3. Personal resolution

    Where you feel confident to do so, you might think of ways in which you can resolve the situation by making it clear that you find the behaviour unacceptable and want it to stop. Options to consider but not limited to:

    1. Placing a block where you are receiving unwanted messages/texts/posts via social media
    2. Speaking to the person responsible for the behaviour
    3. Writing to the person
    4. Speaking to the person whilst being accompanied by another student/friend
    5. Asking another student to speak to the other person on your behalf

    It is normally helpful to use specific examples or evidence of the unwanted behaviour and say how this has made you feel. Explaining the impact of actions and behaviours can be very powerful to affecting change. We would encourage you to keep brief notes of the discussion, and copies of any correspondence, in the event that any follow-up action becomes necessary. The meeting should not be recorded unless everyone has agreed that they are happy to do this.

    9.4. Local resolution

    If the situation means you do not feel confident using personal resolution, or your situation does not improve after a personal attempt, you should contact the Student Centres to discuss the situation. You may also wish to consider seeking assistance from one of the following:

    1. Dignity Adviser
    2. Housing Support Team or your local Residential Support Advisor

    10. Formal routes

    10.1. Complaints about other students

    Formal complaints should be submitted online using the University’s reporting tool or made in writing to the Director of Student Experience (via email: [email protected]), detailing the allegations of sexual misconduct. If submitting a formal report via the online reporting tool, students should note that they will need to submit contact details for this to be progressed.

    Incidents of sexual misconduct breach the University’s Student Code of Conduct and are subject to the Investigative Procedures for Student Matters.

    If you are a student on placement and your complaint is about another student on that placement who attends the University, you should inform the Director of Student Experience as above. We may also need to involve the link tutor for your placement and the issue will be dealt with in line with any relevant regulatory / professional framework appropriate to the situation. For students on professional programmes, where applicable, the Professional Suitability and Fitness to Practise Procedures may be invoked.

    10.2. Complaints about members of staff

    For instances when a student has been the subject of sexual misconduct by an employee, agency staff, member of the governing body, contractor, or supplier undertaking work on behalf of the

    University, or any individual with honorary status, a complaint should be submitted in writing to the Office of the Director of Student Experience, or submitted online using the University’s reporting tool. In this situation, the Dignity and Respect at Work: Harassment and Bullying Policy and associated procedures will be invoked as necessary. Student Support and Wellbeing staff will continue to offer support to the student involved.

    11. What if I have been accused of inappropriate behaviour?

    11.1. What should I do if I have received an informal complaint about my behaviour?

    A fellow student or member of staff may have approached you to tell you that they are unhappy by certain aspects of your behaviour, or you may have been approached by someone acting on behalf of the student or member of staff to inform you that an informal complaint has been made against you. In having been accused of sexual misconduct it is advisable to seek advice from a member of staff listed in 6.2.

    You should bear in mind:

    1. The reporting student (or staff member) does not have to raise the issue directly with you first before making a complaint and in some instances, they may not feel able or comfortable to contact you in person
    2. You may feel shocked or upset to have hear that someone thinks your behaviour is inappropriate. However, all students and staff have the right to ask a person to stop behaving in a manner which they feel is inappropriate, insulting, degrading or offensive
    3. Try to remain calm and listen carefully to the particular concerns expressed, remembering that it is how your actions or behaviours impact others that is important
    4. Consider your actions, and the impact they had, and take time to reflect whether it would be advisable to change your behaviour
    5. Try to agree, with the reporting student (or staff member), on ways to deal with the situation productively

    11.2. What should I do if I have received a formal complaint about my behaviour?

    The University is committed to investigating formally reported incidents of sexual misconduct. We have an equal duty of care to both the reporting student and the responding student. Allegations will not be presumed proven or not proven until properly investigated using the appropriate procedures.

    If you have received notification that a formal complaint has been made in relation to an incident (or incidents) you should:

    1. Read the formal notification informing you of the complaint, noting any actions required on your part
    2. Read this policy and note your own obligations as a member of the University community (sections 1.1-1.4)
    3. Consider seeking advice from staff listed in 6.2.
    4. Avoid contact with the person who has made the allegation
    5. Make notes relating to any incident(s) that have occurred involving the reporting person and be prepared to respond to questions relating to these incidents
    6. Participate in the Investigative Procedure for Student Matters in order to reach a resolution

    12. False complaints

    12.1. The policy is intended to promote fairness and consistency in dealing with allegations of sexual misconduct made in good faith.

    12.2. The University believes that false allegations related to sexual misconduct are rare. The perception that false allegations are common harms students who have experienced sexual misconduct. However, the possibility of false complaints (for whatever reason) is recognised and where a complaint is found to be based on false allegation(s), the reporting student may be subject to disciplinary action following the Investigative Procedure for Student Matters and the Disciplinary Procedures for Student Matters.

    12.3. Sometimes a complaint may prove impossible to uphold e.g. if the allegation is not capable of being substantiated. In these circumstances, this will usually not lead to disciplinary action being taken against the complainant.

    13. Confidentiality

    13.1. In recognition of the sensitive nature of sexual misconduct, privacy will be maintained, wherever possible, throughout the disclosure, reporting and investigatory processes. Throughout all proceedings, the University will act in compliance with the UK General Data Protection Regulation (GDPR), Data Protection Act 2018 and its Student Privacy Notice.

    13.2. The University will only share information without the reporting party’s express permission in exceptional circumstances as described in 4.5 or to discharge the University’s duty as required by law. Any disclosure of information will be restricted to relevant information and conveyed only to those entitled to it for justifiable reasons.

    13.3. Outcomes of any action taken by the University in response to a report of sexual misconduct will be shared with both the reporting and responding party, where it is possible and lawful to do so. Should sanctions be imposed on a responding party, the University will consider on a case- by-case basis whether to inform the reporting party of any disciplinary actions which have been taken.

    14. Monitoring and review

    14.1. In order to review the effectiveness of this Policy and related procedures, we will monitor the level and nature of reported incidents of sexual misconduct. The responsible staff member involved in the case will record information with the Director of Student Experience via staff reporting access to the online reporting tool. All personal details will be anonymised for reporting purposes.

    14.2. The Director of Student Experience will report annually to the University’s governing body, and other relevant committees as appropriate, on trends, outcomes of reports and actions related to the prevention of sexual misconduct at the University.

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