Condition E6: Harassment and Sexual Misconduct

Harassment and Sexual Misconduct

Single Comprehensive Source of Information

The Caspian School of Academics (CSA)is committed to fostering a safe and respectful environment for all students, staff and visitors as well as any contractors employed. To comply with the Office for Students (OfS) Condition E6: Harassment and Sexual Misconduct, the School has set up this webpage which summarises the policies and procedures and guidance on reporting incidents of harassment and sexual misconduct and the support available. This webpage, which is also duplicated on the School’s virtual learning environment (Moodle) is the Single Comprehensive Source of Information required by the Office for Students (OfS registration condition E6).

Scope

CSA policies cover all incidents of harassment and sexual misconduct affecting students, staff, visitors and visiting speakers. This includes unwanted and inappropriate behaviour by staff towards students and other staff and, by students towards students, staff and visiting speakers or other guests on campus including partner awarding body staff.

What is harassment and sexual misconduct?

Harassment: As defined under Section 26 of the Equality Act 2010, unlawful harassment is unwanted conduct related to a protected characteristic, which has the purpose or effect of violating a person’s dignity or creates an intimidating, hostile, degrading, humiliating or offensive environment for that person. The effect of the conduct (and not the intentions behind it) is key to deciding whether harassment has occurred. A single event or a series of incidents might constitute harassment.

Unlawful harassment may involve conduct of a sexual nature (sexual harassment), or it may be conduct related to protected characteristics linked to age, disability, gender reassignment, martial or civil partnership status, pregnancy or maternity, race, sex or sexual orientation, religion or belief.

Sexual misconduct: A form of harassment which constitutes unacceptable behaviour of a sexual nature. Sexual Misconduct can include sexual harassment; sexual violence; intimate partner violence; sexual assault; grooming; coercion or bullying with sexual elements; sexual invitations and demands; comments; non-verbal communication; creation of atmospheres of discomfort; and promised resources, favours, benefits or advancement in exchange for sexual access. Sexual misconduct specifically raises issues of unequal relationships, consent, and the prevention of equal access to education, opportunities and career progression.

Sexual misconduct relates to all unwanted conduct of a sexual nature. This includes, but is not limited to:

sexual harassment as defined by Section 26(2) Equality Act 2010
harassment as defined in section 1 of the Protection from Harassment Act 1997
assault as defined by the Sexual Offences Act 2003
rape as defined by the Sexual Offences Act 2003. Physical unwanted sexual advances as set out by the Equality and Human Rights Commission: Sexual harassment and the law, 2017
intimidation or promising resources or benefits in return for sexual favours as set out by the Equality and Human Rights Commission: Sexual harassment and the law, 2017
distributing private and personal explicit images or video footage of an individual without their consent as defined by the Criminal Justice and Courts Act 2015.

A full definition of Harassment and sexual misconduct can be found in the School’s Bullying and Sexual Harassment policy and the Anit-Bullying, Harassment and Sexual Misconduct policy.

Preventative Measures

To protect students from harassment and sexual misconduct, including the abuse of power we have sought to internally and externally gather information to inform our protection for students. The steps we have taken include:

Consultation with Students: The School has engaged with students through forums and the Student Committee to ensure our policies are appropriate and viewed as appropriate.
Data Collection and Publication: The School has reviewed external sources of information including the National Student Survey’s Sexual Misconduct Survey, and published information about the frequency and the nature of threats. We have also looked at strategies for reporting of harassment and sexual misconduct to inform CSA strategies and strategic planning.
Policy updating: The School has conducted a review its policies and processes, updating and making adjustments to enhance their clarity and effectiveness and ensuring compliance with Condition E6. Previous versions of policies can be viewed through: PreviouspolicieslinkedtoE6@caspianschool.ac.uk

Reporting harassment and sexual misconduct

The School provides an online reporting system which can be used by students and staff to report or disclose any incidents of bullying, harassment, discrimination, hate crime and sexual misconduct. Reporting can be done on your own behalf or on behalf of someone else if you have witnessed an incident, either through providing your name or anonymously. Reporting mechanisms include:

Online Reporting: Anyone can report an incident of harassment or sexual misconduct through the School’s incident reporting portal: incident@caspianschool.ac.uk Reports can include any concerns of bullying, harassment, discrimination, hate crimes and sexual misconduct which an person may have been subjected to or that they have witnessed. When reporting you may choose to include your name or to report an incident anonymously.
In person reporting: Students who do not wish to report an incident online can report an incident to an Incident Advisor who is a member of the Student Support and the Safeguarding Team or to their tutor who will help them to make contact with an appropriate advisor.

Support for those affected by harassment or sexual misconduct

The School can offer support to student affected by harassment or sexual misconduct through:

Counselling Services: Students can gain access to the advice on counselling either in person or online by contacting the Student Services Team: studentservices@caspianschol.ac.uk . As appropriate, students will be provided with contacts for specialist external support locally.
Online Support: All requests for help and support via incident@caspianschool.ac.uk are checked daily and the student will be contacted within 24 hours.
Academic Support: Assistance will be provided including access to recognition of exceptional circumstances as set out in the School’s ‘Extenuating Circumstances and Reasonable Adjustments Policy’ to ensure that students’ academic progress is supported.

Students who are facing allegations as set out in the Harassment and Sexual Misconduct Policy will be provided with a named member of staff who they can contact for support.

Handling Information

Ensuring confidentiality is a key principle in creating a culture where those affected feel safe to make a disclosure about harassment and sexual misconduct.

The School will take all reasonable steps to protect the confidentiality and privacy of those who disclose harassment and sexual misconduct. However, there may be circumstances (for example, in order to protect an individual at risk), where the School is required to share information with other agencies or to share information internally. Further details about confidentiality and information sharing are provided in the Harassment and Sexual Misconduct Policy.

Investigation Process

Our investigation procedures are designed to be credible, fair, and reflective of established principles of natural justice.

Process and Decision-Making

The Harassment and Sexual Misconduct Policy defines what harassment and sexual misconduct are and sets out the School’s approach to preventing and addressing harassment and sexual misconduct.
The Procedures for Handling Cases of Harassment or Sexual Misconduct outlines how incidents will be investigated, whether it involves misconduct by a student, staff member, or third party.
The Procedures for Handling Cases of Harassment or Sexual Misconduct outlines expected timescales for investigations and decisions.
The Procedures for Handling Cases of Harassment or Sexual Misconduct outlines available mechanisms for appealing decisions.

Information Handling

All information related to reports is handled sensitively and in compliance with data protection legislation. Ensuring confidentiality when making reports is key to creating a culture where students feel safe to make a disclosure about sexual misconduct or harassment. We ensure that students understand how their information will be used and maintain appropriate confidentiality throughout the process. Further details about confidentiality and information sharing are provided in the Harassment and Sexual Misconduct Policy.

Training and Awareness

CSA provides mandatory training for both staff and students to ensure understanding of our policies and the behaviours that constitute harassment and sexual misconduct. This includes:

For Students: During induction, training on recognising what constitutes harassment and sexual misconduct and ways of reporting it. Training is also provided for continuing students who have not received training previously, through access to the online training module.
For Staff: All staff working at the School undergo regular safeguarding training and now also have access to training on Harassment and Sexual Misconduct. Those staff whose roles deal with the reporting and investigation process undergo further specialist training on handling disclosures, conducting investigations, and upholding principles of freedom of speech.

Intimate Personal Relationships

To protect students from potential conflicts of interest and abuse of power, we have implemented policies regarding intimate personal relationships between staff and students. There is a ban (with exceptions) on intimate relationships between staff and students. The exceptions are where there is an ongoing relationship that existed before Aug 2025 and, for relationships that existed before the staff member became a relevant staff member to the student.

We will require all staff to disclose intimate personal relationships with students. This is outlined in our Code of Ethics and Conduct for Staff and Governors. This code includes steps deemed significant and credible in safeguarding student welfare and preventing an abuse of power.

NON-DISCLOSURE AGREEMENTS

CSA School does not and has never uses non-disclosure agreements in relation to complaints of harassment, sexual misconduct or other forms of abuse. This has been prohibited by the Office for Students since September 2024.

COMMUNICATION AND ACCESSIBILITY

Our comprehensive source of information is prominently published and easily accessible on our website and on the Virtual Learning Environment (VLE) which is the School Moodle platform. We commit to:

Regular Communication: Informing staff and students about our policies at least once each calendar year.
Inclusion in Key Documents: Featuring information about our policies in main documents such as prospectuses and handbooks.
Version Transparency: Clearly indicating when content has changed and providing access to historical versions of policies.