Harassment, Sexual Misconduct & Intimate Personal Relationships: Single Comprehensive Source (OFS E6)

This single, authoritative page sets out Reaseheath’s policies and procedures on harassment and sexual misconduct affecting higher education students, and intimate personal relationships between relevant staff and students. It must be read alongside the Learner-Harassment-and-Bullying-Policy-and-Procedure and the UCR Code Of Practice Freedom of Speech and Expression.

Reaseheath College & University Centre is committed to providing safe and respectful campuses where all students and staff are protected from sexual harassment and misconduct. This applies to all higher education students (including higher education apprentices and researchers) across all modes of study, and all academic (including guest speakers), administrative, facilities, support and contracting staff. We will take all reports of sexual misconduct seriously, responding with clear procedures, appropriate support, and proportionate action in line with our responsibilities to the wellbeing and welfare of our community

This page is the College’s single comprehensive source for Office for Students (OFS)Condition E6. Where other pages/policies touch similar topics, this page prevails.

This page applies to conduct by staff towards students and by students towards students; includes online and off‑campus conduct where it affects students. It covers incidents, allegations, complaints, suspected behaviour, and formal findings. We will operate in accordance with this page in practice and maintain the capacity and resources to do so.

We place significant weight on lawful freedom of speech and academic freedom. A rebuttable presumption applies where exposure to course content (books, media, ideas) and statements made in teaching, research, or connected academic discussion is unlikely to amount to harassment. We will uphold lawful expression while meeting our equality and safeguarding duties.

See also our Code Of Practice Freedom of Speech and Expression. Anonymous reporting tools are implemented to avoid chilling lawful speech.

  • Harassment: unwanted conduct (including online) that violates dignity or creates an intimidating, hostile, degrading, humiliating or offensive environment, with the statutory objective tests applied.
  • Sexual harassment refers to unwanted sexual advances, inappropriate touching, explicit derogatory statements or sexually discriminatory remarks or jokes which cause the person to feel embarrassed, threatened, patronised or harassed. The behaviours create a hostile, intimidating, or offensive learning environment. Sexual harassment is a form of sexual discrimination which contravenes the Equality Act 2010.
  • Sexual misconduct refers to any unwelcome sexual behaviour conducted without consent and ranges from inappropriate sexual behaviours to sexual harassment and assault. It often involves actions that disregard boundaries, exploit power dynamics, or undermine consent, and it may have legal implications beyond anti-discrimination laws leading to criminal convictions, especially in relation to incidents of sexual assault (Sexual Offences Act 2003).
  • Intimate personal relationship: a relationship involving sexual activity and/or romantic or emotional intimacy.
  • Relevant staff member: staff with direct academic or other direct professional responsibilities in relation to a student.

It is important to note that neither sexual harassment nor sexual misconduct is limited to interactions between individuals of different genders and can occur between individuals of the same gender.

This document sets out to establish:

(a) preventative steps that make a significant and credible difference

(b) ways to report

(c) how we handle information

(d) support for all parties

(e) training for students and staff

(f) fair investigations and decisions

(g) direct communication of decisions

(h) our intimate relationships rules and safeguards.

In order to ensure that we prevent harm and protect students the following will be implemented.

  • Mandatory student training
  • Mandatory staff training for all staff interacting with HE students
  • Data & culture insight: reporting metrics; summary metrics published.
  • Environment awareness : visible communication materials, safer social events guidance, accommodation protocols, and guidance for placements/fieldwork.
  • Non -Disclosure Agreements: Since September 2024, the Office for Students has prohibited Higher Education Institutions from using Non-Disclosure Agreements (NDAs) in relation to student allegations of harassment and sexual misconduct. UCR does not use NDAs or restrict disclosure of information relating to allegations about harassment or sexual misconduct.

Students, staff, witnesses, and third parties can report concerns. You can report even if you are unsure whether an incident meets a legal threshold.

Both disclosure and reporting are important steps in addressing sexual harassment and misconduct, and students may choose to disclose or report based on their own preferences, needs, and circumstances. Students can disclose or report to any member of staff so everyone needs to be aware of the distinction between disclosure and reporting and be prepared to respond appropriately to both.

Disclosure refers to the voluntary sharing of information about an incident for support or validation, while reporting involves the formal communication of information to initiate a process of investigation and intervention by us.

1) Disclosure: making new or secret information known – this could be to, for example, to any member of staff. They may not want to report formally at this stage.

2) Report: formally reporting the incident(s) to us to be processed through our disciplinary regulations and procedures and/or the police. Making a report inherently involves the act of making a disclosure, but making a disclosure does not necessarily always lead to making a formal report.

Reports in relation to perpetrators who do not study or work at Reaseheath can not be investigated by us. The reporting party will be encouraged and supported to make a report to the police if this is what they wish.

Reporting channels

  • Online form: See it, Say it
  • Duty Safeguarding Officer Telephone Number: 07889216789
  • In person: Student Services or any trusted staff member will take a report and pass it to Student Services with sensitivity.
  • Email: ucrstudents@reaseheath.ac.uk (monitored during business hours).
  • We collect information sensitively and store it securely, applying data‑protection law.
  • We explain how information may be used (e.g., risk assessment, support, investigation, disciplinary action) and with whom it may be shared.
  • We balance privacy with safeguarding and legal duties; only those who need to know will have access.

Support we can provide

Ongoing support and resources are provided to survivors of sexual harassment or misconduct, and efforts are made to address any systemic issues or concerns identified during the investigation process.  The following is support that can be provided if applicable to the issue raised:

  • Personal support: counselling referral, wellbeing check‑ins
  • Academic support: attendance flexibility, deadline adjustments, assessment arrangements, placement changes.
  • Practical measures: no‑contact arrangements, timetable or accommodation adjustments.

Who can access support

  • Students who report or experience harassment or sexual misconduct (with or without a formal report).
  • Witnesses
  • Alleged or actual perpetrators, including support to engage fairly with processes.
  • Initial response & risk: We acknowledge reports promptly conduct an initial risk assessment of the report to determine its credibility, severity, and whether it falls within the scope of the Learner Harassment and Bullying policy. Interim measures may be implemented to ensure the safety and well-being of the parties involved, such as no-contact orders, changes to timetable, or temporary suspensions without prejudice.
  • Route setting: We explain options (informal resolution where appropriate; formal investigation; parallel police action). We make clear that our outcomes are not legal determinations.
  • Investigation: Investigators gather information impartially and with sensitivity. Investigators collect evidence related to the incident, which may include witness statements, documents, emails, text messages, social media posts, and any other relevant information. The investigators interview the parties involved, as well as any witnesses identified during the investigation, to gather additional information and perspectives on the incident.
  • Findings and Report: The investigator will compile their findings into a written report detailing the investigation process, evidence collected, witness statements, and conclusions regarding whether the reported behaviour occurred and whether it violated any policies
  • Outcomes & sanctions: Range includes no further action, educational or protective measures, misconduct findings with proportionate sanctions up to exclusion/dismissal (for staff via HR processes).
  • Timescales: The investigation and disciplinary process will be conducted in a fair, prompt, and impartial manner, with respect for the rights and privacy of all parties involved. The investigation aims to be concluded as quickly as possible, however, this is dependent on the complexity and sensitivity of the case.
  • Appeals: Both the reporting and the reported party have the right to appeal the outcome of the investigation, or any disciplinary action imposed. These appeals should be made to the Dean of Higher Education.

To protect students from abuse of power and conflicts of interest, Reaseheath prohibits intimate personal relationships where a staff member has academic, pastoral, administrative or professional responsibility for a student. Beyond this, intimate relationships are strongly discouraged and must be declared so safeguards can be applied.  Breach of this requirement may result in disciplinary action.

10.1 Prohibited

  • Any intimate relationship between a relevant staff member and a student for whom they have teaching, supervising, assessing, supporting, pastoral, disciplinary, accommodation or placement oversight.

10.2 Declaration & registry

  • Staff must promptly declare any intimate relationship with a student to HR via the humanresources@reaseheath.ac.uk email address.
  • Failure to declare may be classed as misconduct.
  • Where a relationship predates employment or enrolment, this must be declared immediately upon becoming a relevant staff member.

10.3 Safeguards

Where there is any issue in respect of a student and a relationship with a member of staff the following safeguards will be considered on a case by case basis.

  • Remove staff influence over the student’s assessment, feedback, references, progression, funding, resources, or opportunities.
  • Alternative supervision/assessment arrangements; timetable and access changes.
  • Prohibit the staff member from involvement in decisions affecting the student or their cohort.
  • Strengthened oversight, with periodic review by HR and the relevant academic manager.
  • Protected reporting channels for the student; explicit anti‑retaliation protections.

Breaches of these rules may lead to disciplinary action, up to and including dismissal. This approach does not diminish safeguarding rules relating to under‑18s and adults at risk (see Section 11 below).

10.4 Confidentiality

Human Resources will maintain a confidential record of all disclosed Intimate Personal Relationships between staff and students. This record will be securely held and managed by a restricted group of staff within the HR Team, in line with data protection requirements

All documentation will be treated as personal data and only shared where it is appropriate to do so. We collect and process personal data relating to our employees’ conduct to manage the employment relationship.

Information about Intimate Personal Relationships will be handled sensitively and will only be available to those who have a need to know the information

Information will be retained on a member of staff’s electronic personal file, which is held in a secure location on SharePoint, only accessible by the HR Team.

Any sexual relationship with a student under 18 is unlawful and constitutes gross misconduct. This page operates alongside our safeguarding policies.

We will maintain appropriate financial resources, trained staff (including investigators and decision‑makers), case‑management tools, and access to specialist services to implement the requirements effectively.

  • This page is published publicly and prominently on our website (no login required to access this page).
  • References to this page will appear in student and staff handbooks, and other onboarding materials as applicable.
  • Downloadable copies will be provided, and historical versions retained (see below).
  • We keep appropriate records of decisions and the factors considered.
  • We publish summary, privacy‑preserving metrics on prevalence, reporting and outcomes.
  • We evaluate training effectiveness and preventative steps annually and adjust accordingly.

We maintain a transparent change log. Historical versions remain accessible for at least six years, or longer where relevant to ongoing matters.

  • 0 – 11 Aug 2025: Initial publication as single comprehensive source; added no‑direct‑responsibility relationship model with safeguards; formalised reporting routes, support catalogue, training, investigation process, decision notifications, and prominence commitments.