Recommendations and Action Plan
At its meeting on 22 November, the Senior Management Group (SMG) formally accepted all 16 recommendations in the report by Morag Ross KC (the Ross Report). We propose to implement the recommendations as soon as possible, with the final components being in place before the start of the 2023/24 academic year.
Implementation will be overseen by a sub-group of SMG comprising David Duncan (Chief Operating Officer [COO]), Christine Barr (Executive Director, People & Organisational Development [P&OD]), Professor Sara Carter (Gender Equality Champion), Professor Martin Hendry (Clerk of Senate) and Rinna Väre (Students’ Representative Council (SRC) President). We will be supported by an external adviser, Paula Tunbridge (former Head of Student Services and a Deputy HR Director in another Russell Group university) and Sarah Quinn (Transformation Team), together with officers from both Student & Academic Services (SAS) and P&OD as appropriate.
We will report on a monthly basis to the Principal and SMG; regular updates will also be shared with Student Experience Committee (SEC), People & OD Committee, Equality & Diversity Strategy Committee (EDSC), Gender Equality Group (GEG) and Court.
1. The University should review its website content relating to gender-based violence and related conduct procedures with the aim of improving accessibility of information.
The Web Team, supported by SAS and P&OD colleagues, will review the content of the website and ensure that all relevant information is available on one easily accessible site.
Completion date: 30 April 2023.
2. The University should continue to work with the SRC with a view to (a) ensuring that there is appropriate funding for the SRC’s own work in awareness raising in relation to gender-based violence, and (b) agreeing a strategy for joint working, whether through a campaign or publishing information, which communicates what gender-based violence is and how it is dealt with.
The budgetary aspects of this recommendation will be taken forward by the COO, the SRC President and Head of University Services Finance, and proposals discussed at the January meeting of SEC.
Completion date: 28 February 2023.
We will develop a joint strategy for regular communications about GBV and how individuals can access advice and support.
Completion date: 31 August 2023.
3. The University should support the SRC in developing appropriate training and other resources in relation to sexual conduct and consent matters. Training and other awareness raising tools are helpful but mandatory training should not be considered to be essential.
We will continue the work currently underway to raise awareness about GBV across the University community.
Completion date: New materials to be developed by 31 August 2023.
4. The management of the online reporting tool should be reviewed and measures put in place to ensure that the first line response to reports is handled at a suitable level. The current arrangement, whereby the immediate response to every report relies on a very senior member of staff taking action, must be reconsidered.
We will ask the external adviser to undertake a review of the management of the reporting tool and the resources deployed to handle first-line responses. We will put in place additional or alternative resources as appropriate.
Completion date: Review completed by 31 May 2023; changes implemented by 31 August 2023.
5. The University should ensure that all information submitted through the online reporting tool and actions taken are recorded consistently.
We will put in place a comprehensive record keeping system as a matter of urgency, drawing on advice from the Data Protection team. In the medium term, we anticipate using the new records system being purchased for Disability Services across a wider range of functions.
Completion date: 31 January 2023.
6. The University should bring forward plans to introduce a safeguarding manager, with a suitable team, to take responsibility for overseeing the response to all safeguarding issues arising, whether those come from online reporting or from elsewhere. The responsibilities of the safeguarding manager would not be limited to responding to reports of gender-based violence but it should be anticipated that such reports would form a substantial part of the workload of that person.
We will ask the external adviser to review our safeguarding arrangements and advise on a revised structure to oversee safeguarding, including defining the role of safeguarding manager.
Completion date: Review completed by 30 April 2023; changes implemented by 31 August 2023.
7. The capacity of the University counselling service should be increased to allow for an expansion in the provision of specialist gender-based violence counselling.
We will ask the Head of Student Services to review capacity within the Counselling and Psychological Services team and to identify needs in terms of additional specialist counselling advice.
Completion date: Review completed by 28 February 2023; additional capacity sourced by 31 August 2023.
8. The University should review the advice, support and training that it provides to members of staff whose responsibilities include, or may include, responding to disclosures of information about gender- based violence. In particular, such advice, support and training should cover data handling and the proportionate communication of sensitive information with a view to ensuring that students do not require to make repeated disclosures of such information.
We will undertake a comprehensive review of the advice, support and training provided to the full range of members of staff involved, probably drawing on external professional assistance.
Completion date: Review completed and changes implemented by 31 August 2023.
9. The University should keep the Code of Student Conduct under review. In the review process, the University should consider the following issues:
Drafting: accuracy and clarity
- Consistency with the Dignity at Work and Study Policy and the Code of Practice on Unacceptable Behaviour
- Ambiguities and the scope for confusion in the list of examples of unacceptable conduct
Policy: issues of principle
- The University should consider and clarify its position in respect of accepting complaints (including complaints from members of the public) about student conduct in situations unconnected with any University activity. It should consider whether, as a matter of policy, it wishes to maintain a position whereby it accepts and processes all complaints, or whether it should apply a threshold test.
- The University should reconsider whether Student Liaison Officers are either necessary or helpful.
- The University should review the position in respect of the differential treatment of students according to the nature of their course and anticipated professional qualifications in the context of the application of sanctions.
Procedural improvements
- The University should revise the procedure to introduce interim procedural time limits requiring evidence or submissions to be provided to the Student Non-Academic Conduct Committee in advance of a meeting and with sufficient time to allow the committee members to consider any such material.
- The University should reconsider whether a student who wishes to be represented (and, in particular, who wishes to have legal representation) at a meeting should be required to obtain permission, and, if so, what criteria should be applied when deciding whether or not to grant permission.
Practical implementation
- The University should consider whether it is realistic to continue to ask members of staff to undertake investigations into non-academic misconduct alongside other full-time responsibilities. The University should consider whether to appoint specialist investigators to carry out all or some non-academic misconduct investigations.
- The University should put in place detailed guidance to assist Investigating Officers.
- The University should put in place suitable guidance to assist members of Student Non- Academic Conduct Committees. In due course, the University should develop and maintain a set of practice notes on procedural and practical matters for the benefit of those serving on such committees.
- The University should put in place suitable guidance to assist reporting individuals, responding students and their representatives and should work with the SRC in making relevant and up to date information available to students.
- The University must ensure that all members of staff adhere to the procedure in the Code of Student Conduct. Where there is scope for resolution at an early stage, that must be done in accordance with the level 1 procedure.
We will undertake a further review of the Code of Student Conduct to address the specific points raised in this recommendation and to develop supplementary guidance. The review will cover, inter alia:
- addressing the issue of representation (see also R11 below)
- consideration of whether to appoint specialist investigators
- development of more detailed guidance for investigators
- development of additional guidance for investigators
- guidance for reporters and responders
- clarification of the relationship between formal conduct processes and informal resolution efforts.
Completion date: Review completed and changes implemented by 31 August 2023.
10. The University, as a matter of urgency, must put in place measures to support the members of staff handling non-academic student conduct cases and to address the current case management and delay issues. In the longer term, the University must ensure that non-academic student conduct work is sufficiently resourced and that proper strategic management is put in place.
We will complete the discussion currently underway with SAS about additional resource requirements in the Conduct team and put these in place as soon as possible.
Completion date: The challenge here is identifying and retaining suitably qualified colleagues. We will aim to have additional resource in place by 30 June 2023 or earlier if possible.
11. The University should work with the SRC to expand the capacity of the Student Advice Centre, with the aim of creating a structure allowing the Student Advice Centre to provide advice and support to both a reporting student and a responding student in any case.
The COO, SRC President and Head of US Finance will take forward discussions about additional resource requirements and report these to the January meeting of SEC.
Completion date: The challenge here is identifying and retaining suitably qualified colleagues. We will aim to have additional resource in place by 30 June 2023 or earlier if possible.
12. The University should discuss with GUSA, the GUU and the QMU revision of their conduct procedures to ensure that there is a mechanism for the unions to refer reports of sexual misconduct to be considered within the University conduct procedures. Reports made to the unions of serious sexual misconduct must be referred to the University. The University and the unions, working with the SRC as necessary and appropriate, should seek to reach agreement on the process, having regard to the issues identified in paragraph 9.6.
We will begin discussions with the GUU, QMU and GUSA immediately to ensure that in future, GBV- related conduct cases are handled by the University Conduct team rather than by the boards of the associations. This may require revision to existing association regulations − we will provide advice on this over the course of the next few months.
Completion date: Changes implemented by 31 August 2023 or earlier if possible.
13. The University should keep under review the extent of the use of the online reporting tool by members of staff. Where the University receives information about gender-based violence affecting members of staff from whatever source, care should be taken to record that information appropriately.
We will keep usage of the reporting tool under regular review, with reports being provided to GEG and EDSC as appropriate.
Completion date: First report to relevant committees by 30 June 2023.
14. In reviewing the procedures applying to staff and students, and the complaints handling procedure, the University should consider introducing a procedural mechanism to be used in complex cases allowing for (a) a conjoined meeting for relevant members of staff to agree on prioritisation and coordination of procedures, and (b) the appointment of a single investigating officer and the preparation of a composite report.
We will consider the introduction of a conjoined mechanism for handling complex cases involving staff and students as proposed in the Ross Report.
Completion date: New mechanism in place by 31 August 2023.
15. The University should keep under review the response times for handling complaints.
We will undertake regular review of the response times for handling complaints and allocate additional resources where necessary.
Completion date: Ongoing; first report to Professional Services Group by 30 June 2023.
16. The University should review the provision of training to members of staff relevant to gender-based violence. That should be with a view to balancing the training that the University is best able to provide, in relation to the conduct procedures themselves, with training that best done by those external providers who have specialist expertise.
We will undertake a review of the training provision provided to members of staff relevant to GBV, ensuring that the training is relevant, comprehensive, balanced and accessible.
Completion date: Review completed and changes implemented by 31 August 2023.