Duty of Care

The College has a duty of care to its students and staff in which all members of the College share.  This means that concerns about the wellbeing of members of the College need to be considered and dealt with appropriately.  This includes providing support to people who may be vulnerable to radicalisation.


Supporting vulnerable people

 

'Radicalisation' could involve an individual moving towards vocal or active support for extremist social, political, or religious causes, movements or ideologies.  'Active' means that there is a risk that the individual could be drawn into violent action or support for violence.  The aim of Prevent - and the College's Referral of Concerns procedure (below) - is to identify vulnerable individuals who may be who may be in the process of becoming radicalised so that we can offer them the proper support as soon as possible.
 

How to raise a concern

 
If you develop a concern that a member of the College (or visitor to the College) may be on a path towards radicalisation you should first discuss this with your Personal Tutor (if you are a student) or line manager (if you are a member of staff).  If you decide together that the concern may be legitimate you should arrange to meet with a Local Adviser in your Faculty/Division (see below) as soon as possible.  They will be able to advise whether more information is needed or on what to do next if they agree that the concern may be legitimate.
 
The College will treat all disclosures made in accordance with these procedures in a sensitive manner.  Please see the note below on confidentiality.
 
Please always read the Referral of Concerns Policy and Procedure before contacting your Local Adviser.         

Referral of Concerns Policy and Procedure

Policy

Policy Statement

Imperial College London has a duty of care to its students and staff.  An important aspect of this involves supporting vulnerable individuals who may be at risk of radicalisation.

This is a legal duty under s. 26(i) of the Counter-Terrorism and Security Act (CTSA) 2015 known as the ‘Prevent duty’ in which all members of College share. 

Therefore, in order to perform this duty, the College requires that all staff and students who develop concerns about a member of College (or a visitor) seek advice promptly and in confidence as explained in the procedure below.

Procedure

There are four main stages to referring a concern.  Please read these and the NOTES below carefully before starting the procedure.

1.    RAISING A CONCERN

You should begin by having a discussion with an appropriate member of College:

Undergraduates should discuss with their Personal Tutor
Postgraduates should discuss with the Academic Supervisor/Course Director
Staff should discuss with their line manager

You should begin by noting that the conversation is Prevent-related and asking that the information you discuss be treated sensitively.  You may choose not to identify who the concern is about and instead discuss this in an anonymised way.  If, after discussion, it is felt that the concern may be legitimate, you should arrange a meeting with a Local Adviser.  You and the member of College you have shared your concern with should attend this meeting together wherever possible.

You may find it useful to consider the Vulnerability Assessment Framework below.

2.    MEETING WITH A LOCAL ADVISER

Local Advisers are trained in fielding and advising on Prevent-related concerns.  It is their role to help you consider your concern and any basis for it carefully so as to determine if the concern may be genuine, if more information is required, or to consider if the concern may have arisen from misunderstandings.   Outcomes of meetings with Local Advisers are decided together with the persons raising concerns and depend on the information discussed.

As above, it may not be necessary to name the person(s) you are concerned about initially.  However, if the discussion suggests it is worth investigating the matter further, the Local Adviser may request some details at the end of the meeting so they can contact someone closer to the person(s) you are concerned about (e.g. their Personal Tutor/Senior Tutor/line manager), to understand whether the concern may be genuine.

Once further information has been gathered, a second meeting will usually be held to consider the concern more fully and to decide whether to close the matter or to refer the concern internally. 

3.    INTERNAL REFERRAL

If, after careful consideration, it is felt that a concern may be legitimate, Local Advisers will contact either the Director of Student Services to refer concerns about a student, or the Director of Human Resources if the concern is regarding a member of staff, to decide if more information is needed or if it is necessary to consider offering the individual support via the Channel programme. 

4.    REFERRAL TO CHANNEL

Channel is an external multi-agency approach to supporting people who may be at risk of becoming radicalised or drawn into terrorism.  This is led by Local Authorities and may include representation from social services and mental health professionals as well as the organisation making the referral.

Support is offered on a voluntary basis, so before a referral can be made, a decision will need to be taken over whether it is appropriate to have a conversation with the person(s) of concern to seek their consent for referral. 

In the case of a student, the Director of Student Services, the College Secretary, and the Vice-Provost (Education) and/or the Academic Registrar are collectively responsible for agreeing to make a referral to the Channel Programme.

In the case of a member of staff, the Director of Human Resources, the College Secretary and the Provost are collectively responsible for agreeing to make a referral.

In all cases, the College Secretary as the College’s Single Point of Contact (SPOC) for Prevent-related matters is responsible for contacting the external Channel programme.

If the evidence suggests that Channel may not be the appropriate route, the College Secretary will contact the Local Authority Channel Adviser and/or the Local Channel Police Practitioner and seek further advice based on an anonymised version of the case.

NOTES

Concerns regarding visitors
Where the individual of concern is a visitor to the College (e.g. from a neighbouring organisation, a contractor, a collaborator, a visiting academic or student) it will become necessary to advise the SPOC within their organisation.  This will be handled by the Central Secretariat in accordance with the Home Office’s Channel Duty Guidance regarding information sharing.

Confidentiality
The College will treat all disclosures made in accordance with this procedure in a sensitive manner.  The identity of the person raising the concern will be kept confidential, if so requested, for as long as possible provided that this does not hinder or frustrate the Referral of Concerns procedure.  However, the procedure may reveal the source of the information, and the person raising the concern may need to provide a statement as part of the evidence required.  If further action is taken under the College’s disciplinary or other procedures as a result of the Referral of Concerns procedure, the person raising the concern may also be required to provide a statement or give evidence as part of that process.

Vexatious referrals
It is a disciplinary offence to misuse this procedure to make false or vexatious allegations about someone. 

Local Advisers

Prevent Local Advisers
NameArea of CollegeEmailPhone
 Dr Phil Power Faculty of Engineering
(for concerns about students)
 philip.power@imperial.ac.uk  020 7594 9990
 Mr Colin Kerr Faculty of Engineering
(for concerns about students)
 c.j.kerr@imperial.ac.uk  020 7594 6044
 Ms Su Nandy Faculty of Engineering
(for concerns about staff)
 s.nandy@imperial.ac.uk  020 7594 1628
 Dr Michael Jones Faculty of Medicine
(for concerns about students)
 m.d.jones@imperial.ac.uk  020 7594 1643
 Dr Joanne Harris Faculty of Medicine
(for concerns about students)
 joanne.harris@imperial.ac.uk  020 7594 9646
 Ms Maria Lynch Faculty of Medicine
(for concerns about staff)
 m.b.lynch@imperial.ac.uk  020 7594 0740
 Dr Simon Archer Faculty of Natural Sciences
(for concerns about students)
 s.archer@imperial.ac.uk  020 7594 5368
 Dr Lynda White Faculty of Natural Sciences
(for concerns about students)
 l.white@imperial.ac.uk  020 7594 8527
 Mr Paul Elliott Faculty of Natural Sciences
(for concerns about staff)
 p.a.elliott@imperial.ac.uk  020 7594 1764
 Dr Benita Cox Imperial College Business School
(for concerns about students)
 b.cox@imperial.ac.uk  020 7594 9164
 Dr Edgar Meyer Imperial College Business School
(for concerns about students)
 e.meyer@imperial.ac.uk  020 7594 7160
 Ms Shola Alabi Support Services
(for concerns about staff)
 s.alabi@imperial.ac.uk  020 7594 5848
 Ms Lisa Phillips Support Services
(for concerns about staff)
 l.phillips@imperial.ac.uk  020 7594 1132
Contact details

Vulnerability Assessment Framework

The following information explains how the Channel Programme assesses individuals as vulnerable using a set of principles built around three factors.

The College recommends that individuals wishing to raise a concern read this before contacting a Local Adviser.  However, the Local Advisers suggest that while this may be a useful tool for considering concerns, there may be cases where it is worth having an initial meeting even if it is unclear whether these factors apply.

In general, cases which have been referred to an external Channel group are assessed according to three factors:

Engagement with a group, cause or ideology;
Intent to cause harm; and
Capability to cause harm. 

The following reproduces guidance from the Home Office’s Channel Duty Guidance (April 2015), see paragraphs 48 - 60:    

48.        The criteria are considered separately as experience has shown that it is possible to be engaged without intending to cause harm and that it is possible to intend to cause harm without being particularly engaged. Experience has also shown that it is possible to desist (stop intending to cause harm) without fully disengaging (remaining sympathetic to the cause); though losing sympathy with the cause (disengaging) will invariably result in desistance (loss of intent).

49.       The three criteria are assessed by considering 22 factors that can contribute to vulnerability (13 associated with engagement, six that relate to intent and three for capability). These factors taken together form a holistic view of the vulnerability of an individual that will inform decisions on whether an individual needs support and what kind of support package may be appropriate. These factors can also be added to and are not considered an exhaustive list. By undertaking regular vulnerability assessments the progress that is being made in supporting an individual can be tracked through changes in the assessment.

50.        Completing a full assessment for all 22 factors requires thorough knowledge of the individual that may not be available at the point of the initial referral. However, there are a number of behaviours and other indicators that may indicate the presence of these factors.

51.        Example indicators that an individual is engaged with an extremist group, cause or ideology include:

      a.  spending increasing time in the company of other suspected extremists;
      b.  changing their style of dress or personal appearance to accord with the group;
      c.  day-to-day behaviour becoming increasingly centred around an extremist ideology, group or cause;
      d.  loss of interest in other friends and activities not associated with the extremist ideology, group or cause;
      e.  possession of material or symbols associated with an extremist cause (e.g. the swastika for far right groups);
      f.  attempts to recruit others to the group/cause/ ideology; or
      g.  communications with others that suggest identification with a group/cause/ideology.

52.      Example indicators that an individual has an intention to cause harm, use violence or other illegal means include:

      a.  clearly identifying another group as threatening what they stand for and blaming that group for all social or political ills;
      b.  using insulting or derogatory names or labels for another group;
      c.  speaking about the imminence of harm from the other group and the importance of action now;
      d.  expressing attitudes that justify offending on behalf of the group, cause or ideology;
      e.  condoning or supporting violence or harm towards others; or
      f.  plotting or conspiring with others.

53.      Example indicators that an individual is capable of causing harm or contributing directly or indirectly to an act of terrorism include:

      a.  having a history of violence;
      b.  being criminally versatile and using criminal networks to support extremist goals;
      c.  having occupational skills that can enable acts of terrorism (such as civil engineering, pharmacology or construction); or
      d.  having technical expertise that can be deployed (e.g. IT skills, knowledge of chemicals, military training or survival skills).

54.      The examples above are not exhaustive and vulnerability may manifest itself in other ways. There is no single route to terrorism nor is there a simple profile of those who become involved. For this reason, any attempt to derive a ‘profile’ can be misleading. It must not be assumed that these characteristics and experiences will necessarily lead to individuals becoming terrorists, or that these indicators are the only source of information required to make an appropriate assessment about vulnerability. Outward expression of faith, in the absence of any other indicator of vulnerability, is not a reason to make a referral to Channel.

Links with extremist groups

55.      The Prevent strategy 2011 makes clear that Channel is about stopping people becoming terrorists or supporting terrorism, and that this will mean intervening to stop people moving from extremist groups or from extremism into terrorist-related activity. Where people holding extremist views appear to be attracted to or moving towards terrorism they clearly become relevant to Channel.

56.        Association with organisations that are not proscribed and that espouse extremist ideology as defined in the Prevent strategy is not, on its own, reason enough to justify a referral to the Channel process. If professionals at a local level determine that someone attracted to the ideology of such groups also exhibits additional behavioural indicators that suggest they are moving towards terrorism then it would be appropriate to make a referral to Channel. It would be the presence of additional behavioural indicators that would determine the suitability of the Channel process and not the fact they are associating with or attracted to a group that manifests extremist ideologies.

57.      Association or support for a proscribed group is a criminal offence. It may be appropriate in some cases for individuals believed to be on the periphery of proscribed organisations to be referred to Channel. Professionals at a local level must consider whether a proscription offence has been committed before doing so. If there is evidence that a proscription offence has been committed this should be passed to the police.

58.        The vulnerability assessment should initially be completed by the CPP and then be circulated in full to panel members in advance of meetings so that all relevant panel members can contribute their knowledge, experience and expertise to the case.

59.        The vulnerability assessment should complement and inform rather than replace professional judgement and/or other assessments such as the Common Assessment Framework (or local equivalent) when deciding on the most appropriate types of support at panel meetings.

Further detail on the Vulnerability Assessment Framework is available at Annex C to the Home Office’s Channel Duty Guidance.