While we do not oppose the idea of a condition of registration relating to harassment and sexual misconduct, it is essential that information collected on any kind of register is held on a restricted basis, adhering strictly to ICO requirements; that information about individual incidents are not published; and that data must only be used for the limited purpose for which it is collected. Inspection of any registers must be by an independent reviewer only. This is to protect both staff and students from data breach and unfair treatment.
We agree that the policies that HE providers use to respond to and address sexual misconduct, harassment and violence should be displayed on their websites.
We are concerned that the consultation does not ask about trauma-informed responses to sexual violence, meaning detailed answers cannot be included in responses. The criminal side of tackling harassment and sexual misconduct is therefore driven by safeguarding procedures, which may not adequately cover the full range of behaviours the regulation seeks to cover.
Full response to consultation