Definitions of harassment and sexual misconduct are defined in our Student Harassment and Sexual Misconduct Policy as follows:

• Harassment is defined in the Equality Act 2010 as unwanted behaviour or conduct related to a protected characteristic^[1] which has the purpose or effect of violating an individual’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for that person. This behaviour (which does not need to be deliberate) may be persistent or occur as an isolated incident.  In addition, you do not need to have previously objected to something for it to be unwanted.  Harassment can also include repeated contact with a person that may cause distress, fear or intimidation.
• Sexual harassment is defined in the Equality Act 2010 as unwanted conduct of a sexual nature that has the purpose or effect of violating the dignity of an individual, or creating an intimidating, hostile, degrading, humiliating or offensive environment for them. Something can still be considered sexual harassment even if the alleged harasser did not mean for it to be.  It also does not have to be intentionally directed at a specific person.
• Sexual misconduct relates to all unwanted conduct of a sexual nature that is committed without consent or by force, intimidation, coercion or manipulation such as sexual assault, sexual harassment, sexual exploitation and sexual intimidation. It therefore includes, but is not limited to:
  • Sexual harassment (as defined by Section 26 (2) of the Equality Act 2010)
  • Unwanted conduct which creates an intimidating, hostile, degrading, humiliating or offensive environment (as defined by the Equality Act 2010)
  • 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).

See our Student Harassment and Sexual Misconduct Policy for other relevant definitions and key terms as well as information on forms of harassment.  See also our Dignity and Respect Policy for some examples of unacceptable behaviour.

^[1] The protected characteristics are age, disability, gender reassignment, race, religion or belief, sex, sexual orientation, marriage and civil partnership, and pregnancy and maternity.

We are committed to creating an environment that promotes a culture of respect in which harassment and sexual misconduct are recognised as unacceptable behaviours.  We are also equally committed to promoting and advancing equality, diversity and inclusion as key features within all our activities, as we believe this to be ethically right and socially responsible.

We articulate our stance on harassment and sexual misconduct within our Student Harassment and Sexual Misconduct Policy and also with a range of other policies and documents including our Dignity and Respect Policy, Equality, Diversity and Inclusion Policy, Email Acceptable Use Policy, Internet Acceptable Use Policy, Student Charter and Student Handbook.  In addition, equality, diversity and inclusion considerations (including harassment and sexual misconduct) are covered at both staff and student inductions.

Given our commitment to the safety of our students, we will not tolerate any form of harassment or sexual misconduct and will therefore treat any allegations of such incidents extremely seriously in line with both relevant legislation (including the Equality Act 2010), regulatory requirements (including Office for Students (OfS) Condition E6) and our own internal policies and procedures.  In terms of any procedure or process relating to the treatment of allegations, we will abide by the expectation set by the OfS to take reasonably practicable steps to secure freedom of speech within the law.

We are also committed to taking steps that will make a significant and credible difference to protecting students from harassment and sexual misconduct.  These include:

• Analysing and publishing data collected from in-person reports and our Report and Support Services webpage.
• Building feedback surveys into our online training for students and staff, evaluating the results and making changes to the training where appropriate.
• Extending the specialist staff training we provide as appropriate.

We are committed to safeguarding our students from abuses of power, harassment and sexual misconduct that may arise from personal relationship with a staff member.  With this in mind, we have introduced a ban on intimate personal relationships between staff and students subject to the following exemptions:

• any intimate personal relationships that existed before 1 August 2025 and that remains in existence;
• any intimate personal relationship that existed before the date that the staff member became a staff member.

Information on relationships between staff and students can be found in our Personal Relationships Policy and Procedure.

We recognise the importance of ensuring that students understand (and recognise) what harassment and sexual misconduct is, how they can report it, the support available to them, what consent means and how to intervene effectively in the context of an incident of harassment or sexual misconduct.  As a result, all new students receive compulsory training in relation to harassment and sexual misconduct within the first few weeks of their course starting. This specialist-led training (which will include bystander training) is consistent with our Code of Practice on Freedom of Speech and Academic Freedom.  In addition, compulsory awareness raising sessions are delivered each year to returning students.

Students who have previously experienced harassment or sexual misconduct can be exempted from the above training and awareness raising sessions.

To complement the formal training and information we provide to our students, we have created an information guide on external organisations that students can contact in relation to hate crime, rape, sexual assault, domestic abuse and violence, and other crimes.

Further information can be found in our Student Harassment and Sexual Misconduct Policy.

All staff are required to complete Advance HE’s Addressing Harassment and Sexual Misconduct Affecting Students in Higher Education online training course on an annual basis.  The purpose of this course is to help staff understand professional boundaries, the nature and impact of harassment and sexual misconduct, and how to respond effectively to disclosures thereby creating safer and more inclusive environments for students and staff.

In addition, we have two trained Sexual Violence Liaison Officers: the Deputy Chief Operating Officer (deputycoo@bil.ac.uk), and the Director of our Centre for Student Engagement, Wellbeing and Success (SEWS) (sarah.bailey@bil.ac.uk) who is also the Institute’s designated Safeguarding Lead. We have also provided additional relevant training to specific staff members from both within our Academic Division and Professional Services team in the following areas given the specific roles they have been assigned in these capacities:

• Hearing disclosures of harassment and/or sexual misconduct
• Conducting investigations
• Acting as panel members

Students and staff can report an incident of bullying, discrimination, harassment, hate crime and sexual misconduct either in person or online.  Reports can also be made by others acting on behalf of students who have alleged and/or experienced such an incident, or on behalf of witnesses, from third parties, for example third party reporting centres.

Students who are in an intimate personal relationship with a staff member that Bloomsbury Institute considers to be exempt from its ban on such relationships are also encouraged to report any inappropriate behaviours from the member of staff in question.  These students would be protected from retaliation by the staff member in question if they were to report harassment or sexual misconduct by the same staff member.

There is no time limit for reporting incidents, however delayed reporting may present challenges when trying to investigate any reported incident.

Although students and staff members are encouraged to report any concerns that they may have or incidents they have experienced or witnessed with whoever they feel most comfortable doing so, they are encouraged to approach one of the members of staff who have received specialist training in relation to disclosures of harassment and sexual misconduct.  Information and contact details for these staff members can be found here.

Online reports can be made on a named basis or anonymously via the Report and Support Services page on our website.  In the case of an anonymous report, we will be unable to provide direct help to the person making that report, and we will also be unable to take formal action (e.g. disciplinary action) against someone named or identifiable.  However, the information shared will help us to offer better support to others and inform prevention work across Bloomsbury Institute.

Reporting an incident online or in person is not the same as making a formal complaint.  There is a separate process for making a formal complaint.  Please refer to the Student Complaints Policy and Procedures.

We take all reports of harassment and sexual misconduct extremely seriously.  We are therefore committed to responding quickly, sensitively and fairly to resolve (without bias) any issues or allegations as we recognise our duty of care to all within our academic community.  This includes not only the Reporting Party, the Reported Party and any witnesses to an incident, but also the wider community which may be affected by the situation.

The following policies are relevant to how we investigate allegations of student harassment and sexual misconduct:

• Our Student Harassment and Sexual Misconduct Policy defines what harassment and sexual misconduct are and sets out our approach to preventing and addressing harassment and sexual misconduct including how any investigation would be conducted.
• Our Student Complaints Policy and Procedures set out the complaints process, covering both the informal and formal stages.
• Our Student Disciplinary Policy and Procedures set out how we will investigate any allegations of harassment or sexual misconduct made against students.
• Our Staff Disciplinary Policy and Procedures set out how we will investigate any allegations of harassment or sexual misconduct made by students against staff.

Both the Student Complaints Policy and Procedures and Student Disciplinary Policy and Procedures set out in detail the relevant process with timescales for investigation and decision-making (including factors that may affect timescales), the range of possible actions, and appeal mechanisms, and  include also a user-friendly flowchart of the procedures involved.  However, if students need any support understanding the procedures, they can contact the Deputy Chief Operating Officer at deputycoo@bil.ac.uk.

Any disciplinary matter will be dealt with under the policy in place at the time the report is made.  Copies of previous iterations of policies can be obtained from our online Quality and Enhancement Manual or directly from our Quality Department.

We will deal with any allegations of harassment or sexual misconduct in a sensitive and objective manner.  We are therefore committed to supporting the Reporting Party, the Reported Party and any witnesses in any alleged incident of harassment or sexual misconduct regardless of whether a formal report or complaint is made.  This support will be available not only at the reporting stage, but  throughout any formal investigation, and following its outcome, as appropriate.

Support information and guidance is available from the Report and Support Services page on our website.

Information on external organisations that you can contact in relation to hate crime, rape, sexual assault, domestic abuse and violence, and other crimes can be found here.

We will maintain a record of disclosed incidents of harassment, sexual misconduct, bullying and/or discrimination in order to inform any further work in these areas in terms of training and changes to reporting mechanisms for example. All records are kept in line with our Records Management Policy.

We will deal with complaints on a confidential basis in line with relevant legislation and internal policies (e.g. our Data Protection and Confidentiality Policy, our Confidentiality Note, and our Duty of Care Guidance) but may need to disclose details of a complaint to other persons or organisations in order to investigate the complaint and seek an effective resolution, and also to safeguard members of our academic community.

We explain within our Student Complaints Policy and Procedures how we may use information disclosed to us, how all relevant parties affected by any decisions will be identified and what information (including outcomes) will be shared (and at what point) with each relevant party. In the event of the Reporting or Reported student requiring internal or external pastoral support, we may, with their consent, need to disclose contained information for referral purposes.

Further details about confidentiality and information sharing are provided on our Report and Support Services webpage.

We do not prevent or impose any restrictions on students disclosing information about an allegation of harassment or sexual misconduct.  As a result, we would not ask students to sign non-disclosure agreements (NDAs) in such circumstances.  Our approach here is in line with the ban that the Office for Students has imposed on higher education providers in using NDAs in relation to student allegations of harassment and sexual misconduct.