1. This monitoring framework sets out how HEFCE will monitor providers’ implementation of the statutory ‘Prevent duty’ in the higher education sector in England. Relevant higher education bodies (defined in paragraph 19) will need to follow this framework to demonstrate due regard to the duty. The framework also sets out how we will support providers and enable the effective sharing of experience and good practice.
2. This framework should be read in conjunction with further guidance produced for the relevant reporting year, which will be published at least three months in advance of the reporting cycle. Please see the HEFCE website for further information (www.hefce.ac.uk/reg/Prevent). Further resources and guidance documents are available on the HEFCE website, including an ‘advice note’ (at www.hefce.ac.uk/reg/prevent/framework), which sets out overarching advice and a number of questions for providers to consider when developing policies, processes or arrangements in relation to the implementation of the Prevent duty.
3. Under the Counter-Terrorism and Security Act 2015, relevant higher education bodies (RHEBs) must have due regard to the need to prevent people from being drawn into terrorism (the Prevent duty). HEFCE is responsible for monitoring whether RHEBs are demonstrating due regard to the Prevent duty. Responsibility for ensuring compliance with the legal duty sits with the governing body or proprietor of the RHEB. By ‘proprietor’ we mean the individual or individuals with strategic oversight of an RHEB’s activities, including ultimate responsibility for its financial management.
4. This updated monitoring framework was issued on 1 August 2017. This supersedes the ‘Updated framework for the monitoring of the Prevent duty in higher education in England’ (HEFCE 2016/24), published in September 2016.
5. This framework is for:
- Prevent leads, senior management and governing bodies of HEFCE-funded higher education institutions
- Prevent leads, senior management, governing bodies and proprietors of other relevant higher education bodies in England, specifically:
- alternative providers that are subject to specific course designation processes administered by HEFCE
- other providers that offer higher education to more than 250 students and are not monitored by either the Office for Standards in Education (Ofsted) or the Department for Education (DfE)
- the autonomous colleges, schools and halls of the Universities of Cambridge, Durham and Oxford.
6. To be assessed as ‘having due regard’ for the Prevent duty, all RHEBs must have robust policies and processes in place which respond to the Prevent statutory guidance, and must demonstrate that they are actively implementing these policies.
7. All RHEBs will need to submit a short annual report every year, summarising any relevant evidence which demonstrates their continuing active and effective implementation of the Prevent duty as outlined in Section 1. Annual reports should be submitted by all HEFCE-funded providers (including the autonomous colleges, schools and halls of the Universities of Cambridge, Durham and Oxford) by 1 December each year, and for alternative providers (including other providers that offer higher education to more than 250 students) by 1 March.
8. In addition, HEFCE will carry out face-to-face ‘Prevent reviews’ on the basis of risk where we have particular concerns.
9. Providers will also need to report to HEFCE as soon as possible:
- any material changes to policies which HEFCE has previously assessed (such as a significant change to an information technology policy as it relates to Prevent)
- any significant changes of circumstance impacting on the provider’s Prevent responsibilities (such as a change in Prevent lead)
- any serious Prevent-related incidents as outlined in Section 3.
10. Providers will be assessed as having ‘due regard’ to the duty if they satisfactorily demonstrate that they both:
- have appropriate policies and processes in place in response to the Prevent statutory guidance
- are following these policies and processes in practice.
Reporting by HEFCE to Government
11. HEFCE will report on a periodic basis to the Department for Education and will publish annual updates on our monitoring work. We may also report to Government on an ad hoc basis, including where a provider has been found not to be demonstrating due regard to the duty following the procedures outlined in Sections 3 and 4.
Supporting good practice and ensuring continuous improvement
12. As part of HEFCE’s role as monitor for Prevent, we are keen to ensure that alongside the formal processes to monitor providers’ ongoing due regard to the Prevent duty, we promote an environment of continuous improvement and support the development and sharing of ‘what works’ in the higher education sector. We continue to work closely with Government, providers, key sector stakeholders and our external advisory group to achieve this through the following activities: undertaking a series of thematic reviews or ‘deep dives’, co-ordinating further ‘What works’ workshops to facilitate the sharing of good practice, and undertaking visits to providers where appropriate to gather further feedback on any new issues and practices.
13. An ‘Evaluation of monitoring of the Prevent duty in higher education’ (HEFCE 2017/12, www.hefce.ac.uk/pubs/year/2017/201712/) highlights the generally positive feedback we received from providers and Government about the light-touch and risk-based approach we have taken to monitoring, with providers welcoming in particular our focus on supporting the ‘What works’ programme and the sharing of good practice. We will continue to evaluate the effectiveness of this monitoring framework and of HEFCE’s role as monitor to ensure it remains fit for purpose. Where this may result in changes to the monitoring framework for future years, we will give providers sufficient notice of any changes which affect them.
Office for Students
14. The Higher Education and Research Bill, passed by Parliament in April 2017, means that from 1 April 2018, a new single regulatory body for higher education will be created – the Office for Students. HEFCE’s regulatory functions will transfer to this new body, including responsibility for monitoring of the Prevent duty. This revised framework has been developed in line with the Office for Students’ proposed approach to regulation and will be kept under review as the organisation evolves.
15. Further information is available through the HEFCE website at www.hefce.ac.uk/reg/prevent/.
16. Every institution has a named Prevent adviser at HEFCE. A list of the advisers and their contact details can be found at www.hefce.ac.uk/contact/. Generic queries can be sent to firstname.lastname@example.org
17. Support and guidance can also be accessed through the network of Department for Education Further Education and Higher Education Prevent Coordinators. Details of the Coordinators can be found at www.hefce.ac.uk/reg/prevent/framework/#contact.