Dear Vice-Chancellor or Principal
Update on HEFCE’s Prevent monitoring activity and guidance for annual reports on 2016-17 Prevent activity
1. This circular letter provides a high-level overview of HEFCE’s monitoring of the Prevent duty in the higher education (HE) sector over the past academic year. It also provides an update and link to further guidance on the approach for annual reports from relevant higher education bodies (RHEBs) to HEFCE on Prevent activity for the 2016-17 academic year.
2. It is expected that the Office for Students will take on the role of monitoring authority of Prevent when it is fully established in April 2018. We are not expecting significant changes to the monitoring framework but we have started to consider and plan for the transition of this function to ensure it is as seamless as possible. Resources, case studies, good practice guides and other information designed to assist providers in implementing the duty which are currently published on the HEFCE website will be transferred across to the Office for Students website.
Annual reports on Prevent activity in the 2015-16 academic year
3. We received annual reports from 313 higher education providers subject to the Prevent duty concerning activity undertaken in the 2015-16 academic year. We have undertaken a detailed analysis of Prevent annual reports and the full report is available on our website at www.hefce.ac.uk/pubs/year/2017/201711/.
Key headlines from the first year of annual reports
4. In summary:
a. From our review of annual reports submitted and taking into account follow-up activity already undertaken, 95 per cent (298 providers) satisfied us that they were demonstrating due regard to the Prevent duty.
b. At the point of publication of this circular letter, we require further evidence from a further 5 per cent (15 providers) that they are demonstrating due regard to the duty. These providers have been given a deadline to submit additional evidence of active implementation, which will be reassessed by HEFCE officers and a revised outcome given as appropriate. Some providers will receive a formal Prevent review meeting to gather additional evidence.
c. No providers were assessed as not demonstrating due regard to the duty.
5. Comparing the outcomes from annual reports with the detailed assessment exercise in 2016, there has been a positive increase in compliance with the duty (though noting the two assessment processes differ).
6. In general, the analysis of the annual reports demonstrates significant progress by the sector in implementing the approaches it set out in the initial phase of monitoring. We have included in our report a range of case studies of good practice across the key themes of the Prevent duty guidance, reflecting the diversity of the sector.
7. We will work closely with individual providers to support them in addressing any feedback detailed in their outcome letters, and particularly those with a ‘further evidence needed’ outcome.
Evaluation of HEFCE’s role as monitor
8. During 2017, we undertook an evaluation of the effectiveness of the monitoring framework and of HEFCE’s role as monitor.
9. An EY audit of our approach to Prevent completed in November 2016 reported positively, noting that HEFCE’s system of internal control over the plans and governance process for the monitoring function is sound overall, and making only minor recommendations for improvement.
10. Building on this audit report, a fundamental element of the subsequent evaluation undertaken between February and May 2017 involved gathering feedback from key stakeholders, including government departments, HE stakeholder bodies, internal stakeholders, and HE providers subject to the Prevent duty.
11. The feedback gathered through the evaluation has in general been very positive and supportive of HEFCE’s approach to monitoring. A number of areas were however identified where HEFCE could further develop its approach. These relate primarily to ensuring clarity and consistency in HEFCE’s engagement with RHEBs, facilitating the sharing of positive practice through case studies and other resources, and providing a forum to identify and help address concerns faced by the sector. There was also a suggestion that the sector would welcome further guidance on annual reporting requirements.
12. The feedback indicated that providers had initially devoted a substantial amount of resource in preparing to meet the duty. However, we expect this demand to decrease after the initial preparatory period, and have already introduced measures to reduce burden further through a refined approach to monitoring.
13. The full report (at www.hefce.ac.uk/pubs/year/2017/201712/) sets out the actions to address these concerns in the next phase of work. We are therefore now shaping our work to take into account the recommendations arising from the evaluation, particularly as we work with the sector in advance of the next annual reporting cycle as outlined below.
Continuous improvement and supporting good practice
14. 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.
15. In response to areas of practice identified as needing further attention we have undertaken a series of thematic reviews pertaining to the duty. These are:
a. Approaches to managing IT access, including acceptable usage policies, filtering and managing legitimate academic access to security sensitive materials.
b. Approaches to safeguarding and welfare, incorporating considerations of equality and diversity, in relation to Prevent, including:
i. Engaging with staff and students in incorporating the Prevent duty into welfare and safeguarding policies, including working with academics and students’ unions.
ii. Working with Prevent partners, such as the police and local authorities (including best practice in sharing information about individuals and involvement in Channel panels).
16. Our approach in undertaking these thematic reviews in 2017 included identifying examples of practice that have worked well through the information submitted to us by providers in annual reports; undertaking further discussions with particular providers to examine in more detail ‘what works’ in different contexts; and delivering a series of well-attended ‘What works’ workshops in March and April 2017 that explored these areas of practice, and gave providers the opportunity to share practice.
17. We have published two blog pieces following the ‘What works’ workshops, and now intend to produce two short guides on IT and on safeguarding and welfare, drawing together the findings from our workshops alongside case studies of positive practice, and signposting to resources and support. The blog posts can be accessed at http://blog.hefce.ac.uk/category/prevent/ and the guides will be made available during summer 2017. We are also working with the Department for Education (DfE) to produce further guidance on IT filtering in advance of the next annual reporting cycle.
18. We are intending to develop a repository of case studies of positive practice to contribute to continuous improvement across the sector. This will be made available over the summer on HEFCE’s website.
19. Following the positive feedback received so far, and the clear steer from our evaluation that this work is welcomed across the sector, our intention is to deliver a similar programme of thematic reviews including ‘What works’ workshops on different themes in 2018. We will provide further information about this programme in the autumn.
Online training materials for staff on Prevent
20. We funded the Leadership Foundation for Higher Education (LFHE) to evaluate the training materials that were developed in 2016 to support the sector in implementing Prevent. The evaluation report has now been finalised, and the findings were broadly positive. The overarching finding is that providers have found the materials to be comprehensive and accessible, and that a very high proportion of users considered that the training had had a positive impact on their knowledge of Prevent and their capacity to act appropriately in relation to the Prevent duty.
21. The evaluation identified a small number of recommendations for improvements to the materials, which the LFHE is taking forward in conjunction with HEFCE, DfE and Universities UK. Refreshed training materials will be launched at the beginning of the 2017-18 academic year, and we are working with LFHE to implement an accreditation certificate for the e-learning module, enabling staff who undertake the module to certify that they have completed the training even if it has not been integrated into their institution’s virtual learning environment. The refreshed materials will include a short briefing document providing an overview of the key components of Prevent and further guidance for providers on how the training materials can be used, including how they can be tailored to meet the individual needs of providers. Case studies which were developed as part of this evaluation, demonstrating how the materials have been used by different providers, will be published on the Safe Campus Communities website as part of this package of refreshing the training materials.
22. The Safe Campus Communities website hosts the training materials and is a repository for other sources of advice and guidance in relation to Prevent. We are working with LFHE, DfE and Universities UK to scope out arrangements (and the associated resource requirements) for the longer-term sustainability of the materials.
Overarching monitoring framework for Prevent from 2016-17 onwards
23. In September 2016, we published an updated framework (www.hefce.ac.uk/pubs/year/2016/201624/) for the monitoring of Prevent within the higher education sector. Having been through a first cycle of annual reporting, we have made some minor amendments to this document to ensure that it can act as a standalone, authoritative framework, but have made no substantive changes to our approach nor to the expectations on providers. The key changes to the framework are set out below and the full document is available at www.hefce.ac.uk/pubs/year/2017/201710/. We have also brought together our learning from the past two years of monitoring the Prevent duty in the higher education sector into an updated version of our advice note (available at www.hefce.ac.uk/reg/prevent/framework/#advice).
Information regarding annual reports for 2016-17
24. We have reflected on the submission deadlines for annual reports from HEFCE-funded providers and alternative providers. As of this year, constituent colleges will submit their annual reports in line with all other HEFCE providers. Given the amalgamation of these two deadlines, we have concluded that to ensure a reasonable turnaround of outcomes, the deadline for alternative providers should be extended by one month to 1 March 2018. This will enable us to ensure that all follow-up activity with HEFCE-funded providers is well under way before starting to assess reports from alternative providers. Any provider that completes their report before the deadline will be able to submit it earlier, but should not expect to hear from us in advance of the timescales set out in the accompanying ‘Guidance for Prevent annual reports for 2016-17’ (available at www.hefce.ac.uk/reg/prevent/framework/#annrep) which provides an overview of the assessment cycle.
25. Deadlines for annual reports for the 2016-17 cycle to be submitted are therefore as follows:
· for HEFCE-funded providers, including collegiate universities – 1 December 2017
· for alternative providers and ‘other providers’ – 1 March 2018.
26. The standalone monitoring framework sets out our broad expectations of the content of the annual report, but each year we will provide higher education providers with specific information and guidance relating to the next phase of annual reporting. While we have not provided a template for the narrative surrounding the annual report, we have listened to feedback from the sector through the evaluation, and as such we have provided more detailed information on the type of evidence that we are looking for and how this might be structured in a submission to HEFCE.
27. We will be running a series of short workshops and a webinar in September and October 2017 to provide further support and guidance on our expectations in relation to the next annual report cycle in 2016-17. Further information on these events will be provided over the summer to the Prevent lead at each provider.
28. Should you have any specific questions on the above, please contact your named Prevent adviser or firstname.lastname@example.org with any general queries.
29. Finally, may I take this opportunity to thank you for your active and positive engagement with this policy, and to recognise the volume of work that has been undertaken across the sector to meet the requirements of the duty.
Professor Madeleine Atkins