From time to time I have what I tend to call “vanishing point” weeks, where lots of the conversations I have with people, and plenty of the things I read, seem to all, in the end, boil down to the same thing.
I was interested, for example, to see that one of the comments underneath Jonathan Simons’ piece on the new OfS Director for Fair Access and Participation identified (academics) working (directly) with children – as part of a new focus on raising attainment in schools – as a potential problem. Given lots of educational charities work in schools, I just thought “ah, well that’s a safeguarding issue, that”.
I was intrigued to talk to an SU this week about the polling they’d done that showed that student safety is coming up a lot as an issue in the feedback. It’s partly about the spiking stuff and reclaiming the night, partly about race and racism on campus, and partly about the state of the student accommodation that some have to live in. “They’re all, in a way, student safeguarding issues” I thought to myself.
I was surprised to find myself in the middle of a decent chat about what the strategic, pedagogical response to a student body that appears to be more anxious than usual might be. Once we stop seeing mental health only as an individual-to-be-treated issue, I unexpectedly was in the middle of a clever conversation with course reps about the things academics do that make students’ anxiety better or worse. “That’s actually a kind of safeguarding issue”, I was thinking.
I was also pleased to take part in a conversation about sexual harassment and midconduct on campus, which covered all sorts of bases – the appropriateness and potentially exploitative harms of staff-student relationships, the confidence that students need from other students to make complaints (and whether those “other students” are then carrying too high a burden), the sorts of students that may not even recognise what they’re experiencing as abuse, and the culture of radicalised misogyny bubbling up online for some young males.
All of them, in one way or another, safeguarding issues – and all raise interesting questions about the role, duties and powers of universities, and the way these issues are prioritised, prevented, managed and mitigated in the round.
Are you sitting uncomfortably
There is a really unhelpful narrative that surrounds “safety” in the context of the campus. There are clearly generational differences that surround the meaning of, awareness of and need to protect people in relation to “emotional safety” – a conflict that’s not made any easier by Spiked! and their ilk fusing with the “never did me any ‘arm” mob in the commentariat.
It’s unhelpful because too often, I see characterisations from commentators that suggest that university as an “adult” environment should somehow be dangerous, while students clamour for it to be safe, as if it was that simple – and until something bad happens, when those calling for university to be “dangerous” suddenly revert to panicked parent mode and demand the infantilization of students because, after all, this should have been prevented and why aren’t they looking after them and something must be done.
Beyond what can often be childish, culture wars characterisations, surely we can evolve a more sophisticated understanding of “safety” – that sets it up a reasonable expectation of an environment, based on a proper assessment of risk, on the basis that it’s probably a precursor for learning? And surely we can get beyond characterisations that swing between treating students like six-year olds on the one hand, and hedonistic Evel Knievels on the other – and instead recognise and consider how to support this “middle stage” of adulthood that manifests in the research?
Look over there
I raise all of this partly because over in the voluntary sector, this week has been something called “Safeguarding Adults Week”, an annual event that draws in charities, councils, government departments and others that is organised annually by the Ann Craft Trust – a charity that supports organisations to safeguard adults and young people at risk. This year’s theme has centred around “creating safer cultures”, and there’s all sorts of resonance for higher education.
And before I go on, this is absolutely not just about “vulnerable adults”.
There’s been a big focus during the week on promoting safer cultures, exploring how organisations and individuals can take steps to minimise harm occurring in the first instance, whilst simultaneously ensuring that good policies and procedures are in place so that safeguarding concerns that are raised, are recognised and responded to effectively. Why wouldn’t universities want do this?
On Monday there was a whole theme around emotional abuse and mental health, exploring how organisations can be emotionally aware and promote respectful cultures where people can speak out without fear of reprimand. Surely universities would want to do this?
Tuesday discussed language, Wednesday covered online safety, Thursday looked at grooming and relationships where power is exploited, Friday tried to identify those less likely in an organisation or beneficiary group to raise complaints or concerns, and Saturday covered making these things everyone’s concern rather than just the senior types. All salient issues for universities, all in our own in the press and in the minds of students and activist campaigners. So why haven’t universities played a leading role in the week?
Enter the regulator
I also raise all of this because as part of the week, the Charity Commission updated its guidance this week on safeguarding and protecting people who come into contact with a charity (including staff and beneficiaries). It says that protecting people and safeguarding responsibilities should be a “governance priority” for all charities. It says doing so is a “fundamental part” of operating as a charity for the public benefit.
It reminds charities that they must take reasonable steps to protect from harm people who come into contact with a charity, will hold trustees to account if things go wrong, and will check that trustees followed the guidance and the law.
It expects charities to assess and set out risks and how they will be managed in a risk register which is regularly reviewed. This is risks to people – not buildings, or finances, or reputation or a drop in international recruitment – it’s a strategic review of the risks to actual people.
It covers all sorts of things – sexual harassment, abuse and exploitation, people abusing positions of trust, bullying or harassment, discrimination on any of the grounds in the Equality Act 2010, self-neglect, extremism and radicalisation and more besides. It expects charities to respond to concerns and carry out appropriate investigations, to not ignore harm or downplay failures, and make sure (and demonstrate) that protecting people from harm is central to its culture.
It’s why the big national charities almost all have a safeguarding strategy, a suite of policies, director level posts that consider these issues in the round, and projects which focus on establishing a shared understanding of everyone’s responsibilities.
So given that the majority of universities are charities, why aren’t all of these expectations that are placed on charities in a strategic, risk based way also ones that are straightforwardly also placed on universities?
At least in England, technically and officially the Office for Students acts as the “principal regulator” of universities as charities – the working assumption being that OfS’ powers overlap in such a way as to mean it’s possible to safely downgrade the Charity Commission’s direct role over universities.
But that assumption is a problem. OfS rarely talks about safety or the safeguarding of staff, students and others that come in to contact with universities in this strategic sort of way, and within universities there’s nothing like the level of coordination and sophistication we might see over these sorts of issues in the big national charities. Are there projects and initiatives on various bits of this? Yep. Are they disjointed and contested and often seem to focus on the wrong things at the wrong times? Yep.
That’s not to say that the university where you work doesn’t take student suicide seriously, or hasn’t looked at the briefing on student initiations, or hasn’t had a read of the online harassment guidance that UUK put out. It’s that all this stuff is so bitty, overlapping, confusing, hard to find, and not integrated. And until everyone in the university understands their role in this sort of stuff, it’s all shiny briefings on shelves rather than work that works.
Put another way – students don’t know what they can expect their university will and won’t do to keep them safe. And not only does that mean they can’t hold them to account if they don’t, remember – the enemy of satisfaction is unmet expectations.
All of which leads me to a simple, straightforward conclusion. Both in Wales in the new commission, and England via OfS (I’ll have a think about SFC and Scotland and ponder NI), there should be a condition of registration on providers that requires them to demonstrate
that in developing and implementing policies, procedures and practice, they have given due regard to relevant guidance about protecting people from harm.
It would involve developing a strategic assessment based on the students and staff at that provider, gathering feedback and stats from students and staff, making the issue everyone’s problem, having a focus on those most vulnerable, and would cover off the careful debate about where safety stops and reasonable risk starts.