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Exceeding Expectations: How the OfS’ guidance on harassment could (and should) go further

Gemma McCall, CEO, Culture Shift

With the first in-person Induction Week for two years in touching distance, university leaders need to be sharpening their focus and fostering a sense of urgency around the pervasive issue of harassment on campus. 

When in April this year, the Office for Students released its finalised Statement of Expectations; a 7-point guidance for universities on tackling harassment and sexual misconduct on campus, it was welcomed.

However, while undoubtedly something is better than nothing, we believe the guidance was long overdue and could go further.

We also worry that it opens up the possibility of universities doing work simply to ‘tick boxes’, without creating meaningful and long-lasting change. 

So, this week we’ve launched some achievable recommendations that build directly on the OfS’ guidance, providing more robust direction and advice for universities looking to tackle harassment and create lasting change.

For clarity, we use ‘harassment’ as an umbrella term covering all forms of sexual misconduct, racial abuse, discrimination towards the LGBTQ+ community, bullying and any behaviour deemed to be inappropriate by the victim. 

With a focus on both prevention and report management, our handbook draws on specialist experience and successful case studies to provide a framework for change.

Where up until now focus across the sector has primarily been on sexual violence on campus, we are encouraging institutions learn from their work in this area and apply it to harassment of all kinds, helping to create safer and happier environments for all staff and students. 


Attempting to sum up a 5000+ word handbook into a 950-word blog means it won’t be comprehensive, however, we’ve broken it down into six key action points below.

Action #1: Build prevention tactics into your strategy and budget 

Unfortunately, harassment continues to exist in institutions despite the existence of behavioural and disciplinary policies. Universities need to move beyond policy, and ingrain action into their ways of working. Our video interview with Professor Graham J. Towl provides advice on how to plan anti-harassment activity into your strategy, on-board senior leadership, and develop realistic tactics to help prioritise your budget.

Action #2: Use real-time data to guide effective planning and governance

Creating change can be time consuming, and often the governing bodies and task forces created to tackle harassment are time poor. Gathering data effectively, and in real time can ensure that you’re acting on the known risks within your institution. Our video interview with London School of Hygiene and Tropical Medicine provides a great case study for using this data to help prioritise your planning and inform governing bodies.

Action #3: Build partnerships to create change from the bottom up 

Change cannot only come from the top down. A bottom-up approach needs to be considered in the development of policies and procedures. However, in order for these policies to be effective, you also need to understand the cultures that are causing problematic behaviour on campus. This requires the ability to effectively communicate with diverse student groups.

Empowering diverse student groups to speak up and engage in the process is vital to ensuring that your support structures don’t ignore some of your most vulnerable students and staff. We spoke with the Birmingham City University Students’ Union to understand how they create change from the bottom up. 

Action #4: Combine targeted training with targeted campaigning 

Compulsory training without context can often be ineffective, impacting the internalisation and implementation of learnings. Trainees need to understand the relevance and importance of training, and it needs to be targeted and relevant to the contribution of specific groups into your university. Communication on why it is needed is also imperative. When planning your training strategy, first understand what can be delivered internally and be honest about where external expertise is necessary. We recorded a case study with SOAS to see how they’re creating training programmes tailored to the needs and requirements of their students and staff.

Action #5: Break down barriers to disclosing and reporting 

98% of cases go unreported. There are a variety of reasons why, and these need to be deeply understood. Not only so you can campaign and create policies to remove barriers for students, but to ensure that you have a full view of the issues impacting your university, and can truly begin to tackle harassment. This requires research, and providing students with multiple options for disclosing information that suit their needs and comfort. In our case study with Bath Spa University you can see how they’re understanding and removing barriers to reporting.

Action #6: Support students throughout the reporting process 

Reporting cases of harassment can be emotionally and mentally difficult. Trauma can be compounded by difficult reporting processes, therefore it’s important to ensure that a lack of information doesn’t become a barrier to reporting. Reducing the negative impact of reporting not only makes the process smoother but also helps to build a positive culture of reporting. We spoke to Clarissa Humphreys for an expert opinion on best practice when managing student complaints and investigations.

Accountability considerations for senior leaders 

We believe that when it comes to harassment, senior teams should be held accountable to the same expectations/sanctions as not achieving other growth targets. So, we also suggest five key questions HE leaders should ask themselves:

  • Do you have data showing the existence of harassment issues within your institution? If not directly, do you know where to get it?
  • Do you understand the impact that harassment is having on your students in terms of use of support services, academic performance, dropout and applicant rates?
  • Do you know where issues within your university are most prevalent?
  • Do you know how frequently your support, discipline and procedural policies and processes are updated?
  • Do you know the level of investment into tackling harassment on campus?

Working together for change

While the OfS’ guidance is undoubtedly essential, from every angle HE providers are being reminded of the need to do more when it comes to harassment. A new academic year brings with it another opportunity for positive change, so we show our support and respect to those already working hard to create this change and to those starting out on their journey to creating safer places of study everywhere. 

Gemma McCall, CEO and co-founder of Culture Shift, the impact software business that works with 70 UK universities and colleges to tackle harassment and bullying.

Exceeding expectations to tackle harassment and sexual misconduct in HE 

30th Nov 2020: The COVID-19 pandemic has resulted in incredibly challenging times for higher education (HE) institutions. From reports of increased hate crime, particularly amongst the Chinese population, to students experiencing a sharp increase in online harassment, tech-for-good developer, Culture Shift, is encouraging institutions to use this critical time to assess practises and processes to ensure the entire student population feels safe and included.

Towards the end of 2019, it was revealed that reports of rape, sexual assault and harassment at UK universities have tripled in three years, with data from 124 of 157 universities highlighting that not all have robust systems to prevent or respond to sexual violence. Due to the growing issue, which continues to be rife on campuses across the UK, the Office for Students (OfS) set out suggested expectations for universities and colleges to follow.

In response to OfS’ consultation on harassment and sexual misconduct in HE, which is currently paused due to the pandemic, Culture Shift has released “Exceeding expectations: guidance on tackling harassment and sexual misconduct” a report highlighting key takeaways for institutions to implement in order to tackle problematic behaviour and exceed the expectations set out.

“Now is the time to evaluate systemic inequity within institutions and ensure there is effective support in place for those further marginalised by recent events. Our report hones in on recommendations for HE institutions to tackle racial harassment and sexual misconduct, including outlining a survivor-centric approach, while also offering advice for institutions to create safe and inclusive spaces where those affected can report and access appropriate support.

“As part of the report, we also interviewed prominent figures from various organisations including University College London (UCL), Rape Crisis South London, Stop Hate UK, University of Surrey, Goldsmiths, and University of London, on everything from how they support survivors of harassment and sexual misconduct, to the work they’re doing to break down barriers and tackle the issue,” comments Gemma McCall, CEO, Culture Shift.

The core takeaways from Culture Shift’s report that HE institutions can adopt to instil change now, include:

  • Helping to remove barriers to reporting by making the reporting process easier
  • Sharing regular updates/signposting to different support services, including any specialist partnerships the university may have in place
  • Reviewing how the university receives disclosures or reports and reducing the number of times a person may need to disclose or share their information
  • Embedding principles of fair treatment within investigation processes to ensure this is carried out swiftly and the report is shared with both parties
  • Ensuring staff and students are appropriately trained to receive disclosures
  • Consistently and persistently communicating the institution’s stance on harassment and sexual misconduct, as well as the reporting pathways and support available

“Despite the fact that the consultation is currently paused by the Office for Students, institutions have long-needed to improve their handling of harassment and sexual harassment. Prevalence is still too high and reporting levels too low. We know from the consultation what the expectations are likely to be, so universities actually have the opportunity to get ahead and put things in place so they can exceed them, not just meet them.

“This report builds on the work from the EHRCNUSUUK and the 1752 Group and gives universities practical advice to drive real positive change. I truly believe we cannot wait for pressure from the regulator to do the right thing, the time is now to create a world of work and study which is safe, inclusive and supportive for everyone,” continues Gemma.

Culture Shift exists to lead positive change in organisational culture, through building products that empower them to tackle harassment and bullying. Its proprietary online reporting platform ‘Report + Support’ gives organisations the insight they need to monitor and prevent bullying and harassment, and support anybody who experiences it.

The underlying principles of removing barriers to reporting and providing a survivor-centred approach and support, were originally developed in collaboration with the Equality, Diversity and Inclusion team at the University of Manchester in February 2017. Since then, Culture Shift has worked with over 60 universities in the UK and Europe to implement positive change.

“The evidence to prove that no place is untouched by this problem is irrefutable. Now it’s time for institutions to take action and a preventative approach to tackling problematic behaviour,” concludes Gemma.

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