Prevent Policy

Vulnerabilities

Indicators

Peer pressure

Withdrawn

Unsettled family life

Change in engagement levels

Need to belong/fit in

Using extremist language, passionate about extremist views

Accessing extremist material

Preaching

Isolation and social exclusion

Change in appearance – dress/body art

Bullied

Change in behaviour within work or learning environment

Media influence

Change in social circles

Natasha Lyon

Assessment Coordinator

Lead Safeguarding Officer. Day-to-day responsibility for ensuring these policies are put into practice

[email protected]

+44 (0)1780 722900  

Mary Delahunty

Qualifications & Apprenticeship Delivery Manager

Safeguarding Officer and Qualifications & Apprenticeship Delivery Manager who reviews the effectiveness of this policy in the annual Credit Academy Self Assessment Report

[email protected]

+44 (0)1780 722900  

Andrea Perry

Learning and Development Co-ordinator

Deputy Safeguarding Officer who contributes to the review of this policy and supports related administration of training and DBS checks

[email protected]

+44 (0)1780 722900  

Trainers/tutors/ coaches

Responsibility to report any concern or issue regarding safeguarding to the Safeguarding Lead or other responsible person identified in CICM policies, e.g. regarding safeguarding issues.

Examiners/ moderators/ apprenticeship assessors

Responsibility to report any concern or issue regarding safeguarding to the Safeguarding Lead or other responsible person identified in CICM policies, e.g. regarding safeguarding issues.

Risk area identified:

The Counter-Terrorism and Security Act 2015 places a duty on all education providers to prevent people from being drawn into terrorism. This is part of a wider government strategy to prevent terrorism and disrupt and stop terror attack.

Notes:

CICM mainly delivers qualification classes online or at an employer’s premise. Risks are minimised because the content is controlled classes and classes are easily monitored. As CICM has learners drawn from widespread areas, including outside the UK, tutors and learners are used to working constructively with others from a range of cultural backgrounds.

Also CICM works in partnership with Apprenticeship Training Providers (as a support provider) which reduces risks because their coaches visit apprentices regularly and therefore can observe the workplace environment and deliver Prevent training. Also they have monthly meetings with the CICM Credit Academy where they highlight any apprentice or tutor concerns.

Risk owner:

Mary Delahunty Qualifications & apprenticeship Delivery Manager Natasha Lyon Assessment Coordinator (Safeguarding Lead)

Risk team members:

Andrea Perry Learning & Development Coordinator,

Gross (or inherent) risk

Status of risk without taking into account any risk response that CICM already has in place

Net (or residual) risk

Status of risk after taking into account any risk management responses that CICM already has in place

Risk decision

LIKELY TO REDUCE

Gross impact (A)

4

Net impact (C)

4

Target impact (C)

4

Gross likelihood (B)

3

Net likelihood (D)

2

Target likelihood (D)

1

Gross score (A*B)

12

Net score (C*D)

8

Target score (C*D)

4

Score rationale:

Due to CICM delivery arrangements and the nature of CICM learners, as explained above the risk of radicalisation or extremism is reduced. CICM policies and training reduces this further. The risk score is likely to reduce further as CICM policies become further embedded,

Description of potential impact

• CICM personnel may inadvertently fail to recognise and prevent radicalism which could lead to extremism and an act of terrorism.
• CICM personnel may raise concerns about a member of staff or learner but senior managers may not understand the potential seriousness and fail to report concerns.
• CICM personnel may not be aware of CICM policy and therefore be unsure how to handle a concern.
• CICM may be directly attacked by an act of terrorism.

Potential contributing factors i.e. increasing likelihood

Online risks

• Extremist organisations are able to radicalise students online and encourage them to commit acts of violence or incite others to commit acts of violence as ‘lone actors’.
• Learners (and staff) are able to access unlawful radicalising material which promotes proscribed terrorist groups.

Inadequate partnerships

• CICM does not establish effective partnerships with organisations such as the Local Authority, Police Prevent Team, DfE Regional Coordinator and others and therefore CICM is not fully appraised of national and local risks and does not have access to developing good practice advice or supportive peer networks. 

Lack of leadership understanding

• Leaders within CICM do not understand the requirements of the Prevent Statutory Duty or the risks faced by CICM and the Duty is not managed or enabled at a sufficiently senior level. The result is that CICM does not attach sufficient priority to Prevent Action plans (or does not have one) and therefore action to mitigate risks and meet the requirements of the Duty are not effective.

Lack or inadequate of training on Prevent

• Staff are not aware of the factors that make people vulnerable to radicalisation and terrorism and are unable to recognise the signs of vulnerability and therefore are unable or unwilling to refer concerns.
• Leaders and staff feel unable or unwilling to challenge extremist narratives or exemplify British Values throughout the organisation.
• Staff are unclear on how to deal with or refer concerns resulting in individuals not being supported and potentially radicalisation remaining unchecked.

Speakers and events

• Extremist organisations are given a platform to radicalise young people because the organisation has ineffective processes in the place for vetting speakers and events.
• Inappropriate or extremist materials are shared with learners (face to face or via weblinks) because insufficient checks are made of external speakers and materials that they promote or share.

Inadequate welfare and pastoral care

• CICM does not provide effective welfare and pastoral support which results in learners (and staff) being unsupported and the risk of vulnerabilities being exploited.

Prayer and faith facilities

• Requirements of learners (or staff) requiring faith support or the use of facilities are not met by the organisation resulting in individuals seeking external support of unknown suitability
• Facilities (either prayer rooms or quiet space type facilities) provided are not effectively managed or supervised and become ungoverned spaces where radicalising, inappropriate or dangerous activities can take place.

Work based learners

• CICM does not have robust processes in place to protect work based students from the risks of radicalisation or views and practices contrary to British Values.
• Employers within work based settings are unaware of issues relating to Prevent the Statutory Duty and how to report concerns.

Promoting British values

• CICM does not have a culture and ethos where British Values are celebrated, which leads to a culture of disrespect and intolerance and where tensions are allowed to flourish.
• Staff and learners do not understand BV (or feel confident about) and extremist views and narratives are allowed to flourish unchallenged.

CICM HQ security

• CICM  does not have sufficient security of its premises and learners are targeted by individuals or groups seeking to share their extremist views or endanger their personal safety.

Control process/procedures or mitigating factors that will reduce impact of likelihood associated with risk

Monitoring process/procedures or early warning alert

Establish a policy which identifies vulnerabilities and indicators of radicalism; factors contributing to vulnerability; referral pathways and key contacts.

Review policy annually/monitor post lesson feedback on lessons for any concerns which may indicate a vulnerability.

All CICM tutors are required to complete training on Equality and Diversity, Safeguarding and PREVENT every two years to refresh their knowledge and Key CICM administrators complete PREVENT training and review the CICM policy.

CICM Credit Academy Board and main apprenticeship training providers audit completion or mandatory training annually.

CICM tutors have a code of practice which supports inclusion; requires them to role model and exemplify British values of ‘democracy, the rule of law, individual liberty and mutual respect and tolerance for those with different faiths and beliefs in our practice; challenges any form of stereotyping or use of sarcasm, insults or belittling comments; and requires the reporting any concerns or signs of extremism.

Feedback from tutors in attendance/ homework logs.

Lesson observations have quality criteria that monitor for evidence of Professional values, equality & diversity, safeguarding, PREVENT in lessons.

The work of CICM tutors is reinforced by Apprenticeship Training Providers coaches who observe the workplace environment, deliver PREVENT training and have monthly meetings with CICM Credit Academy where they highlight any concerns.

CICM Safeguarding Officer understands how to contact the local Police PREVENT Officer where there are concerns about radicalisation.

CICM Credit Academy Board monitors CICM records of any referrals and annual self-assessment against this requirement.

Content of CICM online communication and messages related to CICM is strictly controlled and monitored by CICM Marketing team and any concerns are reported to CICM senior management team.

Although tutors and learners tend not visit CICM HQ, the building has good security with locked doors requiring a code to access, visitor signing in protocols, and an alarm when the building is unoccupied.

Gaps

Contingency and notes

CICM Safeguarding Officer will report concerns about a risk of radicalisation to the local Police PREVENT Officer and will report the matter to the CICM Senior Management team.

Local police departments have standard procedures to assess risks, establish warnings and set up safeguarding measures if CICM personnel receives a threat or the police felt that CICM or CICM personnel were under threat. The outcome may involve an investigation and action such as markers on people’s phones or addresses, warning to parties involved and arrests being made.

Risk scores

Likelihood

Impact

1

very unlikely

1

negligible

2

fairly unlikely

2

minor

3

50/50 chance

3

moderate

4

fairly likely

4

fairly serious

5

almost certain

5

disastrous