Student Worker & Hourly Paid Worker

Mandatory Compliance Training Booklet

Applicable to: Student workers, Hourly paid and other employment options e.g.
Invigilators, Temporary Consultants / Contractors

Date Last Reviewed: August 2021 (UKVI & Prevent updated)

Next Review Date: August 2023

Policy/Procedure Owner: Human Resources (Author) / Compliance Owners

Updated August 2019

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Contents

Anti-Bribery & Corruption Policy...........................................................................................................3

Conflict and Declaration of Interest Policy............................................................................................7

Data Protection: Summary....................................................................................................................9

Diversity in the Workplace – Summary................................................................................................13

Environmental Sustainability...............................................................................................................16

Health and Safety Module 1: Summary...............................................................................................17

Health and Safety Module 2: Summary...............................................................................................18

Display Screen Equipment.................................................................................................................19

Prevent................................................................................................................................................20

UKVI - Student Worker........................................................................................................................24

Safeguarding........................................................................................................................................29

Acceptance Page.................................................................................................................................30

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Anti-Bribery & Corruption Policy
Procedures in Respect of Gifts and Hospitality

Introduction

1.1. It is the policy of the University that all staff and students conduct business in an honest way,
and without the use of corrupt practices or acts of bribery to obtain an unfair advantage.
1.2. Bribery is a criminal offence in most countries and corrupt acts expose the University and its
employees to the risk of prosecution, fines and imprisonment, as well as endangering the
University’s reputation.
1.3. This policy is reviewed annually by the University’s Audit Committee. Concerns and comments
may be reported, in confidence, to the Secretary to Council who has oversight of the
management of the policy within the University. Staff are advised that this policy should be
considered in conjunction with the University’s then-current whistleblowing procedures.

2. What does the policy cover?

2.1. This anti-bribery policy exists to set out the responsibilities of the University and those who
work for the University in regards to observing and upholding our zero-tolerance position on
bribery and corruption.
2.2. The policy acts as a source of information and guidance for those working for the University
and helps them recognise and deal with bribery and corruption issues, as well as understanding
their responsibilities.

3. Policy statement
3.1. The University is committed to conducting business in an ethical and honest manner, and is
committed to implementing and enforcing systems that ensure bribery is prevented. The
University has a zero-tolerance for bribery and corrupt activities and is committed to acting
professionally, fairly, and with integrity in all business dealings and relationships, wherever we
operate.
3.2. The University will constantly uphold all laws relating to anti-bribery and corruption in all the
jurisdictions in which we operate. The University is bound by the laws of the UK, including the
Bribery Act 2010, in regards to its conduct both at home and abroad.

4. The University takes its legal responsibilities seriously and recognises that if it is found to have
committed any bribery and corruption offences that it could be subjected to an unlimited fine, be
excluded from tendering for public contracts, and face serious damage to its reputation.
Individuals found to have committed any bribery and corruption offences could face a ten year
prison sentence and unlimited fines.

5. Who is covered by the policy?

5.1. The policy applies to all staff and officials including Directors of any subsidiary or associated
companies and Council Members. This policy also includes third parties such as agency
workers, consultants, subcontractors and others working on behalf of the University irrespective
of their location, function or grade.
5.2. The University does not wish to stifle the development of good working relationships with
suppliers, agents, contractors or officials; however, the actions must be transparent,
proportionate and auditable. The University expects our business partners, agents, suppliers
and contractors to act with integrity and to avoid any actions that may be considered any
offence within the meaning of the Bribery Act 2010.

6. Definition of bribery
6.1. Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or
soliciting something of value or of an advantage so to induce or influence an action or decision.
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6.2. A bribe refers to any inducement, reward, or object/item of value offered to another individual in
order to gain commercial, contractual, regulatory, or personal advantage.
6.3. Bribery is not limited to the act of offering a bribe. If an individual accepts a bribe, they are also
breaking the law.
6.4. Bribery is illegal. Employees must not engage in any form of bribery, whether it be directly,
passively (as described above), or through a third party (such as an agent or distributor). In
particular employees must not bribe any foreign public officials anywhere in the world.
6.5. If employees are uncertain about whether something is, a bribe or a gift or act of hospitality,
they must seek further advice from the Secretary to the Council or the Head of Legal Services.

7. What is and what is NOT acceptable

7.1. This section of the policy refers to 4 areas:
a) Gifts and Hospitality.
b) Facilitation payments.
c) Political contributions.
d) Charitable contributions.
7.2. Gifts and Hospitality
The occasional exchange of business gifts, meals or low level entertainment is a common
practice and is meant to create goodwill and enhance relationships. However, if the receipt of
business courtesies becomes excessive, it can create a sense of personal obligation on the
part of the recipient. Such sense of obligation can interfere with the individual’s ability to be
impartial in the transaction. Staff may accept business courtesies, but such courtesies must be
modest enough not to interfere with the ethical judgement of the member of staff and must not
create an appearance of impropriety. Corporate hospitality and gifts (whether received or
provided) must be transparent, auditable and proportionate. Modest gifts and hospitality may be
accepted unless an inducement is intended or suspected. Note that there is a current limit of
£50. Refer to 6.2.1j) below.
The University requires the following procedures to be followed.
7.2.1. The University accepts normal and appropriate gestures of hospitality and goodwill
(whether given to/received from third parties) so long as the giving or receiving of such
gifts meets the following requirements:
a) It is not made with the intention of influencing the party to whom it is being given,
to obtain or reward the retention of a business or a business advantage, or as an
explicit or implicit exchange for favours or benefits.
b) It is not made with the suggestion that a return favour is expected.
c) It is in compliance with English law.
d) It is given in the name of the University, not in an individual’s name.
e) It does not include cash or a cash equivalent (e.g. a voucher or gift certificate).
f) It is appropriate in the circumstances (e.g. giving small gifts around Christmas or
as a small thank you to the University for helping with a large project upon
completion).
g) It is of an appropriate type and value and given at an appropriate time, taking into
account the reason for the gift.
h) It is given/received openly, not secretly.
i) It is not selectively given to a key, influential person, clearly with the intention of
directly influencing them.
j) It is not above a certain excessive value, as pre-determined by the Secretary to
the Council (which figure is currently in excess of £50).
k) It is not offered to, or accepted from, a government official or representative or
politician or political party, without the prior approval of the University’s Secretary
to the Council.

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 7.2.2. In no circumstances must any gift of money be made or received by an official of the
University.
7.2.3. Where it is inappropriate to decline the offer of a gift (i.e. when meeting with an individual
of a certain religion/culture who may take offence), the gift may be accepted so long as it
is declared to the individual’s Line Manager and the declaration process is followed.
7.2.4. The University recognises that the practice of giving and receiving business gifts varies
between countries, regions, cultures, and religions, so definitions of what is acceptable
and not acceptable will inevitably differ for each.
7.2.5. The intention behind a gift being given/received should always be considered. If there is
any uncertainty, the advice of the Secretary to the Council should be sought.
7.2.6. As good practice, gifts given and received over the financial threshold (currently in
excess of £50) should always be disclosed to the Secretary to the Council. Gifts from
suppliers should always be disclosed.
7.2.7. The University’s policy on Gifts and Hospitality requires that all gifts and hospitality of an
estimated value of £50 or more, are to be recorded on the Gift and Hospitality
Acceptance Form and for the following procedures to be followed.
7.2.7.1. If it is not possible to value the gift or hospitality received, or if it is unknown,
then that information should be declared on the Gift and Hospitality
Acceptance Form.
7.2.7.2. Gift/hospitality declarations need to be referred to the Line Manager of the
person in receipt of the gift or hospitality for countersigning [in the case of the
Vice Chancellor this shall be the Chair to Council].
7.2.7.3. The Line Manager will send the Gift and Hospitality Acceptance Form to the
Secretary to Council who will make a decision as to whether it can be
accepted. The Secretary to Council may need to seek the advice of the Chief
Finance Officer as to whether the gift or hospitality may be accepted.
7.2.7.4. Issues that cannot be resolved by the Chief Finance Officer and the Secretary
to Council will be referred to the Ethics Advisory Committee for consideration.
7.2.7.5. If it is deemed as unacceptable for the gift/hospitality to be received, but it is not
possible for it to be returned, the gift should be put to charitable use.

7.3. Facilitation Payments

7.3.1. The University does not accept and will not make any form of facilitation payments of any
kind. The University recognises that facilitation payments are a form of bribery that
involves expediting or facilitating the performance of a public official for a routine
governmental action (e.g. processing licenses, permits, visas etc.). The University
recognises that requests for facilitation payments tend to be made by low level officials
with the intention of securing or speeding up the performance of a certain duty or action.

7.4. The University does not allow kickbacks to be made or accepted. The University recognises
that kickbacks are typically made in exchange for a business favour or advantage.

7.5. Political Contributions

7.5.1. The University will not make donations, whether in cash, kind, or by any other means, to
support any political parties or candidates, as the University recognises that this may be
perceived as an attempt to gain an improper business advantage.

7.6. Charitable Contributions

7.6.1. The University accepts (and indeed encourages) the act of donating to charities –
whether through services, knowledge, time, or direct financial contributions (cash or
otherwise) – and agrees to disclose all charitable contributions it makes.

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 7.6.2. Employees must be careful to ensure that charitable contributions are not used to
facilitate and conceal acts of bribery.
7.6.3. The University ensures that all charitable donations made are legal and ethical under
local laws and practices, and that donations are not offered/made without the approval of
the Secretary to the Council.

8. Employee Responsibilities
8.1. University employees will be required to comply with this policy, and with any training or
other anti-bribery and corruption information provided by the University from time to time.
8.2. Employees will be responsible for the prevention, detection, and reporting of bribery and
other forms of corruption and are required to avoid any activities that could lead to, or
imply, a breach of this policy.
8.3. Employees who believe or suspect that an instance of bribery or corruption has occurred
or will occur in the future in breach of this policy, should notify the Secretary to the
Council.
8.4. In addition, employees shall abide by Conflict and Declaration of Interest Policy.
8.5. Employees who are found to be in breach of this policy will be subject to disciplinary
action and could face dismissal for gross misconduct in accordance with the University’s
Human Resources disciplinary code.

9. What happens if I need to raise a concern?

9.1. This section of the policy covers 3 areas:
a) How to raise a concern.
b) What to do if you are a victim of bribery or corruption.
c) Protection.
9.2. How to raise a concern
9.2.1. If you suspect that there is an instance of bribery or corrupt activities occurring in
relation to the University, you are encouraged to raise your concerns at as early
a stage as possible. If you’re uncertain about whether a certain action or
behaviour can be considered bribery or corruption, you should speak to your Line
Manager, the Secretary to the Council, the Head of Legal Services or
Procurement Director.
9.2.2. The University will familiarise all employees with its whistleblowing procedures so
employees can vocalise their concerns swiftly and confidentially.
9.3. What to do if you are a victim of bribery or corruption
9.3.1. You must tell your Line Manager as soon as possible if you are offered a bribe by
anyone, if you are asked to make one, if you suspect that you may be bribed or
asked to make a bribe in the near future, or if you have reason to believe that
you are a victim of another corrupt activity.
9.4. Protection
9.4.1. If you refuse to accept or offer a bribe or you report a concern relating to
potential act(s) of bribery or corruption, the University understands that you may
feel worried about potential repercussions. The University will support anyone
who raises concerns in good faith under this policy, even if any subsequent
investigation finds that they were mistaken.
9.4.2. The University will ensure that no one suffers any detrimental treatment as a
result of refusing to accept or offer a bribe or other corrupt activities or because
they reported a concern relating to potential act(s) of bribery or corruption.
9.4.3. Detrimental treatment refers to dismissal, disciplinary action, treats, or
unfavourable treatment in relation to the concern the individual raised.
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 9.4.4. If you have reason to believe you’ve been subjected to unjust treatment as a
result of a concern or refusal to accept a bribe, you should inform your Line
Manager immediately.

10. Training and communication

10.1. The University will provide training on this policy to all staff as part of its mandatory
training. Furthermore the University will provide relevant anti-bribery and corruption
training to staff etc. where we feel their knowledge of how to comply with the Bribery Act
needs to be enhanced. As good practice, all organisations should provide their
employees with anti-bribery training where there is a potential risk of facing bribery or
corruption during work activities.
10.2. The University’s anti-bribery and corruption policy and zero-tolerance attitude will be
clearly communicated to all suppliers, contractors, business partners, and any third-
parties at the outset of business relations, and as appropriate thereafter.

11. Record keeping

11.1. The University will keep detailed and accurate financial records, and will have
appropriate internal controls in place to act as evidence for all payments made. The
University will declare and keep a written record of the amount and reason for hospitality
or gifts accepted and given, and understand that gifts and acts of hospitality are subject
to managerial review.

12. Monitoring and reviewing

12.1. The Secretary to the Council is responsible for monitoring the effectiveness of this policy
and will review the implementation of it on a regular basis, and will assess its suitability,
adequacy, and effectiveness.
12.2. This policy will be reviewed by the Audit Committee annually, or as and when any
legislative changes occur, to ensure compliance with the principles of the act. Council
will be advised of any action taken via the Annual Report from the Audit Committee.
12.3. Internal control systems and procedures designed to prevent bribery and corruption are
subject to regular audits to ensure that they are effective in practice.
12.4. Employees may raise concerns at any time by using the University’s then-current
whistleblowing procedures

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Conflict and Declaration of Interest Policy

The University seeks to avoid actual and potential conflicts of interest where possible. We aim to act
honestly, ethically and transparently. We seek declarations of both actual and perceived conflicts of
interest and take appropriate action to manage the conflict.

All staff and students should recognise activities that might give rise to conflicts of interest or the
perception of conflicts and to ensure that such conflicts are seen to be properly managed or avoided.

Declarations of interests are invited from all sections of the University community although, for
practical purposes, the scope of the policy is to be restricted to members of Council, salaried staff
and students conducting research. Staff under a duty to make an annual declaration will be
contacted directly. However, all staff and students, regardless of position or seniority, are asked to
consider whether they have a conflicts of interest, actual or possible, that may need to be disclosed.

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Full details of the Conflict and Declaration of Interest Policy and the relevant forms are available
through the following link:
http://www.brunel.ac.uk/about/administration/policies-and-other-important-documents

Guidance
Declaration forms for both Conflicts of Interest and Gifts and Hospitality are available through the
above link. All declarations are kept on a register maintained in the Governance & Secretariat
Office. The information is strictly confidential with access granted only at the discretion of the
Secretary to Council to persons with reasonable grounds to inspect declarations of conflict of
interest, such as the internal and external auditors.

Relevant interests include by way of example, any pecuniary, family [see notes section below] or
other personal interest which might be pertinent to the conduct of the University’s affairs including
the work of Council. This may include:

Paid employment
This includes self-employment and offices held.

Trustee benefits
Trustee benefit is any instance where money or other property goods or services which have
monetary value are received by the trustee [Council Member] from the charity [the University]. The
law says that trustees cannot receive a benefit from their charity unless they have an adequate
legal authority to do so. This does not include:
i. reasonable expenses that Council Members are entitled to claim;
ii. remuneration and salary-related benefits that are provided for in the employment
contracts of staff who are also Council Members.

Directorships
All paid directorships and unpaid directorships should be declared.

Clients
Other than those identified above, clients to which services are provided (or through his or her
employer or company) that arise out of Council membership or University employment should be
declared.

Gifts, Hospitality or Services

This includes financial or other material support, benefits or hospitality. Named post-holders and
anyone required by the Secretary to Council or Council’s Ethics Advisory Committee to make a
declaration are asked to register any such gift received personally or by those close to him or her
from a source which in any way arises out of membership of Council or University employment. If it
is not easy to decide between what is and what is not acceptable in terms of gifts or hospitality, the
offer should be declined or advice sought from the individual’s Line Manager and/or Secretary to
Council and/or Head of Legal Services. For the protection of those involved, the Secretary to Council
will maintain a register of gifts and hospitality received where the value is in excess of £50. Those in
receipt of such gifts or hospitality are obliged to notify promptly the Secretary to Council.

Land
Other than a home used solely for personal accommodation, named post-holders and anyone
required by the Secretary to Council or Council’s Ethical Advisory Committee to make a declaration
are asked to register all land and property within a 10-mile radius of University premises.

Shareholdings
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Named post-holders and anyone required by the Secretary to Council or Council’s Ethical Advisory
Committee to make a declaration are asked to register the name of all public and private companies
or other bodies in which they or those close to them have a beneficial interest. Shareholdings
amounting to less than 5% of the issued share capital, or where the nominal value of the holding is
less than £25,000, do not need to be registered.

Other
This is a general section where interests are registered that do not fall into the above categories but
which fall into the general purpose of the register. For example, unremunerated interests, positions
of authority held or other significant involvement in other organisations, e.g. charitable or political or
other educational bodies. It is imperative for members of the governing body and senior
management involved in procurement to disclose interests they have in, or with, any organisation
from whom the University procures goods or services.

NOTE:
Although there is no obligation to register the interests of their immediate family members, those living
in the same household and other connected persons (other than for gifts and shares), colleagues
should be alert to the possibility that any given matter will concern an interest of such a connected
person. Where the interest is clear and substantial, the person concerned should not take part in the
discussion and should normally withdraw from both discussion and vote on the particular item in
question.

For the purpose of this policy, ‘immediate family’ is defined as follows: spouse or civil partner, son,
daughter. However, the ‘close personal relationship’ giving rise to an interest could extend to the
following (this is not intended to be an exhaustive list): unmarried partner, parent, brother, sister,
grandparent, grandchild, mother-in-law, father-in-law, sister-in-law, brother-in-law, son-in-law,
daughter-in-law, the (unrelated) child of an unmarried partner, as well as adopted, half and step
members of family.

While Council may be required to approve any conflict of interest, colleagues should feel free to
withdraw from a particular discussion or vote on the grounds of an external interest without
specifying the detail of that interest

Where the interest is of relevance to the business of Council or one of its committees, the
declaration shall be made as soon as practicable either at the meeting or in advance to the Chair or
Secretary to Council.

If you have any doubts as to whether to declare a certain interest or not or have any questions
relating to the completion of this questionnaire, please contact the Secretary to Council.

Staff should bear in mind that the obligation to declare an interest is a continuing one. Should a
member of staff realise retrospectively that they have an interest which is connected with a matter
that has been considered they should notify the Secretary to Council of that interest at the earliest
opportunity.

Data Protection: Summary

Data Security
 The Data Protection Act (DPA) governs the use of what is called ‘personal data’ – stating
that it must be kept safe and secure.

 Personal data is ‘any information about an individual held on computer or in organised

filing systems that could identify the individual, either on its own or together with other
information held by a business or a third party’.

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  The DPA is enforced and overseen by the Information Commissioner’s Office (ICO), which
seeks to ensure that organisations keep personal data secure at all times.

 Data breaches (or other DPA violations) have serious consequences. The ICO can
prosecute organisations – imposing fines of £500,000. And reputational damage can be
severe.

The DPA
 The Data Protection Act 1998 has two main aims: to impose practical controls on the
ways that organisations handle personal data; and to give people legal rights over
information that is stored about them.
 Data refers to the information that is held or intended to be held either by
electronic equipment operating automatically or in a relevant (manual) filing
system.
 Personal Data refers to information relating to a living identifiable person
including expression of opinions about or intentions towards that person.
 Sensitive Personal Data refers to personal data that may include information about
an individual’s racial or ethnic origin; political opinions, trade union status or religious
beliefs; health or sexual life; commission or alleged commission of any offence.
 Data Controller refers to the individual or organisation which determines what personal
data is held and processed.
 Data Subject refers to a living, identifiable person.
 Notification is the formal process by which a Data Controller annually registers with the
ICO the type of personal data an organisation processes and for what purposes.
 Processing refers to any operation performed on personal data (such as
organisation, alteration, retrieval, disclosure, erasure and destruction).
 The essence of the DPA lies in its eight data protection principles. Each of these principles
puts obligations on organisations to make conscious decisions on how personal
information is collected, held and used.

o Principle 1: Data should be processed fairly and lawfully: Organisations must

seek to receive consent from data subjects for processing, and demonstrate that
the processing is necessary.
o Principle 2: Data should be processed for limited defined purposes: Before
seeking consent for processing, an organisation must know why personal
information is needed and for what it will be used.
o Principle 3: Data should be adequate, relevant and not excessive :
Collecting personal data just because it might be needed is not justifiable.
o Principle 4: Data should be accurate and, where necessary, kept up-to-
date: The best source of information will be from the individual. If this is not
possible, an organisation should take reasonable steps to verify it.
o Principle 5: Data should not be kept for longer than is necessary: Personal
data that is no longer needed becomes a risk to any organisation that holds it.
o Principle 6: Data should be processed in accordance with an individual’s
rights: Individuals have many rights under the Act.
o Principle 7: Appropriate technical and organisational measures shall be
taken against unauthorised or unlawful processing of personal data and
against accidental loss or destruction of, or damage to, personal data.
o Principle 8: Data should not be transferred to a country or territory outside
the European Economic Area unless that country or territory ensures an
adequate level of protection for the rights and freedoms of data subjects in relation
to the processing of personal data.

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Compliance
 Compliance with Data Protection requirements comes down to establishing a working
culture, where individuals understand what ‘a duty of care’ for personal data means on a
day-to-day basis.

All organisations have several key Data Protection responsibilities. They must:

o Act in compliance with the eight principles of the Data Protection Act.
o Act in compliance with individual rights.
o Register what personal data is held and for what purposes (e.g. notification).
o Understand how the Data Protection Act interacts with other legislation (for
example, the Freedom of Information Act).
o Designate individual(s) to be responsible for compliance.
 To ensure that you as an individual are complaint with Data Protection requirements,
you should always try to follow these ten key guidelines.
 Data disposal: Shred paper documents. When electronic records get out-of-date – delete
them. If you are in charge of getting rid of a work computer(s) make sure that all of the
data on it has been deleted.
 Information security: Always keep personal data secure: lock physical records away,
and keep rooms locked as well (when unoccupied); Make sure unauthorised people
cannot see screens where data is displayed; Follow these steps at home as well as at
work.
 Reviewing files: Review files containing personal data on a regular basis. You should
only store someone’s personal data if it is definitely needed – so if you don’t need it any
more, destroy it securely.
 Data disclosure: If you receive a request from a third party for someone’s personal data,
you should NEVER give it out unless you have the individual’s consent (or there is a
‘reasonable justification’).
 Consent: You should always try to gain an individual’s consent before personal data is
acquired, held or used.
 Individual rights: People have rights to see the personal data that is held on them – so
always aim to be open. Be aware that individuals can request to see ALL personal data
held on them – which includes informal comments (including emails).
 Worldwide transfer: You must always get someone’s permission before you send any of
their personal data outside the EU, Norway, Iceland or Lichtenstein. And never put their
personal details online without their consent.
 Accuracy: You should keep all of the personal data that you hold on someone as up-to-
date as possible (e.g. change of address). If in doubt – don’t use it.
 Sensitive data: Always be especially careful in how you hold and use sensitive personal
data (e.g. mental health, ethnicity, sexuality etc.). It is particularly important to seek
consent for this
 Third party processors: Are you using a third party data processor (e.g. for database
management) who needs access to personal data you hold on people? If so, ensure a
written contract exists that states they will handle such data in accordance with the DPA.

Rights & Enforcement

 The DPA grants individuals many legal rights to control information that organisations hold
on them, and to know what a Data Controller does with that information.
 Right of Subject Access: Individuals have a right to request that a Data Controller
supply them with all information about them (although the Act does not signify a right to
specific documents).
 Right to stop the Data Controller from processing their Data: If someone believes

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 that the Data Controller is using their information in a way that may cause them harm,
they may request that the Data Controller stops processing their information.
 Right to Express Direct Marketing Preferences: Individuals can dictate whether and in
what form the Data Controller can communicate with them, especially in regards to
marketing activities.
 Right to correct Inaccurate Information: One of the eight Principles obliges the Data
Controller to maintain only accurate information about individuals. The Data Controller
must put in place policies and procedures to ensure that requests to update or change
personal data are processed effectively and in a timely fashion.

The public has a right to know about, and request, information held by a Public Authority. This is
enforced by the Freedom of Information Act – which requires public authorities to proactively make
information available and provide it on request. Staff must deal with requests for information within
20 working days.

 Enforcement of the Data Protection Act is the responsibility of the Information

Commissioner’s Office (ICO), backed-up by the court system. The ICO is independent of the
UK government.

The GDPR
 It is currently planned that the EU’s General Data Protection Regulation (GDPR) will
be introduced in the UK during 2017/2018. This is intended to create stronger data privacy
laws that will apply across the EU, replacing different laws (such as the UK Data Protection
Act) that currently exist amongst EU member states.
 Under the GDPR there will be an increase in fines to up to 4% of annual turnover (or €20
million) for some organisations. There will be a ‘points’ system, based around how
serious a breach is, within a ‘tiered’ structure:
 Although the GDPR is not yet the law in the UK, all organisations should be aware of what
its impact will be – as the data protection landscape will fundamentally change.
o Consent: People must give clear, informed and active consent in order for their
personal data to be processed (and for sensitive data, consent must be
‘explicit’). If required, it must be possible to show that someone gave their
consent.
o Personal Data: The definition of what counts as ‘personal data’ will expand to
include additional factors which might potentially identify a specific individual (e.g.
social, genetic or mental characteristics).
o Data Portability: Individuals will be able to demand copies of any personal data
held on them. Accountability: Data Controllers will have to do more to
demonstrate that they are compliant, in terms of process documentation; impact
assessments for ‘high risk’ data processing; and designing processes to reduce risks (e.g.
by minimising the amount of data they need).
o Territorial Reach: Unlike the current situation, under the GDPR, organisations
outside of the EU whose data processing activities relate to EU citizens will need to
comply with the GDPR.
o Data Processors will have direct, specific responsibilities (such as actioning new
technical requirements). This is a major change from the UK DPA.
o Data Breach Notifications: If a serious breach occurs, the relevant national Data
Protection Authority must be informed within 72 hours (unless there is a good reason
why this cannot be done).
o Data Protection Officers: Public authorities involved in large-scale data processing
activities will need to appoint a Data Protection Officer. (This may also apply to
businesses with over 250 employees and/or companies whose data processing
activities are ‘risky’).
o Right to be Forgotten: Under the GDPR, people will (in certain circumstances) have
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 the right to compel an organisation to erase their personal data (e.g. in a situation
where they withdraw their consent).

Change is coming, so UK organisations need to start preparing now – even if some legal
details may change between now and final implementation.

o Consider data subjects – and their rights: Are you ready for a ‘right to erasure’
request from someone? On a general basis – will the personal data you store be
seen as reasonable? Can you show that the rights of data subjects are outweighed
by the legitimate reasons you have for holding their data?
o Set up an accountability framework: Establish robust policies and procedures that
you can use to prove you comply with the GDPR’s requirements. Organisations will
benefit from establishing a governance group to monitor and direct all data processing
activities. This should be led by a senior manager. A Data Protection Officer, if
required, should be appointed – and report to this group.
o Review privacy notices: Any information you provide to data subjects must be
accessible, clear and comprehensible. (And supporting processes and procedures
must also be well-documented).
o Ensure cross-border data transfers are secure: This is not new – but the
sanctions for violations could be much higher.
o Start to practice ‘privacy by design’: The increased regulatory burdens imposed by
the GDPR will make this more important than ever – and following this approach will
help you to show you are compliant, across the board.
o Get ready for breaches: If a breach was to occur – would your organisation be
ready? If not – what policies and procedures need to be put in place (in relation to
both detection, and response)?
o Assess the legal basis of your personal data usage: What kind of data processing
does your organisation engage in? Do you need consent from the individuals
concerned? Is documentation up to scratch? The legal ‘burden of proof’ will fall on your
organisation – so you need to be ready.
o Check the impact if you’re a supplier of data processing services (or use one):
All contracts between third-party suppliers and contractors for data processing
services should be reviewed to check conformance with the GDPR.

-----o0o-----

Diversity in the Workplace – Summary

Introduction
 Diversity is not about 'political correctness'. Rather, it involves acknowledging and valuing
the individual differences in personal attributes, skills, and contributions of everyone within
and outside the University.
 The University values diversity and appreciates that people perform best when they are
free to be themselves, and when their differences are respected, valued and celebrated.
 Discrimination doesn’t just impact ‘minority’ groups, but affects anyone who is treated
differently because of actual or perceived personal characteristics. It can also apply if
different treatment is applied due to association with someone else’s personal
characteristics – e.g. disability.
 The legal issues in this area are increasingly complex and far-reaching, with legislation
extending beyond the traditional boundaries of sex, race and disability discrimination. So
staff need to be aware of their legal responsibilities, both for themselves and the
University.
13
  Direct discrimination occurs where a person is treated less favourably than another in
similar circumstances because of a protected characteristic. These are Age, Disability,
Gender Reassignment, Marriage and Civil Partnership, Pregnancy and Maternity, Race,
Religion and Belief, Sex, and Sexual Orientation.
 Indirect discrimination is where an employer implements a policy or practice which
applies to everyone, but which puts members of a group sharing a protected
characteristic at a particular disadvantage. This is often a less obvious form of
discrimination than direct discrimination.
 Harassment is ‘unwanted conduct’ (from the perspective of the complainant) which has
the purpose or effect of violating the complainant’s dignity, or creating an intimidating,
hostile, degrading, humiliating or offensive environment for them.
 Victimisation involves penalising someone for exercising their rights under equality
legislation, or for making an internal complaint, or for supporting someone else in doing
so.

Bias and behaviours

 We all have biases, and these can affect our ability to make good decisions. So it’s
important to identify them, and put them aside to support the development of all staff. And
we shouldn’t let irrelevant factors like age, race, disability or even size affect our judgement.
 As with our in-built ‘fight or flight instinct’, bias helps us to detect danger, make decisions
quickly and follow our ‘gut reactions’. So every day, even the most aware, fair and objective
people group others into categories based on social characteristics in order to make sense
of the world.
 The first step to overcoming the influence of bias is to recognise that it exists.
 Stereotyping involves identifying features that a group is supposed to have, making these
features the dominant characteristic of the group, and suggesting that all members possess
such features (e.g. ‘students can’t get out of bed in the morning’).
 Prejudice is an opinion or attitude formed beforehand without sufficient information or
from misinformation, that unfavourably affects our thinking about a person or group of
people - we feel 'less positive' about them.
 Bullying is: ‘coercion or intimidation which serves to undermine the competence,
effectiveness, confidence and integrity of another. The abuse of power, position or
knowledge by one person to criticise or humiliate another, can cause the individual being
bullied to feel vulnerable, humiliated and lacking in confidence.’
 You may be able to identify someone who behaves in a discriminatory manner, or know an
individual who is the victim of this treatment. The effects of this behaviour are very serious –
so it’s vital to understand what to do about it if it impacts you, or someone around you.
 Unacceptable behaviour should be challenged at an early stage. Condoning it - by
not challenging it - results in it becoming integrated within an organisation's culture. It
is certainly not just the responsibility of the person who is directly affected.

Equality legislation
 The Equality Act 2010 introduced the term ‘protected characteristics’ to refer to groups that
are protected under the Act.
 Age discrimination is prohibited under the Act in employment and vocational training, which
includes all programmes of study in further and higher education. However, under the Act,
age is not included in the list of protected characteristics with regard to the provision of
goods, facilities and services to the public, so a claim of age discrimination in this context
could not be brought.
 As well as prohibiting disability discrimination, the Act also says that failure to make
‘reasonable adjustments’ is unlawful. This is one of the key principles underpinning disability
14
 legislation, and the provisions do not apply to the other equality strands – they are unique to
disability.
 Reasonable adjustments aim to remove the disadvantage that a disabled person
experiences because of their disability. The law says that this may involve changes to
provisions, criteria or practices or to physical features, or it could mean the provision of
auxiliary aids.
 The Act lists gender reassignment as a protected characteristic and therefore provides
protection from discrimination, harassment and victimisation for transsexual people. For the
purposes of the Act a transsexual person is someone who proposes to, starts, or has
completed a process to change his or her gender. The person does not have to be under
medical supervision to be legally protected.
 Under the Act, marriage and civil partnership is a ‘protected characteristic’, so it is unlawful
to discriminate directly or indirectly against someone because they are married or in a civil
partnership.
 Direct discrimination during pregnancy and statutory maternity leave is unlawful, and the
woman does not need to demonstrate that she has been treated less favourably in
comparison with someone who is not pregnant - only that she has been treated
‘unfavourably’ because she is pregnant or on maternity leave.
 The Act makes it unlawful to discriminate on the grounds of colour, race, nationality
(including citizenship) or ethnic or national origins, in the areas of employment, education,
and the provision of services.
 The Act bans discrimination on the grounds of religion or belief for workers and students
and in the provision of goods, facilities and services. The law also protects those without
religious or philosophical beliefs from discrimination.
 Both men and women suffer from gender stereotyping, and assumptions can often be made
about women taking responsibility for childcare, or care of the elderly. The Act makes it
unlawful to discriminate on the grounds of sex in the areas of employment, education and
the provision of goods, facilities and services.
 The Act bans discrimination on the grounds of sexual orientation against workers and
students and in the provision of goods, facilities and services. The protected characteristic of
sexual orientation is defined as being a person’s sexual attraction towards people of the
same sex as him or her, towards people of the opposite sex, or towards people of both
sexes. The legislation specifically prohibits all forms of discrimination (direct and indirect, by
perception and by association), as well as harassment and victimisation due to sexual
orientation.
 When the Act came into force, it amalgamated the three Public Sector Equality Duties
(Gender, Disability and Race) into one single Equality Duty.
 The Duty requires that public bodies consider the needs of all individuals in their day-to day-
work – in shaping policy, in delivering services, and in relation to their own employees. The
new Equality Duty also supports good-decision making and ensures the government
delivers its strategic objectives and priorities for the public.

An inclusive environment
 Your responsibility as a member of staff is to appreciate diversity by treating colleagues and
students with respect, and according to their needs.
 Individual employees and students can be held responsible for acts of unlawful discrimination
as long as their institution can prove that they have equipped their employee or student to a
reasonable level of ability in carrying out their responsibilities.
 Remember, the University can be vicariously liable for your behaviour - be it intentional, or
inadvertent.
 An Equality Analysis (also called an Equality Assessment) is a way of considering the effects
15
 decisions and policies have on different groups protected from discrimination by the Equality
Act. It involves using equality information, and the results of engagement with protected
groups and others, to understand the actual (or potential) effect of functions, policies or
decisions. It can help to identify practical steps to tackle any negative effects or
discrimination, to advance equality and to foster good relations.

-----o0o-----

Environmental Sustainability
The University shares environmental responsibilities with staff, students, contractors and visitors.
Each of us has a role to play: if we each make small changes, we can collectively make a big
difference.

• While we go about our everyday activities, we need to understand the impact we are having on
the environment, think for a moment about how to make small, positive changes - and
collectively work towards a sustainable campus.
• When thinking about our impact on the environment we need to consider the huge range of activities
that go on at the University every day.
• The University has already taken action on many aspects of sustainability including cutting energy
consumption and emissions, increasing recycling and reducing waste going to landfill to 0%,
encouraging active alternatives to car transport, and ensuring that sustainable development and
procurement are embedded in our practices.
• Our Carbon Management Plan has given us the opportunity to bring these activities together into a
coherent programme.
• We all have a shared responsibility to look after and protect our environment. But some staff have
specific duties to promote and manage environmental concerns.

Individual responsibilities:

• Save energy wherever possible by turning off equipment and lights.

• Be careful when using resources (e.g. print double-sided and in colour only when necessary).
• Don't waste water (e.g. turn off taps).
• Recycle your waste and don't contaminate recycling bins.
• Raise concerns or new ideas improving environmental performance with department Green
Champions.
• Report environmental hazards such as chemical spills to your manager and where necessary to
the Health, Safety and Environment Team.
• Consider your transport options: a surprising number of people drive to the University even though
they could cycle or use public transport
• Consider the environmental, social and ethical impacts of products and services that you buy.
-----o0o-----

16
Health and Safety Module 1: Summary
Individual employees are responsible for:
Complying with the University's Health and Safety Policy by acting in a safe and responsible
manner at all times.
Cooperating with their managers to assess risks.

Reporting any unsafe conditions that may result in a health & safety incident, taking immediate
action to remove the hazard wherever possible.
Reporting any accidents or near-misses (e.g. to a line manager or Safety Rep). Using any
equipment provided for protection.

Managers have a responsibility to:

Identify hazards and ensure that the process of risk avoidance, assessment and reduction is
followed.

Ensure staff receive information, instruction and training. Provide suitable equipment and ensure
its use where provided.

Make sure all accidents, incidents and near misses are recorded arid their causes investigated.

Monitor sickness absence.

Maintain records of incidents and actions taken ensuring regular reviews.

Promote and practice safe working standards via good leadership and listening to
concerns.

Identifying hazards: controlling risks

Having an accident or damaging equipment is costly. It affects people and has money, effort, and
time implications - and much of this can be avoided if safety is considered before something goes
wrong. You should discuss the hazards relevant to your specific job with your line manager, who
should provide you with information including risk assessments. Potentially hazardous activities
include lifting and handling, using a computer, working in a laboratory, and making food. But there
are many more.

Handling accidents:
If an accident or incident occurs, it's important to report it. To do this effectively, you need to be able to
find and complete a University incident report form, and have access to the relevant emergency
numbers. You should also be familiar with the role of a first aider.

Risk assessment:
The purpose of risk assessments is to identify potential hazards, and to then specify measures to
control them. Most risk assessments are quite straightforward.

A hazard can be defined as the intrinsic property of something with the potential to cause
harm. Risk is the likelihood (or probability) of a hazard actually causing harm - coupled to
the severity of the harm that would be inflicted.

Hazards are identified and their consequences are assessed. If the consequences are
serious (e.g. electric shock) then the risk is high - something needs to be done urgently.
But a hazard creating a risk of minor injury (e.g. paper cuts) would only be regarded as
being low.

17
Follow the HSE 'hierarchy of control' by asking these questions in the following order:
1) Can you eliminate the risk or hazard altogether?
2) Can you replace it with something less hazardous?
3) Can the number of people exposed be limited?
4) Can you adapt the work to reduce the risk by using physical controls?
5) Can you write down procedures, safe working guidelines and permits to work?
6) Can the person be protected by the use of Personal Protective Equipment?

Personal Protective Equipment (PPE) such as face masks and gloves is only ever a last
resort. This is because its effective use relies on the individual actually wearing the equipment,
and that it fits properly, and is effective in practice.

Fire Safety:
Familiarising yourself with key fire safety features and procedures - and the effects of fire -
will pay dividends if a fire breaks out:

Smoke Effects: Smoke can have an effect on your health/strength (e.g. causing breathing difficulties)
and on visibility. Both of these can negatively impact your ability to get out of a building safely.

Fire Doors: Fire doors should never be propped open with fire extinguishers! Similarly, fire routes
must be kept unobstructed: don't let rubbish build up, and make sure you are familiar with escape
routes.

Smoke Detectors: Smoke detectors are fitted throughout buildings to enable early warning to be
given of a fire. These should be kept in good working order.

Fire Safety Sign: Evacuation routes are indicated by fire safety signs which are lit even when power
fails. In the event of a fire you should exit calmly and promptly by the nearest route, and proceed to
your assembly point: these will be different for each building within which you may find yourself - so
familiarise yourself with the buildings, assembly points and escape routes relevant to you.

Final Exit Door: In the event of a fire, make sure you do not loiter around the final exit door and so
impede others. And never go back into the building unless you have been told it is safe to do so.

Fire Warden: Fire wardens and fire marshals are trained to assist with the emergency evacuation of a
building. (Security monitor the fire alarm panel, and perform initial investigations when a detector is
activated).

Fire Assembly Point: Assembly points are safe places to gather whilst awaiting further instructions.

-----o0o-----

Health and Safety Module 2: Summary

Manual handling
Definition: Manual handling covers 'transporting or supporting a load, including lifting, putting down,
pushing, carrying or moving it, by hand or bodily force.' This includes activities like operating power
tools, or pulling levers.

Injuries to the back, shoulders, neck, hands, arms and feet mostly result from moving heavy or
awkward loads, restricted space, carrying loads up and down stairs and awkward movements such
as reaching, stooping, pulling and twisting.

Regulations: The Manual Handling Operations Regulations 1992 require employers to:

18
 " Avoid the need for hazardous manual handling, so far as is reasonable practicable.
• Assess the risk of injury from any hazardous manual handling that can't be avoided.
• Reduce the risk of injury from hazardous manual handling, so far as is reasonably
practicable.

Employee duties: As an employee you have duties to:

 Follow appropriate systems of work laid down for your safety. Make proper use of
equipment provided.
 Co-operate on health and safety matters.
 Inform your manager if you identify hazardous activities.
 Take care to ensure that your activities do not put others at risk.

TILE: The four stages to consider in a manual handling risk assessment are 'Task', 'Individual',
'Load', and 'Environment'. In cases where lifting is necessary, this risk can be further reduced by
applying good handling techniques e.g. Think first; Close to waist; Stable position; Good posture.

Display Screen Equipment

Regulations: The Health and Safety (Display Screen Equipment) Regulations 1 992 and Health and
Safety Regulations 2002 require the University to minimise the risks of working with Visual Display
Units (VDUs) by ensuring that workplaces and jobs are well-designed.

Ideal workstation layout: Although your workstation should be set up to suit your individual needs, this
diagram shows the ideal workstation layout in terms of visual and posture requirements:

Visual
A) The screen angle should be adjusted to suit your sitting height with a slightly downward viewing
angle. The top of the screen should be about level with your eyes.
B) The VDU screen should be adjusted to a height to minimise head I neck movement.
C) Adjust the screen to avoid or minimise reflections and glare. Use blinds where appropriate to
assist with this.
D) Adjust the screen brightness and contrast to a level that is comfortable for you. Ensure that the
screen is clean.

Posture
1) Adjust the backrest to support your lower back. If your chair has armrests preventing you from
pulling your chair far enough forward have them removed. Sit directly in front of the screen (not at
an angle) with your head and spine kept upright.
2) Adjust the seat height so you have room between your legs and the desk.
3) Your knees should be level with your hips.
19
4) Keep your elbows close to your sides.
5) If your seating height is correctly adjusted your forearms should be horizontal
6) Your wrists should be slightly flexed.
7) Keep a clear area in from of the keyboard to rest your wrists when not typing.
8) Use a footrest if required but if not keep your feel flat on the floor.

Laptops: Whist the portability of laptops is a great asset, they have a number of shortcomings from an
ergonomic perspective. Steps you can take include considering:
Screen size and weight of the equipment before purchase.
• Use of a separate mouse and keyboard if the laptop is planned to be used for long periods
of time.

Exercises for VDU users: There are a number of practical exercises you can use to help to
prevent stress and muscular-skeletal disorders. Ideally you should perform then on an hourly
basis when using VDU equipment.

Head and neck: Slowly turn your head from one side to the other and hold on each side for
about 3 seconds. Repeat 5-10 times.

Shoulders: Roll your shoulders forward 5 times then roll them backwards 5 times.

Upper back: Raise your hands level with your shoulders, and, keeping your elbows down, push
your shoulders back and hold for a count of 10. Repeat 3 times.

Lower back: Sit back on your chair with your body as relaxed as possible. Slowly bend forward so
that your upper body rests between your knees. Hold this position for a count of 5, and slowly
strengthen and relax. Repeat 3-5 times.

Wrists: Gently pull the fingers back on one hand allowing the wrist to bend. Hold for 3 seconds
before changing to the other hand. Repeat 3-5 times.

Hands: Make tight fists with both hands, then spread your fingers as far as they can go. Hold this
spread position for 5 seconds. Repeat 3 times.

Eyes: Give your eyes a comfort break.

Look away from the screen or close your eyes when you are thinking.

Avoid staring at the screen and blink deliberately, as natural blink reflexes are often
unconsciously suppressed.
"
The University recommends that staff regularly using VDUs have their eyes tested at
appropriate intervals.
-----o0o-----

Prevent
What is Prevent?
The Prevent strategy is part of CONTEST, which is the national counter-terrorism strategy
and aims to reduce the threat to the UK from terrorism by stopping people becoming
terrorists or supporting terrorism. The Prevent strategy has three specific objectives:

20
 To respond to the ideological challenge of terrorism and the threat from those who
promote it;
 To prevent people from being drawn into terrorism and ensure that they are given
appropriate advice and support;
 To work with sectors and institutions where there are risks of radicalisation that we need
to address.

What is the University’s duty under Prevent?

Section 26 of the Counter-Terrorism and Security Act 2015 places a duty on the University to
have “due regard to the need to prevent people being drawn into terrorism”. In carrying out
its duty, the University must have regard to the Revised Prevent Duty Guidance: for England
and Wales (revised 16 July 2015) and supplementary sector-specific guidance (April 2021). .
The University takes seriously its responsibility to ensure the safety and wellbeing of
students, staff and the wider community and recognises the role of Prevent in its
safeguarding duties.
In observing the Prevent duty the University works with the local authority and other relevant
bodies, such as the Police, to help identify staff or students who may be vulnerable to being
drawn into terrorism, to assess the nature and extent of the risk and provide those
individuals with support at an early stage. Where considered sufficiently at risk, the
University may refer a student or member of staff to the local Channel Panel to determine
the appropriate intervention and support. This activity is part of the Channel Programme,
which is a key safeguarding component of the Prevent Strategy.
The University’s approach to Prevent is set out in its Prevent Policy.
Further information about Prevent at Brunel can be found on the Prevent webpage.
What is the University’s Prevent Referral process?
Where a student, staff member or third party is concerned that a student is expressing
violent extremist views or is at risk of being drawn into terrorism, it is important that such a
concern is shared in a safe and supportive manner to enable the concern to be effectively
assessed for the appropriate intervention to be put in place.
Should staff or students have Prevent-related safeguarding concerns about an
individual they may report this via the University’s Report and Support Portal.

For general information about Prevent, such as training queries, an email can be sent
to the University’s Prevent Coordinator: preventsafeguarding@brunel.ac.uk.
The University has a clear pathway for the reporting of such concerns which is managed by
the University’s Prevent Coordinator (See diagram below). The Prevent Coordinator is
responsible for the operational management of casework which may arise as a result of the
Prevent duty. This includes coordinating relevant welfare and academic support services
internally and where considered necessary and proportionate, working in partnership with
the local authority, the Police, the Department of Education (DfE) and the Office for Students
(OfS), as well as possibly referring a case to the Channel Programme.
Following the reporting of a concern, the Prevent Coordinator will carry out an initial ‘Prevent
Incident Assessment,’ seeking to gather substantive information and evidence. A review of
the material will then take place with other relevant members of staff. A decision will then be
made as to the seriousness of the case, with four potential outcomes being likely:
21
a) Concern is NOT RELEVANT to Prevent but may be relevant to another University
policy. In such a case, a referral will be made to the appropriate policy / process;
b) Concern is RELEVANT to Prevent but not serious enough for a Channel Referral. In
such a case, Prevent related welfare action(s) will be put in place such as case
specific internal welfare / academic arrangements – counselling referral, medical
referral, chaplaincy referral etc.;
c) Concern is RELEVANT to Prevent and the case is serious enough to be referred to
the local Channel Panel by the Prevent Coordinator;
d) NO CONCERN and EXIT. No further action is needed.
How does the University deal with events and external speakers?
The University’s ‘Code of Practice to Ensure Freedom of Speech and Freedom of
Expression’ sets out the responsibilities of the University and those of the event organisers
(internal or external) when planning an event on campus or a University branded event off
campus. It further sets out the University’s procedures when arranging meetings and other
activities on the University’s premises which might be deemed controversial by the nature of
the speakers present or by the views which might be expected to be expressed.
Organisers have to complete an event form and seek permission before an event can take
place. The Events Toolkit can be used for this purpose. Authorisation is given if the event
organiser meets all necessary requirements including completing the Freedom of Speech
Form where external speakers are expected to speak. Permission to use University
premises for events will only be granted to those who comply with instructions issued by the
University in relation to the location, arrangements for and conduct of such activities,
including adequate stewarding and control of entry.
The University reserves the right to withhold permission to use its premises if it has reason
to believe that the meeting or the events leading up to it may be in breach of the law.
How does a student raise a complaint about a Prevent related matter?
Students who wish to make a formal complaint about a Prevent related matter should seek
to do so in accordance with the University's Complaints Procedure.
How does a staff member raise a grievance about a Prevent related matter?
Members of staff who wish to raise a formal grievance in relation to a Prevent related matter
should seek to do so in accordance with the University Grievance Policy and Procedures.

22

Brunel University London’s Prevent Referral Process
Concerned about a
Staff, Student,
Speaker or an Event
studentsupport@bru
Concern is NOT
RELEVANT to
Prevent.
Use appropriate
policy / process. For
example, Student
Welfare, Dignity at
Study, Disciplinary
etc.
Prevent Coordinator
conducts an initial
Inform the ‘Prevent Incident NO CONCERN – EXIT
University’s Prevent Assessment’ No further action.
Coordinator via involving internal
Report and Support staff and / or Concern is RELEVANT
or by emailing students, where to Prevent.
relevant
nel.ac.uk Implement Prevent
related action(s)
including
implementation of
case focused
welfare / academic
arrangements such
Where relevant, Prevent as Counselling.
Coordinator may refer to
Channel
-----o0o-----
23
UKVI - Student Worker
Introduction
The information presented here is intended as an introduction to the importance of compliance within the
rules set by UK Visas and Immigration (UKVI).

The information presented here covers:

1. How international students contribute to Brunel University London
2. What it means to be a UKVI licensed ‘sponsor’ of international students and staff
3. Brunel’s key responsibilities as a UKVI sponsor

What our international students mean to Brunel University London

Brunel University London aspires to become London’s international university with a multicultural community
of both students and staff. International students make up approximately one fifth of our enrolled student
population and we currently have approximately 3,500 enrolled international students.

What does this mean to us and the way we work?

In addition to providing the University with cultural diversity, international students are also worth
approximately £40 million pounds to Brunel each year. Although we shouldn’t focus solely on the amount of
money that international students bring to the University, realistically, this massive financial contribution helps
the University meet operational costs.

Overview of UKVI Sponsorship

People who are not nationals of the UK or Republic of Ireland need a visa to study, work and live in the UK.
UKVI has granted Brunel with a sponsor licence, meaning we have been authorised to invite and sponsor
people to come to Brunel to work or study based on our assessment of their qualifications and/or credentials.
We can sponsor the individual to support their visa application to enter or remain in the UK.

Most migrantscome to the UK in one of four Immigration categories,as part of the UK’s points based
immigration system,and Brunel is licensed to sponsor migrants in all four. These are:

Start-up Graduate Entrepreneurs – this allows us to endorse recent graduates to develop business in the UK.
This scheme is supported by our Entrepreneur Hub.

-Skilled Workers (formerly known as Tier 2) - this allows us to recruit skilled professionals from around the
world, such as academics.

Student (formerly known as Tier 4)– this is the category that allows us to recruit and register international
students to study at the University.

Government Authorised Exchanges (formerly known as Tier 5) – this enables us to invite visiting academics
on government authorised schemes.

However, as a licensed sponsor, UKVI place certain responsibilities upon us.

What does it mean to be a sponsor of Skilled Workers and Students?

UKVI have stated that as the beneficiaries of bringing international students and staff into the UK, Universities
must take responsibility for those they sponsor. Therefore, UKVI place trust in us to ensure that the UK
immigration system is not abused. This primarily means that we must ensure that staff and students that we
24
sponsor have a genuine intention to fulfil the purpose for which they are making the visa application i.e. to
study or work with us.

Failure to maintain our sponsorship obligations will result in sanctions from UKVI. Sanctions can include:
 substantial fines to the University,
 suspension or revocation of Brunel’s sponsor licence,
 And in the most extreme scenarios, Brunel’s primary licence holder could be arrested!

UKVI expect Universities to assume a general responsibility for students and workers by ensuring that they all
have suitable immigration permission, they understand their obligations, and we monitor their engagement
with the University.

Sponsored Students
A majority of people whose visa we sponsor are international students. In this case, both the student and the
University have key responsibilities.

A sponsored students’ primary purpose in the UK is to study full time here at Brunel. While studying with us,
they can also:
 Work, however the number of hours are restricted during term time.
 Undertake supplementary studies (i.e. an evening, vocational course) as long they remain fully
engaged on their main course here.

Working in the UK as a sponsored student

Students who wish to work during their studies have an opportunity to gain valuable work experience to
improve employability and help fund their studies.

All sponsored students have a restriction to how many hours they can work. This is determined by their
course and is specified on their visa. Most students on degree level courses are restricted to 20 hours per
week during term time. However, it should be noted that Brunel University London has restricted the
working hours for students to 15 per week to ensure a work/study/life balance.

Term time is defined by the University and is based on the course students are studying. This is available to
students at the Student Centre website: Tier 4 and Sponsored Student Right to Work Policy - January
2021 (1) (brunel.ac.uk)

Work Placements
Sponsored students working on an approved work placement as part of their degree are not subject
to the ‘term time’ restrictions. The placement must be officially approved and reported to UKVI.

Sponsored students do not have right to work in the UK if they:

 Withdraw from their course, or
 Take a temporary period of absence (abeyance)

Students typically are given an additional 4 months on their visa, past their expected course completion date.
Students are allowed to work full time once they have completed their course, and their award is agreed, until
the expiration of their visa.

Sponsorship Responsibilities: What are Brunel’s Sponsor Duties?

As we benefit from recruiting international students, UKVI state that we must ensure that:
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  We only sponsor genuine students
 We monitor our students to ensure they are engaged on their programme
 Our sponsored students are not breaching any of their immigration conditions and we act to remove
sponsorship if uncovered
 We do not allow sponsored students to work more hours than is restricted on their visa
 We are always compliant with the frequently changing immigration rules

What does this mean for Brunel and how we work?

From the point we offer a place to study at Brunel and sponsor a student’s visa, we must have assessed that
they are a ‘genuine’. A genuine student enrols on a course that will help them fulfil their career goals and
rather than to enter the UK or extend their stay here for other purposes.

Once we have agreed to sponsor their student’s visa, we take a level of responsibility to ensure the visa
application is successful and they arrive to enrol.
While studying, we are responsible for students complying with their visa obligations, including work
restrictions and course attendance.

When does Brunel’s sponsor duties start and end?

Our visa sponsorship of a student begins when we make an unconditional offer and ends when we have either
removed our sponsorship or their visa expires upon course completion.
Sponsorship duties would only end prematurely if the University withdraws sponsorship of their visa.

We would remove sponsorship if a student withdraws from the University or is found to have been non-
compliant.

Therefore, Brunel assumes responsibility even before the student arrives and this includes things that might be
beyond our direct control, such as their visa application.

Engagement Monitoring
Brunel University does not currently monitor attendance as this is not required in our senate regulations.
However, UKVI obligations mean that we must monitor sponsored students’ course engagement, to ensure
they are generally attending their scheduled academic activities. This is designed to combat illegal working,
which non-engagement can potentially indicate.

We monitor this through specific ‘contact points’ throughout the academic year, including lectures, seminars,
exams and coursework submission. Students must attend these points to demonstrate their engagement on
their programme. These contact points are normally not known to the students and are spaced throughout the
year.

Employing a Sponsored Student

All employers must ensure that they check a person’s permission to work in the UK, before they start working.
This includes checking passports and, if a nonUK/Irish national, their visa/immigration status to see if there are
any restrictions on the type and amount of work they can do.

What does Brunel have to do if a sponsored student is in breach of their work restrictions?
Any employer who hires a student then must ensure that they do not work more hours than allowed during
term time as indicated on their visa. We are obligated to notify UKVI if we become aware of any sponsored
student who has breached their work restrictions.

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When we employ our students to work on campus, there is a high expectation that we do not allow them to
exceed their work limits, as we also know their;
 registration status
 term dates, as defined by the University

What are the consequences of illegal working?

Students working more hours than allowed is illegal working. This could result in:
 the student's visa being revoked,
 up to a £20,000 fine for Brunel,

UKVI could take further action against us, for example suspend or revoke our sponsor licence, if we breached
these employment regulations to a significant extent.

Documenting Responsibilities
For every sponsored student, we have to retain certain documents on file, including:
 qualifications used to accept the student
 valid passport and visa/s,
 history of UK contact details,
 engagement/absence records

Brunel’s reporting Duties

We must also tell the UKVI of any changes affecting our licence. This could include:
 a name change to the Institution; change in key personnel, or new teaching partnerships

 We must also notify them of any information that is incorrect on a student’s visa, particularly if this
relates to visa conditions/length

Any changes to the student’s circumstances must also be reported. This includes:
 changes to a student’s start date; course; or if the University removes sponsorship of the student’s
visa

Sponsorship may be withdrawn if the student:

 has failed to enrol on their course; has withdrawn from their course; taken temporary leave of
absence; has demonstrated non-engagement of course, or has completed their course early.

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Consequences of Non-Compliance
If Brunel fails to comply with the UKVI regulations, this can result in:

 losing our sponsorship licence

 a significant fine
 up to a 5-year prison sentence to key personnel

The results would be severe if these consequences were to happen:

 Student and Staff Recruitment Problems - Losing our sponsor licence will affect Brunel’s
ability to recruit both new international students and staff.
 Loss of income for at least 2 years - Brunel could only apply for a new sponsor licence after two years
resulting in an estimated £40 million per year income loss.
 Reputational damage - sponsored students currently enrolled at Brunel could be forced to transfer to
another institution. A licence suspension would also result in irreparable reputational damage to
Brunel, making future student recruitment extremely challenging.

What Can Go Wrong

In an ideal world, sponsored students come to Brunel, focus on their studies and successfully complete their
course. However, there are many things that can go wrong along this journey.

As their sponsor, we must ensure we keep the appropriate institution records and our licence with the UKVI
up-to-date. We also must maintain specific required documents and records for all international students and
ensure enrolled students maintain valid permission to study in the UK throughout their course.

All Universities sponsoring students must ensure that student visa refusals are minimal, they enrol as
expected, and complete their course of study. UKVI monitor this to ensure our international student
recruitment methods are effective. We are required to withdraw sponsorship for students who are not
meeting their immigration obligations.

And we must ensure that we only employ staff who can legally work in the UK and that sponsored students do
not work more hours than they are allowed as outlined in their visa restrictions.

For further guidance and support:

 Attend a UKVI compliance workshop. This can be booked on the Staff Development website:
Compliance (brunel.ac.uk).
 Contact the Student Centre (if you have queries relating to sponsored students)
 Contact your HR Business Partner (if you have queries relating to the employment of International
staff)
 Contact our Compliance Team if you have any enquiries about UKVI compliance

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Safeguarding

Brunel University London is committed to providing a safe and secure environment for all students, staff and
individual visitors who access its facilities and services.

Brunel University London recognises its particular responsibility to safeguard the wellbeing of children and
vulnerable adults engaged in the breadth of the University’s activities by ensuring that there are appropriate
arrangements in place to enable it to discharge its duty to provide a safe and secure environment and to deal
with issues concerned with suspected or reported abuse of children and vulnerable groups.

Brunel University London seeks to ensure that its policy and procedures comply with statutory duties, reflects
guidance and good practice in safeguarding children and vulnerable adults, and that safeguarding
arrangements are proportionate and reasonable. This statutory duty extends to reporting incidents as they
occur to the appropriate authorities.

There may be times when you are working with or alongside children under the age of 18, or adults that are
vulnerable. A vulnerable adult is someone over the age of 18 that may require additional support from
community care services due to a disability, their age or illness, or someone that is considered to be unable to
protect themselves from harm or exploitation. All employees of Brunel University London are required to take
additional care when working with these individuals.

If during your time working, a concern is brought to your attention, either by a disclosure from a child or
vulnerable adult, or by other means, then you must pass this information to the University so that appropriate
action can be taken to ensure the safety of the individual.

Any concerns should be passed either to your line manager, to the Student Support and Welfare Team
(studentsupport@brunel.ac.uk), to the Chief Governance Officer (who is the University Principal
Safeguarding Officer) or one of the University Safeguarding Officers as a matter or importance.  

If concern is raised out of normal office hours (evenings and weekends) and it is clear that abuse has occurred
or there is any suspicion of abuse or concern, contact should be made with Hillingdon Children’s Social Care
Department Emergency Duty Team on 01895 556644 or the Police Child Abuse Investigation Team: 0208 246
1901. Advice can also be sought from the NSPCC 24 hour helpline on 0800 800 500.

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 Acceptance Page

This Student Worker/ Hourly Paid Worker Mandatory Compliance Training Booklet will
take approximately 30 minutes to read in full.

Please note: It is a requirement of you being a Brunel University London Student Worker /
Hourly paid Worker that this document is read in full, in the first week of your employment.

Once you have read this document in full, please sign, scan and return this declaration page
to jobshop@brunel.ac.uk for Student Workers or recruit-hps@brunel.ac.uk for all other
Hourly paid workers (including Hourly Paid lecturers, to confirm you have received, read and
understood its content. Failure to do this will result in you not being able to undertake any
further work.

I confirm I have received, read and understood the Student Worker / Hourly Paid Worker
Mandatory Compliance Training Booklet.

Full Name Printed:

Signature:

Student ID no:

Date Signed:

--------------------------------------------------------------------------------------------------------------------------

Date received in Jobshop / HR: ………………………………………………………

Recorded in E-Recruiter by: ……………………………………………………………

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