Sexual Harassment & Misconduct
Harassment and Sexual Misconduct – Policies, Procedures and Information
This webpage is the ‘single comprehensive source of information’ required by the Office for Students (OfS registration condition E6).
What is harassment and sexual misconduct?
Harassment and sexual misconduct are defined in LCCM’s Harassment and Sexual Misconduct Policy as follows:
Harassment LCCM follow the meaning given to harassment in:
Section 26 of the Equality Act 2010
Section 1 of the Protection from Harassment Act 1997
A summarised section of the Equality Act 2010 as follows:
‘harassment, including sexual harassment, includes unwanted behaviour or conduct which has the purpose or effect of violating a person’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment because of, or connected to, one or more of the following protected characteristics: age; disability; gender reassignment; race; religion or belief; sex; and sexual orientation.’
LCCM have summarised section 1 of the Protection from Harassment Act 1997 as follows:
‘a course of conduct conducted on at least two occasions that harasses one other person, or a course of conduct that harasses two or more persons at least once each. References to harassing a person include alarming the person or causing the person distress.’
Sexual Misconduct: LCCM define sexual misconduct as any unwanted or attempted unwanted conduct of a sexual nature. This includes, but is not limited to:
- Sexual assault
- Sexual harassment
- Rape
- Stalking
- Coercion or exploitation for sexual purposes
- Unwelcome physical contact
- Sexual comments, jokes, or gestures
- Sending sexually suggestive messages or content
Reporting harassment and sexual misconduct
How to Report
Informal Reporting: Students or staff may choose to speak informally with their personal tutor, line manager, or HR representative, who can offer support and guidance without initiating formal proceedings.
Formal Reporting: Formal reports of harassment or sexual misconduct can be made by email directly to the designated Head of Operations or Whistleblowing Lead. Reports can be made via the harassment and sexual misconduct portal , including anonymous reports.
Anonymous reports will be accepted; however, these may limit the investigation’s scope and outcomes.
External Reporting. Victims of sexual violence are encouraged to report the matter to the police. LCCM will support individuals who choose to make a police report while also following its internal procedures.
Support for those affected
Counselling Services: Free, confidential counselling services are available to all students and staff affected by sexual harassment or misconduct.
Independent Advisors: Trained advisors will be available to offer support, guidance, and assistance through both internal and external processes, such as police reporting.
Academic Adjustments: Reasonable adjustments may be made to academic schedules or deadlines for those affected by an ongoing investigation.
Investigating harassment and sexual misconduct
The following policies are relevant to how we investigate allegations of student harassment and sexual misconduct:
The Harassment and Sexual Misconduct Policy defines what harassment and sexual misconduct are and sets out the LCCM’s approach to preventing and addressing harassment and sexual misconduct.
In terms of how incidents are investigated, the Harassment and Sexual Misconduct Policy specifies that:
- The Student Disciplinary Procedure will be used to investigate allegations of harassment and sexual misconduct against students.
- The staff Disciplinary Policy and Procedure will be used to investigate allegations of harassment and sexual misconduct made by students against staff.
The Student Disciplinary Procedure and the staff Disciplinary Policy and Procedure set out how allegations will be investigated fairly, including timescales, stages, penalties and appeal provisions.
Handling Information
Confidentiality. All reports will be treated with the highest level of confidentiality. Only staff members involved in the investigation and resolution will have access to the details of the case, and no information will be shared without the consent of the complainant unless required by law or where there is a significant risk of harm to the individual or others.
Further details about confidentiality and information sharing are provided in the Harassment and Sexual Misconduct Policy.
Informing Individuals
In line with the Student Disciplinary Procedure and subject to its responsibilities under data protection laws, LCCM will, where reasonable and practicable, inform the student who reported an allegation of harassment or sexual misconduct of the investigation outcome and/or provide an explanation of any actions taken—or not taken—by LCCM. This also applies if the outcome is later revised. However, the information shared may be limited depending on the specific circumstances.
Training For Students
- Training: LCCM will provide mandatory training on harassment and sexual misconduct, consent, and bystander intervention for all students updated annually.
- Awareness Campaigns: Regular awareness initiatives will be conducted to educate the LCCM community about harassment and sexual misconduct, reporting channels, and available support.
- Partnerships: LCCM will work in partnership with external organisations such as sexual violence charities, local authorities, and law enforcement to offer additional resources and expertise.
Training for Staff
- We are developing mandatory online training for staff. This will be piloted in Autumn 2025
- During the academic year, our team run campaigns to promote awareness, including awareness sessions for staff, and will deliver bespoke training to staff on request.
- Staff involved in specialist roles will receive specialist training appropriate and relevant to their roles.
Personal relationships between Staff and Students
We are committed to safeguarding students from any real or perceived conflicts of interest or abuse of power that may result from intimate relationships with staff. This policy applies to all employees, workers, and individuals holding positions within the company or its group entities. Our Employee-Student Relationships Policy prohibits personal relationships between staff and students, except in cases where a prior relationship exists. Such relationships must be disclosed to ensure that any potential conflicts of interest are properly managed.
Taking Steps to Protect Students
We are dedicated to taking meaningful and effective action to safeguard students from harassment and sexual misconduct. Our efforts include:
- Reviewing and publishing data on the use of our reporting portal.
- Incorporating feedback surveys into online training for students and staff, evaluating responses, and updating the training as needed.
- Collaborating with the LCCM Student Committee on updates to student policies concerning harassment and sexual misconduct. Students are actively involved in the committees that approve these policies.
Non-disclosure agreements
LCCM does not use non-disclosure agreements (NDAs) for handling complaints involving sexual harassment, abuse, misconduct, bullying, or other forms of harassment. Furthermore, as of September 2024, the Office for Students has banned higher education institutions from using NDAs in cases where students report harassment or sexual misconduct.