What is harassment?
Harassment is defined in the University’s Student Harassment and Sexual Misconduct Policy as follows:
“Harassment” has the meaning given in section 26 of the Equality Act 2010 and section 1 of the Protection from Harassment Act 1997 (interpreted in accordance with section 7 of that Act):
- For the purposes of the Equality Act, harassment is unwanted conduct related to a relevant protected characteristic which has the purpose or effect of violating an individual’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment. This includes harassment by association or perception. Under the Equality Act, the relevant protected characteristics are age, disability, gender reassignment, race, religion or belief, sex and sexual orientation.
- For the purposes of the Protection from Harassment Act, harassment is 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.
The definitions of ‘harassment’ in section 26 of the Equality Act 2010 and section 1 of the Protection from Harassment Act 1997 include ‘objective’ and ‘reasonableness’ tests:
- In the context of section 26 of the Equality Act 2010, in deciding whether conduct has the effect of violating a person’s dignity, or creating an intimidating, hostile, degrading, humiliating or offensive environment towards that person, it is necessary to take into account: the perception of the person who is at the receiving end of the conduct; the other circumstances of the case; and whether it is reasonable for the conduct to have that effect.
- In the context of section 1 of the Protection from Harassment Act 1997, harassment is committed only if the person knows the conduct amounts to harassment of the other, or a reasonable person in possession of the same information would think the course of conduct amounted to harassment of the other person.
See our Report + Support portal for further information on What are Bullying and Harassment?
What is sexual misconduct?
Sexual misconduct is defined in the University’s Student Harassment and Sexual Misconduct Policy as follows:
“Sexual Misconduct” relates to any unwanted or attempted unwanted conduct of a sexual nature. This includes, but is not limited to:
- Sexual harassment as defined by Section 26(2) of the Equality Act 2010.
- Assault as defined by the Sexual Offences Act2003, including sexual assault and assault by penetration.
- Rape as defined by the Sexual Offences Act 2003.
- Less favourable treatment for rejecting or submitting to unwanted conduct of a sexual nature as defined by Section 26(3) of the Equality Act 2010.
- Sharing or threatening to share intimate photographs or films of an individual without their consent as defined by the Sexual Offences Act 2003 (as amended by the Online Safety Act 2023).
- Domestic violence and abuse (an incident or pattern of incidents of controlling, coercive, threatening, degrading and/or violent behaviour, including sexual violence, in the majority of cases by a partner or ex-partner, but could also be by a family member or carer).
See our Report + Support portal for further information on What is Sexual Misconduct?
Reporting harassment and sexual misconduct
The University provides a portal, Report + Support, which students and staff can use to disclose bullying, discrimination, harassment, hate crime and sexual misconduct . You can disclose anonymously or ask to speak to a trained advisor to get information on reporting options and support available so that you can make an informed decision on what happens next.
The Student Harassment and Sexual Misconduct Policy sets out other options which students and staff have for disclosing concerns if they don’t want to use Report + Support, including contacting the relevant faculty or directorate for action to be taken under the appropriate University policy. We would however encourage students and staff to consider using Report + Support in the first instance so that they can access specialist support from a trained advisor.
Support for those affected
Students and staff can disclose how they have been affected by harassment and sexual misconduct using the University’s Report + Support portal. You can choose to do this anonymously or you can request support from an advisor. If you choose to speak to an advisor, they will be able to talk through the reporting options and support available to you, in confidence. Our Student Support Advisors are all trained Sexual Violence Liaison Officers and Mental Health First Aiders.
A range of support is available within and outside the University for students and staff who have experienced harassment and sexual misconduct. Further information about support options is available on our Report + Support portal:
Students facing allegations: as indicated in the Student Harassment and Sexual Misconduct Policy, the University has appointed specially trained members of staff who have the competence and confidence to respond to the needs of students who are accused of harassment and sexual misconduct. Support is also available from the Student Wellbeing Service and Greenwich Students’ Union. The Report + Support portal includes information for students accused of misconduct.
Investigating harassment and sexual misconduct
The following policies are relevant to how we investigate allegations of student harassment and sexual misconduct:
The Student Harassment and Sexual Misconduct Policy defines what harassment and sexual misconduct are and sets out the University’s approach to preventing and addressing harassment and sexual misconduct.
In terms of how incidents are investigated, the Student Harassment and Sexual Misconduct Policy specifies that:
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
Ensuring confidentiality is a key principle in creating a culture where those affected feel safe to make a disclosure about harassment and sexual misconduct.
The University will take all reasonable steps to protect the confidentiality and privacy of those who disclose harassment and sexual misconduct. However, there may be circumstances (e.g. in order to protect an individual at risk) where we are required to share information with other agencies or to share information internally. Further details about confidentiality and information sharing are provided in the Student Harassment and Sexual Misconduct Policy, the Student Confidentiality Policy and the FAQs for the Report + Support portal.
Informing Individuals
In accordance with the Student Disciplinary Procedure, where it is reasonable and practicable to do so in accordance with its duties and obligations under data protection legislation, the University will provide the student that has raised an allegation of harassment or sexual misconduct with an outcome of the investigation and/or an explanation of any actions that the University has taken, or not taken. This includes where the outcome is changed for any reason. However, it may only be possible for the University to provide limited information depending on the circumstances.
Guidelines have been agreed between Student and Academic Services (SAS) and People Directorate to ensure effective co-ordination over allegations by students against staff which are considered under the staff Disciplinary Policy and Procedure. This includes:
- Ensuring that SAS is provided sufficient information to enable student expectations to be managed effectively and to provide the student who has made the allegation with progress updates;
- Ensuring that once the investigation is concluded, appropriate information regarding the outcome and next steps is provided to SAS in order for information to be shared with the student such as it is possible for the University to provide in accordance with its duties and obligations under data protection law. People Directorate will ensure that the information provided to SAS for sharing with the student is of the equivalent level of detail that would be provided to a staff member if they raised a grievance or allegation under the relevant People Directorate procedure.
Training for Students
We’re committed to ensuring that students understand what harassment and sexual misconduct is, how to report it, the support available to them, what consent is and how to intervene effectively.
- Since September 2024, all students have been required to complete a mandatory online course on Healthy Sex and Relationships, developed by experts at the University of Greenwich. The course looks at sexual consent, rape culture and how to become an active bystander against sexual violence and harassment. After completing it, we hope students will be confident making a stand against sexual harassment and advocating for others, be an active bystander, understand what does and doesn’t count as consent, and be able to dispel myths about sexual assault. We also provide a short summary on the law around sexual offences in England and Wales and information about sources of support. The course includes two short quizzes on consent and bystander intervention which students must pass to complete the course. Those who complete the course are invited to fill in a survey to help us evaluate and improve it.
- During student induction, we provide sessions for students on Healthy Sex and Relationships (complementing the online course) and sessions to promote awareness of how to disclose incidents and concerns through our Report + Support portal.
- During the academic year, our Report + Support team run campaigns to promote awareness, including interactive training sessions for students on consent to help students understand what consent means, what it looks/sounds like (or does not), and how to apply this knowledge to different situations.
Training for Staff
- We are developing online training for staff based on our successful Healthy Sex and Relationships course for students. This is being piloted with the intention of it being required from autumn 2025.
- During the academic year, our Report + Support 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 (such as Student Support Advisors, Sexual Violence Liaison Officers and staff carrying out investigations) receive specialist training appropriate and relevant to their roles.
Personal relationships between Staff and Students
We are committed to protecting students from any actual or potential conflict of interest and/or abuse of power that may arise from intimate personal relationships with staff. Our Personal Relationships at Work Policy bans personal relationships between staff and students, except for pre-existing relationships which must be declared so any conflicts of interest can be managed.
Taking Steps to Protect Students
We are committed to taking steps that will make a significant and credible difference to protecting students from harassment and sexual misconduct. These include:
- Analysing and publishing data on use of our Report + Support reporting portal. Our annual report covering student disclosures in 2022/23 and 2023/24 is available on the Report and Support portal.
- Building feedback surveys into our online training for students and staff, evaluating the results and making changes to the training where appropriate.
- Consulting with Greenwich Students’ Union on changes to our student policies on harassment and sexual misconduct. Students are represented on the committees where these policies are approved.
Freedom of speech
When investigating allegations of harassment or sexual misconduct, we will have particular regard to, and place significant weight on,the importance of freedom of speech within the law, academic freedom and tolerance for controversial views in an educational context or environment. Our commitments to freedom of speech and academic freedom are set out in our Freedom of Speech Code of Practice.
In particular, we will assume that the exposure of students to course materials, and statements made and views expressed by a person as part of teaching, research or discussions about any subject matter that is connected with the content of a course, are unlikely to constitute harassment, unless it is otherwise demonstrated that these matters do in fact amount to harassment.
Non-disclosure agreements
In March 2022 Greenwich signed Can’t Buy My Silence’s Universities Pledge. This means that we will not use non-disclosure agreements (NDAs) in relation to complaints of sexual harassment, abuse, misconduct, or other forms of harassment and bullying. In addition, since September 2024 the Office for Students has prohibited universities from using NDAs in relation to student allegations of harassment and sexual misconduct. The use of NDAs in relation to complaints of harassment and sexual misconduct by students and staff is also prohibited under provisions of the Higher Education (Freedom of Speech) Act 2023 which came into effect on 1 August 2024.