Sexual Harassment Policy

This policy reflects the changes in national guidance as a consequence of the publication of revisions to ‘Keeping Children Safe in Education’ which became statutory on 1 September 2021 Substantive changes to the statutory guidance came into force 1^st September 2022 and updated again 1^st September 2026. This policy has been reviewed accordingly.

The Designed Safeguarding Lead (DSL), Claire Digby-Maloney and Deputy Designated Safeguarding Leads, Emma Eve-Raw and Vicki Nielsen will ensure that all existing staff receive this addendum to the safeguarding and prevent policy.

Goddard Veterinary Nursing College (GVNC) is a provider of post 16 Education as set out in the Apprenticeships, Skills, Children and Learning Act 2009 and is committed to providing a safe environment for all its learners and staff free from discrimination on any ground and from harassment at work including sexual harassment.

Whilst KCSIE applies specifically to children under the age of 18, GVNC applies safeguarding, welfare and protection principles to all learners, including those aged 18+, where concerns relating to vulnerability, exploitation, abuse or harassment are identified.

We will operate a zero-tolerance policy for any form of sexual harassment, treat all incidents seriously and respond promptly and appropriately to all reports or concerns of sexual harassment as part of our obligations under the Human Rights Act 1998, Equality Act 2010 and Public Sector Equality Duty.

GVNC operates a zero-tolerance approach to sexual harassment. All reports and concerns will be taken seriously and responded to promptly and appropriately in accordance with safeguarding, equality and disciplinary procedures.

Any person found to have sexually harassed another will face disciplinary action, up to and including dismissal from their training programme or employment.

All complaints of sexual harassment will be taken seriously and treated with respect and in confidence. No one will be victimised for making such a complaint.

Definition of sexual harassment

Sexual harassment is unwanted conduct of a sexual nature. It may violate a person’s dignity, make them feel intimidated, degraded or humiliated, or create a hostile, offensive or sexualised environment.

It includes situations which create an environment which is hostile, intimidating or humiliating for the recipient.

Sexual harassment may also occur within abusive intimate or personal relationships. Domestic abuse is a broader safeguarding concern and may include psychological, physical, sexual, financial and emotional abuse, coercive or controlling behaviour, and stalking.

Sexual harassment may be physical, verbal, and non-verbal.

Examples of conduct or behaviour which constitute sexual harassment include, but are not limited to:

Unwelcome physical contact including patting, pinching, stroking, kissing, hugging, fondling, or inappropriate touching
Physical violence, including sexual assault
The use of threats or rewards to gain sexual favour
Comments on an individual’s appearance, age, private life, etc.
Sexual comments, stories, and jokes
Sexual advances
Repeated and unwanted social invitations for dates or physical intimacy
Insults based on sex
Sent sexually explicit messages (by phone or e-mail or social media)
Display of sexually explicit or suggestive material
Sexually suggestive gestures
Wolf-whistling

Anyone can be a victim of sexual harassment, regardless of their sex and of the sex of the harasser.

We recognise that sexual harassment may also occur between people of the same sex. What matters is that the sexual conduct is unwanted and unwelcome by the person against whom the conduct is directed.

We recognise that sexual harassment can be a manifestation of power relationships and often occurs within unequal relationships in the workplace, for example between manager or supervisor and staff member or trainer and learner.

All sexual harassment is prohibited whether it takes place within our training environment in college or within the learner’s place of work or outside, including at social events or training sessions.

Anyone can be a victim of sexual harassment, regardless of their sex and of the sex of the harasser.

What will happen following a complaint of sexual harassment

Anyone who experiences sexual harassment is encouraged to report the matter to the Designated Safeguarding Lead, a Deputy Designated Safeguarding Lead or another member of staff they trust. Individuals are not required to confront the alleged harasser directly. Where all parties are aged 18 or over and there is no wider safeguarding concern, informal resolution may be considered where this is appropriate, safe and genuinely desired by the person making the report.

In line with KCSIE 2026 (Part five: Child-on-child sexual harassment and sexual violence), GVNC recognises that incidents can occur between learners in the same setting (including in workplace) and will ensure our response procedures apply in such cases.

We recognise that it may not be possible for the victim to inform the alleged harasser. If a victim cannot directly approach an alleged harasser, they can approach the Designated Safeguarding Lead or any staff member.

GVNC adopts a trauma-informed approach when responding to any disclosure or concern of sexual harassment. GVNC recognises that victims may not disclose immediately, may feel threatened or embarrassed, and may require alternative forms of support. Staff at GVNC are trained to respond with sensitivity, to listen without judgement, and to avoid any actions or language that could re-traumatise the individual. Support plans will be personalised to the individual, and where appropriate, developed collaboratively with the learner and relevant support services to promote recovery, wellbeing, and continued engagement in their learning.

When a staff member receives a complaint of sexual harassment, they will:

ascertain and take account of the wishes and feelings of the person making the report, while making clear that safeguarding responsibilities may require GVNC to take action or share information even where this is not their preferred outcome.
reassure the victim that the complaint will be taken seriously
record the dates, times, and facts of the incident(s)
ascertain the views of the victim as to what outcome they want
ensure that the victim understands the company’s procedures for dealing with the complaint
discuss and agree the next steps: either informal or formal complaint, on the understanding that choosing to resolve the matter informally may still result in pursuing a formal complaint if they are not satisfied with the outcome

As per our Safeguarding Policy, training provided to all staff is regularly updated to ensure they remain up to date with relevant skills and knowledge to safeguard our learners effectively.

We will identify specific staff and provide them with special training on safeguarding and child protection training to enable them to assist victims of sexual harassment. This also includes online safety as well as an understanding of expectations and responsibilities in relation to filtering and monitoring.

GVNC also adheres to the updated definition of extremism set out in the Prevent Duty Guidance and current statutory definition. Any concerning online or offline behaviour linked to extremism, radicalisation or extremist ideology will be addressed in accordance with our Safeguarding and Prevent Policy.

The EDI lead has had further training in the area of sexual harassment. All staff are enhanced DBS checked.

For visitors, such as external speakers, GVNC will give careful consideration to the suitability of information and resources that speakers can provide to enrich the education of our students. An assessment, following the UKCIS external visitors guidance will be carried out prior to individuals coming onto the premises including an assessment of what is going to be delivered and whether relevant checks will be required. All visitors on whom no checks have been obtained will not be left unsupervised or allowed to work in regulated activity.

GVNC is committed to ensuring that learners are provided with a safe environment in which to learn, therefore as part of this process we ensure that our IT system has appropriate filtering and monitoring systems in place to safeguard both learners and staff from potentially harmful and inappropriate online material. The effectiveness of these measures is regularly reviewed.

GVNC provides student Wi-Fi access to support learning, research and engagement with online educational platforms. Although our digital infrastructure differs from a school-based network, we continue to review our filtering and monitoring arrangements against the expectations set out by the Department for Education. This includes consideration of the DfE’s ‘Plan technology for your school’ service as a reference point to support internal self-assessment and ensure our systems remain robust, proportionate and compliant with statutory safeguarding requirements.

All staff are aware of these measures, and how to escalate concerns if any occur. The Designated Safeguarding Lead has overall responsibility for online safety, while IT systems are overseen by the IT manager including:

maintaining filtering and monitoring systems
providing filtering and monitoring reports if required
completion of actions following concerns or checks to systems

As recommended by Department for Education in their Meeting Digital and Technology Standards in Schools and Colleges guidance[1], the use of South West Grid for Learning’s (SWGfL) testing tool is being used to check filtering systems block access to:

illegal child sexual abuse material
unlawful terrorist content
adult content

These measures support the broader cybersecurity standards for schools and colleges, which are designed to strengthen organisational cyber resilience. GVNC recognises that robust cyber resilience forms part of our safeguarding duty, particularly in mitigating risks linked to online harassment, data breaches and exploitation.

As part of our online safety strategy, filtering and monitoring systems are reviewed not only for illegal child-sexual-abuse and terrorist content, but also for harmful content such as misinformation, disinformation (including fake news), conspiracy theories and the misuse of generative AI tools, in line with the latest statutory guidance.

GVNC also has due regard to the Department for Education’s 2026 guidance on the use of generative artificial intelligence in education. This includes ensuring that staff and learners understand safe, ethical and appropriate use of generative AI tools, and that any misuse which may present a safeguarding risk is identified, addressed and escalated appropriately.

Our filtering and monitoring provision will be reviewed annually to ensure we continue to meet our statutory requirements in KCSIE as well as the Prevent duty.

If a student, clinical supervisor/ mentor or member of the college team was subject to sexual harassment, additional support would be provided on an individual basis, including signposting to support services.

GVNC ensures that every employer e.g. Training Practices are aware of GVNC’s safeguarding policy (including sexual harassment) and how to escalate concerns to the DSL.

Any complaint will be taken very seriously, a robust investigation undertaken and under no circumstances would the two parties be left alone in any situation within the controls of the college and the apprentice workplace.

Support

We recognise that because sexual harassment often occurs in unequal relationships within the workplace, victims often feel that they cannot come forward.

All staff are aware that a victim may not feel ready or know how to tell someone that they are being abused, exploited, or neglected, and/ or they may not recognise their experiences as harmful. For example, they may feel embarrassed, humiliated, or being threatened. This could be due to their vulnerability, disability and/or sexual orientation or language barriers. This should not prevent staff from having a professional curiosity and speaking to the DSL if they have concerns about a student, clinical coach, or a member of the training department.

It is also important that staff determine how best to build trusted relationships with students and those that are training them, to facilitate communication.

Where all parties are aged 18 or over and there is no wider safeguarding concern, informal resolution may be considered where it is appropriate, safe and genuinely desired by the person making the report. Informal resolution will not be used where a learner under 18 is involved or where there are concerns relating to harmful sexual behaviour, sexual violence, coercion, exploitation or other safeguarding risks.

If the victim wants to make a formal complaint or if the informal complaint mechanism has not led to a satisfactory outcome for the victim, the formal complaint mechanism should be used to resolve the matter.

In line with KCSIE 2026, staff should refer to the DfE’s Data Protection guidance to understand how to share and manage information in safeguarding contexts safely. GVNC will ensure that safeguarding records (including complaints of sexual harassment) are stored securely, shared only on a ‘need to know’ basis, and handled with our internal data-protection and confidentiality policies.

Sanctions and disciplinary measures

Anyone who has been found to have sexually harassed another person under the terms of this policy is liable to any of the following sanctions:

verbal or written warning
suspension
dismissal

The nature of the sanctions will depend on the gravity and extent of the harassment. Suitable deterrent sanctions will be applied to ensure that incidents of sexual harassment are not treated as trivial. Certain serious cases, including physical violence or actual abuse, will result in the immediate dismissal of the harasser, including if an apprentice suspension

from the college / course. The victim where applicable will be supported to raise this with the police if deemed necessary.

Learners under the age of 18

For the purposes of Keeping Children Safe in Education 2026, a child is anyone under the age of 18. As GVNC enrols learners from age 17, any concern involving sexual harassment, harmful sexual behaviour or sexual violence where a learner is under 18 will be treated as a safeguarding concern and managed in accordance with GVNC’s Safeguarding and Prevent Policy.

GVNC recognises that harmful sexual behaviour can occur on a continuum and may include inappropriate or problematic sexualised behaviour, sexual harassment and sexual violence. Behaviour may occur face-to-face, online, within college, in the workplace or outside the education or training environment. Misogynistic, coercive, degrading or sexually inappropriate behaviour will be challenged and addressed at the earliest opportunity.

Any incident involving the making or sharing of nude or semi-nude imagery involving a learner under 18, including imagery that has been digitally altered or generated using artificial intelligence, will receive a safeguarding response irrespective of whether the imagery was initially created or shared consensually or non-consensually.

A learner under 18 will not be expected to confront an alleged perpetrator or resolve a safeguarding concern informally. The concern should be reported to the Designated Safeguarding Lead or a Deputy Designated Safeguarding Lead, who will determine the appropriate safeguarding response and whether referral to external agencies is required.

Implementation of this policy

We will ensure that this policy is widely disseminated. It will be included in learner and staff handbooks, and on our e-learning platform. We also inform parent / guardians (if the student is under the age of 18) and employers about this policy.

All learners and staff will be trained on the implementation of this policy as part of their induction into the company.

We will ensure that all staff are aware of the systems in place to support safeguarding including:

Behaviour policy (includes measures to prevent bullying, including cyberbullying, prejudice-based and discriminatory bullying).
Staff behaviour policy to include low-level concerns, allegations against staff and whistleblowing.
How to respond to learners that are absent from education, including repeatedly or for prolonged periods
The role of the designed Safeguarding Lead and Deputy Safeguarding Lead

These policies are included in the Staff Policy Handbook provided to all staff at induction and includes a copy of this policy. In addition, staff will be provided a copy of the most up to date version of the KCSiE statutory guidance for schools and colleges.

In accordance with KCSIE 2026, GVNC recognises that safeguarding responsibilities extend to all environments in which our learners undertake education and training. Where learners attend off-site provision such as training practices, GVNC will obtain written confirmation that appropriate safeguarding checks have been completed via Training Practice visit documentation, that learners’ attendance and wellbeing are monitored, and that any concerns are promptly reported to the Designated Safeguarding Lead. Persistent or unexplained absence, particularly for learners under 18 or those identified as vulnerable, will be treated as a potential safeguarding concern. GVNC will maintain regular communication with training practices to ensure shared understanding of this policy, including expectations regarding professional conduct, sexual harassment prevention, online safety, and escalation of safeguarding concerns.

GVNC also has regard to the statutory guidance ‘Working Together to Safeguard Attendance’ (2026), recognising that patterns of absence, lateness or disengagement may indicate underlying welfare concerns, including harassment, exploitation or abuse.

We will ensure frequent updating of learners and staff on the implementation of this policy.

It is the responsibility of every manager to ensure that their employees are aware of the policy.

GVNC will update this policy in line with any new or amended statutory guidance, including the forthcoming DfE guidance on supporting gender-questioning children, once published.

Goddard Veterinary Nursing College recognises the importance of monitoring this sexual harassment policy and will ensure that it anonymously collects statistics and data as to how it is used and whether or not it is effective. Data will include reports of low-level concerns.

Our clinical governance board will receive regular reports on the effectiveness of this policy, including the number of incidents, how they were dealt with, and any recommendations made.

This will be done on a yearly basis as a minimum.

As a result of these reports, Goddard Veterinary Nursing College will evaluate the effectiveness of this policy and make any changes needed.