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The Heatherley School of Fine Art, 75 Lots Road, Chelsea, London SW10 0RN  |  phone 020 7351 4190


Heatherley School of Fine Art’s policies are available on this page.

Terms and conditionsPrivacy policy | Refunds Policy | Diversity| Anti-Harassment and Anti-Bullying | Safeguarding and Prevent | Complaints Policy | BAC Complaints Policy

Terms & Conditions

Terms of website use

Please read these terms of use carefully before you start to use the site. By using our site, you indicate that you accept these terms of use and that you agree to abide by them. If you do not agree to these terms of use, please refrain from using our site.

Reliance on information posted & disclaimer

The materials contained on our site are provided for general information purposes only and do not claim to be or constitute legal or other professional advice and shall not be relied upon as such.

We do not accept any responsibility for any loss which may arise from accessing or reliance on the information on this site and to the fullest extent permitted by English law, we exclude all liability for loss or damages direct or indirect arising from use of this site.

Information about us is a site operated by The Heatherley School of Fine Art (’We’); we are a Charity registered in England under registration number 312872. Our registered office is Heatherley School of Fine Art,75 Lots Road,London,SW10 0RN.

Accessing our site

Access to our site is permitted on a temporary basis, and we reserve the right to withdraw or amend the service we provide on our site without notice (see below). We will not be liable if for any reason our site is unavailable at any time or for any period.

Intellectual property rights

We are the owner or the licensee of all intellectual property rights in our site, and in the material published on it. Those works are protected by copyright laws and treaties around the world. All such rights are reserved.

You may print off one copy, and may download extracts, of any page(s) from our site for your personal reference and you may draw the attention of others within your organisation to material posted on our site.

You must not modify the paper or digital copies of any materials you have printed off or downloaded in any way, and you must not use any illustrations, photographs, video or audio sequences or any graphics separately from any accompanying text.

Our status (and that of any identified contributors) as the authors of material on our site must always be acknowledged.

You must not use any part of the materials on our site for commercial purposes without obtaining a licence to do so from us or our licensors.
If you print off, copy or download any part of our site in breach of these terms of use, your right to use our site will cease immediately and you must, at our option, return or destroy any copies of the materials you have made.

Our site changes regularly

We aim to update our site regularly, and may change the content at any time. If the need arises, we may suspend access to our site, or close it indefinitely. Any of the material on our site may be out of date at any given time, and we are under no obligation to update such material.

Our liability

The material displayed on our site is provided without any guarantees, conditions or warranties as to its accuracy. To the extent permitted by law, we, and third parties connected to us hereby expressly exclude: All conditions, warranties and other terms which might otherwise be implied by statute, common law or the law of equity.

Any liability for any direct, indirect or consequential loss or damage incurred by any user in connection with our site or in connection with the use, inability to use, or results of the use of our site, any websites linked to it and any materials posted on it, including, without limitation any liability for:

  • loss of income or revenue
  • loss of business
  • loss of profits or contracts
  • loss of anticipated savings
  • loss of data
  • loss of goodwill

wasted management or office time; and for any other loss or damage of any kind, however arising and whether caused by tort (including negligence), breach of contract or otherwise, even if foreseeable, provided that this condition shall not prevent claims for loss of or damage to your tangible property or any other claims for direct financial loss that are not excluded by any of the categories set out above.

This does not affect our liability for death or personal injury arising from our negligence, nor our liability for fraudulent misrepresentation or misrepresentation as to a fundamental matter, nor any other liability which cannot be excluded or limited under applicable law.

Information about you and your visits to our site

We process information about you in accordance with our privacy policy. By using our site, you consent to such processing and you warrant that all data provided by you is accurate.

Viruses, hacking and other offences

You must not misuse our site by knowingly introducing viruses, trojans, worms, logic bombs or other material which is malicious or technologically harmful. You must not attempt to gain unauthorised access to our site, the server on which our site is stored or any server, computer or database connected to our site. You must not attack our site via a denial-of-service attack or a distributed denial-of service attack.

By breaching this provision, you would commit a criminal offence under the Computer Misuse Act 1990. We will report any such breach to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use our site will cease immediately.

We will not be liable for any loss or damage caused by a distributed denial-of-service attack, viruses or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of our site or to your downloading of any material posted on it, or on any website linked to it.

Links from our site

Where our site contains links to other sites and resources provided by third parties, these links are provided for your information only. We have no control over the contents of those sites or resources, and accept no responsibility for them or for any loss or damage that may arise from your use of them. When accessing a site via our website we advise you check their terms of use and privacy policies to ensure compliance and determine how they may use your information.

Jurisdiction and applicable law

The English courts will have non-exclusive jurisdiction over any claim arising from, or related to, a visit to our site.

These terms of use and any dispute or claim arising out of or in connection with them or their subject matter or formation (including non-contractual disputes or claims) shall be governed by and construed in accordance with the law of England.


We may revise these terms of use at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we made, as they are binding on you. Some of the provisions contained in these terms of use may also be superseded by provisions or notices published elsewhere on our site.

Your concerns

If you have any concerns about material which appears on our site, please contact us.

Heatherley School of Fine Art Privacy Policy

Reviewed November 2023
Reviewer Veronica Ricks


Heatherleys School of Fine Art (“the school”) is a data controller and committed to protecting your personal data and working in accordance with all relevant Data Protection legislation.

We use your data to keep in touch with you as students, alumni (lifelong members of the school) and supporters, to keep you informed of our activities and developments, to provide services to you, and to identify ways in which you may wish to support us through financial or non financial support.

We ensure that everything we do with student, alumni and supporters information is as clear and transparent as possible. We have always kept student, alumni and supporter information data secure.

What data do we hold?

The school may hold data relating to you from various sources. For instance, we hold data which you have provided to us during your time as a student, when you completed one of our enrolment forms, attended an event, made a donation or engaged with us in any other way. If you are, or have been, a student at the school your data will be transferred to our alumni database when you leave.

Our records may include details of your education, biographical information such as your date of birth or marital status, your contact details which we update when you tell us they have changed or personal details, for example disability or other health issues you have informed us about.

How do we use your data?

The school primarily uses your data to communicate with you about enrolment, course information, exhibitions and events and in support of our fundraising programme which is becoming an important element of our charitable work.

We are required to conduct due diligence checks before accepting major donations which includes reviewing publicly available data including criminal convictions. Communications may be sent to you by post, telephone, email, text, or other electronic means (for example through social media) depending on the communication preferences you have shared with us.

Sharing your data

We facilitate communication between individual students and alumni of the school but in doing so we do not release personal contact details without prior permission.

Depending on constraints set by you and which you may change at any time, we may share data on a considered and confidential basis, where appropriate with:

● Volunteer partners closely related to us (e.g. school trustees, development board members, student representatives)
● Contractors providing services to you on our behalf or services to us (our data processors)

We do NOT sell data to third parties. We will never share your data with anyone to allow other charities to contact individuals.

How do we protect your data?

Your information and electronic data is held securely and is accessible only to a limited number of school administrative staff.

Your rights and preferences

The legal basis for processing your personal data is your consent, where you have provided this, and otherwise our legitimate interest. There is no statutory requirement for you to provide us with any personal data. The school may contact you by post unless you request otherwise, and by telephone, text, email or other electronic means as you have previously consented. If you no longer wish to receive communications from us by post, telephone, email, text or other electronic means, please contact the school office at 02073514190 or We will retain your data indefinitely or until you request us to do otherwise. If you ask us to delete your data, we will maintain a skeleton record comprising your name, subject of study, year of graduation where appropriate and date of birth to ensure we do not inadvertently contact you in the future. We may also need to retain some financial records for statutory purposes (for example Gift Aid).

You have the right to:

  • withdraw your consent at any time.
  • see or delete the data we hold about you.
  • object to specific data uses
  • object to receiving communications and direct marketing
  • ask for the transfer of your data to a third party.
  • lodge a complaint with the Information Commissioner’s Office at

Other information

Please do not hesitate to contact us at if you have any questions about our Privacy Policy or if you have any queries or concerns about the school’s processing of your personal data This Privacy Policy will be kept under review. Any changes will be updated on our website and communicated to you as appropriate. This privacy notice was updated in November 2023.


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Browser compatibility

Our site is built to work with up to date versions of all popular web browsers. However, we cannot guarantee compatibility with all browsers at all times

Diversity & Inclusion

‘Black Lives Matter’


We have been deeply saddened by the recent tragic events in the United States. In solidarity with the black community and subsequent peaceful protest around the world, we realise that we must also play our part in creating a fair and equal society in Britain. We acknowledge and must act upon our own responsibility to challenge and confront prejudice, bias or any form of racial discrimination whether of action or language within our own school community.

In line with the core values of our school, which include kindness, social justice and equal opportunity, we are committed to supporting our black students, colleagues and our school friends. However, if we are to do this in any meaningful way we must first look in the mirror. We must examine all levels of our own institution for systemic racism and be prepared to give ourselves to the process of honest self reflection which is needed in order to effect change.

We are developing an action plan which will help us take the first steps towards achieving this.

  • On our return to school, we will create a working party which will invite, listen to and learn from the experience of our staff, students and alumni who are black, asian or belong to other ethnic or marginalised  groups. We will use this analysis to examine and inform every aspect of the actions we take and the language we use.
  • We will raise awareness by regularly offering training, guidance and induction to our staff and students to increase understanding of the issues of white privilege, discrimination and inherent bias which, on a daily basis, adversely affect black, asian and ethnic minority members of our community.
  • We will recognise and act upon our responsibility as educators to examine, acknowledge and celebrate the contribution that black artists have made and are making to our shared culture.
  • We will ensure that black, asian and ethnic minority communities are fairly represented at every level in the structure of our institution. To underline this commitment, we will review our employment practices in order to remove any elements of systemic racism or gender based bias so that they are transparent, inclusive and reflect the diverse multicultural nature of our school.
  • We will enhance our provision of bursary funding from ethical sources so that we can provide more accessible opportunities for talented but disadvantaged black artists and for other marginalised minority groups to benefit from our courses and facilities.
  • We will continue to rigorously apply the principles of our school policies to the daily life of the school at every level, including the routes that exist for any member of the school community who experiences discrimination, to be heard and supported.
  • We will communicate our ethos to the wider public by publishing our policies on the website.

We are taking independent steps to address systemic bias in our institution. Although events which have led to this point have been painful, they present us with the opportunity to learn, to change and to create a better future.

We are adamant that racism has no place in our school community.

Anti-Harassment and Anti-Bullying Policy and Procedure


Reviewed November 2023


Heatherley School of Fine Art believes that every member of our school community has the right to study, work and use the School without fear of harassment or bullying. Whether on grounds of sex, race, disability, age, religious or political beliefs, sexual orientation or any other ground which may affect a person’s dignity. We are committed to creating a positive environment where all members of the School can thrive and will not tolerate behaviour that fails to support our values.

It is essential that the School environment is such that victims of harassment or bullying feel able to bring such conduct into the open without fear of retaliation, embarrassment or feelings of guilt. In addition, there must be a well-understood procedure to deal with such incidents and to counteract the effects of harassment and bullying.


Step 1: Ask the harasser to stop

If you feel that you are being personally harassed or bullied you should not feel that it is your fault or that you have to tolerate it. You should approach the individual(s) concerned and make it clear to them that their behaviour is unwelcome. The person may not realise that they are being offensive or unreasonable and talking to them may resolve the problem at this informal stage without the necessity of lodging a formal complaint. If you would like advice on handling the situation you should talk to your Tutor or Course Director if you are a student or to your Line Manager if you are a member of staff.

Step 2: Keep a record of the harassment and seek mediation

If you feel you are being harassed then keeping a record of events will help in any investigation of them, but failure to do so will certainly not invalidate a complaint.

  • Consider the following points:
  • When did it start?
  • What happened?
  • Were there any witnesses?
  • Were there any threats of reprisal?
  • What did you do?

If the harassment continues, despite your efforts to stop it you should report this to your Tutor or Course Director if you are a student or to your Line Manager if you are a member of staff. They will ensure that your complaint is investigated and will help you to try and resolve the matter informally through mediation. In cases involving mediation appropriate safeguards will be put in place to ensure a harassment-free working and learning environment. These safeguards may relate to all persons involved.

Step 3: Make a Formal Complaint

If you consider the harassment or bullying actions to be serious and that mediation will not work you should immediately lodge a formal written complaint to the Principal and this will be investigated according to the School Complaints Policy and Procedure. In cases involving a formal procedure, appropriate safeguards will be put in place to ensure a harassment-free working and learning environment. These safeguards may relate to all persons involved.

1. Our Commitment

Heatherley School of Fine Art aims to create a learning environment free of harassment and bullying where everyone is treated with dignity and respect and students have the opportunity to realise their full potential. The aim of this policy is to support this ethos and to strive to prevent harassment and bullying from occurring.

Harassment and bullying can have very serious consequences for individuals and the School. Harassment or bullying may make people unhappy, may cause them stress and affect their health and family and social relationships, may affect their learning and could cause them to leave their course. Effects on the School could include poor retention rates and damage to the School’s reputation. Any member of the School community found guilty of harassment or bullying may face disciplinary penalties, up to and including dismissal and may find their own and social relationships are adversely affected. Serious harassment may be a criminal offence.

The School will not tolerate any form of harassment or bullying, and is committed to ensuring that all students and members of staff are able to work confidently and without fear of harassment, bullying or victimisation. All allegations of bullying and harassment will be investigated promptly and, if appropriate, disciplinary action will be taken. Where an employee is found to have committed a serious act of bullying or harassment against a student it will be dealt with according to staff disciplinary procedures. Where a student is found to have harassed or bullied an employee, the School will deal with this under the student disciplinary procedure, which could result in expulsion. Where an employee reports an incident of harassment or bullying by a third party, the School will take appropriate action. The School will not tolerate victimisation of a person for making allegations in good faith or supporting someone to make such a complaint. If victimisation is found to have occurred it will be treated as a disciplinary offence.

In order to meet our commitment, the School will ensure that all students and members of staff understand their rights and responsibilities and are aware of the procedure for dealing with complaints of bullying or harassment.

2. Scope

This policy covers the bullying and harassment of students by other students or by staff or anyone else engaged to work at the School whether in a paid or voluntary capacity. Also of staff by any other member of staff or by any student. If the alleged harasser is not employed by the School, e.g. if the worker’s contract is with an agency or sub-contractor, this policy and procedure will apply with any necessary modifications such as that the School could not dismiss the worker but would instead require the agency to remove the worker after appropriate investigation.

The policy covers bullying and harassment in the School but also on any premises where attendance is part of the course or employment contract.

3. What is bullying and harassment?

3.1 Bullying

There is no legal definition of bullying but it may be characterised as offensive, intimidating, malicious or insulting behaviour, and/or an abuse or misuse of power that is meant to undermine, humiliate or injure the recipient.

3.2 Harassment

Harassment is unwanted conduct related to relevant protected characteristics as defined by the Equality Act 2010 which are sex, gender reassignment, race (which includes colour, nationality and ethnic or national origins), disability, sexual orientation, religion or belief and age) that:

● has the purpose of violating an individual’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for that person: or

● is reasonably considered by that person to have the effect of violating their dignity or of creating an intimidating, hostile, degrading, humiliating or offensive environment for them, even if this effect was not intended by the person responsible for the conduct.

Conduct may be harassment whether or not the person behaving in that way intends to offend. Something intended as a “joke” may offend another person. Different people find different things acceptable. Everyone has the right to decide what behaviour is acceptable to them and to have their feelings respected by others. Behaviour which any reasonable person would realise would be likely to offend will be harassment without the recipient having to make it clear in advance that behaviour of that type is not acceptable to them, eg. sexual touching. It may not be so clear in advance that some other forms of behaviour would be unwelcome to, or could offend, a particular person, eg. certain “banter”, flirting or asking someone for a private drink after School. In these cases, first-time conduct which unintentionally causes offence will not be harassment but it will become harassment if the conduct continues after the recipient has made it clear, by words or conduct, that such behaviour is unacceptable to them.

Harassment may occur where a person engages in unwanted conduct towards another because they perceive that the recipient has a protected characteristic (for example, a perception that they are gay or disabled) when the recipient does not in fact have that protected characteristic. For example, it would be harassment for an individual to repeatedly tease an individual because of an incorrect belief that the recipient is deaf. Similarly, harassment could take place where an individual is bullied or harassed because of another person with whom the individual is connected or associated, for example if they have a child who is disabled, a wife who is pregnant or a friend who is a devout Christian.

A single incident can be harassment if it is sufficiently serious. 

Bullying or harassment will constitute unlawful discrimination where it relates to one of the protected characteristics. Serious bullying or harassment may amount to other civil or criminal offences, e.g. a civil offence under the Protection from Harassment Act 1997 and criminal offences of assault.

3.3. Examples of bullying and harassment

Examples of unacceptable behaviour that are covered by this policy include (but are not limited to):

  • Physical conduct ranging from unwelcome touching to serious assault
  • Unwelcome sexual advances
  • Threats for rejecting sexual advances, eg. suggestions that refusing advances will adversely affect a student’s marks or an employee’s work reference
  • Demeaning comments about a person’s appearance
  • Unwelcome jokes or comments of a sexual or racial nature or about an individual’s age, disability, sexual orientation or religion
  • Questions about a person’s sex life
  • Unwanted nicknames relating to a person’s age, race or disability
  • The use of obscene gestures
  • Excluding an individual because they are associated or connected with someone with a protected characteristic, eg. they have a child who is gay, a spouse of different ethnicity or a parent who is disabled
  • Ignoring an individual because they are perceived to have a protected characteristic when they do not, in fact, have the protected characteristic, eg. an employee is thought to be Jewish, or is perceived to be transsexual
  • The open display of pictures or objects with sexual or racial overtones, even if not directed at any particular person, eg. magazines, calendars or pin-ups unless this is part of an academic critique
  • Spreading malicious rumours, allegations or gossip or insulting someone.
  • Copying emails that are critical about someone to others who do not need to know
  • Picking on someone or setting them up to fail
  • Overbearing supervision or other misuse of power or position
  • Shouting, abusive or intimidating language
  • Intrusion by pestering, spying or stalking
  • Cyber-bullying: ie. The sending or posting of harmful, cruel or offensive text or images by email, internet, social networking websites or other digital communication devices.

The above list is intended to give an indication of the types of behaviour that the School considers to be unacceptable; however, it is not exhaustive.

It is accepted that vigorous academic debate and an occasional raised voice or argument in class, of itself may not necessarily constitute harassment or bullying.

Bullying must be distinguished from the right of, and obligation placed on, staff to exercise proper supervision of students in the course of their duties, which may include legitimate, constructive and fair criticism of a student’s performance or behaviour at school. Staff will exercise this supervision in a fair, constructive, consistent and reasonable manner that does not compromise the student’s dignity. Similarly, reasonable (but perhaps unpopular) requests to students by a member of staff, in the normal course of their duties, will not be viewed as acts of harassment or bullying.

3.4 Third Party Harassment

The Equality Act 2010 makes the School potentially liable for harassment of its students or staff by third parties who are not employees of the School, such as a contractor. For example, it might be that a contractor makes a series of racist remarks to a student. Liability occurs when harassment has occurred on at least two previous occasions; the School is aware that the harassment has taken place and has not taken reasonable steps to prevent it from happening again.

If a student or member of staff feels that they have been bullied or harassed by a third party, they should report any such behaviour to their tutor, Course Director or their line manager who will take appropriate action.

3.5 Victimisation

Victimisation is subjecting a person to a detriment because they have, in good faith, complained (whether formally or otherwise) that someone has been bullying or harassing either them or someone else, or because they have supported someone in making a complaint or given evidence in relation to a complaint. This would include isolating someone because they have made a complaint.

Provided that a student or employee has acted in good faith, ie.they genuinely believes that what they have said is true, they have the right not to be victimised for making a complaint or doing anything in relation to a complaint of bullying or harassment. The School will take appropriate action to deal with any alleged victimisation. This may include disciplinary action against the person who is alleged to have victimised the person who has made a complaint.

Making a complaint that the complainant knows to be untrue, or giving evidence that is known to be untrue, may lead to disciplinary action being taken against the complainant.

4. Responsibilities

4.1 Trustees are responsible for ensuring that:

● They are familiar with the anti-harassment and anti-bullying policy
● They are aware of the School’s legal responsibilities in relation to harassment and bullying.

4.2 Managers

The Principal and senior members of staff are responsible for:
● Taking the lead in creating a positive, open culture that challenges unacceptable
● Ensuring that they are aware of their legal responsibilities towards learners and
members of staff
● Ensuring that appropriate information is provided to students and staff
● Ensuring that staff understand how to manage the procedures
● Monitoring and reviewing the policy

4.3 Staff

Members of staff are responsible for ensuring that they:
● Set a good example by their own behaviour
● Create a supportive learning environment
● Make sure that students know what standards of behaviour are expected of
● Intervene to stop bullying and harassment
● Are familiar with the harassment and bullying policy, and understand how to
deal with a formal complaint

4.4 Students

All students are responsible for ensuring that they:

● Are aware of how their behaviour may affect others and changing it, if
necessary, as behaviour can cause offence even it if is only meant to be a joke
● Treat all members of the school community with dignity and respect
● Take a stand if they think inappropriate jokes or comments are being made and
make it clear that they find harassment and bullying unacceptable
● Make it clear to others if they find their behaviour unacceptable
● Intervene, if possible and safe, to stop harassment or bullying and give support
to recipients
● Are familiar with the policy and what to do if they wish to make a complaint
● Participate in an investigation as and when appropriate

5. Guidance and information for students and staff

In order to support the School’s aim of preventing harassment and bullying, guidance and information will be provided digitally or by hard copy to all staff and full time students. The Anti-harassment and Bullying policy will be made available in hard copy at information points in the school to all students and members of staff.

6. Support Available to Students

The School recognises the sensitive nature of harassment and bullying. Students or members of staff who believe they are being harassed or bullied may wish to discuss their particular situation in confidence before deciding what action to take. Students should discuss problems with their personal tutor but may also speak to any member of staff. Members of staff should speak to their line manager or to the Principal.

Confidentiality will be maintained as far as possible. However, if a student or member of staff decides not to take any action to deal with the problem and the circumstances described are very serious, the School reserves the right to investigate the situation in accordance with its duty of care to ensure the safety of all members of the school community who may be affected by the alleged behaviour.

7. Review and Monitoring

Managers will review and monitor the application of the policy on a regular basis, using information such as the number and nature of complaints raised and general feedback from students and staff. Managers will then make appropriate changes.


Step 4: Formal Investigation

Your complaint will be considered and the School may appoint an Investigating Officer to fully investigate any formal complaint of alleged harassment or bullying. The School will endeavour to support alleged victims of any harassment and bullying to ensure they can work and study without fear. This may involve suspension without prejudice of alleged perpetrators whilst the investigation is being completed or, in very serious cases, it may include the involvement of outside bodies such as the police.

Step 5: Action

After the investigation has been completed an appointed senior manager of the School will determine what further action may be required. A justified complaint may result in action being taken under the School’s Disciplinary Procedures. Equally a complaint which is made and considered by the School to be cynical or mischievous may result in disciplinary action being taken against the complainant.

Cases involving Vulnerable Adults

Full and part time students in the school must all be aged 18 years or older. Where a victim is considered to be a vulnerable adult appropriate actions will be taken which may include contacting parents, guardians or other designated carers.

Veronica Ricks (Principal)
November 2023

School Level

1. Discuss the draft with managers and get it approved by the Trust as soon as possible.
2. Arrange training for staff so they are familiar with it.
3. Get it onto the website and in leaflets, part of student and staff induction, etc.


Ask the complainant to be specific about any incidents as general assertions about feeling bullied are not helpful as they cannot be investigated. Details needed are:

● When did it start?
● What happened?
● Were there any witnesses?
● Were there any threats of reprisals made?
● What did you do?

The management focus needs to be on taking the reports seriously but not escalating the matter to formal if informal and mediation can work. However, staff need to keep notes, even if only diary notes in case the matter goes formal. Not documenting can give you problems later!

Step 1 – The student asks the harasser / bully to stop

With ‘non-vulnerable’ adult students or members of staff the expectation is that they will:

● Raise the matter at the time with the person who is harassing them.
● Say clearly what aspect of their behaviour they do not like
● State how they would like the behaviour to change

Step 2 – Mediation

If the matter is not resolved then the next step should be mediation involving staff if the complainant is a student. If the complainant is a member of staff they should report the matter to their line manager.

Step 3 – Formal written complaint

If the matter cannot be resolved informally then the complainant needs to make a formal written complaint, with details as per 1 above, which needs investigating and documenting.

Step 4 – Formal investigation

This should be by a ‘neutral’ member of staff to ensure objectivity. Each person involved writes and signs a statement. Independent witnesses are helpful as incidents of one against one are impossible to prove and you get into balance of probability. This is not a court of law!

Step 5 – Action

The procedure from here is the relevant School Student or staff Disciplinary procedure if there is sufficient evidence.

Equally a mischievous complaint also needs dealing with.

It depends on what is in your disciplinary procedure but if there is a hearing it would usually be acceptable for the person who is accused to have a companion with them – this is usually another student or member of staff. It can be a family member/ official guardian for or a key worker for a vulnerable adult. In no circumstances would a legal representative be permitted in an internal investigation / hearing. The companion is just that and does not represent the member of staff or student being investigated

In some circumstances bullying and harassment are not just upsetting, they are illegal, so members of staff need to be very careful to manage complaints quickly and thoroughly.

Safeguarding & Prevent Support Guide

Reviewed November 2023

This guide is to inform staff in the implementation and support of Safeguarding & Prevent responsibilities.

The guide includes the following information –

  1. Introduction to Prevent
  2. Risk
  3. Radicalisation and extremism
  4. Responsibilities
  5. Prevent and British Values
  6. Freedom of Speech
  7. Understanding and defining Safeguarding
  8. Possible signs of Abuse or Radicalisation
  9. Code of Conduct
  10. Challenging extremism
  11. Safeguarding and Prevent referral agencies
  12. Channel and Procedure
  13. HM Government ‘Seven Golden Rules to Sharing Information’
  14. Safeguarding and Prevent Incident form

General Statement

In 2010 the Government published the Prevent Strategy, a national programme to stop people becoming terrorists or supporting terrorism. There have been several occasions in which extremist groups have attempted to radicalise vulnerable young people to hold extreme views including views justifying political, religious, sexist or racist violence, or to steer them into a rigid and narrow ideology that is intolerant of diversity and leaves them vulnerable to future radicalisation.

1. Introduction to Prevent

The government’s strategy for countering terrorism, the Contest Strategy, is split into 4 areas: Pursue, Protect, Prepare and Prevent.  All FE institutions have to comply with the Prevent Duty under the Counter Terrorism Act 2015.

The Prevent Strategic objective is to stop people from becoming or supporting terrorists or radicalisation and to challenge all forms of terrorism, including the influence from far right extremist groups.   

The Prevent Duty is to protect people from all streams of extremist activity and is not solely aimed at one specific group.

The Prevent Strategy has 3 key objectives:-

  • Respond to the ideological challenge of terrorism and the threat we face from those who promote it
  • Prevent people from being drawn into terrorism and ensure that they are given appropriate advice and support
  • Work with sectors and institutions where there is a risk of radicalisation which we need to address

The Home Office Prevent Duty guidance document sets out clear expectations and responsibilities for board members, leaders, managers and staff:-

“We expect active engagement from boards, managers, leaders and staff with other partners including the police and regional Prevent coordinators”

“We expect institutions to demonstrate that they undertake appropriate training and development for boards, leaders, managers and staff”

Prevent is part of safeguarding learners and all providers of Further Education have a duty to safeguard their learners from all aspects of abuse, exploitation and radicalisation.  Implementing the Prevent Duty can be a sensitive issue for some learners and communities and it is important to state that this is not about spying on learners or staff or about stopping conversations on controversial or sensitive topics.  The Prevent Duty is intended to safeguard providers of Further Education, learners and staff from being exposed to exploitation or radicalisation and to support the discussion and understanding of complex and controversial issues.

2. Risk

The current threat from terrorism in the United Kingdom may include the exploitation of vulnerable people, to involve them in terrorism or in activity in support of terrorism. The normalisation of extreme views may mean that young and vulnerable people are susceptible to manipulation and exploitation. The Heatherley School of Fine Art (HSFA) is clear that this exploitation and radicalisation should be viewed as a safeguarding concern and seeks to protect young and vulnerable people against the messages of all violent extremism.

Risk reduction. The Senior Management Team and the designated Lead Safeguarding Officer (Safeguarding Champion) will assess the level of risk which may include consideration of the use of our premises by external agencies, curriculum, Outreach provision, disclosed safeguarding cases, anti-bullying policy and other issues specific to our profile, community and philosophy.

Intervention. Numerous factors can contribute to and influence the range of behaviours that are defined as violent extremism, but most young people do not become involved in extremist action. For this reason the appropriate interventions in any particular case may not have any specific connection to the threat of radicalisation, for example they may address mental health, relationship or drug/alcohol issues.

3. Radicalisation and extremism

Radicalisation refers to the process by which a person comes to support terrorism and forms of extremism leading to terrorism.

Extremism is defined by Government in the Prevent Strategy as:

Vocal or active opposition to fundamental British values, including democracy, the rule of law, individual liberty and mutual respect and tolerance of different faiths and beliefs.

Extremism is defined by the Crown Prosecution Service as:

The demonstration of unacceptable behaviour by using any means or medium to express views which:

  • Encourage, justify or glorify terrorist violence in furtherance of particular beliefs;
  • Seek to provoke others to terrorist acts;
  • Encourage other serious criminal activity or seek to provoke others to serious criminal acts
  • Foster hatred which might lead to inter-community violence in the UK.

There is no such thing as a “typical extremist”. Those who become involved in extremist actions come from a range of backgrounds and experiences, and most individuals, even those who hold radical views, do not become involved in violent extremist activity.

Students may become susceptible to radicalisation through a range of social, personal and environmental factors. It is known that violent extremists exploit vulnerabilities in individuals to drive a wedge between them and their families and communities. It is vital that staff are able to recognise those vulnerabilities.

Indicators of vulnerability include:-

a. Identity Crisis – the student is distanced from their cultural / religious heritage and experiences discomfort about their place in society;

b. Personal Crisis – the student may be experiencing family tensions; a sense of isolation; and low self-esteem; they may have dissociated from their existing friendship group and become involved with a new and different group of friends; they may be searching for answers to questions about identity, faith and belonging

c. Personal Circumstances – migration; local community tensions; and events affecting the student’s country or region of origin may contribute to a sense of grievance that is triggered by personal experience of racism or discrimination or aspects of Government policy;

d. Unmet Aspirations – the student / pupil may have perceptions of injustice; a feeling of failure; rejection of civic life;

e. Experiences of Criminality – which may include involvement with criminal groups, imprisonment, and poor resettlement / reintegration;

f. Learning Support Needs – students may experience difficulties with social interaction, empathy with others, understanding the consequences of their actions and awareness of the motivations of others.

This list is not exhaustive, nor does it mean that all people experiencing the above are at risk of radicalisation for the purposes of violent extremism.

More critical risk factors could include:-

a. Being in contact with extremist recruiters;

b. Accessing violent extremist websites, especially those with a social networking element;

c. Possessing or accessing violent extremist literature;

d. Using extremist narratives and a global ideology to explain personal disadvantage;

e. Justifying the use of violence to solve societal issues;

f. Joining or seeking to join extremist organisations;

g. Significant changes to appearance and / or behaviour;

h. Experiencing a high level of social isolation resulting in issues of identity crisis and / or personal crisis.

4. Responsibilities

The Heatherley School of Fine Art (HSFA) will provide staff with the support they need to implement the Prevent Duty.  This will include annual Safeguarding and Prevent risk assessments, arranging training, awareness sessions for staff and management, sharing good practice and ensuring communication is frequent and open.

HSFA acknowledges its responsibilities and requirements in relation to Prevent and Safeguarding.

The Board of Directors have responsibilities under the Prevent Duty to:–

  • Actively engage with partners, including the police and Prevent coordinators
  • Undertake appropriate training and development in Prevent Duty
  • Nominate a Prevent board member who will oversee the Duty and Safeguarding
  • Exemplify British Values in their conduct (see Prevent and British Values definition below)
  • Set the school strategy for Prevent
  • Comply with the requirements of the Equalities Act 2010 in ensuring that the school will challenge discrimination and expects learners to comply with this legislation also
  • Ensure that the school will challenge racism, islamophobia, tackle hate and prejudice based bullying, harassment and intimidation as part of a commitment to exemplify British values.
  • Appreciate the sensitivity of the subject and the need to approach the issues carefully with all learners and communities
  • Ensure that the Duty and its requirements are communicated to all levels of the school organisation – management, teaching staff, technical, administrative and support staff and learners

Senior School management have responsibilities under the Prevent Duty. They must ensure that:-

  • They have active engagement with local partners and support groups and regular contact with Prevent Coordinators
  • There are clear, visible policies and procedures for managing whistleblowing and complaints
  • Policies are in place for learners using IT equipment safely, legally and securely
  • Prevent compliments the school’s Safeguarding Policy and the Equality Acts and covers the welfare and safety of learners and staff
  • A risk assessment is carried out by the school to address the implementation of Prevent.
  • Appropriate training in Prevent is provided for all staff.
  • Staff exemplify British Values in their management, teaching and through their  general behaviours in the school.
  • Opportunities within the curriculum are used to promote British Values to learners
  • Robust procedures are in place for sharing information internally and externally about vulnerable individuals
  • There is a clear Prevent referral process with a designated single point of contact who is known to all staff and learners
  • Pastoral care is at the heart of the school and available to all learners who are vulnerable or being exploited

5. Prevent and British Values

To comply with the Prevent Duty, providers of further education are expected to exemplify British Values in their management, teaching practice and general behaviours.

British Values are defined as:-

  • Rule of Law
  • Individual Liberty
  • Mutual respect and tolerance of those from other backgrounds, religions, beliefs,
  • Democracy
  • Compliance with the Equality Act and those protected by it.

The Protected Characteristics in the Equality Act are:-

  • Age
  • Gender reassignment
  • Disability
  • Marriage & civil partnership
  • Pregnancy & maternity
  • Race
  • Religion or belief
  • Sex
  • Sexual orientation

Tutors at HSFA are expected to understand and embed British Values within their teaching, to ensure learners are aware of them, can evidence and exemplify them and understand what it means to be a successful learner who can take part in life in Britain today.

Tutors must promote an open culture which allows freedom of speech and exploration of issues that affect learners locally, nationally and internationally.

Learners are required to understand how to keep themselves protected from risks associated with radicalisation, extremism, forms of abuse, grooming, bullying and staying safe online.

The Heatherley School of Fine Art must operate as a safe place for learners to communicate, but challenge views or discussions where they become offensive, extreme or upsetting to others.

6. Freedom of Speech

HSFA values freedom of speech and the expansion of beliefs / ideology as fundamental rights underpinning our society’s values. Both students and staff have the right to speak freely and voice their opinions. However, freedom comes with responsibility and free speech designed to manipulate the vulnerable or that leads to violence and harm of others goes against the moral principles in which freedom of speech is valued. Free speech is not an unqualified privilege; it is subject to laws and policies governing equality, human rights, community safety and community cohesion.

Tutors must promote an open culture which allows freedom of speech and exploration of issues that affect learners locally, nationally and internationally.  Heatherleys will operate as a safe place for learners to communicate, but challenge views or discussions which become offensive, extreme or upsetting to others.

7. Understanding and defining Safeguarding

Organisations which work with vulnerable groups, must always act in their best interests and ensure they take all reasonable steps to prevent harm to them. Having safeguards in place within an organisation not only protects and safeguards those who are vulnerable but also enhances the confidence of trustees, staff, carers and the general public.

Working together to Safeguard vulnerable adults includes:-

  • Promotion of the welfare of vulnerable adults which is paramount and must be a basis of our working practices
  • Ensuring that every vulnerable adult not only feels safe but is safe in all areas of the school.
  • Operating zero tolerance to bullying by staff and learners
  • Having the ability to identify categories of abuse or exploitation and know the support and referral channels available
  • Having appropriate policies, procedures and training in place to safeguard learners, staff and the organisation.
  • Having  a designated member of staff in place to support safeguarding arrangements.

Training organisations must comply with the Safeguarding Vulnerable Groups Act (2006)

This act defines two groups of people that it sets out to protect:-

  • Children (under 18)
  • Vulnerable Adults

The Heatherley School of Fine Art does not admit children or young people under the age of 18 years old to any of it’s Diploma, Part time, Vacation or Online courses

Outreach projects may involve HSFA staff in working off site with young people under the age of 18 or with vulnerable adults. Where this is the case DBS checks will be made and kept on a secure central register. Where HSFA staff are invited to conduct workshop projects offsite in local school settings, pupils will be accompanied and supervised by a teacher or guardian appointed by their school.

Local schools may be invited to visit HSFA in order to make use of our studio facilities. Appropriate risk assessment will be carried out. Young people will be accompanied and supervised during their visit by a teacher appointed and vetted by their school.

The Safeguarding Vulnerable Groups Act 2006 defines a Vulnerable Adult as:-

  • Those in residential accommodation provided in connection with care or nursing or in receipt of domiciliary care services
  • Those receiving health care
  • Those in lawful custody or under the supervision of a probation officer
  • Those receiving a welfare service of a prescribed description or direct payments from a social services authority
  • Those receiving services, or taking part in activities, aimed at people with disabilities or special needs because of their age or state of health
  • Those who need assistance in the conduct of their affairs

The Safeguarding Vulnerable Groups Act aims to prevent unsuitable people from working (either paid or unpaid) with vulnerable adults.  It does this by vetting all those who wish to work with vulnerable groups and barring those where information shows they pose a risk of harm. HSFA will ensure that tutors and all staff working with young people or vulnerable adults will receive DBS checks and these will be stored on a secure central register.

To fulfil the requirements of the Safeguarding Act The Heatherley School of Fine Art must:-

  • Adopt recruitment processes that comply with the law and ensure that vulnerable adult learners are protected.
  • Ensure that all recruitment processes are in accordance with the “Safer recruitment” guidance
  • Take all necessary actions to comply with current legal safeguarding requirements.
  • Ensure that annual Safeguarding training is completed for all staff
  • Undertake an adequate risk assessment to establish what action is required where their employees have regular contact with vulnerable learners.
  • Ensure that school staff working in Outreach projects with vulnerable adults or young people receive DBS checking, the details of which are kept on a secure central register.
  • Ensure that Health and Safety and Safeguarding Assessments are checked annually.
  • Ensure that a Staff Safeguarding Code of Conduct is produced to help protect staff as well as learners.

The Heatherley School of Fine Art has a legal Duty of Care for all learners they work with.

HSFA will appoint an appropriate person as Safeguarding/Prevent lead. Part of this duty of care is to report cases of suspected abuse.  If any member of staff has concerns about a learner they work with, they must report this to the Safeguarding / Prevent lead.

8. Abuse

There are different categories of abuse all leaders, managers and staff need to be aware of. These are –

  • Physical Abuse
  • Emotional / psychological Abuse
  • Sexual Abuse
  • Severe neglect
  • Financial / material abuse
  • Exploitation (inc Radicalisation).

Possible signs of abuse

Staff may become aware of potential abuse in three main ways –

  • They may observe signs in a learner that lead to a suspicion of a form of abuse
  • Learners themselves may disclose that they have been abused
  • A whistleblowing claim may be made about a learner by someone who may suspect a form of abuse

There are signs to look out for when working with learners that may indicate abuse. Although these signs may not directly indicate a safeguarding issue, it may help tutors or support staff to identify differences in behaviours that may need some follow up action.

Physical Abuse:–

  • Unexplained injuries or burns (inc Self- Harming)
  • Refusal to discuss injuries
  • Improbable explanations to injuries
  • Untreated injuries or lingering illnesses
  • Admission of punishment which appears excessive
  • Shrinking from physical contact
  • Fear of returning home or of parents / guardians / spouse being contacted
  • Aggression or bullying of other people
  • Significant behavioural change
  • Deterioration of work (which could have various explanations)
  • Unexplained pattern of absences

Emotional / Psychological Abuse:–

  • Continual self-deprecation
  • Fear of new situations
  • Inappropriate emotional responses
  • Self-harm or mutilation
  • Compulsive stealing
  • Drug / alcohol / solvent abuse
  • ‘Neurotic’ or obsessive behaviour
  • Social isolation  (which could have various explanations)
  • Desperate attention seeking  (which could have various explanations)
  • Eating problems (which could have various explanations)
  • Depression & withdrawal  (which could have various explanations)

Sexual Abuse:–

  • Bruises, burns or bite marks
  • Sexual awareness inappropriate to the persons age
  • Aggressiveness, anger, anxiety, tearfulness
  • Withdrawal from friends
  • Promiscuity, prostitution, provocative sexual behaviours
  • Self-injury, suicide attempts, self-destructive behaviour
  • Recoiling from physical contact
  • Eating disorder  (which could have various explanations)
  • Changes in behaviour  (which could have various explanations)
  • Depression  (which could have various explanations)

Severe Neglect: –

  • Constant hunger
  • Poor personal hygiene
  • Inappropriate clothing
  • Frequent lateness or non-attendance at work or class
  • Untreated medical problems
  • Low self-esteem
  • Poor social relationships
  • Compulsive stealing
  • Constant tiredness

Financial / material :–

  • Loss of jewellery or personal property
  • Unexplained withdrawal of cash
  • Lack of money to purchase basic items
  • Misuse of benefits
  • Inadequate clothing

Exploitation / Radicalisation :–

  • Unexplained absences from work or class
  • Appearing with unexplained gifts or new possessions
  • New friends that are older
  • Mood swings or changes in emotional well being
  • Drug or alcohol misuse   
  • Individuals views becoming increasingly extreme
  • Becoming increasingly intolerant
  • Expresses desire / intent to take part in extremist activity
  • Downloading, researching or viewing extremist propaganda
  • Withdrawn & focused on only one ideology
  • Changes in appearance, personality and becoming isolated from friends, family & local community  (This needs to be addressed sensitively as it could have various explanations and could happen at different times during the year / religious celebrations)

9. Code of Conduct

Staff working with Vulnerable Adults must follow the Code of Conduct set out in this document.

You must NOT:

  • Make any unnecessary physical contact with a vulnerable adult. However if physical contact is unavoidable e.g providing comfort at times of distress, this should only take place with the consent of the learner.
  • Take vulnerable adults or young people alone in a car
  • Meet vulnerable adults outside the work / training environment
  • Engage in sexually provocative conversations or activity
  • Allow the use of inappropriate language to go unchallenged
  • Do things of a personal nature that learners can do themselves
  • Make promises to keep any disclosure confidential from the relevant authorities
  • Show favouritism to the vulnerable adult
  • Lie or say that everything will be ok when you cannot promise that
  • Criticise the abuser, especially if it is a parent / carer
  • Press for answers the learner is unwilling to give


  • Listen carefully to what is said
  • Take what is said seriously and accept what is told
  • Respect learners rights to privacy and encourage them to feel comfortable enough to report attitudes or behaviours they do not like
  • Act with discretion with regard to their personal situations and relationships.
  • Be aware of the procedures for reporting concerns or incidents and familiarise themselves with the contact details of the safeguarding champion and local authority contacts
  • Make your safeguarding champion aware of any inappropriate affection or attention from a learner to you
  • Report any concerns relating to the welfare of the learner to your safeguarding champion
  • Write down as soon as you can exactly what has been said – do not add in anything extra and use only the words used by the learner
  • Tell the learner you must pass the information on but only to those who need to know and tell them who these people are
  • Inform your safeguarding champion as soon as possible.

10 Challenging extremism

If students make comments which could be regarded as extremist staff should encourage students to:-

  • think critically
  • consider whether the evidence they have is accurate and full
  • consider whether they have received a partial and/or unsustainable interpretation of evidence
  • consider alternative interpretations and views

Staff should use opportunities to challenge extremist narratives through discussion with students. If staff do not feel confident in challenging extremist ideas with their students they should ask for support from the Safeguarding lead (safeguarding champion)

If students behave in a way which contravenes the equality and diversity aspects of the Code of Conduct which they have signed, e.g. refusing to work with a gay student or a student of a different ethnicity, then this is a disciplinary issue and should be dealt with through normal disciplinary processes.

Tutors must promote an open culture which allows freedom of speech and exploration of issues that affect learners locally, nationally and internationally.  Heatherleys will operate as a safe place for learners to communicate, but challenge views or discussions which become offensive, extreme or upsetting to others.

11. Safeguarding and Prevent Referral Agencies


Safeguarding & Prevent designated Leads–

  • Veronica Ricks ( Principal)
  • Diana Horton (Student Support Officer)

Board of directors Prevent designated person:- HSFA Chair of Trustees

Prevent Contact – Jennie Fisher

FE/HE Regional Prevent Co-Ordinator for London

Counter-Extremism Division

20 Great Smith Street, London SW1P 3BT

Mobile: 07880 469 588

Confidential Counter Terrorism Hotline – 0800 789321 or 999

Channel-Contact local Police PREVENT Lead by dialling 101 and asking for the PREVENT Lead for your area.


Channel is an early intervention multi-agency process designed to safeguard vulnerable people from being drawn into violent extremist or terrorist behaviour. Channel works in a similar way to existing safeguarding partnerships aimed at protecting vulnerable people.

If you believe that someone is vulnerable to being exploited or radicalised, please use the safeguarding procedures established by HSFA to escalate your concerns to the Safeguarding lead, who can raise concerns to Channel if appropriate.



  • Clarify the concern:   
  • Member of staff identifies a potential concern and documents as appropriate
  • Discuss with Safeguarding Lead.
  • Safeguarding lead will gather information.
  • Assessment: No concern. No further action required. Document as appropriate.



  • Safeguarding lead will assess the situation.
  • Assessment: Monitor future behaviour and re- raise the concern if required.
  • Obtain further advice or clarification if required by referring to Channel.
  • No concern. Channel advise no requirement for intervention



  • Safeguarding Lead will assess the situation.
  • Assessment: take the concern further by referring to advice from Channel.
  • If the concern is about a member of staff contact the Principal: Veronica Ricks.
  • No immediate danger but support intervention required.



  • Safeguarding lead will assess the situation.
  • Contact local Police PREVENT Lead by dialling 101 and asking for the PREVENT Lead for your area. Or use the contact details given above.
  • Complete documentation for HSFA and store in a secure central register.


Contact the Counter-Terrorism Hotline on 0800 789321 or 999.

HSFA Safeguarding lead will:-

  1. Act on advice received.
  2. Document all conversations and advice received.
  3. Complete Incident Form.

13. The seven golden rules to sharing information

(Information sharing Advice for practitioners providing safeguarding services to children, young people, parents and carers)

  1. Remember that the Data Protection Act 1998 and human rights law are not barriers to justified information sharing, but provide a framework to ensure that personal information about living individuals is shared appropriately.

  1. Be open and honest with the individual (and/or their family where appropriate) from the outset about why, what, how and with whom information will, or could be shared, and seek their agreement, unless it is unsafe or inappropriate to do so.

  1. Seek advice from other practitioners if you are in any doubt about sharing the information concerned, without disclosing the identity of the individual where possible.

  1. Share with informed consent where appropriate and, where possible, respect the wishes of those who do not consent to share confidential information. You may still share information without consent if, in your judgement, there is good reason to do so, such as where safety may be at risk. You will need to base your judgement on the facts of the case. When you are sharing or requesting personal information from someone, be certain of the basis upon which you are doing so. Where you have consent, be mindful that an individual might not expect information to be shared.

  1. Consider safety and well-being: Base your information sharing decisions on considerations of the safety and well-being of the individual and others who may be affected by their actions.

  1. Necessary, proportionate, relevant, adequate, accurate, timely and secure: Ensure that the information you share is necessary for the purpose for which you are sharing it, is shared only with those individuals who need to have it, is accurate and up-to-date, is shared in a timely fashion, and is shared securely (see principles).

  1. Keep a record of your decision and the reasons for it – whether it is to share information or not. If you decide to share, then record what you have shared, with whom and for what purpose.

14. Safeguarding & Prevent Incident Form

Please use this form to record an incident or concern of abuse, neglect or potential vulnerability of any learner on your training programme.   This includes any concerns for those learners who are /may be at risk of radicalisation or extremism. It is vital that HSFA maintain records of any incidents and pass them to the required agencies.

Name & full contact details if possible.

Concern or Incident

Date, time & Location

Action Taken

Follow up by HSFA




Please retain a copy of this form for your records and pass the original copy to HSFA.