Safety and Wellbeing

The College does not tolerate harassment, sexual misconduct, or inappropriate conduct by its staff, students or visitors. CNM will never use non-disclosure agreements (NDAs) to prevent the reporting of, or talking about, cases related to harassment and sexual misconduct.

What is Harassment?

Harassment includes unwanted and/or unwarranted behaviour or conduct, normally repeated, which has the purpose or effect of violating a person’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment. This includes behaviours, sometimes obsessive, experienced online as well as in person. The Equality Act 2010 prohibits by law any inequality and/or harassment based upon age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation. Harassment includes, but is not limited to:

• Actions or words that cause alarm, distress or fear of violence, e.g. stalking.
• A course of conduct motivated by hostility or prejudice.
• Persistent unwanted communications and/or face to face contact.
• Restricting, or attempting to restrict, an individual’s right to lawful freedom of expression (freedom of speech).

What is Sexual Misconduct?

Sexual misconduct relates to any attempted or actual unwanted conduct of a sexual nature. This includes, but is not limited to:

• Physical unwanted sexual advances and/or acts, e.g. indecent exposure, upskirting unwanted comments and touching.
• Sexual harassment and/or assault, e.g. rape, repeated unwanted following or stalking (inc. cyberstalking).
• Distributing private and personal explicit images or video footage of an individual without their consent (e.g. sextortion).
• Intimidation, or promising resources or benefits in return for sexual favours.

How to Report

As a student, if you, or someone you know, has been affected by harassment and/or sexual misconduct you can report it to us via your Director of Studies, or the Student Liaison Director. These staff have been trained to respond sensitively and confidentially to your disclosure. Alternatively, you can download a Disclosure Report Form here.

You will be listened to and supported throughout the process. You are entitled to bring a friend or family member with you to meetings. If you need reasonable adjustments to your studies whilst the matter is handled, these will be put in place. We’ll help you to navigate formal police disclosure if this is necessary. If we have concerns relating to your immediate safety on CNM premises, we’ll put measures in place to protect you. This may include adjustments to your timetable or an emergency hearing, which can result in the exclusion of individuals from College premises if deemed necessary.

All formal investigations will be conducted in accordance with the Harassment & Sexual Misconduct Policy. All information disclosed will be treated confidentially on a need-to-know basis.

CNM reserves the right to undertake a formal investigation of cases of harassment and/or sexual misconduct that it is made aware of, even where no formal complaint has been made. Anonymous reports will be considered carefully and logged in accordance with the College’s Records & Documents Retention Guide.

As a member of staff, complaints relating to harassment, sexual misconduct, or inappropriate behaviour will be managed under CNM’s Employee Handbook policies on Grievances and Disciplinary Actions.

• Employees should raise concerns formally with HR.
• HR will investigate and, where appropriate, take disciplinary action.
• Where a complaint relates to a student, HR will liaise with the relevant Director of Studies.

If you are a member of the public attending a clinic as a client of CNM and you wish to raise an issue, you should approach your clinic supervisor, preferably on the same day. If the issue cannot be resolved at this level and you wish to make a formal complaint, the grievance must be put in writing using the grievance form linked in your clinic confirmation email. CNM takes seriously the grievances of any client and will take all necessary measures to ensure the fair and efficient resolution of all formal complaints.

Visitors to CNM premises or hosted event should email any issues they may have to info@naturopathy-uk.com.

You may wish to download and complete our Safeguarding Report Form. The completed form should be emailed to your local Designated Safeguarding Lead or qualityassurance@naturopathy-uk.com. For a more immediate response you can contact your local DSL directly.

Safeguarding refers to protecting individuals from harm, abuse, neglect, or exploitation. While CNM does not enrol students under 18, we are committed to safeguarding the wellbeing of all our students, including vulnerable adults and anyone facing risk.

Concerns for the safety and wellbeing of vulnerable adults could arise in a variety of ways and in a range of different settings. For example, an individual may report or display signs of abuse; someone may hint that an individual is at risk or that a colleague is an abuser; an individual may raise concern that a student or member of the CNM Community is at risk of being drawn into extremism or radicalisation.

If you’re worried about your own safety or someone else’s, please contact either your local campus Director of Studies (responsible for safeguarding) or the College’s Designated Safeguarding Lead (DSL) @ qualityassurance@naturopathy-uk.com

All concerns are handled with care, respect, and confidentiality on a need-to-know basis. The DSL and Managing Director will agree whether a disclosure needs to be referred to other agencies such as the local authority or the police. The College will respect the rights and dignity of those involved and will make decisions that are proportionate to what it deems to be the risk of harm.

Prevent Duty

Higher Education Institutions (HEIs) have been identified as potential sites for radicalisation under the Prevent Duty. Radicalisation is the process by which a person comes to supports terrorism and forms of extremism. CNM adopts a safeguarding approach to Prevent, recognising that concerning behaviour may have multiple causes and should be assessed carefully.

Suspicions that fall within the scope of the PREVENT Duty (e.g. concerning radicalisation and/or extremism) should be reported in the first instance to the local campus Director of Studies or Student Services studentservices@naturopathy-uk.com

CNM’s Prevent Duty Policy and Procedures provides detailed guidance. A link to this policy is available at the bottom of this webpage.

If you are the subject of a complainant’s initial informal disclosure with respect to harassment, sexual misconduct or safeguarding, you may not yet have been identified in the disclosure. If the complainant decides to take no further action the matter will be closed. If a formal complaint is made against you, you will be contacted by the relevant member of CNM staff and will receive mental health and wellbeing support.

During academic tuition and peer/tutor or peer/peer discussion, topics that arise may be offensive to some based upon their personal views. Academic expression should always be relevant and respectful but discussions relating to controversial and sensitive topics and beliefs do not constitute harassment or misconduct. Students and staff must be mindful of the interaction between the principles of lawful free speech and the protected characteristics identified in the Equality Act 2010. CNMs Freedom of Speech Policy is available via the link at the bottom of this webpage.

CNM actively discourages its staff from engaging in close personal or intimate relationships with students due to the potential for abuses of power and conflicts of interest that can arise. Nevertheless, CNM recognises that personal relationships (romantic, family, financial, or close friendship) may pre-exist or develop in the workplace.

• Staff–Student Relationships: To avoid any risk of abuse of power or perception of bias, staff must declare to HR any personal relationship with a student, failure to do so may result in disciplinary action.
• Staff–Staff Relationships: Employees must declare to HR any personal relationship where a potential conflict of interest may arise.
• HR will handle disclosures in confidence and may adjust reporting lines, remove decision-making responsibilities, or take other steps to manage conflicts.
• For CNM staff, failure to declare a relevant relationship, or to engage in conduct at work that undermines professionalism, may result in disciplinary action.

CNMs Personal Relationship Policy and Conflict of Interest Policy are available via the link at the bottom of this webpage.

As a student you may be entitled to receive (or it may be necessary for us to make) adjustments to your timetable, attendance and assessments whilst you are in the process of making, or a subject of, a complaint that falls within the scope of the Policy on Harassment & Sexual Misconduct. Your Director of Studies will advise you of the options that may be available to you.

For staff undergoing a complaint that falls within the scope of the Policy on Harassment & Sexual Misconduct (either as a complainant or a respondent), reasonable adjustments and flexibility will be put in place as appropriate. Support with adjustments will normally be managed by HR and the relevant Line Manager unless the Line Manager is implicated in the case. In some circumstances, significant alternative temporary working arrangements may be agreed/implemented subject to periodic review.

All staff and students will be required to complete mandatory training in relation to harassment, sexual misconduct, safeguarding including suicide prevention and Prevent duty. Training will be delivered as part of the induction process and periodically as appropriate. This will include consent and bystander training.

• Training will be evidence-based and regularly updated.
• Clear easily accessible policies will inform the CNM community.
• CNM will involve students in the review and development of these policies.
• Anonymised case studies may be used to inform training.

Complete the Government Prevent duty training here: https://www.support-people-susceptible-to-radicalisation.service.gov.uk/portal

This free online caregiving course teaches you how to protect vulnerable people and raise concerns regarding their wellbeing. We explain ‘Disclosure and Barring Service’ checks that prevent harm befalling vulnerable adults. We also cover the different ways to share information with relevant bodies regarding abuse and neglect.

https://alison.com/course/safeguarding-vulnerable-adults

Universities UK published a report setting out a framework to understand and mitigate suicide risk, available here. https://www.universitiesuk.ac.uk/sites/default/files/field/downloads/2021-07/guidance-for-sector-practitioners-on-preventing-student-suicides.PDF

• CNM will review its policies and protocols annually to ensure compliance with OfS Condition E6 and with employment law.
• Feedback from students and staff will be considered in each review.
• Outcomes from anonymised case studies will be used to inform policy and provide a consistent benchmark for decision making.

All disclosures and referrals made under the auspices of the various policies and procedures detailed in this website will be treated confidentially and only shared between CNM senior staff on a need-to-know basis. Records of disclosures, formal complaints, safeguarding and duty of care concerns will be maintained and securely stored in accordance with the following CNM policies.

• Data Protection Policy and Procedures.
• Records & Documents Retention Guide.
• Privacy Notice.

The Information Commissioner’s Office (ICO) provides guidance and resources in relation to UK GDPR – https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/

If you are unhappy with the way your matter has been handled by the College and you have exhausted all internal procedures you can ask the Office for the Independent Adjudicator to investigate the matter on your behalf. Visit their web-site to understand the criteria you need to meet in order to qualify for help. https://www.oiahe.org.uk/contact-us/

You can access CNM policies using the link below.

https://www.naturopathy-uk.com/about/policies-and-procedures/

To access previous versions of policies relevant to the time-period related to your enquiry please email: qualityassurance@naturopathy-uk.com