Promoting Good Campus Relations: Policies and Procedures Introduction 1. King s College London was founded by King George IV in response to the then Prime Minister (the Duke of Wellington) and the Archbishop of Canterbury upon the principles of debate and education in the context of religious inclusion. The latest version of the Royal Charter of the College states that: 3. (1) The objects of the College shall be to advance education and promote research for the public benefit. In so doing the College shall have regard both to its Anglican tradition and the diverse beliefs and backgrounds of its members; Ordinance E.3 places a particular responsibility upon the Dean of King s College to ensure that these objects are upheld. In performing these duties the Dean will be responsible to the Principal and President. 2. Therefore, King s College London (KCL) is committed to upholding freedom of speech and to making our campuses safe and inclusive places for the expression of beliefs and views where people from different backgrounds or with different beliefs are tolerant and respectful of each other. KCL provides an intellectually rigorous environment where debates flourish and staff and students are able to engage in free-ranging discussions. Therefore every member of KCL shall be entitled to freedom of thought, conscience and religion, to hold opinions without interference, disability or disadvantage, and to freedom of expression within the constraints of the law. 3. The Education (No 2) Act 1986 states that: Every individual and body of persons concerned in the government of any establishment to which this section applies shall take such steps as are reasonably practicable to ensure that freedom of speech within the law is secured for members, students and employees of the establishment and for visiting speakers. 4. Discrimination, intolerance and violence have no place on campus. Therefore the right to freedom of speech must be balanced with the need to protect people from abuse, for example through the inciting of hatred. KCL recognises that its first duty is to protect its staff and students and limit damage to its reputation. 5. The Equality Challenge Unit s 2005 guidance Promoting Good Campus Relations states that...threatening behaviour such as hate crimes and intolerance can include: Crimes or behaviour motivated by prejudice, hatred or intolerance that intentionally demean individuals and groups defined by their ethnicity, race, religion and belief, sexuality, gender, conscience, disability, age or lawful working practices and which give rise to an environment in which people will experience, or could reasonably fear harassment, intimidation or violence. 6. This document will bring together the relevant policies and procedures that exist to ensure that none of the above occurs at KCL, but that preventing their occurrence does not remove the right of students and staff to debate, discuss and associate freely at KCL. Such policies include: It s My Campus! Policy Room Bookings with External Speakers Policy KCLSU External Speakers Policy Maintaining Good Relations in the College Community statement 1
Policy and Procedure in Respect of Permissable Activities Provision of Muslim Prayer Rooms on all campuses College Timetable Policy Religion and Belief Equality Policy Statement Statement on Use of Public Space in College Statement on catering provision from King s Food 2
It s My Campus! Policy 1.1 King s College London (KCL) has made it a priority to make our campuses as available for as much time possible to students, in order to promote student activities including free and open debate. Bookable rooms on campus are used primarily for teaching. However, once teaching needs are met, KCL will make available as many spaces as possible for student usage, notwithstanding advance bookings for external events. KCL is committed to supporting student societies and co-curricular activities on campus. 1.2 Students wishing to book a room should fill in the enquiry form https://internal.kcl.ac.uk/about/ps/estates/bookroomstudents/studentbookingform.aspx 1.3 There is no charge for usage of standard AV or IT equipment that is installed in KCL rooms. Standard equipment is a data projector/lcd screen, PC with audio and network connection, visualizer, overhead projector or flipchart. If non-standard equipment is required, or if AV support is required outside of core AV hours (9.00 17:00 Monday-Friday), a charge may be levied, with a reduced rate charged to student societies regardless of their affiliation to KCLSU. Bookings should be made using the online booking form: https://www.kcl.ac.uk/kis/support/avsu/avbook/ 1.4 Limited self-catering is permitted, i.e. soft drinks & snacks, provided that the room is cleared at the end of the event. Any other catering should be booked through King s Food: http://www.kingsvenues.com/catering/catering.aspx No alcohol is permitted unless booked through King s Food. 1.5 Student room bookings will not pay room hire charges. If King s Venues decides that there is a need for a security presence, the charges for this will be waived. 1.6 If external speakers are involved procedures in the Room Bookings with External Speakers Policy should be followed http://www.kcl.ac.uk/governancezone/governancelegal/room-bookings- External-Speakers.aspx 1.7 Organisers must ensure that nothing in the preparations for, or in the conduct of, a meeting or activity infringes upon the law i.e. by conduct likely to cause a breach of the peace. For guidance, please refer to the KCLSU Safe Space Policy: http://www.kclsu.org/pageassets/safespace/kclsu-safe-space- Policy.pdf 1.8 It is the responsibility of the organiser to ensure they are aware of fire procedures and in the event of a fire are responsible to instruct those in attendance to fire exits. Fire regulations can be found here: https://internal.kcl.ac.uk/about/ps/safety/fire-building/build-fire-plan.aspx 3
1.9 The event organiser will be responsible for ensuring that the room used for the event is left in a clean and tidy condition. Room Bookings with External Speakers Policy 1. Policy 1.1 This policy sets out King s College London (KCL)'s policy on room bookings for events that include an external speaker(s). The policy applies to anyone internal to KCL who wishes to book a room at KCL, including: King s College London Students Union (KCLSU) Any event organised by a ratified student group/society, Student Council, Student Officer or KCLSU member of Staff that will take place in a KCL space. Departmental Bookings Any event organised by an academic or professional services department, or a society or study group that is not ratified by KCLSU. This applies to staff or students of the department. External speaker bookings that form part of an academic programme are not subject to this policy, but are subject to the normal processes associated with the delivery of all academic programmes. Students wishing to book a room without an external speaker should follow the It s My Campus policy http://www.kcl.ac.uk/governancezone/students/room-bookings-its-my- Campus-Policy.aspx. Individual students are not permitted to invite an external speaker to speak in KCL rooms, any bookings of this nature should be made via KCLSU or Departments. 1.2 External speakers are defined as speakers invited to attend an event who are not current members of either the staff or student body of KCL. This also applies to events where external speakers are streamed live into an event, or a pre-recorded film of a speaker delivering a speech for the event is shown. 1.3 KCL is committed to upholding freedom of speech and to making our campuses safe and inclusive places for the expression of beliefs and views where people from different backgrounds or with different beliefs are tolerant and respectful of each other. KCL provides an intellectually rigorous environment where debates flourish and staff and students are able to engage in free-ranging discussions. Therefore, every member of KCL shall be entitled to freedom of thought, conscience and religion, to hold opinions without 4
interference or disadvantage, and to freedom of expression within the constraints of the law. 1.4 These principles are also protected by the KCLSU Safe Space Policy - http://www.kclsu.org/pageassets/safespace/kclsu-safe-space-policy.pdf - which is applicable to all KCLSU events and KCLSU space. KCLSU believes all students should be free from intimidation or harassment, resulting from prejudice or discrimination on the grounds of age, disability, marital or maternity/paternity status, race, religious beliefs, sexual orientation, gender identity, Trans status, socio-economic status, or ideology or culture, or any other form of distinction. 1.5 Discrimination, intolerance and violence have no place on campus. Therefore, the right to freedom of speech must be balanced with the need to protect people from abuse, for example through the inciting of hatred. KCL recognises that its first duty is to protect its staff and students from harm. 1.6 Section 43 of the Education (No. 2) Act 1986, requires KCL to issue and regularly update a Code of Practice governing the procedures to be followed and the conduct required at meetings to ensure freedom of speech within the law is secured for students, staff - including honorary and visiting staff - and for all persons authorised to be on the institution s premises, including visiting speakers. The full legislation is referred to in Appendix A. This policy serves as the Code of Practice for meetings and the External Speaker policy. 1.7 KCL expects KCLSU to monitor and, where appropriate, update their own policies and procedures in relation to room bookings and external speakers, and to ensure they are aware of the obligations placed upon KCL under the legislation in Appendix A. 1.8 All bookings are covered by King s Venues terms and conditions https://www.kingsvenues.com/conferences-meetings/how-to-book.aspx 1.9 Any event held on premises not owned or managed by KCL but run as a KCL event will be subject to this policy and approval must be given before the event can be advertised. Any event found to be using KCL branding without permission of the university will be treated as a breach of copyright and subject to legal challenge if not removed. 2. Booking A flowchart explaining the booking process can be found on page 7 of this policy. 2.1 Any meeting held on KCL premises must have a designated event organiser who is responsible for the arrangements and the conduct of the meeting. 5
2.2 In all cases, if external speakers are involved, 21 days advance notice of the booking will be required. Bookings involving external speakers that provide less than 21 days advance notice may not be accommodated. 2.3 For KCLSU bookings, a member of the club or society or a KCLSU member of staff should complete the KCLSU online booking form at http://www.kclsu.org/bookaroom/ When KCLSU have exhausted their processes they will notify KCL of the event request via the form http://internal.kcl.ac.uk/timetabling/contacts-newsand-help/external-speaker.aspx KCLSU will include a clear description of the event, state their decision in the comments section and upload a copy of the Risk Assessment if completed and any other relevant documents. This will include any events which KCLSU do not approve. 2.4 Departmental Bookings should be made through the relevant Department Office, with the booking submitted by a designated member of staff. This staff member must be able to take responsibility for the booking and therefore have an understanding of the event and contact with the main organisers, and will usually be a member of the departmental administrative team. The event organiser should complete the form in this link: http://internal.kcl.ac.uk/timetabling/contacts-news-and-help/externalspeaker.aspx 2.5 Spaces will be allocated depending on the profile of the event and the number of attendees. High demand event space, such as the Great Hall or the Safra Lecture Theatre, will only be allocated for high-profile events or if other spaces are unavailable. Events will be deemed high profile based on the speaker and subject matter. 2.6 If the event organiser wishes to make amendments to a booking, such as changing the title of the event or inviting further speakers, these changes must be communicated to King s Venues. Additional speakers will be considered if they are within 21 days of the event date requested. 3. Authorisation of Events 3.1 KCL are ultimately responsible and accountable for all events held on KCL campuses, and therefore no event will be confirmed until KCL have authorised the booking. 3.2 The Head of Administration and College Secretary is responsible for the decision regarding the approval of events at KCL. 3.3 For all events booked at KCL, consideration will be given by the Head of Administration and College Secretary as to: 6
i. The potential for any decision to limit freedom of speech as per the university s code of practice in pursuance of the 1986 Education Act ii. The potential for the event going ahead to cause the university to be in breach of its equal opportunities policy iii. The potential for the event going ahead to cause the university to fail in its wider legal duties iv. The potential for the speaker s presence on campus to cause fear or alarm to members of the student or staff body v. The potential for the speakers presence on campus to give rise to breach of peace vi. The potential for the event going ahead to cause reputational risk to the university 3.4 Requests will be subject to an initial risk assessment, which will refer to the KCLSU risk assessment where relevant. This will be conducted by King s Venues on behalf of The Head of Administration and College Secretary. They may seek advice from relevant departments, such as Security, Student Services, External Relations, related academic departments and, if the event has a religious theme, The Dean s office in order to complete this, or any subsequent, assessment. 3.5 Risks will be categorised as low, medium or high based on the factors highlighted above, as well as; i. The speaker s history and the organisation they represent; ii. The impact such a visit will have on KCL s community relations and on the wider community; iii. Whether the event is part of a tour iv. Background checks that indicate the speaker s conduct at previous events or his/her prior denial of free speech to others; v. The title and content of the event; 3.6 Medium or high risk events will also take into consideration whether the speaker has spoken at an event at KCL in the previous six months; 3.7 If the initial assessment deems the event to be low risk then it will be approved. If the assessment deems the event to be medium or high risk then 7
King s Venues will request a further risk assessment and/or checks to be made. 3.8 Events where the risk level is identified as medium will be referred to the Head of Administration and College Secretary for a decision by them or their delegate. 3.9 Events where the risk level is identified as high will be referred to the the Head of Administration and College Secretary for a decision to be ratified by the Principal and President. 3.10 KCL reserves the right to refuse to hold any event if it is deemed to be at risk of any of the points in this policy even if the event has been passed by KCLSU. 3.11 Following the risk assessment, KCL will confirm whether the event can go ahead, cannot go ahead or can go ahead subject to conditions these include, but are not limited to: * The event be filmed by an independent body or recorded using the internal lecture capture system; * The event is observed by Union, University or third party officials. The Union, University or third party officials reserve the right to stop events if any of KCL or KCLSU s policies are contravened before or during the event; * The event be stewarded by Safe Space Marshalls or subject to security (or extra security) on the door (at the expense of the club or society hosting the event); * An event promoting debate of an issue includes mitigations to ensure a balanced set of views are presented; * An event that was for society members only be opened to all KCL students or KCLSU members; * A copy of any speech to be delivered by the speaker is submitted in advance; * The speaker is invited to meet with a member of KCL senior management to discuss the event; * The event is approved to take place at a date different from that which was requested by the organiser; * Consideration of the appropriateness of the chair of the event and whether an alternate or additional chair may be required; 8
3.12 A decision will be communicated to the designated event organiser within 10 days of the request being referred to KCL. In all cases where an event is not permitted to go ahead, or where mitigations are put in place as outlined above, a clear communication of the reasons for the decision will be sent to the event organiser, or KCLSU, and the reason must be given as one of those in this policy. 3.13 Large-scale events and lectures (including those with non-king s attendees) may subject to additional constraints, such as no tickets being sold on the door of KCL premises due to licensing laws. Societies must abide by any other instructions issued by KCLSU, KCL or KCL contracted staff or officers. This may include opening the event to KCL cardholders only and conducting checks on entry to the event. 3.14 KCL retains the right to approve or reject requests for events to be covered by external media organisations. King s student media groups do not need to request permission. All requests should be directed to pr@kcl.ac.uk. 3.15 If an event organiser is unhappy with the decision given, you may use the College s complaints procedures. http://www.kcl.ac.uk/aboutkings/orgstructure/ps/acservices/conduct/complain ts.aspx 4. Responsibilities of Event Organisers 4.1 Events may not be advertised until the booking has been confirmed by KCL and by KCLSU where relevant. Where an event involves an external speaker, the event may not be publicised or considered confirmed until the speaker has been cleared through the procedures detailed in this policy and the event organiser has confirmed the event. This includes advertisement through any social media platform. The booking of the event will be at risk if it is promoted before being confirmed. 4.2 Organisers must ensure that nothing in the preparations for, or in the conduct of a meeting or activity, infringes upon the law i.e. by conduct likely to cause a breach of the peace. For guidance, please refer to the KCLSU Safe Space Policy: http://www.kclsu.org/pageassets/safespace/kclsu-safe-space- Policy.pdf 4.3 It is the responsibility of the organiser to ensure they are aware of fire procedures and in the event of a fire are responsible to instruct those in attendance to fire exits. Fire regulations can be found here: https://internal.kcl.ac.uk/about/ps/safety/fire-building/build-fire-plan.aspx 4.4 The event organiser will be responsible for ensuring that the room used for the event is left in a clean and tidy condition. 9
4.5 KCL may request a meeting with the event organiser and/or KCLSU if relevant to discuss the event, either in planning it or as a de-brief after the event has taken place. 5. Conduct of events 5.1 The institution s Head of Security is responsible for the management of any event that may pose a security and/or safety risk to any person, building or facility at KCL. However, they may delegate that management to appropriate nominees, The Head of Security will act as the main point of contact for the Police if necessary. 5.2 The organiser of the meeting has a duty as far as is possible to ensure that the speaker(s) and the audience at a meeting comply with the law; for example it is unlawful to incite racial hatred, or to cause a breach of the peace. 5.3 Organisers who are applying for approval of a meeting must show that they can ensure adequate control of the event. This may include a risk assessment and mitigation strategy. 5.4 Freedom of expression within the constraints of the law is a right for speakers and audience members alike. Any action that denies speakers or audience members this, such as verbal or physical intimidation or violence, is forbidden. Non-violent disagreement or protest is a part of debate, providing it does not deny an individual their freedom of expression within the constraints of the law. 5.5 In the case of unlawful conduct the organiser is required to warn the speaker(s) or members of the audience that their conduct is unacceptable and, if appropriate, the meeting will be terminated. This includes if the speaker changes the subject on which they have been approved to speak if that subject falls into the categories listed in section 3.3. If KCL observers are present as part of the agreement to stage the event and they decide to terminate the meeting on these grounds then their decision is final. 6. Monitoring and Enforcement 6.1 Data on room bookings will be collected by KCL via the King s Venues office. This will include the date and title of events, names of external speakers requested, names of the society, department or individual making the booking and the decisions made on those requests. This will include events held in KCLSU rooms, 6.2 Any group or individual who books a room for an event with an external speaker but does not inform KCL of the speaker in the booking process will put their booking, and future bookings, at risk of cancellation. 10
6.3 Data on events will be reviewed by the Good Campus Relations Working Group to ensure that requests are processed effectively to ensure KCL complies with relevant legislation. This includes obligations to ensure freedom of speech and debate as set out in the Education Act. 7. Segregation, including gender segregation at events 7.1 Compulsory segregation, including on the grounds of gender, at events booked using this procedure is explicitly not permitted by KCL event policy. KCL will not interfere with the right of attendees to sit in the location of their choosing at events but organisers must not enforce it. KCL will follow guidance set out by the Equality and Human Rights Commission http://www.equalityhumanrights.com/sites/default/files/publication_pdf/guida nce%20for%20universities%20and%20students%20unions%2017-07-14.pdf 11
Appendix A The Law Section 43 of the Education (No. 2) Act 1986, requires KCL to issue and regularly update a Code of Practice governing the procedures to be followed and the conduct required at meetings to ensure freedom of speech within the law is secured for students, staff - including honorary and visiting staff - and for all persons authorised to be on the institution s premises, including visiting speakers. Legislation in this area is characterised by three themes: (1) Protection of the special status of Higher Education Institutions (HEIs): Education Act 1986 Education Reform Act 1988 (2) Anti-discrimination legislation and proactive equalities legislation: Human Rights Act 1998 (incorporating the European Convention on Human Rights) Employment Equality (Sexual Orientation) Regulations 2003 Employment Equality (Religion or Belief) Regulations 2003 Race Relations Act 1976 Race Relations (Amendment) Act 2000 Sex Discrimination Act 1976 Disability Discrimination Act 1995, as amended Equality Act 2006 Equality Act 2010. (3) Provisions that qualify rights: Public Order Act 1986 Crime and Disorder Act 1998 Protection from Harassment Act 1997 Criminal Justice Act 2003 and Criminal Justice (Scotland) Act 2003 The Racial and Religious Hatred Act 2006 (amended the Public Order Act 1987 to create offences involved in stirring up hatred namely the manifestation of hatred that could lead to a public order offence against persons on religious grounds). Criminal Justice and Immigration Act 2008. Other References The Counter Terrorism and Security Act 2015, http://www.legislation.gov.uk/ukpga/2015/6/contents/enacted/data.htm 12
Prevent Duty Guidance for England and Wales - issued under section 29 of the Act. https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/44597 7/3799_Revised_Prevent_Duty_Guidance England_Wales_V2-Interactive.pdf NUS Guidance on Managing the Risks Associated with External Speakers http://s3- eu-west- 1.amazonaws.com/nusdigital/document/documents/14292/e6abc78de93eae48eb6c26 76d64c5438/Managing%20the%20risks%20associated%20with%20external%20spe akers%20england%20and%20wales.pdf KCLSU Safe Space Policy http://www.kclsu.org/pageassets/safespace/kclsu-safe- Space-Policy.pdf Equality and Human Rights Commission Guidance on Gender Segregation at Events and Meetings http://www.equalityhumanrights.com/sites/default/files/publication_pdf/guidance% 20for%20universities%20and%20students%20unions%2017-07-14.pdf. 13
KCLSU External Speaker Policy Introduction December 2014 We welcome Union events hosted both in King s and KCLSU venues and elsewhere. Many of these events have external speakers attending. As a Students Union our External Speakers Policy, in conjunction with our Safe Space policy, makes sure that we re providing a platform for educational experience whilst following the charity and other legislation that we re responsible for upholding. Freedom of expression Freedom of expression and speech are basic human rights that are protected by law. Academic freedom is a term used to describe the law that allows for open and honest debate in an academic context. King s has a legal duty to secure the development of students ideas and understanding in the form of academic freedom on campus. Academic freedom only applies to College staff and academics and does not apply to students and visiting speakers. Student safety and welfare is at the heart our KCLSU policies and practices. The freedom to express views needs to be balanced with the need to secure freedom from harm for students and communities. We want all of our Union activities including those hosted by of our Officers, student groups, and Student Council to be: Safe (complying with our safeguarding and safe space policies) Within the law As part of our process for approving who speaks on campus we assess all our external speakers and their topic of discussion to assess the risks that they present to our policy or legal responsibilities. We re committed to working together with event organisers and if necessary the external speakers themselves to make sure that we reach a judgement that is reasonable, informed and within the law. External speakers This policy is a KCLSU policy and does not take into account any KCL requirements, such as involvement of the Dean s or PR office in case of external speaker. This policy applies to all Union events including those organised by Student Councillers, Officers, KCLSU staff or student groups or clubs. All Councillers, Officers, KCLSU staff or student groups or clubs will have undergone President & Treasurer or similar training and therefore know the importance and impact of communicating the correct information regarding their events and potential speakers, and also the repercussions for not adhering to our policies, which could be that the result in disciplinary procedures. No event organiser should bypass this policy by contacting KCL directly. An external speaker is used to describe any individual or organisation who is not a student or staff member of King s College London, KCLSU or is KCLSU Associate Member. KCLSU reserves the right to extend this policy to Associate Members. This includes any individual who is a student or staff member from another institution or Students Union. All events organised with external speakers in a KCLSU building or property our outside it, are still within the responsibility (and liability) of the KCLSU including: Any event organised by a ratified student group/society, Student Council, Student Officer or KCLSU member of Staff that will take place in a Union space Any event organised by the above that will take place outside the Union building (for example in the College, off campus, out of the immediate area or in another country) Events where external speakers are streamed live into an event, or a pre-recorded film is shown The President of the group organising any event is responsible for the activities that take place within their events. All speakers will be made aware of their responsibility to abide by the law, the University and the Union s various policies, including that they: must not incite hatred, violence or call for the breaking of the law are not permitted to encourage, glorify or promote any acts of terrorism including individuals, groups or organisations that support such acts 14
must not spread hatred and intolerance in the community and thus aid in disrupting social and community harmony must seek to avoid insulting other faiths or groups, within a framework of positive debate and challenge are not permitted to raise or gather funds for any external organisation or cause without express permission of the trustees Our procedure Event organisers must notify the Union of any events that involve external speakers (defined as individuals or organisations that are not part of the Union or the University) through this procedure. Any room booking with an external speaker involved must be made no later than 21 days before the date of the event. This is to allow for adequate safeguarding checks to be made, as well as allowing time for alterations to the event if necessary. All External Speakers agree to the KCLSU External Speaker s Briefing (Appendix Item 1). No event involving any external speakers may be publicised or considered confirmed until the speaker has been cleared through the procedure detailed in this policy. This includes advertisement through any social media platform. KCLSU reserves the right to cancel, prohibit or delay any event with an external speaker if our policy is not followed or if health, safety and security criteria cannot be met. Any request made outside of this timeframe will be rejected. When booking for a room online with external speakers you ll be asked to detail a: brief description or booking title full description of the event detailing the exact purpose of the booking group size (please note that if this is over the limit for that room then it will be rejected automatically) name and contact details of the person making the booking start and end time of the event contact details for external speaker brief biography of the speaker If the event is outside of your core activity, the event will need a separate risk assessment Any failure to disclose the full details of an external speaker will result in an event / booking being cancelled and could result in disciplinary action or society based sanctions. The completed form will be passed to the KCLSU student centre team who will check all speakers details, group links and other connections (up to the maximum of 6 pages Google results and any web link that is provided) on the spreadsheet provided. If there is cause for a referral then the details for the booking need to be sent to the Chief Executive, (or their nominee during absence), for further investigation and guidance. Reasons for a referral are any of the following The potential for the event going ahead to cause the union to be in breach of its equal opportunities policy The potential for the event going ahead to cause the union to fail in its wider legal duties The potential for the event going ahead to give concern for the health and safety of the people attending the event or nearby The potential for the event going ahead to cause reputational risk to KCLSU The potential for the speaker s presence on campus to cause fear or alarm to members of the student body The potential for the speakers presence on campus to give rise to breach of peace Examples for referral include 15
The external speaker is linked to a proscribed organisation: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/380939/proscribe dorganisations.pdf The external speaker is on a speaker tour across a number of institutions or organisations The profile of the speaker/event/performance is such that it may be subject to a large crowd that will need managing Concerns a talk by an organisation generally considered extremist It is reported that the external speaker has spoken previously at another institution that has caused fear and/or intimidation of students, staff or other members of the public The speaker/event/performance is reported as being highly controversial The topic of the event or the external speaker is reported as likely to cause harm to a specific group of students The external speaker or performer has over 1000 twitter followers The external speakers has received coverage in the mainstream media e.g. TV channel or national or London newspaper coverage Speaker validation Upon referral, the Chief Executive will conduct a short investigation into the speaker and the event that, wherever relevant, takes representations from the event organiser related to the booking and from a wide number of concerned groups, university officials and external bodies. In making recommendations they will assess risk based on the following Risks will be identified as low, medium or high: any decision to limit freedom of speech as per the University s code of practice in pursuance of the 1986 Education Act the event going ahead to cause the Union to be in breach of its equal opportunities (or other) policy the event going ahead to cause the Student s Union to fail in its wider legal duties the event going ahead to cause reputational risk to the Union or KCL the speaker s presence on campus to cause fear or alarm to members of the student body the speaker s presence on campus to give rise to breach of peace and/ or overcrowding issues leading to health and safely fears any other factor which is felt to be appropriate to take into account They may make one of the following recommendations: to not permit the event with the external speaker to go ahead to fully permit the event with the external speaker to go ahead unrestricted to permit the event with the external speaker to go ahead on the basis of regulatory steps designed to reduce risk Regulatory steps may include requiring that: the event be filmed by an independent body The event is observed by Union, University or third party officials. The Union, University or third party officials reserve the right to stop events if any of KCLSU s policies are contravened before or during the event The event be stewarded by Safe space Marshalls or subject to security (or extra security) on the door (at the expense of the club or society hosting the event) An event promoting a particular view includes an opportunity to debate or challenge that view An event that was for society members only be opened to all members of the Union A copy of any speech to be delivered by the speaker is submitted to the Union in advance When considering any regulatory steps designed to reduce risk, the potential of those steps to cause risk (for example, the sense of oppression felt by having security on the door) should be taken into account. The recommendation will be put to the Vice President Activities and Development who will make a decision. Information on these decisions will be communicated to the Trustee board by the Head of Operations in the quarterly reports. 16
External Speakers Policy v2 Approval: Senior Leadership Team 1/1/15 For review: 31/12/15 Appendix KCLSU s External Speaker s Briefing Welcome, and thank you for agreeing to speak to our students at a KCLSU event. We welcome the events hosted both in King s and KCLSU venues and elsewhere, but we have to make sure that our students feel safe at all of these events. A number of our societies choose to fulfil these objectives by inviting in speakers broaden the scope of discussion and debate at events and we are grateful to those who volunteer their time to contribute to the extra-curricular development of our students. In allowing speakers to attend KCLSU events we approve them based on the understanding that they act within the law and the regulations set by the College and the statutes that those regulations are drawn from. The use of KCL and KCLSU premises for events that involve external speakers is regulated by University Room Booking Procedure and these rules are therefore adopted by KCLSU in line with our use of their premises for our events. It is our duty to act within the law and protect the safety of our students and staff. Our objective to promote Freedom of Speech is limited only by statute laws that protect individuals and groups of individuals from hate speech. These statutes forbid communication which is hateful, threatening, abusive or insulting and is intended to harass, alarm or distress. Communication which targets a person based on their skin colour, race, nationality, ethnicity, religion or sexuality is forbidden. It is also a criminal offence to incite or encourage others to break the law. All speakers, as well as event attendees, must be respectful of the beliefs and opinions of others. If there are concerns raised at any point in the lead up to the event regarding the safety of attendees such as a breech of the peace or a criminal offence the Union will inform the University Head of Security, in line with the University Code of Practice, and conditions may be made before the continuation of the event/event approval. These may include: Requesting submission of the speeches in advance of the meeting Limitation on attendees Declaration of attendees in advance of the meeting Stewards to be provided by the organisers Presence of officers of KCLSU to ensure good order Limitation on what attendees may bring to the event, which may include banning food or drink or anything that could be used as a missile No banners, flags, placards or similar items being allowed in to the building Alteration of the conduct of the meeting or its facilitation. Organisers would be consulted on these conditions in advance of the event and all speakers notified of the outcome. An event may also be cancelled if there are concerns that the event would risk student safety, violation of health and safety requirements or if the event risked violating the aforementioned laws regarding hatred, discrimination or incitement. KCLSU reserves the right to cancel or postpone any event should they have any concerns. We also reserve the right to perform spot checks on events being hosted by KCLSU clubs and societies. If there are breaches of the KCLSU or KCL policies at our event the matter will be referred for disciplinary or legal action. This briefing document has been provided to ensure all of our speakers are aware of the framework we operate within when facilitating external speakers and the measures that may, rarely, be required to support Freedom of Speech at our events. Again, we thank you for agreeing to speak at one of our events and if you have any questions regarding any of the information in this document please contact us. 17
Useful Links Terrorism Act 2000 The Education (No. 2) Act 1986 S43 Education Reform Act 1988 Academic Freedom The Human Rights Act 1998 Equality Act 2010 (s.10 relates to religion & belief as a protected characteristic) Discrimination Law religion and belief Public Order Act 1986 Violent, Threatening or Abusive Conduct and Speech KCL Policy on harassment, bullying and discrimination for students KCL Maintaining good relations in the College community KCL Policy and procedures in respect of permissible activities KCL KCLSU Room Booking Policy and Procedure KCLSU Safe Space Policy Protecting Free Debate 18
Maintaining good relations in the College community The College is committed to the principles of free enquiry and free speech; freedom of thought, conscience and religion; freedom of expression, and freedom of assembly. It is committed to the promotion of a culture based on trust and mutual respect. The College actively promotes equality of opportunity and diversity, and good relations between all members of the King s community. The College values and upholds the principle of academic freedom and seeks to ensure that staff and students have freedom within the law to question and test received wisdom, and put forward new controversial or unpopular opinions, without placing either their employment or studies at risk. The College considers that vigorous debate is proper and acceptable and is tolerant of a wide range of views and opinions on social, economic, political, cultural and religious issues. Such freedoms, however, do not give immunity from the law nor from personal liability. The College is obliged under law to ensure that any action, publication or speech on its premises is lawful, and to protect its staff, students and visitors from victimisation, harassment or unlawful discrimination. The College will provide facilities for lawful views to be expressed, and for lawful activities to take place on its premises. The College states, however, that providing such opportunities does not in any way imply or confirm that the College endorses such views or activities. The College will take all reasonable steps to ensure public order and to prevent crime on its premises; to ensure public safety, and to protect the rights and freedoms of staff, students, visitors and guests. The College will consult with external agencies as it deems necessary and will co-operate with such agencies as required by law. As a large and diverse institution, founded on the principles described above, the College considers that prescribing rigid parameters and constraints for activity contradicts the spirit of free enquiry and free speech. The College has a duty to mediate in and ultimately control situations where the lawful actions of one part of the College community have an adverse impact on the maintenance of good relations. The College has a responsibility to adjudicate in such circumstances, and to balance the opportunity to protest and argue with the expectation of being able to work and study without perceived intimidation or fear. However, whilst appropriate self-moderation and self-regulation on the part of staff and students is implicitly assumed, the College is ultimately responsible for observing its obligations to the whole community, and must act accordingly. To that end it has laid down its expectations in respect of permissible activities, and illustrated the parameters within which it will operate (for further information see: College Policy and Procedures in Respect of Permissible Activities). This statement summarises the principles underlying the College Policy and Procedures in Respect of Permissible Activities approved by the Principal s Central Team on 1 June 2009. Enquiries relating to this statement and the Policy and Procedures should be addressed to the Director of Services for Students. 19
College policy and procedures in respect of permissible activities Policy The College actively and regularly promotes a culture of trust and respect within its community, based on knowledge and understanding. The College aims at all times to support the freedom of its staff and students, within the law, to question and test received wisdom, and to put forward new, controversial or unpopular opinions. At the same time, the College has a responsibility to balance the opportunity to argue and protest, with the expectation of being able to work and study without perceived intimidation or fear. The College recognises it must therefore state its expectations of staff and students in respect of the conduct of events, meetings and other activities, and make clear the parameters within which it will operate. The following procedures are intended to provide clear guidance as to those expectations and actions which College and KCLSU officers may take. The parameters necessarily take account of a wide range of circumstances, and it should be noted that at all times the College endeavours to respond in a considered and thoughtful way to the sensitive issues which will arise in a large, complex and diverse community. Permissible activity To that end, the College will only permit those events, meetings, protests, demonstrations or other activities to take place which: are lawful; do not put the health and safety of personnel and buildings at risk; do not undermine good community relations; do not significantly constrain the work of the College; and will not cause damage to the College s reputation. Where any or all of these requirements are not satisfied, the College may prohibit an activity from taking place, or may bring such an activity to an end. Procedures A Permissible activities review The College has a range of formal policies and procedures in place to deal with issues of equality of treatment; discrimination on the grounds of race, religion, belief, age, disability, gender and sexual orientation; victimisation and harassment, and incitement to religious hatred. It is the College s responsibility to ensure that all staff and students are aware of their responsibilities in these matters, and that those who wish to pursue an issue or complaint have easy access to the relevant personnel and procedures. There is, however, a range of issues which may arise within the College which will require prompt and immediate guidance and action, for which formal processes may be irrelevant or untimely. This may include the review of printed and eliterature or posters; consideration of the potential outcomes of a meeting, event, activity or invited speaker, and the possible need to liaise with the police or other security agencies. Such matters will normally be addressed at appropriate levels of the pertinent line management structure. Managers or individuals may, however, refer a matter to any of the following team of College officers, who will provide advice, and consult colleagues as appropriate: Vice-Principals (as appropriate) 20
Head of Administration & College Secretary Director of Academic Services Director of Services for Students Director of Human Resources Director of Estates & Facilities The Dean President/Chief Executive, KCLSU College Head of Security Director of Information Services & Systems Director of External Relations B Events/activities on College premises Facilities for events and activities on College premises are booked through the Conference & Timetabling Services (CATS) Office. There are three relevant policy documents: http://www.kcl.ac.uk/about/structure/admin/facser/roombook/conferences.html which defines the requirements for staff-led events involving external speakers and/or delegates; http://www.kcl.ac.uk/about/structure/admin/facser/roombook/policy.html which defines the requirements for student-led events; and http://www.kcl.ac.uk/about/structure/admin/facser/conbro/book/termscondconf.html which defines the terms and conditions for third-party hire of College facilities. There may be occasions when the CATS Office, KCLSU, or an individual member of staff or student within the College community identifies that a particular event or activity may cause discord or concern within the larger community; may attract unwarranted external publicity; or may ultimately disrupt College business and as such cannot be addressed at local level. In this case the matter should be referred to a relevant College officer (see above) for consideration and response as appropriate. The range of usual responses may include review of subject matter and promotion materials; provision of additional support for an event; preparation for potential publicity, and local mediation between interest groups. In the event of action being required, an appropriate member of staff may be designated as the lead officer to co-ordinate provision for that meeting, event or activity. C Exceptional events or activities Where KCLSU, CATS or some other member of the College community identifies that a meeting, event or activity connected with the College may fall outside the range of permissible activities, and cannot be addressed at local level, they should refer the details to a relevant College officer (see above). The proponents of the meeting, event or activity which is under review are required to designate a lead organiser or co-ordinator, who will be responsible for liaising with a lead College officer and ensuring that the meeting, event or activity fulfils the requirements of a permissible activity. The lead organiser/co-ordinator will provide the lead College officer with such information as the latter may require, in addition to the routine material already provided in the course of making a booking. This will include, for example, the name of the principal speaker or speakers at a meeting, event or activity and, if relevant, the name of the person who will chair the meeting, the subject of the address or addresses, and other logistical information. 21
Where the meeting, event or activity is student-led, KCLSU will offer appropriate guidance to the lead organiser/co-ordinator and provide a conduit for student views or complaints. The lead College officer may grant or withhold permission for the use of College premises (including, as appropriate Union premises, in which case the lead officer may be the KCLSU representative) for the meeting, event or activity proposed if it falls outside the definition of a permissible activity, or if the lead organiser cannot or will not ensure compliance with any conditions set by the lead College officer. Such conditions may include requirements with regard to for example, the designation of the meeting as public or private ; ticketing; stewarding; use of a specific venue; admission or otherwise of external media; management of the meeting, and security. The College may withdraw permission for a meeting, event or activity if, having originally granted permission, it is judged that the meeting, event or activity will not in fact conform to the College s requirements for permissible activities. D Dean and Chaplaincy: oversight of prayer rooms and multi-faith facilities The Dean of King s College London is an ordained person, responsible for overseeing the spiritual development and spiritual welfare of all students and staff. The Dean and the Chaplaincy team are a pastoral resource for the whole College community. They are all available to see any member of College on any matter in complete confidence. They are available to people from all faith communities and beliefs. The Dean and Chaplaincy directly oversee any multi-faith and quiet rooms on College campuses. In conjunction with the Islamic Society, the Dean also co-ordinates and supports the operation of Muslim Prayer Rooms, which have a separate Code of Conduct. E Infringements The Head of Administration & College Secretary will shall report to the Council on the circumstances of any significant infringements of, and departures from, the provisions of this guidance. Any such infringements or departures, in whatever respect, may render those responsible liable to disciplinary action under the College s disciplinary procedures. F Unauthorised activities and events The College recognises that, from time to time, activities such as protests, demonstrations and occupations may occur on university premises. Although the College is sympathetic to the desire of staff and students to express their strongly held views, it has a responsibility, on behalf of its community, to ensure the continuation of core College business and to ensure the health and safety of its staff, students and visitors including any of those who may be involved in unauthorised action. In accordance with the relevant regulations for students and terms and conditions for staff, staff or students participating in unauthorised activities may be subject to disciplinary action. Approved by the Principal s Central Team on 1 June 2009. This Policy is supported by the statement Maintaining Good Relations in the College Community. Enquiries relating to the Policy and Procedures should be addressed to the Director of Services for Students. 22
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