ANTI-HARASSMENT AND ANTI-BULLYING POLICY & PROCEDURE: STUDENTS
By Chair’s action
Period of approval:
ANTI-HARASSMENT AND ANTI-BULLYING POLICY AND
The purpose of this policy is to ensure that all students at Wrexham Glyndŵr University
(“the University”) are treated and treat others with dignity and respect, free from
harassment and bullying. The University aims to provide a safe and supportive
environment for students to study and interact with other students, staff and visitors,
and where staff can work free from harassment and bullying.
Students at the University must treat other students, staff and others with dignity and
respect, and should always consider whether their words or conduct could be
offensive. Even unintentional harassment or bullying is unacceptable.
The University takes allegations of harassment or bullying seriously and will address
them promptly, and treat them confidentially where possible.
The University will provide a framework within which allegations of harassment or
bullying can be explored and resolved informally if possible, providing support for both
the student expressing the concern and the person against whom the allegation is
Where an instance of alleged harassment or bullying cannot be resolved informally,
this will be investigated and may result in disciplinary action being taken under either
the Disciplinary Procedure for Students or the Disciplinary Procedure for Staff.
The University aims to balance the rights of the person making the allegation and those
of any person against whom an allegation is made; all parties must be treated with
dignity and respect. A student should not expect to suffer any reprisals for making an
allegation in good faith, and any evidence of recrimination should be brought
immediately to the attention of the Academic Registrar.
However, if there is reason to believe that an allegation is malicious or vexatious, the
individual making the allegation might be subject to disciplinary procedures.
The University may decide, at any stage, that it is unable to consider an allegation
further if there is evidence of the individual making the allegation:
• being aggressive or abusive towards staff or other students;
• making unreasonable demands, for example, demanding responses within an
• insisting on seeing or speaking to a particular member of staff,
• continual telephone calls, emails or letters,
• repeatedly changing the substance of the allegation or raising unrelated
• being unreasonably persistent, for example, persistent refusal to accept a
decision made in relation to an allegation,
• persistent refusal to accept explanations relating to what can or cannot be done
about the allegation, and
• continuing to pursue an allegation without presenting any new information.
The Equality Act 2010 prohibits harassment related to age, disability, gender
reassignment, marital or civil partner status, pregnancy or maternity, race, colour,
nationality, ethnic or national origin, religion or belief, sex or sexual orientation. For
more information see the University’s Equal Opportunities Policy.
The Protection from Harassment Act 1997 also makes it unlawful to pursue a course
of conduct which you know or ought to know would be harassment, which includes
causing someone alarm or distress.
Who is covered by the policy?
This policy covers harassment or bullying by a student against another student, by a
student against a member of staff (or individual attending the University such as a
contractor, visitor, consultant, casual or agency worker) or by a member of staff against
a student. Only current students may pursue an allegation under this Policy and
What is harassment?
Harassment is any unwanted physical, verbal or non-verbal conduct which has the
purpose or effect of violating a person's dignity or creating an intimidating, hostile,
degrading, humiliating or offensive environment for them. A single incident can amount
to harassment. It is unjustifiable in relation to professional roles, performance or
Unlawful harassment may involve conduct of a sexual nature (sexual harassment), or
it may be related to age, disability, gender reassignment, marital or civil partner status,
pregnancy or maternity, race, colour, nationality, ethnic or national origin, religion or
belief, sex or sexual orientation. Harassment is unacceptable even if it does not fall
within any of these categories.
Behaviour which is not intended to be offensive may be perceived as harassment
because of differences in culture or attitude or misinterpretation of social signals. The
perception of the person offended is an important consideration. The University will
consider also whether the behaviour could reasonably be expected to cause offence.
Behaviour that continues once an individual has indicated by words or conduct that it
is unwanted is harassment.
Harassment may include but is not limited to:
physical conduct or "horseplay", including hitting, slapping, touching,
pinching, pushing, shoving, grabbing, brushing past someone, invading
their personal space, and more serious forms of physical or sexual
unwelcome sexual advances or suggestive behaviour (which the
harasser may perceive as harmless), and suggestions that sexual favours
may result in improved academic marks or support or that a refusal may
result in lower academic marks or less academic support, intentional and
unnecessary contact of an intimate nature;
sexually orientated comments or gestures which can reasonably be
expected to offend others;
intrusion into personal life such as direct or indirect pestering including
suggestions for social activity unrelated to work; unwanted telephone
calls, emails or texts at home or at work; spying or stalking;
sending or displaying material that is pornographic or that some people
may find offensive or sexually provocative or orientated (including e-
mails, text messages, video clips and images sent by mobile phone
downloaded or posted on the internet);
offensive or intimidating comments or gestures, or insensitive jokes or
mocking, mimicking, offending, or belittling a person's disability;
hostility and/or unreasonable obstruction or removing barriers to
workplace needs of disabled people or excluding disabled individuals
from workplace meetings or activities on the grounds of their disability;
racist, sexist, homophobic or ageist jokes, or derogatory or stereotypical
remarks about a particular ethnic or religious group or gender;
attempting to recruit people into racist organisations/groups or activities;
attempting to engage people in criminal or antisocial behaviour;
outing or threatening to out someone as gay, lesbian, bisexual or
ignoring or shunning someone, for example, by deliberately excluding
them from a conversation or a workplace social activity.
A person may be harassed even if they were not the intended “target". For example, a
person may be harassed by racist jokes about a different ethnic group if they create
an offensive environment for him/her.
This list is non-exhaustive and any offence which is deemed to be harassment is
treated very seriously and may be referred to the University Disciplinary Procedure for
Students or the Disciplinary Procedure for Staff. A possible outcome is summary
dismissal or expulsion from the University.
What is bullying?
Bullying is offensive, intimidating, malicious or insulting behaviour involving the misuse
of power that can make a person feel vulnerable, upset, humiliated, undermined or
threatened. Power does not always mean being in a position of authority, but can
include both personal strength and the power to coerce through fear or intimidation.
Bullying can take place in public or in private.
Bullying can take the form of physical, verbal and non-verbal conduct such as written
communication. Bullying may include, by way of example:
shouting at, being sarcastic towards, ridiculing or demeaning others;
physical or psychological threats or violence;
overbearing and intimidating levels of supervision of academic work;
inappropriate and/or derogatory remarks about someone's performance
or personal attributes;
persistently ignoring or patronising;
abuse of authority or power by those in positions of seniority; or
deliberately excluding someone from meetings or communications
without good reason.
Legitimate, reasonable and constructive criticism of a student’s performance or
behaviour, or reasonable instructions given to students in the University, will not
amount to bullying on their own.
If you are being bullied or harassed, you should keep a written record of incidents, with
dates, times and the names of any witnesses.
If you are a student, you should initially consider raising the problem informally with
the person responsible, if you feel able. Recognising that premature escalation may
damage professional and personal relationships needlessly, the University expects
staff and students to be open with each other and try to resolve their concerns
informally in the first instance. You should explain clearly to the perpetrator that his/her
behaviour is not welcome or makes you uncomfortable. If this is too difficult or
embarrassing, you should speak to your personal tutor or a representative of the
Students’ Union who can provide confidential advice and assistance in resolving the
issue formally or informally.
If you are a member of staff and consider that you are being bullied or harassed by a
student, then you should follow this procedure but should approach your line manager,
a member of the Human Resources Department, your union representative, or a
Dignity at Work Advisor informally for confidential advice. If the person you consider
is subjecting you to bullying or harassment is not a student, then you should refer to
the University’s Dignity at Work Policy and Procedure which is available on WGYOU.
If you are not certain whether an incident or series of incidents amount to bullying or
harassment, you should initially contact your personal tutor or a representative of the
Students’ Union informally for confidential advice (please refer to 6.3 if you are a
member of staff).
A personal tutor or the representative of the Students’ Union may suggest that you put
your concerns in writing to the perpetrator or s/he may offer to arrange a meeting
between you and the perpetrator to discuss the issue and try to find a way forward
without referring the matter to a formal procedure. (Please refer to 6.3 if you are a
member of staff). The perpetrator may be unaware that his/her conduct is unwanted
or causing offence and agree to cease such conduct. You may feel that it is sufficient
to accept an apology. Other ways forward may be proposed, such as mediation.
The alleged perpetrator will also have access to advice from his/her personal tutor, a
representative of the Students’ Union, a member of the Human Resources Department
or a union representative and this will not be interpreted as an indication of guilt.
If informal steps have not been successful or are not possible or appropriate, you
should follow the formal procedure set out below.
Raising a formal complaint
If you wish to make a formal complaint about bullying or harassment, you should
submit your complaint in writing to the Academic Registrar.
Your written complaint should set out full details of the conduct in question, including
the name of the harasser or bully, the nature of the harassment or bullying, the date(s)
and time(s) at which it occurred, the names of any witnesses and any action that has
been taken so far to attempt to stop it from occurring.
The University will not normally consider a formal complaint in respect of bullying or
harassment that has happened in the past, if the behaviour has ceased more than
twelve weeks prior to the complaint being submitted.
As a general principle, the decision whether to progress a complaint is up to you.
However the University has a duty to protect all of its staff and students and may
pursue the matter independently if, in all the circumstances, the University considers it
appropriate to do so.
The Academic Registrar or his/her nominee will notify both you and the alleged
perpetrator in writing within five days of receiving the complaint of the following:
that a formal complaint has been received and that it will be investigated
in accordance with this procedure;
that you both will be invited to attend a meeting in accordance with this
that you have a right to be accompanied at the meeting by a
representative of the Student’s Union, a fellow student, a member of staff
or a carer at all stages of the process, if you are a student. If you are a
member of staff, you have a right to be accompanied by a colleague or a
representative of a trade union. You may also have a translator present;
that the alleged perpetrator has a right to be accompanied at the meeting
by a representative of the Student’s Union, a fellow student, a member of
staff or a carer (and a translator), if s/he is a student, or by a fellow
member of staff or trade union representative if s/he is a member of staff
at all stages of the process;
that full details and any supporting witness statements will be supplied to
each of you at least 5 days prior to the hearing.
A copy of this policy should be supplied to both of you.
The Academic Registrar will appoint an Investigating Officer within a reasonable
practicable time to investigate your complaint.
First Stage – Investigation by the Investigating Officer
The initial investigation will be conducted by an Investigating Officer with appropriate
experience and no prior involvement in the complaint. The investigation should be
thorough, impartial and objective, and carried out with sensitivity and due respect for
the rights of all parties concerned.
The Investigating Officer will arrange a meeting with you and a separate meeting with
the alleged perpetrator and/or any third party involved to the complaint, usually within
five days (or as soon as is reasonably practicable) of receiving the complaint, so that
each party can give his/her account of events. The alleged perpetrator has a right to
be informed of the allegations against them, so that s/he can respond.
It may be necessary to interview witnesses to any of the incidents mentioned in your
complaint. If so, the importance of confidentiality will be emphasised to them.
Each party has the right to be accompanied as outlined in 7 above. The person
accompanying either party must respect the confidentiality of the investigation. The
Investigating Officer may arrange further meetings with either party as appropriate
throughout the investigation.
Where your complaint is about a member of staff, the University may consider
suspending them on full pay or making other temporary changes to working
arrangements pending the outcome of the investigation, if circumstances require.
Where your complaint is about a student, the University may consider suspending
his/her studies pending the outcome of the investigation, if circumstances require. This
decision will be made by the Deputy Vice-Chancellor.
Where your complaint is about someone other than a member of staff or a student,
such as a contractor, visitor, consultant, casual or agency worker, the University will
consider what action may be appropriate to protect you and anyone involved pending
the outcome of the investigation, bearing in mind the reasonable needs of the business
and the rights of that person. Where appropriate, the University will attempt to discuss
the matter with the third party.
The University will also seriously consider any request that you make for changes to
your own circumstances during the investigation. For example you may ask for
permission not to attend certain teaching sessions or for a change of supervisor so as
to avoid or minimise contact with the alleged harasser or bully.
Alleged perpetrator is a student
Where the allegation is in respect of a student, the case will be referred to the
Disciplinary Procedure for Students at the stage of Convening the Disciplinary Panel.
The hearing shall be conducted as described in the Procedure.
However, in addition
to the penalties outlined in the Procedure, the Panel may refer the matter for mediation,
or require that the perpetrator is referred for counselling. The complainant may agree
to accept an apology and the issue will be formally resolved. The remainder of the
Disciplinary Procedure for Students will apply.
Sections 9 and 10 of this Procedure do not apply. Sections 11 and 12 of this Procedure
Alleged perpetrator is a not a student (see section 3)
8.10.1 Once the Investigating Officer has collated information, this will then be passed
to the Head of Human Resources, who will convene an Investigation Panel
which will investigate complaints in a timely and confidential manner without
unnecessary and unreasonable delay. Individuals not involved in the complaint
or the investigation should not be told about the matter.
8.10.2 The Investigation Panel may invite you, and any other third parties who may be
involved, such as witnesses, to a hearing. Each party will be provided with all
documentation that is to be relied upon at least five days prior to the hearing.
8.10.3 The Investigation Panel will be chaired by a Senior Manager who has the
appropriate experience and will have had no prior involvement in the complaint,
or no managerial or personal relationship with any party to the complaint. The
Investigation Panel will also include a representative of the Human Resources
8.10.4 The investigation hearing will be thorough, impartial, objective and carried out
with sensitivity and due respect for the rights of all parties concerned. The
purpose of the hearing is to give parties the opportunity to give their input and
respond to allegations.
8.10.5 Records will be kept of all interviews, meetings and phone calls relating to
8.10.6 The purpose of the Investigation Panel is to obtain as much information as
practicable in relation to the allegations and relevant surrounding
circumstances and review all evidence which has been placed before them.
The aim of this process is to ensure a balanced view of the facts, evidence and
surrounding circumstances in relation to the allegations. Where necessary, the
Investigation Panel will re-interview any of the parties to clarify their input
8.10.7 At the end of the investigation, the Investigation Panel will consider the
complaint, collate a written report of its findings and provide a recommendation
as to whether any further action should be taken, which may include disciplinary
proceedings. The chair of the panel will notify the Human Resources
Department of the Investigation Panel’s decision. The Human Resources
Department will then notify all parties in writing of the outcome and whether any
further action is to be taken. A decision will be made as soon as reasonably
practicable and without unnecessary delay
8.10.8 If you accept an apology, the issue will be formally resolved and no further
action will be pursued.
Action following the investigation
If the Investigation Panel considers that harassment or bullying has occurred, prompt
action will be taken to address it.
Where the harasser or bully is an employee the matter may be dealt with as a case of
possible misconduct or gross misconduct under the University’s Disciplinary
Procedure. If this is the case, the Human Resources Department will make the
Where the harasser or bully is a third party, appropriate action might include putting
up signs setting out acceptable and unacceptable behaviour; speaking or writing to the
person and/or his/her superior about their behaviour; or, in very serious cases, banning
them from the premises or terminating a contract with them.
Whether or not the complaint is upheld, the University will consider how best to
manage the ongoing relationship between you and the alleged harasser or bully. It
may be appropriate to arrange some form of mediation and/or counselling, or to
change the duties, working location or reporting lines of one or both parties.
Any student or staff member, including the complainant, who deliberately provides
false information or otherwise acts in bad faith as part of an investigation may be
subject to action under the appropriate University Disciplinary Procedure.
If you are not satisfied with the outcome you may appeal in writing to the Vice-
Chancellor, stating your full grounds of appeal, within ten days of the date on which
the decision was sent or given to you. You should also ensure that the Human
Resources Officer receives written notification of your appeal at the same time.
An appeal hearing will be held, normally within one week of receiving your written
appeal. This will be dealt with impartially by a more Senior Manager who has not
previously been involved in the case (although s/he may ask anyone previously
involved to be present). You may be accompanied at the meeting by a representative
of the Student’s Union, a fellow student, a member of staff or a carer. You may in
addition bring a translator.
You will receive a final decision in writing, usually within one week of the appeal
hearing. This is the end of the procedure and there is no further right to appeal.
Protection and support for those involved
Students or staff who make complaints or who participate in good faith in any
investigation conducted under this policy must not suffer any form of retaliation or
victimisation as a result.
If you believe you have suffered any such treatment you should inform the Academic
Registrar, your line manager or the Human Resources Department. If the matter is not
remedied you should raise it formally using this procedure.
Anyone found to have retaliated against or victimised someone for making a complaint
or assisting in good faith with an investigation under this procedure will be subject to
disciplinary action under the appropriate University’s Disciplinary Procedure.
Independent counsellors external to the University may be utilised by exception, e.g.
on medical advice, or where the issue is beyond the skills of internal resources and
the University considers that specialist help is necessary.
Confidentiality and data protection
Confidentiality is an important part of the procedures provided under this policy.
Everyone involved in the operation of the policy, whether making a complaint or
involved in any investigation, is responsible for observing the high level of
confidentiality that is required. Details of the investigation and the names of the person
making the complaint and the person accused must only be disclosed on a "need to
Information about a complaint by or about a student or a member of staff may be placed
on the student’s file or employee's personnel file, along with a record of the outcome
and of any notes or other documents compiled during the process. These will be
processed in accordance with the University’s Data Protection Policy.
Breach of confidentiality may give rise to disciplinary action under the appropriate
University Disciplinary Procedure.
Updated for nomenclature changes following restructuring October 2018