Policies and Procedures

Harassment Policy and Procedures



If you feel you’re being harassed by others …. And you are a learner at Global London College’s training provision;


lRead the Policy and Procedure documents;

lIf at all possible, make clear to the person causing offence that such behaviour is unacceptable to you;

lIf you feel unable to confront the person directly or if talking to them has no effect, either:Talk the problem through with a friend, or, if you feel it would help, with a member of Global London College team.

lSeek a confidential interview with a member of the Global London College senior management team.

If you’re a member of staff, the procedures are more or less the same; you can also seek advice from your line manager, the Global London College directors or refer to details provided in the Staff Handbook.



Personal Harassment Policy




1. Global London College are committed to providing a learning environment free of unlawful discrimination and improper harassment. Sexual, racial and other forms of personal harassment can seriously worsen study and social conditions and affect the general quality of life for all members at Global London College training provision, as well as the direct victims. Any allegation of personal harassment will therefore be regarded extremely seriously and will be investigated and, if appropriate, may be grounds for disciplinary action.

2. All members of Global London College  staff and learners, are responsible for helping to ensure that individuals do not suffer sexual, racial or any other form of harassment, and that they are encouraged and supported in any legitimate complaint.

3. Any difficulty in defining what constitutes harassment should not deter  anyone from complaining of behaviour which causes them distress, nor should they be deterred by embarrassment, intimidation or fear of publicity. The sensitivity of harassment complaints and the desire for confidentiality will be respected by Global London College.

4. Threats, abuse or insults which are actually intended to cause harassment, alarm or distress constitute a criminal offence. This is so whether or not they are racially or sexually motivated, and whether the victim’s response is one of fear or of counter-aggression. But less extreme behaviour can be equally insidious and upsetting and will be viewed seriously by Global London College.


What is Harassment?


Harassment is unwanted behaviour which is hostile and/or offensive to the recipient or others, and which is not justified by the professional or working relationship. Such behaviour may be physical, verbal, non-verbal, or be in written form (communicated as graffiti, letters or e-mail).


What Distinguishes Harassment From Other Forms of Behaviour?


Personal harassment takes many forms, but has certain characteristics in each of those forms: there are words or conduct which cause unwanted offence or intimidation, and would be regarded as doing so by any reasonable person with a firm idea of what is and is not acceptable. It is this which distinguishes it from mere rudeness or bad manners, and also ensures that nothing is treated as harassment which would not generally be regarded as such. This is not to say that the victim’s own feelings are irrelevant, merely that they are not conclusive. Furthermore, there may be differences of culture, or of social attitudes between individuals which lead to misunderstandings. On the other hand, once the victim’s unusual sensitivity becomes known, the reasonable bystander might well say that, for example, the sort of tactless joke which was not harassment the first time becomes harassment if repeated.


In general terms, therefore, harassment is the unreasonable abuse of the victim, whether by another learner or by a person in a position of authority. It may take a number of forms.
Sexual harassment occurs when a person’s sexuality is emphasised over and above their standing as a member of the college community. Most commonly it will be harassment of a woman by a man, but is equally unacceptable between members of the same sex or when a man is harassed by a woman.


Examples of unwanted and unreciprocated conduct amounting to harassment would include-

a. remarks, gestures, jokes or offensive language which can reasonably be said to belittle or intimidate the victim;

b. provocative or suggestive remarks or pressure to   accept unwelcome invitations

c. display or circulation of pornography or material stridently attacking particular   sexual preferences

d.  deliberate physical contact to which the victim has not consented, or to which no opportunity to object has been given.

In all these cases, harassment occurs if the reasonable person would agree that the conduct, in itself or by reason of repetition, makes the victim’s academic or social environment hostile or intimidating. In extreme cases, this can be taken for granted. The promise of academic success in return for sexual favours could never be anything but harassment; nor could indecent assault, let alone more serious sexual aggression.


Racial harassment is hostile and offensive behaviour by an individual or group (usually) towards those of another racial or ethnic group. As in the case of sexual harassment, the words or conduct complained of are such as can reasonably be regarded as taking one characteristic as the defining and undesirable characteristic of the victim. For example-

lthe use of derogatory names, insults, racist jokes or ridicule of cultural differences

lthe display or circulation of racist material, or racist graffiti

lverbal abuse or threats which, in any case, create an intimidating or hostile environment.

Other forms of personal harassment are forms of unacceptable bullying or insult which any reasonable person would recognise as creating a hostile or intimidating environment for the victim. Examples might in particular cases include –

ldirect or indirect references to a disability or impairment

linvasion of privacy, for instance by anonymous phone calls or letters

lrepeated practical jokes

labusive or rowdy behaviour calculated to interfere with the victim’s study or social life.


Some such conduct will simply be thoughtless or ill-mannered, but there will come a point at which, because of the extreme form it takes, or because it is repeated or persisted in once known to be unwanted, it becomes more than the assertion of freedom of expression and behaviour, or the manifestation of high spirits, and may reasonably be judged to be harassment.


Personal Harassment Procedures

These procedures give effect to Global London College’s policy statement and are concerned with all complaints of harassment from a learner about another learner, and from a learner about a member of staff. A learner experiencing harassment from someone outside the Global London College training provision can seek guidance and support their assessor, mentor, ETE coach or a member of the Global London College ! senior management team. A member of staff with a complaint about another member of staff, a learner or a visitor to the College should refer to operations director.




1.Global London College is committed to providing a learning environment free of discrimination and harassment. The primary consideration is to ensure that maximum and appropriate support is made available to any subject of any alleged harassment and that action to resolve a complaint is tactful, sensitive, sympathetic and prompt. Where the harassment takes a serious form, either because of its nature, or because of the repetition of the act, Global London College will also need to consider whether any disciplinary action is appropriate.

2.This procedure consists of a number of stages. Normally allegations of harassment would initially be dealt with at stage 1 unless the offence was particularly serious or involved repetition of conduct that had previously been recognised as harassment.


Stage l – informal Procedures


1.A person who believes that s/he is the subject of harassment should, wherever possible, ask the person to desist from the behaviour complained of.

2.Where the harassment continues or is serious; or where the victim does not want to approach the perpetrator; or where the harasser cannot be identified, the victim should approach a member of staff. The important point is that the member of staff is someone they feel able to approach and talk to.

3.If the learner has been attacked or assaulted, the operations or training director must be contacted immediately: see section 3.

4.When approached by a learner who has experienced harassment, the member of staff should arrange space and time to hear the whole story. The role of the member of staff is to provide support and guidance: to listen to the learner’s account and to help him/her decide what to do next. It is important for the member of staff to agree at the beginning what record is to be kept of the meeting and the para meters of confidentiality.

5.If after listening to the learner the staff member feels, for any reason, that the learner should be interviewed by another member of staff, this should be discussed with him/her, reasons given, and a rapid referral made.

6.When listening to the learner, the following questions will need to be answered:

a.Does the reported behaviour appear to be harassment?

b.Does the learner want some action to be taken by Global London College?

7. If the answer to both of these is YES, the member of staff should    contact either the operations or training director. They will hear the allegation, probably see the complainant, and decide upon the next course of action. This may be informal or they may suggest the learner makes a formal complaint, so that the matter can be addressed under the Global London College’s disciplinary procedures and decide the next course of action. At this stage nothing should take place without the agreement of the complainant.

8. Where mediation, conciliation or an informal warning has failed to stop· the harassment the matter must be referred back to the operation or training director. At this stage, if the alleged harasser is a member of staff, the WELFARE OFFICER OR PRINCIPAL must be informed.

9. If the incident is clearly one of harassment but the learner doesn’t want or isn’t sure they want some action to be taken by the College, the member of staff must report the incident to the directors, and explain the learner’s wishes or concerns. These will be taken into consideration but Global London College reserves the right to take action in extreme circumstances without the permission of the complainant.

10. If the incident appears to be other than harassment and the learner does not want any action taken by the Global London College, the role of the staff member is to provide support and advice.

11. If the incident is not obviously harassment but the learner feels it is, and wants some action to be taken the member of staff must speak to the directors.



Stage 2 – Formal Complaint


1. Although the learner has the right to make a formal complaint at any stage, such a submission is likely to occur where:

   a. the harassment is particularly serious;

  b. the harassment is of a continuing nature, and is therefore considered a more serious offence.

2. To make a formal complaint, the learner must write to the training director detailing the incident/so This may be done with assistance of the member of staff the learner approached or was referred to.

3. Where the alleged harasser is a learner, the training director will normally interview both the complainant and the alleged harasser/s, and any other person s/he considers relevant. Both complainant and alleged harasser may be accompanied by a friend at such interviews. If the training director is satisfied that an offence has been committed, s/he will decide whether the matter can be dealt with a reprimand, or whether it should be reported to the WELFARE OFFICER OR PRINCIPAL for dealing with through the Stage 3 procedure. The training director will notify both the complainant and the alleged harasser of the outcome of his/her deliberations and will maintain a confidential record of all cases, however resolved.

4. A learner who has denied the offence but has been reprimanded by the training director may appeal against the decision to the WELFARE OFFICER OR PRINCIPAL.

5. Where the alleged harasser is a member of staff the matter should be referred in the first instance to the Director of Training.

6. A learner who makes a false statement with malicious intent in connection with allegations of harassment will be reported to the WELFARE OFFICER OR PRINCIPAL, and may be subject to disciplinary action.


Stage 3 –  Formal Disciplinary Hearing


1. Serious cases of harassment by a learner will be reported to the College Director, and will be considered under the Global London College’s Code of Learner Discipline.

2. Serious cases of harassment by a member of staff will be considered under the relevant disciplinary procedures.



Updated: 24 February 20