Joint letter to Office for Students on their new approach to regulating harassment and sexual misconduct
Refuge has signed an open letter to Susan Lapworth, the Chief Executive of the Office for Students, calling for of all aspects of domestic abuse to be included in the organisation’s new approach to regulating harassment and sexual misconduct in English higher education.
Dear Ms Lapworth,
Domestic abuse and the Office for Students’ new approach to regulating harassment and sexual misconduct in English higher education
We write to you as seven specialist domestic abuse and violence against women and girls (VAWG) organisations to express our disappointment at the omission of domestic abuse from the Office for Students’ proposed new approach to regulating harassment and sexual misconduct in higher education.
A new ongoing condition of registration for providers to introduce systems and policies for tackling harassment and sexual misconduct provides an opportunity to transform the higher education sector’s response to VAWG. However, as your consultation notes, the proposed definition of harassment and sexual misconduct does not adequately cover some forms of domestic abuse, such as coercive control, economic abuse and emotional abuse.
Young people experience the highest rates of domestic abuse of any age group in the UK – 10.2% of adults aged 20 to 24 experienced domestic abuse in the year ending March 2022. Students are the occupational group with the highest likelihood of experiencing domestic abuse, and an estimated 162,073 higher education students experience domestic abuse each year in the UK. These facts are acknowledged within your consultation document. We are therefore disappointed that the Office for Students has concluded that a broad definition of domestic abuse should not be included within the definition of harassment and sexual misconduct because it is a “complex area.”
We are further concerned by the rationale that an expansion of proposals to include all forms of domestic abuse was discounted as regulation in this area could place “additional burden” on higher education providers, because only a small proportion currently have established processes and policies related to domestic abuse. This is not an acceptable reason. The response to domestic abuse must be cross-societal, and education providers have a key role to play in supporting survivors and challenging perpetrators.
The consultation states that the Office for Students will “keep the situation under review and may revisit this issue in due course.” This will be far from reassuring for students currently experiencing domestic abuse, and also fails to make clear that domestic abuse will not be tolerated. We urge you to make a swift and robust commitment to ensure higher education providers put in place domestic abuse policies and processes to support students. Such commitments should take into account the Office for Students’ own acknowledgement that self-regulation and voluntary action by providers have so far failed to achieve progress in addressing harassment and sexual misconduct.
We would welcome an opportunity to meet with you to discuss the Office for Students’ approach to domestic abuse further. Please contact us to arrange a meeting.
Tracy Blackwell, Director of Strategic Insights and Partnerships, Refuge
Isabelle Younane, Head of External Affairs, Women’s Aid Federation England
Sarah Hill, CEO, IDAS
Cyrene Siriwardhana, Legal and Policy Manager, Surviving Economic Abuse
Natasha Rattu, Executive Director, Karma Nirvana
Faustine Petron, Founder, Make It Mandatory
Liz Thompson, Director of External Relations, SafeLives