Prevent Policy

Last updated: April 2024

1

Introduction

1.1

Kaplan SQE has been appointed by the Solicitors Regulation Authority Limited (“SRA”) as the sole provider of the Solicitors Qualifying Examination (“the Assessment”) and the End Point Assessment Organisation (“EPAO”) for Solicitor Apprentices. In complying with our duty under the Counter Terrorism and Security Act 2015 we have had due regard to the risk of radicalisation in the context of the delivery of the Assessment and the specific and limited contact with and between SQE candidates during the Assessment.

1.2

Prevent is one of the strands of the UK counter-terrorism strategy (CONTEST) which covers prevention of extremism and radicalisation pursuant to the Counter Terrorism & Security Act 2015.

1.3

The threat to the UK from international terrorism is substantial. The terrorist threats that we now face are more diverse than ever before, dispersed across a wider geographical area and often in countries without effective governance.

1.4

Early intervention is at the heart of Prevent which aims to divert people away from being drawn into terrorist activity. Prevent happens before any criminal activity takes place by recognising, supporting and protecting people who might be susceptible to radicalisation.

2

About this Policy

2.1

The purpose of this document is to set out Kaplan SQE’s policy in respect of the prevention of extremism and radicalisation in connection with the delivery of the Assessment.

2.2

The objective of this Policy is to:

2.2.1

Ensure an awareness of Prevent amongst Kaplan SQE staff, contractors and subcontractors so that all have the confidence to recognise the signs that a candidate or colleague is at risk of extremism or radicalisation;

2.2.2

Provide a clear framework to structure and inform Kaplan SQE’s response to concerns of extremism or radicalisation, including a supportive referral process for those who may be susceptible to the messages of extremism; and

2.2.3

Provide support for candidates who may be at risk of radicalisation with appropriate sources of advice and guidance.

3

Scope of this Policy

This Policy confers responsibility on all staff, examiners, assessors, contractors, consultants and other individuals working on behalf of Kaplan SQE or its subcontractors involved in the delivery of the Assessment whose role involves contact with SQE candidates.

4

Definitions

4.1

Extremism: The vocal or active opposition to fundamental British values, including democracy, the rule of law, individual and mutual respect and tolerance of different faiths and beliefs;

4.2

Radicalisation: The process of causing someone to support Terrorism and forms of Extremism, such as extreme religious, social or political views or beliefs, which may lead to Terrorism; and

4.3

Terrorism: An action that endangers or causes serious violence, damage or disruption and is intended to influence the government or to intimidate the public and is made with the intention of advancing a political, religious or ideological belief.

5

Prevent Lead for Kaplan SQE

5.1

The SQE Academic Director:

5.1.1

is the Prevent Lead, with responsibility for ensuring that this Policy is implemented across Kaplan SQE and that any concerns are shared with the SRA and other relevant partner organisations, in order to minimise the risk of SQE candidates becoming drawn into Terrorism; and

5.1.2

will undertake Prevent training in order to have the skills to recognise those who may be vulnerable to Extremism, Radicalisation or Terrorism and to know the appropriate action to take if they have concerns.

5.2

In the event that the Prevent Lead is unavailable the Head of Equality and Quality shall assume responsibility for Prevent matters and compliance with this Policy.

6

Prevent Responsibilities

All individuals in scope for this Policy have a responsibility to:

6.1

Create and support an ethos that upholds British values and to create an environment of respect, equality, diversity and inclusion;

6.2

Report any concerns around Extremism, Radicalisation or Terrorism via the safeguarding reporting channels;

6.3

Report and remove any literature displayed in connection with the SQE that could cause offense or promote Extremist views;

6.4

Support the development of staff and candidate understanding of the issues around Extremism, Radicalisation or Terrorism through activities such as training and awareness campaigns; and

6.5

Not stereotype, label or single out candidates or colleagues based on their origins, ethnicity, faith and beliefs or any other characteristics protected under the Equality Act 2010.

7

IT Networks

7.1

Kaplan SQE considers it unacceptable for its IT networks to be used in any way that supports, promotes or facilitates Extremism, Radicalisation or Terrorism.

7.2

The Prevent Lead will ensure that appropriate methods such as the use of filters are kept under regular review as a means of restricting access to harmful content via Kaplan SQE IT networks.

7.3

Kaplan SQE takes the challenges presented by social media very seriously. Any extremist material identified on social media services such as Facebook or Twitter which are reported to Kaplan SQE will be investigated. If Kaplan SQE deems appropriate after such investigation, reasonable steps will be taken to remove such material.

8

Communications

8.1

Kaplan SQE shall not permit materials to be displayed in connection with the SQE which could be deemed offensive or supporting Extremist views at any of its premises and will remove any such material if it is found.

8.2

Kaplan SQE will seek to ensure that Kaplan SQE printed and electronic communications (including its website) do not contain or support Terrorist or Extremist material or material likely to encourage Terrorism or Extremism and will investigate immediately if any such instances are raised.

8.3

Any individuals who come across signs of potential or actual harm or abuse in respect of Vulnerable Adults undertaking the SQE or who have concerns in respect of the wellbeing of any SQE candidate should report this to the Lead Safeguarding Officer as quickly as possible.

8.4

The Lead Safeguarding Officer will invoke appropriate procedures to protect the relevant individuals and discuss the case with the Kaplan SQE Senior Leadership Team where appropriate.

8.5

Referrals to social services, the police or the statutory authorities should be made by the Lead Safeguarding Officer in consultation with the Kaplan SQE Senior Leadership Team.

8.6

When any individual in scope for this Policy is unsure and needs guidance about safeguarding issues, they are encouraged to seek guidance from the Lead Safeguarding Officer.

8.7

In the event that the Lead Safeguarding Officer is unavailable the Head of Quality and Equality shall assume responsibility for safeguarding matters and compliance with this Policy.

9

Referral of Concerns Regarding Prevent

9.1

Any Kaplan SQE member of staff or other individual within scope of this Policy may identify concerns about an SQE candidate potentially being drawn into Extremism, Radicalisation or Terrorism based on information received or behaviour observed.

9.2

It is important that such concerns can be shared in a safe and supportive fashion to enable concerns to be investigated and an appropriate intervention to be developed, if required.

9.3

It is equally important that assumptions are not made on the basis of information received and that referrals are investigated thoroughly and fairly. Kaplan SQE shall seek to approach such concerns from the perspective of safeguarding the individual about whom concerns have been expressed.

9.4

Where an individual has concerns that a candidate is expressing Extremist views or is at risk of being drawn into Extremism, Radicalisation or Terrorism these concerns should be passed to the Prevent Lead.

9.5

The Prevent Lead will investigate the matter, seeking to gather together the substantive information and evidence which would allow a full consideration of the case.

9.6

The Prevent Lead will make a decision as to the seriousness of the case following investigation. There are four possible outcomes:

9.6.1

No further action is required: In this case a confidential record of the case will be held on Kaplan SQE systems and the Prevent Lead would notify the Kaplan SQE Senior Leadership Team that a case had been investigated but no further action is required.

9.6.2

There is substance to the case but at this stage only internal action is required: The Prevent Lead would determine the exact nature of the intervention required and decide upon the actions and review date. At the review the Prevent Lead would assess the situation again and take appropriate action. It is anticipated that in the majority of cases the intervention would be supportive and safeguarding in nature. The Prevent Lead will brief the Kaplan SQE Senior Leadership team on the outcome.

9.6.3

There is substance to the case and external support is being considered: In cases where an individual is believed to be at risk of, or undergoing the process of Radicalisation, but there is no evidence to suggest any criminal act has or is planned to take place then the Prevent Lead should seek specialist external support and advice in order to determine the most appropriate way of helping the individual concerned. This should be agreed following discussion between the Prevent Lead and the Kaplan SQE Senior Leadership Team. Advice may be sought from the local police or local authority designated Prevent or Channel Coordinator. Only where there is clear and compelling evidence of a requirement to do so will information be shared with other agencies as per section 10 of this Policy.

9.6.4

A referral to the police is required because there are serious and immediate issues of safety to the student or others, and/or there is evidence to suggest a criminal act may be committed or has been committed. This decision would be taken by the Prevent Lead only in the most serious of circumstances and only following discussion with the Kaplan SQE Senior Leadership Team and Kaplan Legal Department.

10

Information Sharing

10.1

Kaplan SQE is aware of the opportunities for informal and formal sharing of information with relevant authorities. The Prevent Lead will use these when considered necessary and appropriate to do so in the interests of preventing people from being drawn into Extremism, Radicalisation or Terrorism.

10.2

Kaplan SQE will share only sufficient and relevant information in order to allow the concern to be appropriately followed up. Information sharing will only take place with external authorities when this is consistent with the provisions of the Data Protection Act 2018.

11

Related Policies and Procedures

This policy should be used in conjunction with the following Kaplan policies and procedures:

• Safeguarding Policy
• Equality & Diversity Policy
• Data Protection Policy
• Acceptable Use IT Policy
• Health & Safety Policy
• Whistleblowing Policy
• Code of Business Conduct
• Dignity at Work Policy

12

Policy Review and Publication

The Prevent situation in terms of both statutory regulation and emerging risk factors is changing rapidly. It is essential therefore that this Policy is kept under constant review by the Prevent Lead and circulated to Kaplan SQE Senior Leadership Team for annual review. The Policy will be published on the SQE website.