SUMS Principal Consultant Helen Baird outlines key findings from our evaluation report on the Office for Students’ (OfS) statement of expectations. The evaluation concludes that while some progress has been made, it is highly variable and recommends that regulatory intervention is required to drive sector-wide improvement.
The statement of expectations
In mid-2021 the Office for Students’ (OfS) published a set of expectations containing recommendations to assist universities and colleges in developing and implementing effective systems, policies and processes to prevent and respond to all forms of harassment and sexual misconduct. Aims of the statement are to ensure that all higher education (HE) students are protected from harassment and sexual misconduct from other students, staff and visitors. The statement was based on learning from all the principles, recommendations and good practice established in various sector frameworks and reports, originating with Universities UK’s (UUK) Changing the Culture report in 2016. Compliance with the statement is not currently mandatory.
Evaluation of the statement’s initial impact
SUMS conducted an independent evaluation for the OfS looking at the initial impact of the statement of expectations between March and October 2022. We examined how universities and colleges have responded to the statement; heard from students and students’ unions on whether things are changing for the better; and considered whether further change is needed. The evaluation built on all the sector reports and guidance developed over recent years and the growing body of literature. It also involved extensive research with HE providers (including through a large survey), sector bodies, students and their representatives, and the study was supported by an expert advisory group.
Our evaluation report
The purpose of our final evaluation report, published on 10 November 2022 by the OfS, is to summarise the findings and conclusions from our research over the past eight months. We also make 16 recommendations for the OfS, other sector bodies and individual HE providers, intended to drive further and more radical change in tackling all forms of harassment and sexual misconduct in higher education.
Overview of findings and the need for further change
Overall, this evaluation has shown that:
- The statement of expectations has helped maintain momentum in the sector of the work of many previous initiatives designed to address harassment and sexual misconduct, most notably the Changing the Culture framework and OfS’ Catalyst safeguarding funding, and it has helped keep these issues firmly on the sector’s agenda.
- Addressing harassment and sexual misconduct however is very much still ‘work in progress’ in the sector. There remains substantial variations and levels of maturity among HE providers, and in the consistency of their approaches and level of prioritisation being accorded to tackling harassment and sexual misconduct.
- The statement has helped bring about changes in the sector, but the right people have to be in place to prioritise these issues. A key determinant still appears to be whether there is senior leadership engagement and particularly a championing role being taken by one or more members of the leadership team.
- There are many exceptions and lots of evidence of good practice and professionalisation across the sector, but progress often depends on staff, students’ unions and students pushing this area forward, often accepting the ‘emotional labour and burden’ that comes with it.
- Work on racism and all the other forms of harassment associated with protected characteristics seems much less well developed at HE providers than that addressing sexual misconduct. Action to address hate crime and harassment continues to have a lower profile and priority status and less progress is being made.
- Prevention of harassment and sexual misconduct came up as a key area where there are barriers to progress being made and providers want to see more research, guidance and good practice sharing about ‘upstream activities that work’.
- There is also a lack of standardisation across providers in responding to misconduct, including in appropriate approaches to investigations and disciplinary processes, outcomes and sanctions for non-compliance used, as well as in levels of information sharing.
- Reporting and disciplinary procedures are often considered overly bureaucratic, lengthy and emotionally draining for students, which may be inhibiting reporting as experiences are shared. There are also particular issues for marginalised groups and for students at smaller providers, where making disclosures and reports can be challenging.
Strategic change needed
Our overall assessment from the evaluation is that the OfS’ statement of expectations has been a useful intervention in maintaining momentum and focus on issues of harassment and sexual misconduct in the sector, and consequentially further progress has been made.
The main focus of the statement is to set out the baseline for what policies, systems and processes are needed. Crucially though, even where appropriate policies, systems and processes are in place, this is not always matched by willingness by providers to be transparent and proactively encourage their students to report incidents through awareness-raising campaigns and information-sharing, especially about outcomes of disclosures, reports and disciplinary proceedings.
The key ‘take away’ message is that the position and progress being made is highly variable in the sector, with some examples of excellent practice, but also some very poor practice which could be improved significantly. This variability speaks most loudly to the need for further interventions to drive change. There is also wide recognition of the limitations of the current voluntary system. Therefore, our report recommends that the OfS makes prevention of and response to harassment and sexual misconduct a mandatory duty and part of the regulatory framework.
Clearly further research and sector wide data are also needed to better understand and inform efforts to address these issues. Our report also recommends that OfS conducts a national prevalence survey of student experiences of initially sexual misconduct in HE, and later other forms of harassment, to provide a robust evidence base to help inform and evaluate further actions in this area at national and institutional level.
Moreover, we suggest that a well-articulated overarching vision for the sector is needed, and a national approach taken to help communicate this broadly. Further opportunities are also needed to foster sharing and embedding of good practice to help standardise aspects of the prevention and response approaches.
Our conclusion is that the statement of expectations has not been a sufficient catalyst for change in its current form and that further change is necessary. However, there is unlikely to be a single intervention or initiative that is a ‘silver bullet’ that will solve all the issues detailed more fully in our report so change needs to be multi-layered. Therefore, we have made multiple recommendations for the OfS, other sector bodies and individual providers, and these along with much more detail on the findings are set out in our evaluation report.
Note of thanks
The SUMS evaluation team would like to thank everyone who contributed their time and ideas so generously to the consultation for this evaluation, especially the members of our Expert Group, and all the practitioners and student campaigners working to tackle issues of harassment and sexual misconduct in higher education.
Notes
Helen Baird led the independent evaluation of the initial impact of the statement of expectations and is lead author of the report. Helen also led Advance HE’s evaluation of the OfS’ safeguarding students Catalyst Fund projects during 2017-19 and was lead author of the Final Summative Evaluation Report. She also led the study for Universities UK in 2017 and authored the report Changing the Culture: One year on.
With expert input from Professor Graham Towl, Professor of Psychology at Durham University provided subject matter expertise to the evaluation. He is a widely acknowledged sector expert in the policy context and practical requirements for addressing sexual violence at universities and has written extensively on the topic.