Staff and student relationships policy

1.1. The purpose of this policy is to:

• Communicate the University’s commitment to encouraging positive professional relationships between students and staff members, whilst protecting students from the harm that may result from the power imbalances that can arise from relationships that transgress the bounds of professional conduct.
• Communicate the University’s position and expectations in respect of consensual relationships between students and staff members with professional responsibility for them. 
• Provide guidance on how such relationships that predate the introduction of this policy and/or were in existence before the staff member had professional responsibility for a student should be managed.

2.1. This policy statement applies to:

• All individuals (referred to collectively as ‘members of staff’ in the context of this policy, regardless of their contractual relationship with the University) working on University premises or in a hybrid capacity, whether under a formal contract of employment; as a casual paid worker; on a sub-contracted or self-employed basis; as an agency worker; as an academic visitor; or any other individual to whom the University offers any of the privileges or facilities normally available to its employees, whether remunerated or not.  
• All members of staff working or acting on the University’s behalf, or otherwise representing the University, away from University premises, e.g. at sporting events or in the capacity of ‘flying faculty’.
• All students, meaning any individual studying a course at any level and provided in any manner or form by, or on behalf of, the University; or applicants and offer holders for such courses. It is also inclusive of visiting or exchange students, and all students who are registered for a course, even if their status is suspended.

2.2. Where a student undertakes employment within the University and, in that role, has academic or pastoral responsibilities for other students, this policy will apply to them as a staff member in the context of that employment. 

2.3. This policy applies to consensual intimate and close personal relationships between a student and a staff member, where the staff member has direct or indirect academic or professional responsibilities in relation to that student, as defined in paragraphs 4.5. and 4.6. 

2.4. It does not seek to prevent consensual relationships where no such responsibilities exist, but staff members are encouraged to carefully consider the potential consequences of entering into such a relationship. The responsibility for maintaining safe and professional boundaries always rests with the staff member.

2.5. Students studying through a partnership agreement with another institution may also be subject to the policies and procedures of the partner institution. Details about local practices will be set out in their Partner Handbook.

3.1. Oxford Brookes University recognises that positive professional relationships between staff and students are crucial to a student’s educational growth and wellbeing, and should be encouraged.

3.2. The University is also committed to maintaining high professional and ethical standards. Intimate or close personal relationships between students and staff with responsibility for them can lead to actual or perceived conflicts of interest and power imbalances. Such relationships can harm student welfare, undermine confidence in the academic process and pose risks to both the staff member and the University as a whole.

3.3. The University takes a zero tolerance approach to harassment and sexual misconduct. This policy concerns consensual relationships between members of staff and students; non-consensual behaviour (or allegations of behaviour where consent has been put into doubt) is covered by the University’s Anti-Harassment and Discrimination Policy.

4.1. Abuse of power means a situation where a staff member with professional responsibility for a student uses their position of power in an unacceptable manner, whether consciously or not. This may include, but is not limited to, grooming, manipulation, coercion and pressuring others to engage in behaviour they do not feel comfortable with. Examples of detrimental and favourable treatment of students that may occur in the context of intimate or close personal relationships are provided in Appendix A.

4.2. An intimate personal relationship is a relationship with one or more students that involves one or more of the following elements, whether online or in person:

4.2.1. Physical intimacy, including isolated or repeated sexual activity; or

4.2.2. Romantic or emotional intimacy.

Emotional intimacy may be formed through grooming behaviours, which could result in, or constitute, an abuse of power. However, reference to ‘emotional intimacy’ should not prevent a member of staff from engaging compassionately and considerately with a student on a professional basis, for example, when engaging with students in distress.

4.3. Close personal relationships exclude intimate relationships but means a relationship where the nature, content, emotional involvement and/or frequency of interactions and/or communications between a staff member and a student transgress the boundaries of professional conduct, or may be reasonably perceived to do so. This includes interactions that take place in digital spaces. Further guidance on identifying close personal relationships and professional conduct is in Appendix B.

4.4. Excluded relationships means any ongoing intimate or close personal relationship with one or more students that:

• Existed before the policy commencement date and that remains in existence; or
• Existed before the date from which the staff member had any direct or indirect responsibilities in relation to that student.

4.5. Direct responsibility for a student is defined widely and includes any responsibility that can influence a student's education or wellbeing, including teaching, professional, pastoral or administrative responsibilities whether temporary or permanent and whether formally conferred on or voluntarily assumed by the staff member. It includes but is not limited to lecturing, teaching classes or seminars, overseeing projects or fieldwork, supervising, and setting and/or marking examinations or other assessments of any type. It also includes acting as a mentor, counsellor, sports coach, fitness and wellness practitioner or other pastoral role and making decisions over internships or work placements. There is further guidance in Appendix A.

4.6. Indirect responsibility for a student is where a staff member has an indirect ability to influence a student's academic experience, progression or wellbeing, whether on a temporary or permanent basis, and whether formally conferred on or voluntarily assumed by the staff member. This might particularly be the case for senior members of staff. There is further guidance in Appendix A.

4.7. A consensual relationship is a relationship between individuals who freely and actively agree to participate in that relationship. Giving consent is defined as agreeing and giving permission to interact with another person in any way that would impact on the personal boundaries of either party and is not exclusive to sexual consent.

5.1. To protect the welfare of students, and in the best interests of staff:

• With the exception of excluded relationships, staff members are prohibited from pursuing or entering into an intimate personal relationship with one or more students for whom they have direct or indirect academic or professional responsibilities. 
• With the exception of excluded relationships, staff members are prohibited from pursuing or entering into any other close personal relationship that transgresses the boundaries of professional conduct with one or more students for whom they have direct or indirect academic or professional responsibilities.

5.2. Any breach by a staff member will result in the University taking appropriate steps in line with its disciplinary procedure, which may result in action up to and including dismissal of the staff member. The consequences of a policy breach will be appropriate and proportionate to the seriousness of the conduct that has taken place. 

5.3. In the rare circumstances where this policy is breached unintentionally, for example where a staff member is unaware that the other party is a student and had no reasonable basis to suspect it, the staff member should inform their line manager or link Strategic People Partner as soon as they become aware of the situation. 

5.4. There will be no disciplinary consequences for a student involved in a prohibited relationship or who fails to disclose an existing relationship unless another policy has been breached. Inappropriate behaviour by a student towards a member of staff or another student that amounts to sexual misconduct, physical misconduct, abusive behaviour, or otherwise breaches the University’s Anti-Harassment and Discrimination policy and/or Student Conduct Regulations, may lead to action being taken under the Student Conduct Procedure.

5.5. Members of staff must never enter into an intimate relationship with a student or any other person under eighteen years of age or with a student who is an ‘Adult at Risk’, irrespective of whether the member of staff has any responsibility for that person. Staff are reminded that intimate relationships involving students (including applicants or offer-holders) under the age of eighteen where the staff member is in a position of trust or where the student is an adult at risk could fall within the scope of the Sexual Offences Act 2003.

5.6. Anyone suspecting a member of staff of acting inappropriately towards a student or any other person under the age of eighteen or an adult at risk should refer to the Safeguarding of Children and Adults at Risk Policy and contact the Designated Safeguarding Officer, who may contact the Local Authority Designated Officer and/or the Police.

5.7. In cases where a criminal offence may have been committed, the University may also have a responsibility to report the matter to the Police. Such instances will include, but are not limited to, sexual violence, grooming or domestic abuse. If an incident is reported through the University’s procedures, this does not impact an individual's right to also report a matter to the Police. 

5.8. Where an intimate or close personal relationship exists before a staff member has academic or professional responsibilities in relation to that student, it is the responsibility of the member of staff to inform their line manager or link Strategic People Partner, in order that appropriate alternative measures can be taken. For information on this process refer to Appendix C. 

5.9. Where an intimate or close personal relationship between a staff member and student was in existence before the introduction of the policy and remains in existence it is the responsibility of the member of staff to inform their line manager or link Strategic People Partner so that an assessment can be made of any actual or perceived conflict of interest and/or actual or potential abuse of power. For information on this process refer to Appendix C. 

5.10. Whilst not falling directly under the remit of this policy, any instance where a staff member has responsibility for a student with whom they have a relationship which might objectively be viewed as representing a conflict of interest (e.g. the student is a familial member or the child of a friend or professional contact) should also be reported using this process so that any actual or perceived conflicts of interest can be appropriately managed. The staff member should also refer to the University’s Conflict of Interest Policy.  

5.11. If a member of staff is unsure whether a relationship with a student should be disclosed under this policy, the member of staff should disclose it.

5.12. When taking steps to manage actual or potential conflicts of interest and/or actual or potential abuse of power that arise in an existing intimate personal relationship, the University will take all reasonable steps to ensure that a student involved in a relationship is not disadvantaged.

6.1. All members of staff have a responsibility to ensure that they are aware of and understand this policy. They must disclose any required relationship in accordance with the policy and act in compliance at all times. 

6.2. Any member of staff with responsibility for engaging and / or managing relationships with a third party, including, but not limited to, visiting industrial fellows, visiting research fellows, external examiners, affiliates, external consultants and temporary agency staff, are responsible for ensuring that the third party is made aware of the policy where they may have direct or indirect responsibility for a student.

6.3. Line managers are responsible for ensuring that their team members are aware of the policy and any amendments made to it, and for familiarising themselves with the procedures and available sources of support. They are also responsible for reporting any disclosures to their Head of School/Directorate. 

6.4. Heads of Schools and Directorates are responsible for ensuring that up-to-date records of declarations and conflicts of interest are maintained. With support from the People Directorate, they should periodically review disclosures relating to the policy and any resulting protective actions. 

6.5. The People Directorate are responsible for ensuring that this policy is maintained, available for all employees to view, and that appropriate supplementary guidance or training for staff is provided to support its implementation. They are also responsible for ensuring that appropriate support is available for staff members should a concern related to the policy be raised.*

6.6. The Academic and Student Administration Directorate (ASA) are responsible for providing advice to and support for students relating to this policy. 

6.7. All roles involved in providing direct guidance and support to members of staff and students are responsible for ensuring that information is handled confidentially. Further information is set out in section 8.

6.8. The Directorate of Financial and Legal Services, Directorate of Sport and Active Wellness and Estates and Campus Services are responsible for ensuring that alignment with this policy is embedded into procurement procedures relating to service partners or contractors operating on University premises, and for ensuring that this policy is enacted through ongoing contract relationship management. 

6.9. Deputy Pro-Vice Chancellors are responsible for ensuring that alignment with this policy is embedded into the establishment and ongoing management of educational partnership agreements and for ensuring that appropriate procedures for the management of this policy are in place.

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*Concerns may be raised via the Resolving Grievances at Work Policy

7.1. Concerns raised and information disclosed under this policy should be treated in confidence by all parties as far as that is reasonably possible and consistent with safeguarding the welfare of students and staff. Information will only be shared on a need-to-know basis with members of staff who may be responsible for any required actions.   

7.2. Information about an intimate or close personal relationship between a member of staff and a student may be placed on the member of staff’s personnel file. Records will be treated as confidential and will not be kept longer than necessary in accordance with the General Data Protection Regulations (GDPR) and the University’s Retention Schedule.

7.3. Communications regarding measures put in place as a result of this policy should, as far as possible, be non-judgmental, limited to essential facts, and not include details of the situation that gave rise to them.

General documents 

• Conflict of Interest Policy
  Policy outlining the University's duty to prevent conflicts of interest.
• Anti-Harassment and Discrimination Policy
  Policy outlining the rights and responsibilities that all members of the University have in relation to working, studying and participating in University life in an environment free from discrimination, harassment, bullying and victimisation. 
• Data Protection 
  Policy detailing the rights and responsibilities that all members of the University have in relation to data protection. 
• Safeguarding of Children and Adults at Risk Policy
  Policy outlining the roles and responsibilities for safeguarding. 
• Whistleblowing (Public Interest Disclosure) Policy
  Policy outlining the means by which individuals who have a reasonable belief that there are significant matters of public interest that are causing concerns can report them and ensure that they are appropriately considered 

Documents for staff 

• Employment of relatives' guidance 
  Guidance on the employment of relatives and other people with close relationships to existing employees.
• Code of Conduct for Staff
  Framework outlining general expectations in relation to staff conduct including probity, conflict of interests and behaviour. The Anti-Harassment and Discrimination Policy forms part of this framework and expands on the Code of Conduct to outline the University’s expectations of conduct specific to this area 
• Resolving Grievances at Work Policy
  Document setting out the policy for raising a grievance. 
• Staff Disciplinary Procedure
  Document setting out the procedure that will be invoked if staff do not meet expected standards of behaviour

Documents for students

• Brookes Behaviour Policy
  Document detailing expectations for student behaviour. The Anti-Harassment and Discrimination Policy forms part of this framework and expands on this document to outline the University’s expectations of conduct specific to this area.
• Student Conduct Procedure
  Document setting out the procedure that will be invoked if students do not meet expected standards of behaviour

Related Legislation 

Relevant legislation includes:

• Care Act 2014
• Domestic Abuse Act 2021
• Equality Act 2010
• Sexual Offences Act 2003 
• The Data Protection Act 2018
• Worker Protection (Amendment of Equality Act 2010) Act 2023

This Appendix is intended to provide further guidance on the definitions listed in section 4 of the policy. It provides indicative examples of the role types, behaviours and activities that fall under the scope of this policy. They are not intended to represent an exhaustive list and recognise that staff and student roles may change or develop over time. 

It should be emphasised that a staff member who fulfils their role in a professional manner would not be considered in contravention of this policy.

Examples of roles subject to the policy that are considered to have direct responsibility (4.5) for a student include: 

• Any role involving a direct supervisory or teaching relationship, such as lecturers, or dissertation or project supervisors.
• Any role involving direct responsibility for a student’s personal welfare, such as providing counselling or chaplaincy, acting as a mentor or academic advisor, or offering pastoral care, such as Hall Wardens and Residence Assistants. 
• Any member of staff who has a mentoring or ongoing administrative responsibility for a student such as Student Support Coordinators, or those working in Student Finance or the Careers Centre.
• Any member of staff involved in the admission or selection of applicants or offer holders. 
• Any staff member involved in the assessment or progression of students, including external examiners.
• Any member of staff involved in the management or support of student complaint processes, or who may be involved in making decisions relating to these.
• Any member of staff involved in the organisation or selection of work placements.
• Security staff.
• Staff members known as ‘flying faculty’, whether remunerated or not, who are responsible for the selection, progression and pastoral support for students in certain international partnerships.
• Industry experts, whether remunerated or not, such as Visiting Industrial Fellows, Entrepreneurs in Residence and Practice Educators. 
• Sports coaches, fitness and wellness practitioners.

Examples of roles subject to the policy that are considered to have indirect responsibility (4.6) for a student include:

• A Head of School, Faculty or Directorate who has supervisory responsibility for all students. 
• Senior members of staff with responsibility or oversight of wider institutional strategy, processes and delivery, for example, the Vice-Chancellor and other members of VCG.
• Members of the Board of Governors.

Examples of behaviours and activities that staff might participate in but which would not constitute a breach of this policy when carried out in a professional manner are:

• Offering advice and/or mentoring.
• Providing counselling or one-to-one pastoral support.
• Project or dissertation supervision.
• A staff member having necessary, appropriate physical contact with a student as a part of their academic or professional role, e.g. demonstrating physiotherapy techniques or providing personal fitness training. 
• A senior PhD student or a post-doctoral researcher assisting a more junior PhD student to safely use equipment, learn techniques or to conduct experiments.
• PhD students and post-doctoral researchers in the same research group and/or who are pursuing research in related areas who liaise closely about progress and best practice and/or share accommodation and socialise together.
• Friendships between PhD students and post-doctoral researchers where the member of staff has no responsibility for that student’s academic progress, teaching, supervision, welfare or for any administrative decisions that affect them.

Examples of detrimental treatment of students that could occur in the context of intimate or close personal relationships are:

• Not receiving a positive review or reference, or receiving a negative review or reference.
• Unfavourable treatment in academic assessments, for example, less access to support or feedback, less opportunity for extensions, lower grades or marks.
• Not receiving funding for research.
• Restricting access to resources and/or individuals. 
• Restricting participation in aspects of a student’s education.
• Overlooking a student for additional opportunities, such as attending an industry event or conference.

Where a student feels they have experienced detrimental treatment as a result of an intimate or close personal relationship, they may wish to refer to the Anti-Harassment and Discrimination Policy. 

Examples of favourable treatment of students that could occur in the context of intimate or close personal relationships are:

• Receiving a positive review or reference.
• Favourable treatment on academic assessments, for example greater access to support or feedback, more opportunity for extensions, higher grades or marks.
• Being promised access to funding and resources. 
• Being promised introductions to others who could advance their academic or professional career.
• Letting significant or multiple mistakes pass or using their position of power to cover up mistakes.
• Offering a lighter workload, such as requiring the student to deliver fewer presentations or assignments.
• Offering greater flexibility in terms of absences, lateness or group contributions.

Adult at risk is defined in accordance with the Care Act 2014 as someone aged 18 years or over who may be in need of community care services by reason of mental or other disability, age or illness; and who is or may be unable to take care of themselves, or unable to protect themselves against significant harm or exploitation. For more information see the Policy for Safeguarding of Children and Adults at Risk.

An interest is defined in accordance with the Conflict of Interest Policy as anything that can objectively be seen as prejudicing a person’s impartiality in their judgement, choices or behaviour. Decisions taken for, by and at the University should not be influenced by any factor beyond the best interests of the University.

Grooming can take place online or in-person and is when a person builds a relationship with a child, young person or an adult who is at risk so they can abuse them and manipulate them into doing things. The abuse is usually sexual or financial, but it can also include other illegal acts.

Professional conduct is defined for the purposes of this policy as acting with integrity and respect towards staff and students, in line with the values expected of staff as outlined in the Staff Code of Conduct.

Sexual misconduct describes a range of conduct or attempted conduct of a sexual nature including sexual assault, sexual harassment, stalking, voyeurism, revenge porn and any other conduct of a sexual nature that is non-consensual or has the purpose or effect of threatening, intimidating, undermining, humiliating or coercing a person. 

It includes but is not limited to:

• Sexual harassment as defined by section 26(2) of the Equality Act 2010;
• Assault as defined by the Sexual Offences Act 2003;
• Rape as defined by the Sexual Offences Act 2003

Close personal relationships are defined in Section 4; however, to aid the identification of close personal relationships a staff member should also consider:

• Any form of dependence, whether emotional, practical, financial or otherwise, and whether the student appears dependent on the member of staff or vice versa; and/or
• Favouritism towards any student, which might include, for example, circumstances where a student is treated in a way that is exclusive or exceptional.

Even in cases that are not covered by this policy, i.e. where a staff member does not have and is not likely to have direct or indirect academic or professional responsibility for a student, staff are strongly encouraged to be cautious about embarking on an intimate or close personal relationship with any student. Such relationships can run into difficulties and give rise to formal complaints or concerns rooted in real or perceived inequalities of power, accusations of bias or exploitation and questions about the nature of consent. The risks of such complaints or concerns are likely to be heightened where there is a large age difference between the staff member and the student; where a student is undertaking their first degree after leaving school; and/or when a student is more vulnerable because of certain disabilities or health conditions.

If in doubt, the best course is to declare a relationship, or any interaction with a student that is of concern, so that appropriate measures to protect both the student and the member of staff can be considered.

Additional guidance 

The following advice has been developed to enable policy interpretation and encourage best practice between staff and students; however, breaches may not in themselves be considered a contravention of the policy. 

It is strongly recommended that staff should:

Communications 

• Wherever possible, communicate with students via University accounts linked to their role; for example, using University email addresses, telephone numbers and/or Google Meets. 
• Give careful consideration before sharing personal mobile phone numbers, particularly with an undergraduate student. It is recognised that sometimes this may be unavoidable, for example, when arranging and taking part in conferences or field trips. Sharing personal social media accounts in this context should also be avoided.
• Keep in mind that any communications with students and/or colleagues about a particular student may be disclosed to that student or their legal representative under data protection law.
• Consider communication style and language to maintain professional boundaries. 
• Be mindful when using social media; whilst this may provide a helpful platform on which staff can share, collaborate and network, it may also blur professional boundaries. Both the University’s Code of Conduct and the advice in this guidance apply to any form of media.*

Pastoral Support 

• Ensure students with support needs are referred to a relevant University support service and limit roles in providing personal support to a student where this is not part of official employment duties.
• Not seek personal information from a student unless required for a University process, such as a counselling referral, medical information required for special consideration, or personal circumstances information required as part of an academic progress process. Any information obtained this way must be stored and retained in accordance with local and institutional data protection requirements.

Spaces 

• Ensure spaces are designed to remind that this is a formal place of work or study.
• Hold meetings with students in appropriate spaces on campus.
• Not invite a student to their private home, room or vehicle, especially if others are not present, or visit a student in their home or room, including while at conferences, on overseas trips or on a placement. 
• Consider and seek advice as to whether it is appropriate to invite students to a social event that is not part of usual student engagement activity, especially where this is outside of usual working hours and/or when alcohol is present.

Boundaries 

• Not give undue special attention to a particular student over another or demonstrate any behaviour that could be interpreted as grooming. 
• Avoid accepting gifts from a student, other than low value items, or any gift of a personal nature and giving gifts, other than low value items that are solely for academic purposes, e.g. a published academic text.
• Not engage students to work in their home or in a personal capacity, for example, dog walking, child minding or house sitting.
• Not purchase transactional sex or sexual imagery from any student.
• Be mindful that situations involving alcohol may lead to impaired judgment about appropriate behaviour and boundaries.

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* Online behaviour may also be subject to the IT Acceptable Use Policy

All declarations of intimate or close personal relationships are to be made as soon as reasonably practicable and always within one week in the case of physical intimacy (4.2.1) or one month of the commencement of the relationship, or of the staff member becoming responsible for the student.

In the rare circumstances where this policy is breached unintentionally, for example, where a staff member is unaware the other party is a student and had no reasonable basis to suspect it, the staff member should inform their line manager or link Strategic People Partner as soon as they become aware of the situation. If a member of staff is unsure whether a relationship with a student should be disclosed under this policy, the member of staff should disclose it.

The purpose of making a disclosure is to enable steps to be taken to appropriately manage any actual or perceived conflicts of interest that may arise from a relationship between a staff member and a student. It is not intended to lead to punitive measures. All parties involved in making, receiving and responding to disclosures are reminded that maintaining confidentiality and remaining non-judgemental is important in all circumstances, and that every effort should be made to avoid potentially harmful consequences for the staff member and / or student. They should be mindful that the staff member may find it difficult to make the disclosure, for example, if they fear personal persecution, incrimination or other harmful consequences. There may be particular sensitivities around LGBTQ+ relationships where there is a risk of ‘outing’ individuals or putting them at increased risk of persecution in legal contexts outside of the United Kingdom. 

The staff member is responsible for completing the Declaration Form, but students may also choose to complete it. 

If a staff member is unsure whether the nature of the relationship warrants disclosure or would like more information on the process, they should contact their link People Manager for informal advice. 

• Step 1: Staff should initiate a verbal conversation with their line manager to disclose the relationship. If a staff member does not wish to notify their line manager, they can omit this step and proceed directly to completing the Declaration Form. 
• Step 2: The line manager directs the staff member to complete a centralised form to report the relationship. 
• Step 3: The staff member completes the form, which is reviewed by their link Strategic People Partner to determine whether the nature of the relationship requires any measures to be put in place. The SPP will notify the staff member of their decision. If the SPP determines that measures may be needed, they will share relevant details with the staff member’s line manager (or, exceptionally, their Head of School/Directorate) at this stage. Any information shared will be kept to a minimum and treated as confidential but it may not be possible to avoid disclosing sensitive personal information. 
• Step 4: The line manager (or Head of School/Directorate) will consult with the parties on the actions that will be required to remove any potential or actual conflict of interest and/or potential or actual abuse of power. This may be done with the support of a relevant member of the People Directorate. This will be sent to the Strategic People Partner to be documented and copies provided to the relevant parties.
• Step 5: Any unresolved matter may be referred to the Chief People Officer (or Academic Registrar and Director of Academic and Student Administration when relevant). 

If changes are required to any agreed actions to remove any actual or potential conflict of interest or abuse of power, it is the responsibility of the staff member to notify their line manager. 

In putting in place measures to manage any actual or potential conflict of interest and/or abuse of power, the line manager or Head of School/Directorate will consider the following:

• Whether the relationship is considered an ‘excluded relationship’ (4.4)
• Whether the relationship has been disclosed within the required timeframe (Appendix C)

The line manager or Head of School/Directorate may consider the following:

• Any known vulnerability of the student or staff member;
• The student’s or colleague’s personal circumstances at the time;
• Whether there is a supervision or teaching arrangement in place at the time;
• The circumstances of the student when the close personal relationship commenced or was initiated (for example, if the personal relationship existed prior to this policy’s commencement date);
• Any family, kinship or other relationships;
• The nature of the two individuals’ contact in study, research or employment;
• The potential for the staff member to influence the academic progress and outcomes or career progression of the student; and
• The extent of the power imbalance between the two individuals.

A non exhaustive list of example measures that might be put into place to manage any conflict of interest or abuse of power are:

• Changes to project, research and/or dissertation supervision arrangements; 
• Changes to teaching and/or lecturing arrangements; 
• Changes to interview, selection and/or examination arrangements; 
• Changes to counselling, mentoring, academic advising and/or other pastoral support arrangements; 
• Changes to the location, mode or reporting line of work/studying arrangements. 

Both the staff member and student will be notified of any conflict of interest management measures put in place. 

The Staff and Student Relationship Declaration Form is linked here.

The University is committed to ensuring the welfare of and providing support for its staff and students and the following support resources are available.

Details of help for any member of staff or student who has been subjected to sexual misconduct, including sexual assault or rape, is available through the University’s website. This includes details of services provided by both the University and external specialist organisations.

Information about sources of staff support is available on the University wellbeing pages and includes the University Employee Assistance Programme, Occupational Health Service as well as external support for those who have experienced sexual assault. 

Members of staff can also access support from their line manager, the People Directorate, a Staff Harassment Advisor or Trade Unions.

Support for students is detailed on the student support webpages and includes the Student Welfare and Support Advice Team, Student Counselling Service, Independent Sexual Violence Advisor (ISVA), Chaplaincy and Brookes Union Advice Service. 

Oxford Brookes University (OBU) as the Data Controller is committed to protecting and respecting your privacy. This Privacy Notice explains how we will process: collect, use, and share your Personal Data (Data), and your rights in relation to the data that we hold.

This Privacy Notice applies to the use of a Google form to collect data on staff-student relationships in accordance with the Staff Student Relationship Policy. 

1. Data We Collect 

Personal Data:

The Google Form will collect Personal Data related to:

• Staff name 
• Line manager’s name 
• Job title and location
• Staff Identification Number
• Student name 
• Student’s school of study

Special Category Data:

We will collect data related to protected characteristics which may include:

• Sex life 
• Sexual orientation
• Marriage or Civil Partnership
• Pregnancy and maternity 

The form includes a free text box, in which staff may voluntarily disclosure data related to additional protected characteristics, this may include:

• Age 
• Disability or long-term health condition 
• Ethnicity
• Sex
• Trans Status or Gender reassignment
• Religion or belief
• Caring Responsibilities
• Pregnancy and Maternity 

There is potential that the data will include information on criminal offence data and will be managed according to UK-GDPR (2018), Article 10. 

2. How We Use Your Data 

We will use your data to:

• Protect students and staff from any actual or potential conflicts of interest and/or abuses of power. 
• Monitor the effectiveness of the Student Staff Relationship Policy. 
• Consider whether any additional measures are required to reduce and/or remove any actual or potential conflicts of interest and/or abuses of power between staff and students. 
• Consider whether a relationship should be considered an ‘excluded relationship’ as defined by the Student Staff Relationship Policy (Section 4).
• In some cases, where relevant policy has been breached, we may be required to initiate the Disciplinary Procedure or appropriate People Directorate policies or procedures in order to investigate the matter reported. When you have submitted a report disclosing your details, we will inform you of what we are doing.
• In some cases, where the information in your report highlights a potential risk to the health and safety of you or another person, we may notify relevant external services such as the Police or Local Safeguarding Officer. 
• If OBU asks you for sensitive data such as; ethnicity, political opinions, religious or philosophical beliefs, trade-union membership, data concerning health or sexual life, genetic/biometric data or criminal records OBU will use these data because:
  • You have given Oxford Brookes University Explicit Consent to do so
  • The University needs to use this data to protect you or others from the risk of harm where consent cannot be given

3. Sharing Your Data With 

We will share your data with:

Relevant members of the People Directorate, your line-manager, any relevant students identified within the report.  

We may share your data with:

In some cases, the data may also be shared with the Head of School or Directorate, and in exceptional circumstances with the Chief People Officer (or Academic Registrar and Director of Academic and Student Administration when relevant). 

Your personally identifiable data will not be disclosed to any third parties without your written consent, unless the information in your report potentially highlights a  significant risk to a person’s health and safety. In this case, we may share the information in your report with the University’s Security Services Team, Student Investigation and Resolutions Team, People Directorate, Student Welfare Team and/or external services such as the Police or Local Safeguarding Officer. 

Anonymised data related to the number of disclosures per year may be published as part of annual reporting. 

4. Legal Basis for Processing 

We process your personal data based on:

• Consent under Art., 6(1)(a) of the UK GDPR 2018.
• Legal obligation under Art., 6(1)(c) of the UK GDPR 2018.
• Vital interest under Art., 6(1)(d) of the UK GDPR 2018.

And special category under

• Art., 9(2)(a), UK GDPR 2018.
• Art., 9(2)(c), UK GDPR 2018.
• Art., 9(2)(g), UK GDPR 2018.

5. Will my data be transferred outside of the EEA?

No.

6. Are there any consequences of not providing the requested data?

No.

7. Will there be any automated decision making using my data?

No. 

8. Data Security and Storage

We are committed to ensuring the security of your personal data. Here at the OBU we implement a variety of security measures to maintain the safety of your personal information. These measures include:

• Encryption: We use encryption to protect sensitive data during transmission and storage.
• Access Controls: Access to personal data is restricted to authorised personnel only, based on their role and responsibilities.
• Regular Audits: We conduct regular audits and assessments of our data protection practices to ensure compliance with relevant laws and regulations.
• Secure Storage: Personal data is stored in secure facilities with appropriate physical and technical safeguards.
• Incident Response: We have procedures in place to respond to data breaches or security incidents promptly and effectively.

9. Data Retention

All data will be stored for up to 6 years in accordance with the Oxford Brookes retention schedule 6.9.1.

10. What rights do I have regarding my personal data?

• You have the right to be informed.

• You have the right of access to your data.
• You have the right to correct data if it is wrong.
• You have the right to ask for your data to be deleted.
• You have the right to restrict use of the data we hold.
• You have the right to data portability.
• the right to object to OBU using your data.
• You have rights in relation to using your data automated decision making and profiling.

If you have questions or concerns about our use of your personal information?  Please contact Oxford Brookes at info.sec@brookes.ac.uk to ask for guidance or make a complaint. 

You can independently contact the independent Oxford Brookes Data Protection Officer at BrookesDPO@brookes.ac.uk. 

If you are unhappy with how we have processed your personal data, you can also complain directly to the ICO as shown below.

The ICO’s address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

• Helpline number: +44 (0) 303 123 1113
• ICO website