Policy category: Falmouth Policies

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Policy 017: FINANCE 

1. PURPOSE 

1.1 This policy outlines the arrangements for collection of student fees and charges. It covers sanctions which may be used in relation to students with overdue debts and is designed to ensure that all students are treated fairly, equitably and reasonably. Where arrangements apply specifically to international students, this will be made explicit in the paragraph wording. 

1.2 It is the intention of this Policy to clearly outline fee liability for all students at ACM Guildford, ACM Birmingham and ACM London. 

1.3 Students studying on short courses at ACM are required to pay the fees in full seven days prior to the commencement of their studies. No refund will be applicable should a student withdraw. 

1.4 ACM follows the guidance of Student Finance England, which administers student loans on behalf of the Government. Information on this can be found on the Student Finance England website: https://www.practitioners.slc.co.uk/policy/  

2. POLICY DETAILS 

Tuition fee charges 

2.1 The amount that you will pay in respect of tuition fees is dependent on the course and year of study that you attend during the academic year. 

2.2 Fees at ACM are set on an annual basis each autumn for the following academic year, based on Government policy. 

2.3 Tuition fees may increase for every new academic year for the duration of your course dependent on government policy and to take into account inflation linked to the retail price index and costs associated with delivery. Therefore, students may be charged different fees for subsequent years of their chosen programme of study. Any changes will be notified to students in a timely manner. 

2.4 Tuition fees for each year of study, payment methods and due dates are outlined in the Fee Schedules for each programme. 

2.5 Annual Tuition fees at ACM cover registration, first attempt tuition, and entrance to first attempt examinations. Note: the fees do not include those for graduation, which are payable to the awarding university, or any resit assessments or retake modules. Any study visits or additional activities are not covered by tuition fees. Any additional fees for any second attempt teaching or retakes, will be confirmed at the point of relevance but will be set based on the relevant course fee and period of attendance required. 

2.5 Annual Tuition fees at ACM cover registration, first attempt tuition and entrance to first attempt examinations. Note: the fees do not include those for graduation, which are payable to the awarding university, or any resit assessments or retake modules. Any study visits or additional activities are not covered by tuition fees. Any additional fees for any second attempt teaching or retakes, will be confirmed at the point of relevance but will be set based on the relevant course fee and period of attendance required. 

2.6 Once enrolled, students are responsible for the payment of tuition fees and any other associated charges, including any amounts due from third parties which are not paid. Failure to settle fees on time will mean that ACM will withdraw access to relevant learning facilities and this may ultimately lead to deregistration from the University in the case of unpaid tuition fees. 

2.7 ACM reserves the right to reassess any student’s tuition fee liability should new information come to light that may affect the original assessment. 

2.8 Should a student change Programme, Pathway, Modules or Level during the course of the year, a tuition fee review and relevant change of tuition fee charges may be incurred. 

Tuition Fee payment types. 

2.9 There are three tuition fee payment types: 

(a) Fully funded by student loan – a student loan is available to cover the full tuition   fee; 

(b) Part-funded by student loan, and part self-financing – student loan only covers 

      part of the tuition fee and student is self funding the remaining element. 

(c) Fully self-financing – student is not eligible for student loan, or opts to self-fund the full tuition fee. 

2.10 Students waiting for confirmation of funding from Student Finance England or equivalent will be classified as fully self-financing until confirmation of support is received. Students will be required to provide evidence that the loan application is in progress if funding is not in place at the start of the academic year. 

2.11 Students aged 18 and under on the start date of their programme, studying on an FE course should be entitled to full government funding of tuition if the eligibility criteria is met. Students that have not secured government funding or that are aged 19 and over on the start date of their programme, will become personally responsible for the payment of tuition, unless a specific government funding plan exists. 

Tuition Fee Liability 

2.12 Students (or their parents or legal guardians for those students under the age of 18) become liable for the payment of the Annual Tuition Fee 14 days after the course start date, or 14 days after enrolling onto the programme where enrolment takes place after the course start date, having signed the terms and conditions. 

2.13 ACM offers home students the facility to pay their full fee in instalments. Students must be aware of instalment payment dates, which are detailed on the Fee Schedule sent to each student following acceptance onto a programme of study. 

2.14 Even where fees are payable by a third party, students remain personally liable to ACM for fees notified to them. 

2.15 The overall fee liability is based on the annual course fee liability, not any instalment plan that may have been agreed. 

2.16 Where a home student opts to pay their fees in full by the single upfront fee payment deadline, students will be offered a 10% discount on the Annual Tuition Fee. The discount will be removed if third party funding is later secured and the refund of the initial payment is requested. The discount described in this paragraph only applies to home students. 

2.17 UK undergraduate and postgraduate students and students with Settled Status under the EU Settlement Scheme (EUSS) are responsible for ensuring that their application for financing from Student Finance England (SFE) or equivalent is made before the start of the academic year. Students must also ensure that any requests for further documentation and or information are complied with as soon as possible. 

2.18 If an employer or a third party organisation is paying the tuition fees, the student will need to provide evidence of this in writing in line with the payment deadlines above. A purchase order (as provided by your Sponsor) containing your details including your student ID and the value of your sponsors’ contribution should be emailed to studentfinance@acm.ac.uk 

2.19 ACM reserves the right to reject sponsorship purchase orders or letters if they are not original documents, do not contain the correct information, or if they are found not to be issued by a recognisable third party organisation. All invoices issued by ACM must be settled in full within 30 days. If invoices are not paid in accordance with these terms the debt will revert to the student. 

2.20 Fees paid by a relative or friend of the student is not considered to be a formal sponsorship. In this instance, the student will be considered to be self-financing. 

Fee Liability, Change of Circumstances and Withdrawal from Programme

2.21 Tuition fee charges are determined on the basis of enrolment status and not actual attendance. This means that if a student stops attending, but does not formally withdraw or interrupt, the student will be liable for tuition fees up until the point in time that they officially notify ACM or are de-registered by ACM. 

2.22 In order to officially withdraw or interrupt from a programme of study, the student must contact ACM to request a Change of Circumstance form, complete the form and submit it to registry@acm.ac.uk  In the absence of written notification of a change, the student shall be deemed to be enrolled and, as such, liable for the payment of tuition fees for the academic year. Further details on the Change of Circumstances procedure can be found in ACM’s Withdrawal, Interruption and Internal Transfer Policy. 

2.23 The fee schedule for the relevant academic year confirms a student’s individual fee liability based on the date of withdrawal or interruption. International students are required to pay each academic year’s fees in full prior to the start date of the relevant academic year. 

2.24 Where exceptional circumstances have arisen, ACM may review the fee liability for an individual student. Exceptional Circumstances would cover cases of bereavement, critical illness and other severe medical and social circumstances that would prevent a student being able to complete studies and benefit from the cost of education. 

2.25 In the matter of the recovery of the outstanding programme fees, ACM will consider each student on a case-by-case basis. The options which may be applied in each case are: 

• Fee remission, where students are permitted a part or full tuition fee waiver; 
• Charge for the full Annual Tuition fee for the current academic year; 
• Charge for the full Annual Tuition fee for all years of the program attended. 

2.26 Where payment has been made in excess of the tuition fee charged (including non-refundable deposits) the overpayment will not be refunded for an interrupting student. Any credit balance may be carried forward to be applied against future tuition fee charges. The credit may be carried forward for up to one academic year. 

2.27 When an interrupted student returns to study in the subsequent year, ACM will charge the student the relevant fee for that course and Year of Study for the relevant Academic year. This may result in a student incurring a higher or lower fee upon return. 

Fee waivers, Scholarships and Bursaries 

2.28 ACM offers fee waivers in the form of scholarships and bursaries. Details of these can be found on the ACM website or via separate communication. Please refer to the relevant terms and conditions. 

2.29 Applicants who successfully secured a fee waiver, scholarships or Bursary and leave the course early or defer entry will have the funding provided by ACM pro-rata for the period attended. 

Debt policy and procedures 

2.30 Failure to pay tuition fees or any other charges on time may result in various connected services including access to tutorials, rehearsal space/studio bookings, and career development services being withdrawn, and access to ACM buildings may be denied. 

2.31 ACM reserves the right to withhold award certificates and/or assessment results, where arrears of tuition fees exist. 

2.32 Students who are unable to pay any fees or charges by the appropriate due date are encouraged to contact studentfinance@acm.ac.uk  at the earliest opportunity, as help may be available. ACM will be sympathetic and assist where it can. However, the quality of teaching is dependent upon funding and so it must act to recover all outstanding debts. The Student Finance Team will be able to give advice on sources of funding available including Hardship loans. 

2.33 If your financial circumstances change after you start your course, then you may be able to agree to a non-standard instalment plan. To find out, contact the Student Finance team: 

• by email at studentfinance@acm.ac.uk
• by telephone on 01483 500804 

Please note that documentary evidence to support your request will be required before it can be considered. Please have this information to hand when contacting us. 

De-registration for non–payment of tuition fees 

2.34 Students who fail to pay their tuition fees, maintain an agreed payment plan or provide confirmation of sponsorship will be suspended at the end of learning week six. For students who fail to pay their tuition fee instalments in Term 2, suspension will take place at the end of the sixth teaching week in Term 2. For students who fail to pay their tuition fee instalments in Term 3, suspension will take place at the end of the sixth teaching week in Term 3. The option to pay by instalments, available at the start of the academic year, may no longer be available. 

2.35 Following suspension enacted for non-payment of tuition fees or for non-confirmation of sponsorship, ACM will start the de-registration process if no acceptable provisions have been made to secure funding, make payments or confirm sponsorship. Such provisions must be made within the six-week period following suspension for the de-registration process to be reviewed. Provisions must be evidenced and acceptable to ACM. It is the student’s responsibility to keep ACM informed of their funding status and of any provisions being made to secure funding or sponsorship. The option to pay by instalments, available at the start of the academic year, may no longer be available. 

2.36 Any student who has been de-registered will be liable for tuition fees up to the point of de-registration, as per paragraph 2.21 of this policy. 

Late payment charges 

2.37 Students who fail to pay their tuition fees or provide confirmation of sponsorship on or before payment deadlines will be subject to a £200.00 late payment charge. This late payment charge will be payable on each occurrence of default, including the first instalment. 

Financial Holds 

2.38 If you have a tuition fee debt that becomes overdue, holds will be applied to your student account automatically. Holds are designed to prevent access to certain facilities and services, depending on the age and value of the tuition fee debt. The hold types and their effects are as follows: 

Hold severity	Effects of holds
Overdue tuition fee debt Stage 1	There is a financial obligation to ACM that takes place within the first six weeks of enrolment, within the first six weeks of Term 2 or within the first six weeks of Term 3 (whichever shall apply with regard to the debt). Payment or proof of sponsorship must be provided. No restrictions are applied.
Overdue tuition fee debt Stage 2	You will be suspended from your programme at Week 6 of your enrolment, at the sixth week of Term 2 or at the sixth week of Term 3 (whichever shall apply with regard to the debt). You will not be permitted to attend lectures or campus, or engage with any assessment activities. You will not be permitted to attend extra-curricular activities and any additional privileges (e.g. student ambassadorship) will be revoked for the duration of the suspension. During this suspension you will not be able to re‐enrol, change modules or module components, or apply for a new programme. You will not be able to view your final assessment and grade results, and progressions and programme results.
Overdue tuition fee debt Stage 3	De-registration will take place at Week 12 of your enrolment, at the twelfth week of Term 2 or at the twelfth week of Term 3 (whichever shall apply to the debt). You will not be able to view your final assessment and grade results, and progressions and programme results. You will not be able to graduate if you have outstanding debts.

Returning students with debt 

2.39 Students with outstanding debts from a previous academic year may not be permitted to re-enrol or resume their studies. All debts should be paid in full ahead of the following academic year. 

External debt collection agencies 

2.40 ACM reserves the right to refer debt in respect of any alumni or ex-student to a county court and/or external debt collection agency for recovery. 

Refunds 

2.41 If a self-financing student has paid up front for the academic year and subsequently chooses to withdraw or interrupt, the student can claim for a refund of any fees paid ahead of the liability point. 

2.42 Refunds can only be applied for once the withdrawal process has been completed and any refund of tuition fees will take effect from the date the Change Request form is authorised. ACM’s Student Engagement or Student Finance team will confirm the new fee liability as part of this change process. 

2.43 Tuition fee refunds and other monies paid to ACM are only refunded to the individual or organisation that paid ACM originally. Refunds should be processed within 2 weeks of the request being received by ACM finance. 

2.44 Where fees have been paid by the Student Loan Company, any refunds due will be paid to the Student Loans Company thereby reducing the value of the loan secured by the individual student. 

2.45 ACM will confirm any fee changes to the Student Loans Company directly upon confirmation of a Change Request Form being submitted in writing. 

2.46 For the purposes of tuition fees, only monies paid to ACM will be refunded. Any scholarships or fee waivers awarded by ACM will be excluded from any refund. 

2.47 Refunds will not be made in cash or by banker’s draft. 

Anti-money laundering regulations 

2.48 ACM will not accept any payment from persons or organisations unless they relate to a valid charge, levied or impending. This is to comply with UK Money Laundering regulations. Any suspicious payments and or refund requests may be reported to the appropriate regulating body. 

2.49 ACM will not accept Tuition Fee payments in cash to ensure compliance with the UK Money Laundering regulations. 

Library Charges, Materials and Other Equipment 

2.50 Students using the Library and/or borrowing equipment of any type have an obligation to respect the rights of others by returning library and other equipment on time. To encourage this, fines are charged on items that are returned late and sanctions may be imposed for non-payment. 

Fee Complaints 

2.51 Students who wish to dispute a debt must submit their dispute within 21 days of receiving a request for payment. The dispute must be in writing and forwarded to studentfinance@acm.ac.uk  Please include attachments of any supporting evidence. Any fee complaint will be handled in line with ACM’s Student Complaints and Grievances Policy and Student Complaints and Grievances Procedure. 

3. POLICY SCOPE 

3.1 This Policy applies to students at ACM Guildford, ACM Birmingham and ACM London studying across all levels, less the exceptions outlined in 3.2 and 3.3 below. 

3.2 This Policy does not apply to students studying at Level 2 or Level 3 who are aged 18 or under on the start date of their programme, and are eligible for UK government funding for FE programmes. 

3.3 This Policy does not apply to students studying at Level 2 or Level 3 under an Educational Health Care Plan (EHCP) for which they are eligible for UK government funding. 

4. RELATED POLICIES 

• Withdrawal Interruption and Internal Transfer Policy 
• Refunds and Compensation Policy 
• Student Protection Plan 

5. POLICY OWNER 

5.1 This Policy is under the responsibility of the Academic Board. The responsible committee will ensure the cyclical review of this Policy is carried out under ACM’s Quality Assurance Framework. The Academic Board delegates operational responsibility of this Policy to ACM’s Finance and Registry departments. 

6. DOCUMENT HISTORY AND NEXT REVIEW 

Version	2.3
Approved on	01 September 2025
Approved by	Academic Board
Date of next review	August 2026

 

Download: 017 POL_017_Finance_202407

Policy_020: Data Access and Protection

1. Purpose and Scope

1.1 This policy describes how the Academy of Contemporary Music (ACM) meets its data protection obligations.

1.2  It is intended to explain in an open and accessible manner the provisions adopted by ACM to meet its data protection obligations.

1.3 This policy applies to staff, students, prospective students, alumni, and anyone else about whom ACM may have reason to collect and process data. It is designed to ensure their fair, lawful and equitable treatment in relation to the use of personal data kept by the ACM.

2. Policy Statement

Data Protection

2.1 The Academy of Contemporary Music (ACM) needs to obtain and process certain information about our students to allow us to register students, organise programmes, and to carry out other essential activities.

2.2 ACM has a need to obtain and use certain items of personal data in order to discharge our responsibilities and fulfil our obligations to educate and support our students, which could not be fulfilled without holding and using this personal data.

2.3 ACM holds and processes personal data for recruitment, admission, enrolment, the administration of programmes of study and student support and associated funding arrangements, monitoring student performance and attendance, supervision, assessment and examination, graduation, alumni relations, advisory, pastoral, health and safety, management, research, statistical and archival purposes.

The Six Principles

2.4  The General Data Protection Regulations (GDPR) ensures that Data Controllers treat data subjects and data items with an enhanced level of consideration in relating to ensuring the privacy and fair processing of the data it holds. ACM ensures that the following principles are embedded within our privacy operations:

1. Lawfulness, fairness and transparency:

Data is processed lawfully, fairly and in a transparent manner in relation to individuals.

2. Purpose limitations:

Data is collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;

3. Data minimisation:

Data held is adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

4. Accuracy:

Data is accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay.

5. Storage limitations:

Data kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals.

6. Integrity and confidentiality

Data is processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures

General Data Protection Regulation (GDPR)

2.5 The EU GDPR replaces the Data Protection Directive 95/46/EC and is designed to standardise data privacy laws across Europe, with the intention to protect and empower all EU citizens’ data privacy and to reshape the way organizations across the region approach data privacy.

2.6 The following Higher Education Statistics Agency (HESA) statutory data returns include personal data as defined in the DPA and GDPR:

• Alternative Provider student record;
• The Graduate Outcomes survey (first collection 2018/19)
• Staff record;
• Student contact details may be passed to survey contractors to carry out the National Student Survey (NSS) on behalf of government agencies.

The lawful basis under the DPA and the GDPR for collecting personal data for these returns is described in the relevant Collection Notice as required by GDPR Article 13.

Collection Notices

2.7 For the purposes of data protection legislation, ACM is a Data Controller and staff, students, prospective students, alumni and others about whom we collect and process information is a Data Subject. The DPA (Principle 1) and GDPR (Article 13) require data controllers to provide information to data subjects whose data is collected that identifies data controllers and describes their purposes for processing personal data, including transfers and disclosures to other data controllers.

2.8 HESA’s Collection Notices provide this information for students, staff and graduates on behalf of HESA, HESA Services Ltd, and the other organisations who are data controllers in common of HESA datasets. ACM ensures that students and staff are informed that their personal data will be submitted to HESA, and make the HESA Collection Notices available to all relevant data subjects.

The HESA Collection Notices are published at: www.hesa.ac.uk/about/regulation/data-protection/notices

Specific data protection guidance in relation to the HESA Graduate Outcomes survey can be found here: www.hesa.ac.uk/innovation/outcomes/providers/data-protection.

Fair Collection and Processing

2.9  The specific conditions contained in Schedules 2 and 3 of the DPA regarding the fair collection and use of personal data will be fully complied with.

2.10 Individuals will be made aware that their information will be collected, and the intended use of the data specified either on collection or at the earliest opportunity following collection.

2.11 Personal data, that is data which can be connected to a specific individual, will be collected and processed only to the extent that it is needed to fulfil business needs or legal requirements.

2.12 Personal data held will be kept up to date and accurate.

2.13 Retention of personal data will be appraised and risk-assessed to determine whether business needs and legal requirements are met, with appropriate retention schedules applied.

2.14 Personal data will be processed in accordance with the rights of the individuals about whom the personal data are held.

2.15 Individuals whose personal information is held on an ACM database will be provided with the option to ‘opt out’ of receiving future communications.

2.16 A “cease processing” request from a data subject (often relating to unwanted communications) will be acknowledged within 3 working days, with a final response within 21 days. The final response will state whether ACM intends to comply with the request and to what extent, or will state the reasons why it is felt the requestor’s notice is unjustified.

2.17 Staff will advise the nominated ACM Data Protection Officer, in the event of any intended new purposes for processing personal data. The Data Protection Officer will then arrange for a Privacy Impact Assessment to be conducted.

Security

2.18 ACM will take all reasonable technical measures to ensure the security of its network and data stored by means of its IT facilities. See also our Acceptable Use of IT and E-Safety Policy and Procedure.

2.19 Training in data protection is provided to keep staff informed of relevant legislation, guidance and best practice regarding the processing of personal information. Data protection promotes awareness of ACM’s data protection and information security policies, procedures and processes. It will also promote safe practice in the use of devices off-site, handling of personal information in shared work environments and telephone conversations with third parties requesting information about data subjects.

2.20 Individual members of staff are responsible for ensuring that all personal data to which they have access is kept secure.

2.21 Staff must report any actual, near miss, or suspected data breaches to the designated Data Protection Officer for investigation. Any areas of risk identified in an investigation will be relayed to those processing information to enable any necessary or desirable improvements to be made.

2.22 Any unauthorised use of personal data collected by ACM by staff, involving the sending of sensitive or personal data to unauthorised persons or otherwise causing a breach of data protection, will be regarded as a breach of this policy. Staff disciplinary proceedings may result from wilful or negligent breaches of data protection.

Data Sharing

2.23 ACM processes applicant and student data to meet our statutory, business and other binding obligations. These include submission of statistical and data returns to the UK government and its agencies, including local authorities, the Office for Students (OfS), other official bodies, such as the Higher Education Statistics Agency (HESA), and occasional third parties carrying out contracted activities on behalf of these bodies.

2.24 In addition to the data submissions listed above, ACM may be required to provide further information to local authorities and other government agencies. This information could include learner contact details and consequently learners may be contacted separately by these local authorities or other government agencies.

2.25 Personal data in any format will not be shared with a third party organisation without a valid business reason, a Data Sharing Agreement in place, or without the consent of data subjects affected. Data Processing Agreements will be applied to all contracts and management agreements where ACM is the data controller contracting out services and processing of personal data to third parties (data processors). These agreements will clearly outline the roles and responsibilities of both the data controller and the data processor. ACM shares students’ registration and academic information with the relevant validating or franchising partner institutions as part of such an arrangement, and with external examiners working on their behalf, in order to administer our courses, programmes and learning opportunities, guarantee its quality and award qualifications.

2.26 ACM may be obliged to share data with bodies such as the Police and Security Services, Her Majesty’s Revenue and Customs, the Home Office and UK Border Agency, the Department for Work and Pensions, Local Authorities, Health Authorities, and similar. These bodies may require the data for the purposes of:

• the detection or prevention of a crime;
• the apprehension or prosecution of an offender;
• the assessment or collection of any tax or duty or any imposition of a similar nature; or
• establishing whether a person is “fit to practice” in a professional context, for example in healthcare.

2.27 In certain circumstances, staff members at ACM may have a duty to disclose sensitive information about students under the age of 18, or vulnerable adults, to designated colleagues or appropriate government agencies under the terms of our Safeguarding Policy or the Prevent Duty.

2.28 ACM may be required to give information to the UK Border Agency about students, particularly those holding Tier 4 visas. Reporting duties include informing the UK Border Agency if a relevant student fails to register, withdraws from their course, or fails to attend classes and submit assignments.

2.29 ACM cannot release any information about data subjects over the age of 18 to their parents, or other sponsors, without consent (however the Data Protection Act allows disclosure without consent in certain specific circumstances). Where parents or sponsors pay tuition fees, this does not give them a right of access to students’ personal information. All necessary information will be issued to the student directly. It is then the student’s responsibility to pass relevant information onto their parents or sponsors.

However, students may provide consent that we in turn provide information directly to a parent or sponsor by informing Registry staff. In this event, ACM would engage directly with the third party.

2.30 Personal data will not be transferred outside the European Economic Area (EEA) unless the country or territory in question can ensure a suitable level of protection for the rights and freedoms of the data subjects in relation to the processing of their personal data.

2.31 ACM normally will not reveal personal information about students or alumni to other students or alumni except in certain specific cases of student employment with ACM, for example, students employed conducting surveys or acting as Student Ambassadors. In these situations full cognisance will be taken of data protection concerns in the relevant training and job description.

Next of Kin/Emergency Contact Details

2.32  All students are asked to provide next of kin or emergency contact details. In the event of an emergency, ACM may need to make contact with, or disclose information to, students’ next of kin or other nominated emergency contact without obtaining consent. However, this information will only be used in exceptional circumstances.

Sensitive personal data/Special categories of personal data

2.33 There are particular categories of data that are categorised as ‘Sensitive personal data’ under the DPA and ‘Special categories’ under GDPR. These are subject to stricter conditions of processing. The following data fields in the HESA record capture sensitive or special categories of personal data:

• Disability
• Ethnicity
• Gender Identity
• Religion or belief
• Sexual orientation

2.34 Collection of these sensitive or special categories of data is necessary for statistical research purposes to help public authorities to meet their public-sector equality duties under the Equality Act 2010. This processing is lawful under the Data Protection (Processing of Sensitive Personal Data) Order 2000 (Schedule (9)) and GDPR Article 9(2)(j).

Extenuating Circumstances Applications

2.35 Applications for deferred assessments, consideration of extenuating circumstances, and associated documentation may contain personal and medical information which is categorised as “sensitive personal data”.

2.36 Personal sensitive data relates to racial or ethnic origins, political opinions, religious beliefs, union membership, physical or mental health (including disabilities), sexual life, and the commission or alleged commission of offences and criminal proceedings.

2.37 Since this information is considered sensitive, and it is recognised that the processing of it may cause particular concern or distress to individuals, staff and students will be asked via the Extenuating Circumstances forms to give express consent for ACM to do this.

Access

2.38 Members of staff will have access to personal data only where it is required as part of their functional remit.

2.39 All data subjects have a right to:

• find out what personal data ACM holds about them, why we hold it and what we do with it, how long we keep it and to whom we may disclose it;
• Ask ACM to correct inaccurate data;
• Ask ACM not to process information about students that causes them substantial, unwarranted damage or distress;
• Request a copy of their personal information held by ACM and know the source of the information;
• request information about the reasoning behind any automated decisions

This is known as a Subject Access Request.

2.40  ACM has 40 calendar days to comply with a student’s request after receiving proof of identity, the statutory fee of £10 and any further information needed to find the information requested.

2.41 Staff are made aware that in the event of a Subject Access Request being received, their emails may be searched and relevant content disclosed, whether marked as personal or not.

2.42 Third party personal data will not be released by ACM when responding to a Subject Access Request or Freedom of Information Request (unless consent is specifically obtained, obliged to be released by law, or necessary in the public interest).

Links with the Freedom of Information Act 2000

2.43 The Freedom of Information Act 2000 (FOIA) enables greater public access to information held by public bodies and by companies receiving public funding. However, personal data continues to be protected by the Data Protection Act 1998, and is therefore exempt from disclosure under the Freedom of Information Act (Section 40).

2.44 Any FOI request for information which would involve the disclosure of third party personal information must be considered by ACM, but any decision to disclose or refuse to disclose will be made in accordance with the FOIA, and if appropriate in consultation with the person or persons whose personal information is, directly or indirectly, the subject of the request.

2.45 ACM will, as required by the FOIA, disclose information covered by the FOIA on receipt of a valid request.

Student Responsibilities

2.46 It is essential that ACM has a complete and accurate record of students’ relevant personal information and course/programme details. ACM initially collects students’ personal data from their application form. After enrolment, we request that students notify ACM promptly to let us know if any of this information changes during the course of the year.

2.47 Every student therefore has a responsibility to help ensure that the information held about them on ACM’s student record system is correct.

 Addresses and student contact details

2.48  All written communication sent by ACM will be forwarded to the address held on a student’s record. During the span of a programme of study, written communications will normally be sent to a student’s term-time address; before or after a programme of study. If this address is incorrect, ACM cannot be held responsible for any problems arising from the late receipt, loss of information, or receipt of information by a third party, including Induction and Registration information or Award Certificates or transcripts.

2.49 ACM contacts students via text message and will use up to date mobile telephone numbers for that purpose.

Student Email Addresses

2.50 Enrolled students receive an ACM email Account. This is for internal access only. Students and staff should not disclose another student’s email address without their express permission. Staff email addresses should not be disclosed without permission except where the disclosure is reasonably covered by the staff member’s professional function.

2.51 ACM will, on occasion, send emails to all students containing important academic or administrative information, or information/advice that may be of benefit.

Students’ Assessed Work

2.52 Coursework and assignments (not examination scripts) are considered to be intellectual property and the personal data and therefore the property of students. Students are advised to retain a copy of all assessed work, and are expected to obtain and make a copy of their feedback as soon as it is available.

2.53 ACM will retain coursework/assignments for a period of 1 academic year after submission for consideration by the relevant Student Progression and Achievement Boards and/or Finalist Examination Boards, and in order to meet internal academic, statutory and regulatory requirements.

2.54 After this period and without further notification, coursework and assignments will be securely destroyed.

Transcripts and Degree Certificates

2.55. Please note that ACM may withhold personal information relating to academic attainment such as transcripts and certificates where a student owes tuition fees to ACM.

2.56 Where ACM has withheld a student’s transcript or degree certificate, students can request their information via a Subject Access Request (see 2.37 above). This is a request for information about you to which you are entitled under the Data Protection Act, 1998.

Retention of Information

2.57 ACM will keep a full student record for the duration of a student’s studies at ACM, plus one academic year. After this time the only documentation that ACM guarantees to keep in perpetuity is a transcript of results and a standard academic reference.

2.58 Certain materials may be held for longer periods to comply with legal requirements, for quality assurance purposes, to meet professional body requirements, or the needs of a validation body. These will be held, wherever practicably and appropriately, anonymously or with the consent of the student concerned.

2.59 Archived records are securely destroyed after the appropriate length of time, in accordance with the relevant ACM record retention schedule.  Please refer to ACM’s Data Retention Policy for an in depth explanation of ACM’s approach to Data Retention.

2.60 Archive boxes should be clearly labelled with:

1. Contents (and whether contents are confidential)
2. Disposal date

Information Commissioner’s Register of Data Controllers

2.61  ACM’s entry in the Information Commissioner’s Register of Data Controllers can be seen by interested parties. This register entry describes, in very general terms, what personal data we process and why, how ACM obtains personal data and to whom we may disclose it.

2.62  ACM’s Registration Number is Z6627433.

2.63 ACM’s nominated Data Protection Officer can be contacted via:

• DPAofficer@acm.ac.uk
• Data Protection Officer

The Academy of Contemporary Music

Rodboro Buildings

Bridge Street

Guildford

Surrey

GU1 4SB

United Kingdom

3. Responsible Parties

3.1 The policy lead is responsible for the cyclical monitoring and review of the policy in liaison with the Quality Assurance and Enhancement Manager. The Data Protection Policy lead is:

• ACM Data Protection Officer

3.2 All ACM staff with line management responsibility, and direct reporting staff, have a responsibility to demonstrate due regard to the Data Protection Policy.

3.3 Implementation and compliance with the Policy, overseen by the following designated staff:

• Registry Manager
• Human Resource staff
• Quality Assurance and Enhancement Manager
• Head of Information Technology
• Student Finance Officers
• Admissions Manager
• Group Head of Facilities

4. Reference Points

4.1 Internal:

• Quality Assurance and Enhancement Policy
• Admissions
• Acceptable Use of IT
• Equality and Diversity
• Safeguarding Policy
• Prevent Duty Policy
• Data Retention Policy

4.2 External:

• HESA Collection Notices (https://www.hesa.ac.uk/about/regulation/data-protection/notices )
• EU General Data Protection Regulation (GDPR)
• Data Protection Act 1998
• Freedom of Information Act 2000
• Education Act 2002
• Further and Higher Education Act 1992
• QAA Quality Code, Chapter C: Published Information
• CMA Guidance for HE Providers
• ICO Guide to the General Data Protection Regulation

5. Date of Approval and Next Review

Version:                         1.3

Approved on:               01 Sep 2025

Approved by:               ACM Data Protection Officer

Next Review:                August 2026

Download – POL_020_Data Access and Protection_202209

The General Data Protection Regulation (GDPR) protects the rights of individuals by setting out certain rules as to what organisations can and cannot do with information about people. A key element to this is the principle to process individuals’ data lawfully and fairly. In order to meet the fairness part of this we need to provide information on how we process personal data.

This Fair Processing Notice satisfies this element of legislation and is designed to highlight the areas of Data Protection which may be of particular concern to current and/or former students, and to help those people understand how information about them will be used. It will also provide guidance on your individual rights and how to make a complaint to the Information Commissioner’s Office (ICO), which is the regulator for data protection in the UK.

This Fair Processing Notice applies to all students aged 13 and over. If you are under the age of 13, we will require your parent/guardian to provide initial consent in accordance with UK law, in order to process your data and will also need to involve them in certain aspects of your relationship with ACM. If you are between the age of 13 and 18, we will not need your parent/guardian’s consent to process your data, but we may still need to involve your parent/guardian in certain aspects of your relationship with ACM. For such reasons, therefore, this Fair Processing Notice also applies to parents/guardians providing information about students.

Separate Fair Processing Notices are available for the Public, contracted Staff and Suppliers.

More widely, ACM is committed to meeting the entirety of its responsibilities to current and former staff under the General Data Protection Regulation (GDPR) and related legislation taking these matters very seriously. We will always ensure personal data is collected, handled, stored, shared, retained and disposed of in a secure manner.

For the purpose of your data protection, ACM is the recognised ‘controller’ of your data. ACM’s registered company is ACM Guildford Ltd (company number 11210577), trading as ACM and the Academy of Contemporary Music. ACM’s Data Protection Officer can be contacted about any of the content held herein via:  

Postal Address:

Data Protection Officer
ACM

Rodboro Buildings
Bridge Street
Guildford
GU1 4SB
United Kingdom

Telephone: +44 (0)1483 357408 

Email: dpaofficer@acm.ac.uk

The legal basis by which we will process and may have already processed data about you

When we collect or process data about you, we have to observe the requirements of the UK General Data Protection Regulation (GDPR).

Under the General Data Protection Regulation our legal bases for processing this information about you as a student will be that processing is necessary:

• “For the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.” This means the information is needed for the delivery and administration of your studies at ACM.
• “For compliance with a legal obligation.” This means ACM is legally required to share some information about you, for example with the Higher Education Statistics Agency (HESA).
• “To protect the vital interests of a data subject or another person.” This means that in some rare circumstances it may be necessary to share information about you, for example to the emergency services.

If you go on to be an alumna or alumnus of ACM the legal basis for continuing to process your personal information would then be:

• “Necessary for the purposes of legitimate interests pursued by the controller or a third party, except where such interests are overridden by the interests, rights or freedoms of the data subject.” 

This means it is reasonable to expect that ACM would contact you once you have finished your studies.

If you were a student of ACM before May 25th 2018 (the date on which GDPR came into effect), it is important for you to remember that your personal data was already protected another way, by way of The Data Protection Act (The DPA). The DPA established a framework within which information about living individuals can be legally gathered, stored, used and disseminated. At its core were eight Data Protection Principles, which ACM and other organisations needed to abide by. These specified that personal information must be:

• Processed fairly and lawfully, and only if certain conditions are met
• Obtained for specified and lawful purposes, and not used for purposes other than those for which it was gathered
• Adequate, relevant and not excessive
• Accurate and where necessary kept up to date
• Kept for no longer than necessary
• Processed in accordance with individuals’ rights
• Kept secure
• Not transferred outside the European Economic Area unless certain conditions are met

GDPR builds on these requirements and states that from 25 May 2018 information must be:

• Processed lawfully, fairly and in a transparent manner in relation to individuals;
• Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
• Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
• Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
• Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals;
• Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

GDPR also requires that:

• “the controller shall be responsible for, and be able to demonstrate, compliance with the principles.”

These protections apply to information in electronic form and also many types of data in paper form. Further information about the Data Protection Act and the General Data Protection Regulation is available from the Information Commissioner’s Office (ICO) at www.ico.org.uk  

How and why does ACM use personal data?

Student and Alumni personal data is processed primarily for, but not limited to, the following purposes:

• To administer and support your studies and record academic achievements, e.g. your course choices, attendance, assessments and the publication of any graduation programmes
• To assist in pastoral and welfare needs, e.g. the counselling service and services to students with disabilities
• To administer financial aspects of your registration as a student, e.g. payment of fees, debt collection
• To tell you about things that are happening in and around ACM
• To manage course facilities, such as computing facilities and the Library
• To produce management statistics and to conduct research into the effectiveness of our courses
• To monitor our equal opportunities policies, e.g. compliance with the Race RelationsAct
• To administer student employment processes, if you choose to work for ACM whilst you are studying with us
• For security and disciplinary purposes
• For internal and external audits and quality assurance exercises
• For alumni relations purposes

We may disclose your data to certain outside organisations as outlined in this Fair Processing Notice. We may use copies of the data, including sensitive personal data which we hold about you, for the purpose of testing our IT systems. If your data is used for system testing, it will be copied to a test environment and used with data on other students to test changes to our IT systems in a realistic way. 

This is done to ensure that changes will be effective and will not cause loss or damage to data. The data about you which we hold in our live systems will not be affected. Your data will not be kept in the test environment for longer than is necessary for testing purposes. Data in that environment will not be used for purposes other than testing. We will also apply appropriate security precautions to the data.

What personal data does ACM collect?

ACM collects personal data from students at various stages. The volume and nature of the personal data collected is described below, but is not limited to the data items specified:

Personal data:

• Your name
• Your contact details
• Details of your emergency contacts / parents / guardians / next of kin
• Your date of birth
• Your nationality
• Your country of residence
• Your ethnic origin
• Your gender identity
• Any disabilities which you have disclosed to us
• A digital photograph used to produce your student ID, and for security and identification purposes
• Medical information, such as information held by Student Services
• Audio/Visual data relating to your application / enrolment at ACM

Course-related data:

• Information from your application process
• Your academic background and qualifications
• Your academic record while at ACM (including measures of attendance,engagement and attainment)
• Details of any degrees which you are awardedFinance data:
• Fee information
• Bursary or sponsorship details
• Payment / Bank details.Other data:
• Any disciplinary action taken against you
• Information relating to any academic appeals or complaints raised by you
• Attendance warnings issued to you
• Official letters requested by you during your studies, for example Council Tax exemption
• Your use of ACM’s facilities, such as the Library
• Online identifiers, such as your ACM username that is used to access our systems

Some of this information, such as your ethnicity, medical information and information about disabilities, is classed as “sensitive” personal data under the Data Protection Act. 

Under the General Data Protection Regulation sensitive data covers information consisting of racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person’s sex life or sexual orientation. Sensitive personal data is subject to extra legal protection and we have to meet an additional set of conditions in order to use the data fairly and lawfully.

Sensitive data about you, for example relating to your health, may be shared with restricted departments within ACM to ensure that you have access to appropriate services and support. Sensitive personal data may also be used to monitor equality of opportunity and access to higher education, but will not be used to make decisions about you. For further information about sensitive personal data, see ACM’s Data Protection Policy.

NB: If you are under 18, we may also need to collect details from a parent/guardian for the purpose of administering your education with ACM, and if you are under 13, we will need to specifically collect their consent to collect and process your information.

Your Student Profile:

In the normal course of study, your name, course and ACM email address may be made available to your fellow Students via ACM systems. Your contact details will also be made available in a directory to staff via ACM systems. This may include name, photo, course, ACM email address and a contact telephone number. Should there be times at which you are unable to be contacted by way of ACM-operated communications platforms, relevant staff may be provided access to your non-ACM contact details, only as necessary. This may extend to sharing of emergency contact details, if the need arises.

Information, such as your name, course and career credits may be made available in a public manner, where relevant to promote ACM’s work, for example in our prospectus and on our website.

ACM Communications Platforms:

Where ACM’s email and other communications services are provided by third parties, you are bound by their terms of service. ACM undertakes that data held within these services is held in accordance with GDPR legislation. ACM has contracts in place with these providers to ensure the protection of ACM-owned personal data.

Student email addresses are issued and used for communicating about ACM and studies, and are monitored to ensure compliance with our Data Protection and associated policies, as well as legislation such as The Prevent Duty.

CCTV:

For safeguarding and crime prevention purposes, we may operate CCTV systems that cover areas you access at ACM. Please refer to our CCTV policy for more information.

ACM Performances and Events:

ACM routinely photographs and films activities, performances and events for the purpose of promoting ACM and its programmes. This may include images or recordings in which students are identifiable. ACM relies on its legitimate interests to carry out this activity and will always do so in a way that does not unfairly impact you. You may refuse or withdraw your consent at any time without detriment. 

For non-ACM events or filming/recording by third parties in which students are identifiable, we may facilitate additional consent requests by these third parties which do not form part of this Notice. 

Who else has access to my data?

ACM is required to share personal data with certain other organisations in order to meet statutory requirements or to provide services to students. Sharing will always be undertaken in line with the requirements of data protection law, either through the consent of the individual, or another relevant legal gateway. The personal data that is actually shared will always be limited precisely to what the other organisation needs to meet its requirements or deliver its services.

Although we do not transfer data outside of the European Economic Area (EEA) as a matter of course of usual business, if this disclosure involves the transfer of your data outside the European Economic Area (EEA), we will inform you of this in advance, along with information about the safeguards in place. The data will only be transferred outside the EEA if one of the conditions set down in the Data Protection Act has been met, or in compliance with the conditions of transfer outlined in the General Data Protection Regulation.

Your data may also be sent to different companies/departments within the ACM group where this is necessary for our day to day administration. ACM’s registered company is ACM Guildford Ltd (company number 11210577), trading as ACM and the Academy of Contemporary Music. The information below outlines the key partners with whom ACM shares personal data on a periodic basis:

Professional and Funding Bodies:

• Validation of registrations and awards; and
• Approval of funding applications.

Partner institutions such as Middlesex University (HE provision), East Surrey College (FE provision), RSL (FE provision):

• External examiners connected to the awards we operate for examination, assessment and moderation purposes.

National/Local Government Departments and other public bodies:

• Higher Education Statistics Agency (HESA) to produce a variety of statistical reports about higher education that are required to be published in the public interest for which a separate data collection notice can be found at https://www.hesa.ac.uk/about/regulation/data-protection/notices#student ;
• The Office Of The Independent Adjudicator (OIA) to review student complaints;
• The Office for Students (OfS) during institutional audits and other quality assessment exercises;
• The Student Loans Company in connection with grants, fees, loans and bursaries;
• The courts, the police and other organisations with a crime prevention or law enforcement function (subject to the proper entitlements);
• Local authorities for the purposes of assessing and collecting council tax;
• Communications Platforms to facilitate marketing and communications of ACM services (governed by GDPR-compliant data sharing agreements);
• Facebook for re-marketing of ACM services to you via its channels;
• Clickatell for SMS (text message) services; and
• Mailchimp and Mandrill for campaign and transactional email services.

Service Platforms to facilitate the administration and distribution of ACM services (governed by GDPR-compliant data sharing agreements):

• Canvas Virtual Learning Environment for your online learning tools;
• Turnitin plagiarism and AI detection software for verifying the originality of your submitted work; and
• Music Gateway for your professional development opportunities.

Other individuals / organisations:

• International recruitment consultants and agents (for relevant international students);
• Housing providers for students;
• ACM’s insurers and legal advisers for the purpose of providing insurance cover or in the event of a claim;
• Employers who request a reference from ACM (for relevant staff and students);
• If you leave ACM owing money to ACM, we may at our discretion pass this information to a debt collection agency;
• We may disclose information for the purpose of verifying data about you held by ACM, held by another higher education institution, or held by government agencies.
• We may disclose information if there are concerns regarding student vulnerability and susceptibility to radicalisation as part of our responsibilities under the Counter Terrorism and Security Act 2015.

Personal data may also be disclosed when legally required or where there is a legitimate interest, either for ACM or the data subject, taking into account any prejudice or harm that may be caused to the data subject.

ACM may also use third party companies as data processors to carry out certain administrative functions on behalf of ACM. If so, a written contract will be put in place to ensure that any personal data disclosed will be held in accordance with GDPR legislation.

How long do we keep your data, and what happens after you leave ACM?

ACM takes its obligations under data protection laws very seriously. We do not hold onto personal data for any longer than is necessary, and we operate a strict internal retention schedule.

Data Retention Periods

After you leave ACM, we will continue to hold data about you in digital and paper form. Depending on the category, data is retained for different lengths of time:

• Data relating to your application – retained for 6 years after you leave ACM;
• Anonymised records which don’t identify you which are used for data analysis purposes – retained indefinitely;
• Records relating to applications for Extenuating Circumstances – retained for one year after the end of your final academic year;
• Your contact details – ACM is required by statute to retain these to enable the Higher Education Statistics Agency’s national survey of Graduate Outcomes;
• Data relating to your assessment and degree outcome – retained indefinitely to be able to provide academic transcripts;
• Data relating to any student complaints or academic appeals – retained for one year after the end of your final academic year;
• Financial data relating to payments received from you or paid to you – there is a mandatory requirement to keep financial data for at least seven years for audit purposes. 

How We Use Your Data After Graduation

Upon completing your studies or graduating, ACM processes specific elements of your personal data. We do this to fulfil our ongoing administrative duties, meet our statutory obligations, and pursue our legitimate interest in maintaining a lifelong relationship with our former students. This includes:

• Academic Verification: Providing transcripts, confirmation of qualifications, and references to employers or institutions when requested by you.
• Legal & Statutory Compliance: Supplying data to regulatory bodies and agencies to whom we are legally required to provide information (such as the Higher Education Statistics Agency’s national Graduate Outcomes survey).
• Institutional Metrics: Producing management statistics, internal audits, and quality assurance reviews.
• Research & Feedback: Contacting you for a limited range of institutional research purposes or graduate outcome tracking.
• Alumni Network & Engagement: Administering the ACM alumni network, providing networking or career opportunities, and sending you alumni communications (such as newsletters and event invitations).

Where your alumni communications are sent electronically and contain promotional, commercial, or fundraising material, we rely on your explicit consent. You can manage, update, or completely withdraw this consent at any time.

Because we process your general alumni data under legitimate interests, you also retain the right to object to being part of the alumni network or receiving any non-marketing updates. To change your preferences or object to this processing, please contact dpaofficer@acm.ac.uk 

Examples of how we will use your data after you finish or graduate include:

• Academic Verification: To provide evidence of your academic achievements when requested to do so (such as transcripts, confirmation of qualifications, and references);
• Legal Compliance: To provide information to statutory and regulatory bodies to whom we are legally required to supply data;
• Institutional Metrics: To produce internal management statistics, audits, and quality assurance reviews;
• Research & Feedback: To contact you for a limited range of institutional research or graduate outcome surveys;
• Alumni Network & Engagement: To administer the ACM alumni network, maintain accurate records, provide networking or career opportunities, and send you alumni communications (such as newsletters and event invitations).

We are required by statute to maintain and share your contact details to enable the carrying out of surveys conducted by or on behalf of HESA, the Office for Students or other official agencies. Where we report a variety of data to HESA, a separate data collection notice can be found at:

https://www.hesa.ac.uk/about/regulation/data-protection/notices#student

We may also contact you to carry out our own research into your experiences at ACM and after leaving ACM in order to evaluate the effectiveness of our courses and improve our services to students. If you do not want to be contacted for these purposes, please notify dpaofficer@acm.ac.uk 

ACM graduates automatically become members of the ACM Alumni Network as ACM would like to stay in contact with you.

ACM retains some data about current and former students indefinitely, for the reasons outlined below:

• To be able to verify qualifications with future employers;
• To be able to respond to safeguarding responsibilities. 

A full schedule concerning data retention and disposal is available via the policies section of our website. 

What are my rights regarding the personal data you hold relating to me?

• An individual has the right to be informed about data collection via a Fair Processing Notice. This is that notice.
• An individual has the right to ask ACM what personal data we hold about them, and to ask for a copy of that information. ACM reserves the right to ask you to provide proof of identification and for you to clarify your request if it is unclear in the first instance. You will normally receive a reply no longer than 30 calendar days from the date you make the request in writing unless your request is complex. If you are unhappy with the initial response, you can ask ACM to undertake a further search if there is specific information you have good reason to believe exists but which hasn’t been delivered to you.
• You have the right to rectify data that is incorrect. If you believe ACM holds information about you that is factually incorrect please email our registry department to provide the correct information, and ACM should update it within one month.
• You have the right to be forgotten. Where there is not a legal / statutory obligation for ACM to hold data about you, you have the right to be forgotten.
• You have the right to data portability. Where the personal data is processed with the consent of the data subject, not where the personal data has been collected using any of the other legal bases for processing.
• You have the right to restrict processing.
• You have rights in relation to automated decision making and profiling.
• You also have the right to object / withdraw consent from the processing of your personal data by ACM at any time, if your consent was sought initially to use your personal data.

You may make a complaint to ACM if you consider that, in connection with personal data relating to you, there is an infringement of the UK GDPR. ACM will acknowledge receipt of your complaint within the period of 30 days beginning when the complaint is received. ACM will respond without undue delay and will take appropriate steps to respond to your complaint, and inform you of the outcome. Complaints should be sent to complaints@acm.ac.uk 

If you believe your complaint has not been dealt with properly by ACM, you have the right to complain to the UK Regulator, the Information Commissioner’s Office (ICO). A complaint can be raised via the ICO’s website at www.ico.org.uk (the ICO strongly recommends using their electronic form) or by writing to the following address:

The Information Commissioner’s Office 

Wycliffe House
Water Lane

Wilmslow 

Cheshire 

SK9 5AF

How do I exercise my rights under GDPR?

For the purpose of your data protection, ACM is the recognised ‘controller’ of your data. ACM’s registered company is ACM Guildford Ltd (company number 11210577), trading as ACM and the Academy of Contemporary Music. ACM’s Data Protection Officer can be contacted if you would like to exercise any of your rights under GDPR: 

Postal Address:

Data Protection Officer
ACM

Rodboro Buildings
Bridge Street
Guildford
GU1 4SB
United Kingdom

Telephone: 01483 357408 

Email: dpaofficer@acm.ac.uk

What are my responsibilities?

ACM will make every reasonable effort to keep your details up to date. However, it is your responsibility to provide us with accurate information about yourself when you provide it. It is also your responsibility to let us know of any subsequent changes to your details. You must also abide by ACM’s Data Protection Policy when handling any personal data you come into contact with for which ACM is responsible.

 

The Equality Act 2010 (Specific Duties and Public Authorities 2017 requires gender pay reporting for employers with 250 or more employees to publish statutory calculations showing how large the pay gap is between their male and female employees. For organisations with less than 250 employees this is voluntary (as was applicable to The Academy of Contemporary Music in 2021-22).

View the organisation’s 2021-22 Gender Pay Gap Report here.

 

1. Purpose and Scope

1.1.  This policy outlines ACM’s approach towards the safety of those who work alone, without close or direct supervision.

2. Policy Statement

2.1 ACM, as an employer, has a legal duty to assess all risks to health and safety, including the risks of lone working. The Health and Safety Executive (HSE) defines lone workers as “those who work by themselves without close or direct supervision”. Many of the hazards that lone workers face are similar to those faced by other workers. However, the risks involved may be greater because the worker is on their own. Lone working may also occur where it is necessary for ACM staff to work outside their nominated working hours, or in settings where staff are required to work away from ACM sites when representing the business, for example, external events. This may refer to representation of ACM overseas, and away from a worker’s home domicile.

2.2 There is no specific law dealing with lone working. However, all health and safety legislation applies equally to lone workers and in some cases, is even more applicable. Lone working does not in itself contravene the law, but it may often bring additional risks.

2.3       Some of the key hazards are:

• Violence and assault – for staff working alone the risks are even greater than usual. They are more vulnerable to assault, and less able to call for assistance.
• Manual handling – the most common accidental injury at work is manual handling and for lone workers, the risk is even higher – there is no-one to ask for help.
• Fire – Lone workers are less likely to be aware of a fire until they themselves see or smell it and less able to call for assistance if they get into trouble. It is important that staff always know how to deal with or escape from a fire whilst working.
• The increased risk of threatening behaviour, due to the vulnerability of lone workers, including the risk of theft and intruders.
• The suitability of the workplace for lone working.
• Lone worker medical suitability for lone working.
• The risk of social isolation.

2.4 All lone workers should be fully trained in the safe working practices to be adopted in order to carry out their tasks safely. This will apply to employees and other workers where applicable, such as agency staff and self-employed contractors.

2.5 Line Management have a responsibility to engage direct reports in discussions to ascertain the suitability for lone working arrangements, taking into account feedback and staff concerns, relating to risk or staff suitability for lone working practices.

2.6 Staff hold the right to decline lone working arrangements based on the suitability of the lone-working setting, and based on their ability to discharge their responsibilities in a lone-working setting, taking into account any medical or personal barriers or complexities.

2.7 Where lone working arrangements are deemed unsuitable or undesirable, line management and direct reports should engage in an open dialogue to propose alternative arrangements.

2.8 Where lone working arrangements are agreed, all lone workers are expected to co-operate fully with any instructions given by their employer. They are also expected to follow their employer’s safe systems of work and any associated procedures.

2.9 It is the joint responsibility of line management and direct reports to establish a point of contact, and contact procedures, to ensure oversight of lone workers safety and well-being. The nominated contact should be agreed prior to lone working taking place.

Risk Assessment

2.10 Prior to the joint agreement of lone working arrangements, line management will ensure a comprehensive risk assessment is completed.

2.11 The risk assessment procedure operates to identify potential hazards, taking into account:

• Assess the nature and severity of the risks taking into account the likelihood of any violence and abuse
• Enable control measures to be sought and implemented to remove the risks

2.12 It is expected that the risk assessment will allow line management and staff to identify and minimise possible areas of risks so that they are adequately controlled.

2.13 The risk assessment must take into account:

• Immediate risks associated with the vulnerability of lone working staff, relating to the increased risk of violence, threatening behaviour, theft, and intruders.
• The suitability of the nominated place of work, where lone working will occur. The suitability of the workplace should take into account the availability of welfare facilities, hygiene facilities (taking into account individual staff needs and personal circumstances)
• Any necessary reasonable adjustments to a nominated workplace.
• The availability of training, prior to the commencement of lone working arrangements, to ensure staff are made aware of manual handling practices.
• The availability of nominated staff trained in First Aid, including ensuring that lone workers are aware of the specific named staff member, and their contact details.
• The ease of which, if necessary, emergency services are able to access individuals, should such an emergency situation arise.
• The availability of contact points, via landline phones, mobile phone coverage, and wifi connectivity.

2.14 All lone workers should ensure that they are fully conversant with the Lone Worker Policy prior to lone working arrangements commencing.

2.15 Lone workers are expected to exercise sound judgement relating to their individual circumstances, their surroundings, their personal boundaries and their safety in instances where lone working arrangements occur.

3. Responsible Parties

3.1 The policy lead is responsible for the cyclical monitoring and review of the policy in liaison with the Quality Assurance and Enhancement Manager. The Lone Workers Policy lead is:

• Human Resources Operations Manager

3.2 All ACM staff with line management responsibility, and direct reporting staff, have a responsibility to demonstrate due regard to the Lone Workers Policy.

3.3 Implementation and compliance with the Policy, overseen by the following designated staff:

• Human Resource Department
• Staff with Line Management Responsibility of a Lone Worker
• Staff with responsibility for casual student employees, particularly Student Ambassadors,
• Nominated First Aid contacts within the Business
• Designated Safeguarding staff

4. Reference Points

4.1 Internal

• Critical Incident Policy
• Safeguarding Policy
• Staff Code of Conduct Policy
• Staff Grievance Policy
• Health and Safety Policy
• Equality and Diversity Policy

4.2 External

• Health and Safety at Work Act 1974
• Management of Health and Safety at Work Regulations 1999

 

5. Date of Approval and Next Review

Version:                       1.2

Approved on:              01 Sep 2025

Approved by:               Academic Board

Next Review:                August 2026

Click to download this policy

1. Purpose and Scope

1.1 The purpose of this policy is to set out the arrangements for assessing the risks around particular events and external speakers, and for managing those risks.

1.2 The Academy of Contemporary Music has welcomed many external speakers since commencing delivery of music industry programmes in 1995.   Such speakers have brought and continue to bring great diversity of experience, insight and opinion for the benefit of students, staff and visitors.

1.3 This Policy applies to all staff, students, and third parties of ACM and to all Academy-controlled activities undertaken in the UK, and has been developed with regard to the PREVENT Duty, Equality and Diversity policy, and institutional strategic objectives.

2.Policy Statement

Legal Context and ACM’s Approach

2.1 All students and staff have the right to participate without fear of intimidation, harassment and threatening or extremist behaviour. The key factor for the preservation of academic freedom is tolerance and a respect for diversity. Intolerance involves behaviour motivated by prejudice or hatred that intentionally demeans individuals and groups defined by their ethnicity, race, religion and/or belief, sexuality, gender, disability, age or lawful working practices and which give rise to an environment in which people will experience, or could reasonably, fear harassment, intimidation or violence. ACM has a duty of care to all of its students and staff.

2.2 ACM values the opportunities presented by external speakers for students and staff to experience diverse opinion and to enter into debate. This is seen as an essential part of both personal, professional, and academic development.

2.3 ACM values the tradition of academic freedom and holds that no subject or belief should be excluded from reasonable, constructive discussion and debate. ACM values freedom of opinion and speech but recognises that, in the interests of the whole learning community, this must exist within formal guidelines.

2.4 ACM recognises and supports moral and legal frameworks of the society and community within which it works.

2.5 ACM will not accept the use of language by external speakers that offends and is considered to be offensive or intolerant. Specifically, this means offensive, misogynistic, misanthropic, sexual or racist language irrespective of context. Direct attacks on any religions or beliefs are not condoned.

2.6 ACM will not tolerate any person who intentionally demeans individuals and groups defined by their ethnicity, race, religion and/or belief, sexuality, gender, disability, age or lawful working practices and which give rise to an environment in which people will experience, or could reasonably, fear harassment, intimidation or violence.

Booking an External Speaker

2.7 Anyone organising an event must follow the process detailed below.

2.8 The majority of external speaker requests will be straightforward and can be handled entirely at a local (departmental) level. In these cases, following the steps outlined in the “Local assessment of proposed external speaker(s)” below will suffice. However, some requests may be complex and may require referral for further consideration. The “referral process” will only apply in a minority of circumstances – to events or speakers deemed to be higher-risk.

2.9 All requests for an external speaker are to be submitted by the event organiser making the request using the appropriate form to the Industry Link team at least ten working days before the planned event.

2.10 A transcript of the intended talk must be provided, where requested, and a written undertaking to abide by the provisions of this policy and to uphold the ACM policy on Equality and Diversity. Requests that do not comply with this provision will be refused. If the risk is considered medium to high risk a transcript must be attached to the External Speaker Submission Form.

2.11 ACM reserve the right to require references for the proposed speaker and also to refuse permission for the speaker to visit ACM. A refusal is final.

2.12 An appropriate member of staff will be present at all talks to monitor any concerns.

2.13 Speakers must be informed that all such events may be recorded/filmed by ACM. These recordings are for future reference and marketing purposes associated to ACM and to prevent the abuse of trust.

Assessment of Proposed External Speaker(s)

2.14 Prior to the confirmation of any external speaker, the event organiser will be responsible for assessing the speaker against the following set of questions:

Question 1: Has the speaker previously been prevented from speaking at ACM or another college or University or previously known to express views that could place at risk public order and safety, or represent a breach of law and breach of the External Speaker Code of Conduct.

Question 2: Does the proposed title or theme of the event present a potential risk that views/opinions expressed by speakers may place at risk public order and safety, or represent a breach of law and breach of the External Speaker Code of Conduct.

Question 3: Is the proposed speaker/theme likely to attract attendance from individuals/groups that have previously been known to express views that may place at risk public order and safety, or represent a breach of law and breach of the External Speaker Code of Conduct.

If the answer to all three questions is NO:

The event organiser can confirm the external speaker and book them to speak at their event or activity. It is required that the external speaker is sent the External Speaker Code of Conduct and Declaration Form to sign before the event takes place.

If the answer to any of the questions is unclear:

The event organiser must seek guidance from their line manager and respective Campus Head of Education, whose responsibility will be to further review the speaker(s) against the questions above and information submitted via the ACM External Speaker Submission Form.

If the answer to any of the questions is YES:

It is the responsibility of the event organiser to refer the External Speaker Submission form to the Director of Creative Industry Development. Where there are Prevent Related concerns the submission form shall be also sent to the ACM Prevent Lead. The ACM Prevent Lead will seek advice from the Regional Prevent Coordinator before reaching any decision.

Process for Assessment and Referral

2.15 The event organiser should use the External Speaker Submission Form to detail the event and review potential risk.  In the case of referral the form should be submitted to the Director of Creative Industry Development and ACM Prevent Duty Lead with any other information as available.  Where appropriate ACM will seek the advice of external agencies as to whether a particular event should take place.

3. Management of External Speakers

3.1 Any external speaker or event to be hosted by or at an ACM campus must be aware of, and comply with the ACM External Speaker Code of Conduct. It is the responsibility of the person organising the event to ensure that the speaker receives the ACM External Speaker Code of Conduct and has their attention drawn to its contents, and the declaration form is signed and returned for central keeping by the Industry Link Team.

4. Responsible Parties

4.1 The policy lead is responsible for the cyclical monitoring and review of the policy in liaison with the Quality Assurance and Enhancement Manager. The External Speaker and Events Policy lead is the:

• Director of Creative Industry Development

4.2 Implementation and compliance with the Policy, overseen by the following designated staff:

• Prevent Duty Lead (currently Head of Quality and Student Experience)
• Industry Link Team
• Executive Council
• Education Executive
• Campus Heads of Education
• Human Resource Department
• Designated Safeguarding Lead

5. Reference Points

5.1 Internal:

• The Prevent Policy
• External Speaker Submission Form
• External Speaker Code of Conduct and Declaration Form
• Safeguarding Policy
• Safeguarding Procedure
• Critical Incident Policy
• Equality and Diversity Policy
• Health and Safety Policy
• Staff Disciplinary Policy
• Acceptable Use of IT and E-Safety Policy
• Freedom of Speech Policy

5.2 External:

• The Prevent Duty
• The Charity Commission: Safeguarding children and young people
• Higher Education and Research Act 2017
• Safeguarding Vulnerable Groups 2006
• Protection of Freedoms Act 2012
• Working Together to Safeguard Children 2015
• Keeping Children Safe in Education 2015

6. Date of Approval and Next Review

Version:                                     1.3

Approved on:                            01 Sep 2025

Approved by:                            Academic Board

Next Review:                            August 2026

Click to download this policy

The .pdf version of this policy linked above contains the External Speaker Submission form.

Policy 046: Risk Assessment

1. Purpose and Scope

 1.1 This Policy provides an outline of ACM’s approach to identifying, assessing and managing risks that may be present where an individual has a unique set of  circumstances that may require specific consideration in relation to their individual identified risks that may be impacted by, but not limited to, physical or mental disability or impairment. The policy identifies the proactive approach adopted to support individuals and mitigate identified risk factors for individuals working or studying within ACM.

1.2 This Policy is aligned with the regulations of ACM’s validating partners and other external stakeholders to whom ACM must make reference.

2. Policy Statement

Risk Assessment

2.1 Where a need is identified, the risk assessment should be proactive and consider the particular needs of the student or staff member to whom the assessment refers.

2.2 The process of assessing risk should be practical and include discussion and information from any members of ACM staff with relevant experience and expertise, as well as including advisory notices from any external agencies where relevant.

2.3 The student or staff member should be included in the consultation and assessment of risks with the nominated assessor, with their commentary or suggestions treated with due diligence and incorporated into assessment and subsequent planning.

2.4 When considering risks, the severity and likelihood of potential harm or hazard should also be considered, to ensure that appropriate precautions have been considered and applied.

2.5 The assessment will focus on, but not be limited to, all campus environments and learning and teaching spaces within ACM. The risks associated with other ACM venues, catering services, partnering accommodation services, local transportation and environmental factors should also be considered.

2.6 Risk assessments will reflect current working and learning practices and make explicit references to areas of enhancement and any reasonable adjustments identified as necessary.

2.7 A collaborative and positive health and safety culture exists within ACM, with students and staff taking proactive responsibility for their needs and wellbeing. Students and staff are well supported with their changing, and additional, needs and encouraged to contribute to open dialogue regarding appropriate and dynamic support.

Record of Assessment

2.8 Risk Assessments provide an effective method to ensure that appropriate consideration and controls have been taken into account and that ACM premises provide the basis for a safe learning and working environment. They further provide a framework for ensuring ongoing review and enhancement.

2.9 Risk Assessments are reflected in, and contribute towards, the associated prevention documentation. This documentation refers to Risk Management Plans, Risk Management Registers and, where necessary, Personal Emergency and Evacuation Plans (PEEPs).

2.10 Risk Assessment Forms make explicit reference to potential individual hazards, the stakeholders to which the Assessment refers, the controls which ACM currently has in place for managing risk, and responsible officers in the implementation and support of Assessments and Plans.

2.11 Risk Assessment documentation takes into account any proposed changes (for example, to building layouts), and therefore should be easily adaptive.

2.12 Consideration of the longer term effects of the individual’s health and well-being should be addressed, updated, and reflected into risk prevention, to ensure risk assessment plans have legitimacy and currency, as well as being fit for their primary purpose.

Risk Prevention

2.13 Risks which are categorised as ‘moderate’ or ‘severe’ will be managed via Risk Management Planning. The stakeholder to whom the assessment refers to will be central in the collaboration and agreement of such planning.

2.14 Planning for risk prevention should make explicit reference to long term risk management and short term risk management.

2.15 Risk Prevention should ensure that precautions are reasonable and are representative of good practice within ACM.

2.16 Where risks are identified, every reasonable effort should be made to ensure the risk no longer exists. However, where this is not practical, due diligence should be given to considering and ensuring risks are controlled to ensure harm is unlikely.

2.17 Information regarding identified risks must be communicated to all stakeholders who may be affected.

3. Responsible Parties

3.1 All ACM staff and students have a duty to comply with any controls which have been identified in completed risk assessment exercises.

3.2 The following staff have a direct responsibility to ensure implementation of the Policy:

• Education Guidance Manager
• Facilities Manager
• Human Resources Manager

4. Reference Points

4.1 Internal:

• Critical Incident Policy
• Safeguarding Policy
• Health and Safety Policy
• Equality and Diversity Policy

4.2 External:

• Management of Health and Safety at Work 1999

5. Date of Approval and Next Review

Version:                        1.2

Approved on:               01 September 2025

Approved by:               Academic Board

Next Review:                August  2026

Download POL_046_Risk Assessment_170728

Policy 043: Critical Incident

1. Purpose and Scope

1.1 This policy sets out ACM’s approach for handling an emergency situation that affects the ACM community that may occur in or out of teaching hours, weekends and during holidays.

1.2 A critical incident may involve both internal and external factors that may include hazards and events that pose direct or imminent threat to the safety, security and wellbeing of ACM students and staff.

1.3 This policy outlines the management plan for critical incidents as they may occur while students are undertaking their study during nominal teaching hours, and ensures that ACM is equipped to provide meaningful support to all students and staff affected by an incident.

1.4 The policy provides guidance to actions which should be considered by Executive Management, the Senior Management Team, and the Critical Incident Management Team (CIMT) in case of an emergency within ACM or the local community, or on an educational visit.

1.5 This policy gives clear guidance regarding the circumstances under which the policy would be enacted. The Designated Safeguarding Lead, on assessment of all factors, and individuals directly or indirectly involved, would exercise judgment over the policy’s activation and implementations.

2. Policy Statement

Critical Incidents

2.1 ACM  is committed to emergency planning to ensure the safety of its members and the smooth running of its business.

2.2 It is important to the success of emergency planning at the institution that its community is aware both of the central responsibilities and commitments in the case of a critical incident on campus, but also of local responsibilities and information outlets.

2.3 A critical incident is a sudden event or situation which may put staff and students under stress both physically and emotionally. In assessing a critical incident, consideration must be given to the existing factors and the impact on staff and students. It must also be considered with regard to the scope, and the wider public impact.

2.4 In general terms, a critical incident is defined as a traumatic event which causes or is likely to cause extreme physical and/or emotional distress to staff and/or students and may be regarded as outside the normal range of experience of the people affected. This may include, but is not limited to events involving ACM students and staff, where there has been:

• Extremist acts of aggression
• Serious injury or death
• Physical or sexual assault
• Violence or threats of violence
• Hold up, attempted robbery
• Sudden or unexpected death or suicide of a member of the ACM community
• Natural disasters
• Fire, explosion, bomb threats
• High publicity violent crimes
• Any incident that is charged with extreme emotion.
• Any fatality, near fatality or incident likely to affect seriously a number of staff and/or students
• Serious traffic accidents
• Major theft or vandalism
• A student reported as a missing person.

2.5 Every critical incident is unique and will need to be dealt with differently, according to the needs of the people affected.

Critical Incident Management Team (CIMT)

2.7 The CIMT is responsible for:

• The initial and ongoing assessment of the scale, duration and impact of the critical incident;
• Establishing ACM’s operational and business critical priorities in responding to the incident;
• The allocation of staff and resources;
• The management of, and support, of any ACM representatives who are responsible for the planning, management, and response taken by ACM;
• Liaison with external agencies as needed.
• Note: any suspected extremist based acts of terrorism, including threats physical spaces and the community, or cyber based threats must be reported to the ACM Police immediately. The Prevent Lead will contact the Police to discuss arrangements for the handling of these matters which may or may not involve the CIMT.

2.8 In the longer term, the CIMT will support the Senior Management Team to ensure adequate implementation of:

• Institutional reputation management;
• Long-term business recovery;
• Financial control;
• Corporate priorities;
• Community engagement;
• Decisions relating to long-term staffing needs, which may result from an emergency or sustained disruption to area’s of ACM’s business needs.

2.9 The CIMT with normally comprise of 3-5 members, including:

• A member of Executive Management
• Two Members of Senior Management Team

And may include:

• ACM Designated Safeguarding Lead (DSL)
• ACM PREVENT Duty Lead
• A member of student support services
• A member of the education team
• A member of the marketing team
• Student Representatives

2.10 Depending on the nature of the incident, the CIMT may be expanded to include Heads of department (or their nominees) with specific responsibilities within the impacted areas.

Activation of the Policy

2.10 Information about an incident may come from a staff member, student, parent, the emergency services or the local authority.

2.11 The staff member who receives the notification should be mindful to request and make a record of as much information provided as possible:

• The name of the person who has reported the incident
• The specific incident details
• Who, if anyone, has also been informed (for example, any emergency services)
• The exact location of the incident
• Details of any casualties
• What, if any, action has been taken so far
• A name of a contact at the scene, and their contact details
• What further assistance, if any, is needed

Staff and Student Welfare

2.12 ACM takes the responsibility towards staff and students seriously, with student and staff welfare considered a priority.

2.13 Where there is an occurrence of a critical incident, welfare and well being of all affected individuals should be considered, with individuals who have been particularly adversely affected identified for additional support, should they wish to engage with it.

2.14. The diversity of staff and students should be taken into account when considering additional support, including considering contact with leaders within local faith communities.

2.15 Support which is accessed and made available after an incident may be referred to as Post-Incident Care. This is aimed at helping individuals to understand their feelings following an emergency and to identify sources of future support. The overall aim of the support is to help people in a way that will reduce the possibility of developing long-term effects and difficulties as a result of a critical incident.

Communication

2.16 Effective communication is integral to the successful management of any critical incident. It should include effective information exchange within the response team, engagement with staff, students and others immediately affected by the incident, and liaison with the wider public via the media where necessary. Crisis messaging must be managed with the utmost care and sensitivity after the initial incident.

2.17 Communication surrounding any incident should  focus on mitigating the effects of the incident on those who are directly involved. Relevant information will be shared with those who are impacted by the incident. It is vital to ensure that all communication is conducted in a manner that protects the interests and privacy of those involved.

2.18 Post-incident communication will focus on encouraging an orderly return to normal operations in a manner that protects the interests and privacy of those who were involved. Its scope includes, but is not restricted to, providing reminders to the community on how individuals can access support, including Medical Services and Counselling Services, and how members of the community can become involved in any post incident analysis.

2.19 By necessity, communication will be influenced by the nature of the critical incident. A communications plan will be developed by the CIMT to ensure that a clear communication protocol that outlines the responsibilities for the development and implementation of both internal and external communications.

2.20 Following an incident, the Senior Management Team should ensure that all ACM staff are fully briefed on facts and are aware of what information can be disclosed to the wider community, including media representatives.

2.21 Staff should be made aware of confirmed facts relating to incidents, and what information is authorised to be released. They should also be made aware of the potential problems caused by the spread of misinformation through word of mouth, media and social media platforms.

2.22 Designated staff, approved by Executive Management in consultation with the CIMT will are given responsibility to speak to external stakeholders, organisations, and media in relation to the incident. In some cases this may also be informed by the Police and other Government agencies. This does not preclude ACM student’s or employee’s right to freedom of speech, but does ensure that official communication is consistent and equitable.

3. Responsible Parties

3.1 The policy lead is responsible for the cyclical monitoring and review of the policy in liaison with the Quality Assurance and Enhancement Manager. The Critical Incident Policy lead is:

• ACM Designated Safeguarding Lead

3.2 The Senior Management Team are responsible for ensuring staff awareness and effective implementation of the Critical Incident Policy.

3.3 Implementation and compliance with the Policy, and corresponding Procedure will be overseen by the following staff:

• Executive Management
• Senior Management
• Education Management
• Designated Safeguarding Lead
• PREVENT Duty Lead
• Human Resources Department

4. Reference Points

4.1 Internal:

• Emergency Closure Policy
• Safeguarding Policy
• Health and Safety Policy
• Content Approval Policy
• ACM Prevent Policy

4.2. External:

• Civil Contingencies Act 2004
• Counter-Terrorism and Security Act 2015
• Revised Prevent Duty Guidance: for England and Wales
• Health and Safety at Work Act 1974
• Human Rights Act 1998
• Corporate Manslaughter and Corporate Homicide Act 2007

5. Date of Approval and Next Review

Version:                        1.1

Approved on:               03 September 2024

Approved by:               Academic Board

Next Review:                August 2025

Download POL_043_Critical Incident Policy_170728