Policy category: Falmouth Policies

1. Introduction:

This code of conduct exists to provide guidance of legal obligations relating to external speakers and events at ACM, and to ensure that all speakers taking part in an event or activity, on an ACM campus or elsewhere in relation to ACM, act in accordance with the ACM External Speaker and Events Policy.

It is the responsibility of the event or activity organiser – the individual, named in the External Speaker submission form and the ACM Industry Link team to ensure that:

• The External Speaker Code of Conduct is communicated to all external speakers (once approved and confirmed via the External Speaker Booking Process) and the declaration form is signed, returned and stored centrally with the respective booking form.
• That all reasonable steps are taken to ensure that the requirements within it are upheld during the running of the event or activity.

2. Freedom of speech:

Freedom of speech is fundamental to ACM as a Higher Education provider. The Higher Education and Research Act 2017 requires ACM to take such steps as are reasonably practicable to ensure that freedom of speech, within the law, is secured for its employees, students and visiting speakers. All staff and students through their membership are expected to tolerate and protect the expression of opinions, within the law.

Whilst the law promotes and protects freedom of speech, it also places limits on those freedoms in order to maintain public order and safety. ACM acknowledges that it has a legal responsibility to create a balance between minimising the possibility that extremism or unlawful conduct will arise on an ACM campus and ensuring that it meets its legal obligations in relation to securing freedom of speech.

3. Conduct 

ACM expects external speakers to act in accordance with the law and not to breach the lawful rights of others. Set out below are examples of the expectations, this is by no means an exhaustive list.

During the course of the event at which he or she participates, no speaker shall:

• Incite hatred, intolerance or violence or act in any way that is a breach of the Criminal Law.
• Encourage or promote any acts of terrorism or promote individuals, groups or organisations that support terrorism.
• Discriminate against or harass any person or group on the grounds of their sex, race, nationality, ethnicity, disability, religious or other similar belief, sexual orientation or age.
• Defame any person or organisation.
• Raise or gather funds for any external organisation or cause without express permission of the Director of Creative Industry Development.

ACM reserves the right to not permit an external speaker to speak at or attend an event, to refuse to permit an event and/or to halt an event at any time if it reasonably considers there may be a breach of the External Speaker and Events Policy or of any legal obligation.

4. Segregation

ACM as a Higher Education provider, employer and service provider has duties under the Equality Act 2010 and Higher Education (Freedom of Speech) Act 2023. ACM will not unlawfully discriminate against students, employees and other individuals to whom services are provided.

Segregation by sex or gender is not permitted in any academic meetings or at events, lectures provided for students, or at events attended by members of the public or employees of ACM. Segregation is therefore not permissible for any event covered by the ACM External Speaker and Events Policy and this Code of Conduct.

5. Date of Approval and Next Review

Version:                        1.3

Approved on:               01 Sep 2025

Approved by:               Academic Board

Next Review:               August 2026

Download this code of conduct

The .pdf version linked above contains the ACM ‘External Speakers and Code of Conduct Declaration Form’, which needs to be read and signed by all external speakers to ACM.

 

 

 

 

 

 

 

 

 

If you have a disability which makes reading this document or navigating our website difficult and you would like to receive information in an alternative format, please contact: anddegree@acm.ac.uk

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: http://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

If you have a disability which makes reading this document or navigating our website difficult and you would like to receive information in an alternative format, please contact: anddegree@acm.ac.uk 

Procedure 003: COMPLAINTS AND GRIEVANCES

1. PURPOSE

1.1 This procedure describes how the Academy of Contemporary Music (ACM) ensures the equitable, transparent and timely consideration of student complaints and grievances in relation to any aspects of their student experience, student services, administration, financial matters, and information for their programme of study.

1.2 This procedure aims to explain the reasonable due course which students are required to consider and follow when submitting a complaint or grievance.

1.3 This policy and procedure relates to students studying at ACM Guildford, ACM London and ACM Birmingham, on programmes validated by Middlesex University (HE) and University of the Arts London (FE).

2. PROCEDURE STATEMENT

2.1 ACM encourages all students to discuss any concerns that they may have at the earliest opportunity to avoid delays and unnecessary escalation of matters. Most issues can normally be resolved quickly at the local level, without going through the complaints and grievances procedures. Key points of contact if there is a concern are:

• Student Relations Officers (in campus reception areas) 
• Student Services (Hub), who will direct you to the department or information source
• Registry team, who will direct you to the department or regulations, policies and documentation registry@acm.ac.uk 
• If unsure who to contact, the Student Hub team studentsupport@acm.ac.uk can assist students at this stage.

2.2 ACM seeks to resolve all complaints and grievances in a timely manner through considered escalation of concerns as outlined in this procedure. Students that wish to lodge an appeal of an academic decision should refer to the Academic Appeals Policy and Procedure (POL 002).

Stage 1: Early Resolution

2.3 In the first instance students who wish to make a complaint should discuss it with the relevant team responsible to be invited to an in-depth discussion for early resolution. They will advise whether or not the complaint is best progressed through:

• An informal meeting or mediation;
• A Student Forum or Board of Studies (for concerns impacting a wider group/cohort);
• Consultation with specific persons who can resolve the problem (E.g. Tutor, Module Leader);
• Referral to an external agency, or
• Escalation to the Formal Stage 2

2.4 A student should, if possible, address their complaint to the member of staff most directly involved in the event leading to the complaint in order to give that person the opportunity to address the concerns.

2.5 If for any reason the student does not feel that this is possible, they should seek advice from the Student Hub team (studentsupport@acm.ac.uk) in order to identify an appropriate alternative mechanism of early resolution. 

2.6 Every effort will be made to resolve the complaint simply and quickly. The member of staff investigating the complaint may invite the student to a meeting to discuss the matter in an attempt to reach a resolution. The member of staff investigating shall discuss the complaint with the student and, with the student’s consent, engage anyone else involved, to see if the concern can be resolved through early resolution.

2.7 Any resolutions and actions that are agreed with the student must be kept on record and communicated to the student in writing within 21 working days.  At the end of Stage 1, a student will be provided with a written response to their complaint, which will either:

• Detail the proposed resolution; OR
• If no resolution has been proposed, explain why the resolution has not been considered to be possible.

Stage 2: Formal Stage

2.8 If the student is dissatisfied with the outcome of an early attempt to resolve the matter, for example, under Stage 1, they may opt to escalate the complaint to the second (formal) stage.  All formal complaints must be submitted in writing to complaints@acm.ac.uk within 21 working days of the informal stage having been completed. The student should complete the Complaints Form and attach all relevant supporting materials and evidence to support their complaint. Complaints that lack relevant supporting documentation may be dismissed or referred back to the student for further consideration.

2.9 The Quality Assurance team will acknowledge receipt of the complaint in writing and notify the student of the next steps within 7 working days of receiving the complaint. Student Engagement will assign the complaint to a senior member of ACM staff who will undertake a provisional investigation to see if a resolution to the concern can be reached prior to the proceeding to a formal panel.

2.10 If a Quality Assurance team member was involved in the case at Stage 1, they will nominate an appropriate alternative individual to take a lead on the case. If no appropriate individual can be found, the Student Engagement team may refer it to Registry, who will then assign the lead to an appropriate individual.

2.11 The lead investigator shall convene a panel of relevant staff to consider the case appropriately. They will consider the evidence, written or otherwise, and, if necessary, hold such discussions with the complainant and any other persons they deem appropriate in order to fully investigate the complaint.

2.12 The complaints panel will determine appropriate timescales based on the nature and complexity of the case. These timescales should be communicated to the student and the student kept informed of any changes. Where possible, complaints should normally take no longer than 21 working days to investigate from the acknowledgement being sent.

2.13 The lead investigator having fully investigated the complaint over a period not normally exceeding 21 working days from its receipt, shall decide whether:

• the complaint should be progressed through other procedures; or whether
• there is no reasonable justification for the complaint, in which case the complaint shall be terminated at this stage; or whether
• there is reasonable justification for the complaint.

2.14 The lead investigator shall:

• make their decision known in writing and sent to the student within 5 working days;
• recommend resolutions to any justifiable complaint which all parties involved in the complaint shall be invited to accept; and
• if the recommendations are agreed, shall take steps to ensure that they are implemented in full within the agreed time period.

2.15 The Quality Assurance team will:

• Inform the student and the members of staff or other students involved of the decision.
• Monitor the agreed resolutions to the complaint as necessary.
• The Quality Assurance team will seek confirmation from the student(s) that they are satisfied with the agreed outcome. 

Where a student is not satisfied with the outcome of the second stage, and where the complaint is related to the student’s academic programme, they may escalate their appeal to the formal stage 3.

2.16 Where a student is not satisfied with the outcome of the second stage, and where the complaint is not related to the student’s academic programme, students are not required to escalate the matter to ACM’s validating partner (as described in Stage 3 of this Procedure) and  may escalate their appeal to the Office of the Independent Adjudicator (OIA) for Higher Education. Where this is the case, ACM will make this clear in the Stage 2 outcome letter and will also issue a Completion of Procedures (COP) letter. Information and eligibility rules are available at: www.oiahe.org.uk

Stage 3: Validating Body/ Partner Institution Review

Middlesex University Provision

2.17 This section applies to students studying on the BA(Hons) Music Industry Practice programme or the BA(Hons) Creative Industry Futures programme or the MCCI or MA/MSc in Creative Industry Futures programme at ACM Guildford, ACM Birmingham or ACM London.

2.18 If a student considers that:

1. there has been a procedural irregularity in the investigation of a complaint regarding a matter related to their academic programme carried out by ACM;
2. new information has come to light, which the student was unable to disclose previously, and which would have had a material impact upon the investigation previously undertaken;
3. the decision reached was unreasonable based on the information that had been available to ACM when the case was considered,

they can request a review of the outcome of the investigation carried out by ACM, by completing a CPULR form (Collaborative Partner University Level Review).

2.19 The student is expected to submit the CPULR form and all supporting documentation within 21 working days of receiving written confirmation from ACM of the final outcome of ACM’s investigation. The CPULR form must be submitted to the Director of Affairs at Middlesex University.

2.20 The receipt of the CPULR form will normally be acknowledged within 7 working days, and ACM will be informed of the nature and substance of the complaint.

2.21 The CPULR form will be reviewed by the Director of Student Affairs or nominee. The University review will consider whether a) there has been a procedural irregularity in the investigation of the complaint by ACM, or b) any new evidence has come to light which would have had a material impact on the investigation. Discussion may be held with the student and/ or subject of the complaint and with members of staff involved in ACM’s investigation process.

2.22 Where possible, reviews should normally take no more than 21 working days to investigate from the acknowledgement being sent. The Director of Student Affairs or nominee will establish appropriate timescales based on the nature and complexity of the case. These timescales should be communicated to the student and the student kept informed of any changes.

2.23 The Director of Student Affairs or nominee will inform all parties of the proposed outcome of their investigation and give all parties the opportunity to comment. Following consideration of any comments, the Director of Student Affairs or nominee will communicate the outcome of the review, with reasons and in writing, to all parties within 21 working days.

Stage 4: (HE students only)

2.24 When the review has been concluded, the student will be issued with a Completion of Procedures (COP) letter. Following this, any student who is dissatisfied with the final decision on their case may be able to apply to the Office of the Independent Adjudicator (OIA) for Higher Education. Information and eligibility rules are available at: www.oiahe.org.uk.

University of the Arts London (UAL) Provision (FE)

2.25 This section applies to students on Level 2 and Level 3 provision at ACM whose complaints relate to their course/ award.

2.26 UAL will onIy consider a complaint from a student at a partner institution in circumstances where a student feels that there was a material or procedural error in the operation of ACM’s procedures, and the University Secretary and Registrar considers it fair and reasonable in all the circumstances to permit the complaint.

2.27 Students can find further information on UAL’s complaints procedure on their website (click here).

East Surrey College (FE)

2.28 This section applies to students on Level 2 and Level 3 provision at ACM whose complaints relate to funding.

2.29 Details on East Surrey College’s Concerns and Feedback procedure can be found on their website (click here).

Groups of Complainants

2.30 
ACM recognises that students may wish to lodge complaints collectively. In such instances students are asked to nominate one spokesperson with whom ACM staff will liaise to address the complaint. The spokesperson should endeavour to gather the views of all of the students who wish to lodge the complaint. If Stage 1 does not satisfactorily address the complaint, the spokesperson should complete a written explanation of the complaint (either a report or via the Student Complaints Form), which should be agreed by the entire group before submission. Students may opt to have their elected Student Representative act as spokesperson for the group.

Student Progression

2.31 Until the complaint is concluded, the student:

• Will be allowed to continue their studies, except under circumstances where there is a disciplinary matter involved where the student has been suspended for their own or others’ safety;
• Must continue to meet attendance, engagement, and assessment requirements for the programme.

3. POLICY OWNER

3.1 The policy lead is responsible for the cyclical monitoring and review of the policy in liaison with the Quality Assurance Team. The Student Complaints and Grievances Procedure lead is:

• Quality Assurance and Enhancement Manager

3.2 Decisions and appropriate actions in support of the implementation of the Policy will be authorised by the following designated staff:

• Quality Assurance and Enhancement Manager or nominee
• Head of Student Services
• Registry Manager
• Senior Management, including Executive Senior Management

4. SUPPORTING INFORMATION

4.1 Internal Documents

• Academic Appeals
• Academic Integrity
• Admissions
• Student Disciplinary
• Equality and Diversity

4.2 External Documents

• Middlesex University Regulations: Student complaints and grievance procedures
• University of the Arts, London: Student Complaint Procedures
• East Surrey College: Client Feedback Policy
• QAA Quality Code, Chapter B9: Academic Appeals and Student Complaints
• OfS Conditions B1 – B6

5. DOCUMENT HISTORY AND NEXT REVIEW

5.1 This procedure applies to Academic Year 2024-25

Version	3.2
Approved on	03 September 2024
Approved by	Academic Board
Date of next review	August 2025

 

Download:                Procedure 003 Complaints and Grievances AY2024-25

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