Middlesex Policies

Policy_081 Under-18 Higher Education Admissions

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Policy 081: UNDER-18 HE ADMISSIONS

INTRODUCTION

1.1 ACM is committed to equal opportunities and all applications are considered on their individual merits.

1.2 Occasionally, ACM admits students who are under the age of 18. In most cases this will be a very temporary situation, as the student will be approaching their eighteenth birthday at the time they enrol. These students and their parents/guardians should understand that ACM predominantly admits students who are over the age of 18 and that they will be entering an adult environment. ACM treats all its students as independent, mature individuals. Students who are under the age of 18 will be treated in the same way.

1.3 The usual personal and academic support arrangements will apply to students who are under 18 years old. This normally includes the allocation of a personal tutor and a comprehensive range of specialist student services.

1.4 However, ACM acknowledges that anyone under the age of 18 living in England is legally a child and recognises that students under the age of 18 may therefore have additional needs in relation to their wellbeing and require additional support.

1.5 This policy should be read in conjunction with ACM’s Safeguarding Policy and Procedure documents.

1.6 ACM does not act in loco parentis.

POLICY

2.1 ACM cannot assume parental responsibility for a student under the age of 18. In applying to ACM and accepting an offer, applicants and their parent/guardian accept that ACM is an adult environment. All ACM students are expected to behave like adults and to assume adult levels of responsibility.

2.2 In the case of students joining ACM before their 18th birthday, ACM does have an enhanced duty of care as such students are regarded as minors under English law. The following guidance seeks to ensure that the respective responsibilities of ACM and parent or guardian in relation to the applicant are clear.

2.3 ACM does not normally admit students under 16 years old.

ACM Consent Form for Applicants Under the Age of 18

2.4 It is a condition of admission to ACM that the parent or guardian of any student who is under the age of 18, confirms, by providing a signed copy of the ACM Consent Form for Applicants Under the Age of 18 before enrolment, their acceptance of the arrangements set out in this Policy.

Emergency contact (next of kin)

2.5 It is particularly important that emergency contact details are provided for students under the age of 18 and such students and/or their parents or guardians are required to supply this information prior to their registration with ACM. Students under 18 will not be allowed to register on their course unless this information is provided. For students whose parents are not in the UK, this could be a UK Guardian or close relative.

PROCESS

3.1 Where an applicant will be under the age of 18 on 1st September for the year they are joining, ACM will require the applicant’s parent or guardian to sign the ACM Consent Form for Applicants Under the Age of 18, for students under the age of 18, where they are accepting an offer from ACM.

3.2 Completing this ACM Consent Form for Applicants Under the Age of 18 confirms the parent/ guardian has read and understood the nature of the obligations which ACM owes to its students under the age of 18 and the extent of the services available to them.

3.3 No applicant under the age of 18 will be eligible to be enrolled at ACM until the Parent/Guardian ACM Consent Form for Applicants Under the Age of 18 has been signed and returned.

3.4 Where a student is an international student and their parents remain overseas, ACM requires the details of a guardian who is based in the UK.

3.5 ACM will only be able to enrol a student once they have provided details of their UK based guardian. If, however, they do not have a contact in the UK who is willing and able to act as a guardian, then there are agencies who will, for a fee, make arrangements for them. The Association of Educational Guardians for International Students (AEGIS) inspects and provides accreditation to guardianship organisations in the UK in line with current UK legislation.

3.6 Notwithstanding the need for a parent/guardian, ACM will correspond with the student, and not with parents or guardians, unless ACM receives express written permission from the student or there is a medical, criminal or similar emergency.

3.7 A UK guardian is necessary because people under the age of 18 are classified as children under English law. This means that their parents or legal guardians must make decisions on their behalf and hold legal responsibility for their protection and safety while their child is in the UK. ACM must therefore be able to contact a UK-based guardian who has been nominated by parents/legal guardians to act on their behalf and be the liaison between ACM and the parents should an emergency situation arise, or if there are serious concerns for the health or wellbeing of the person under 18.

3.8 Any adult can be a guardian. Whoever is taking on the role of guardian should ensure:

That they will be available for contact throughout the period that the child is under 18;
That they understand that they will be contacted in the case of emergency situations where they will be expected to liaise directly with the parents/legal guardians and may be expected to attend ACM premises or other location where the incident has occurred, where this is deemed necessary;
That they understand they may need to arrange for alternative accommodation at short notice should ACM be closed due to an emergency or in the unlikely event that the student is suspended from ACM due to breaches in regulations, etc;
That they understand they will need to take responsibility for any travel activities that the child arranges while in the country.

REQUIREMENTS FOR STUDENTS UNDER THE AGE OF 18

This section outlines the key requirements and expectations applicable to students who are under the age of 18 at the point of enrolment. It should be read alongside the ACM Consent Form for Applicants Under the Age of 18, which provides further detail on the responsibilities of both the student and their parent or guardian.

4.1 Parental responsibilities: As noted above, ACM is not able to take on parental responsibility for students under the age of 18. Students who are under the age of 18 years will be required to provide proof of a UK-based parent or guardian who is willing to be contacted in an emergency. Students who do not have a suitable relative in the UK will be required to register with and pay for a professional guardianship service. Students will be required to demonstrate that their guardianship contract covers the entire period until they become 18 years old.

4.2 Contracts: A student who is under the age of 18 has the status to enter into necessary contracts (e.g. for education) and will be liable for fees and charges payable under such contracts. In circumstances where a person must be aged 18 or over to be legally competent to enter into a contract, ACM requires a student’s parents/guardians to honour all obligations that the student enters into before their 18th birthday (under any contracts with ACM). This means that parents/guardians must pay any sums agreed under a contract if the under-18 student fails to do so, and where that debt was incurred when under the age of 18. Failure to pay debts that are due to ACM could result in the student’s enrolment at ACM being suspended or terminated. When students turn 18, they become liable for the fees and charges payable under such contracts.

4.3 Academic course content: Academic programmes are designed and validated to be delivered to students over the age of 18. Therefore, they may contain teaching materials that are 18-rated. If students and their parents/ guardians are concerned about the content of the programme they wish to enrol on, they are advised to discuss the content of the programme with the Executive Dean of Education.

4.4 Off-campus activities: Programmes or extra-curricular events or activities may involve travel and attendance at off-campus locations. ACM is not able to take any additional responsibility for a student who is under the age of 18 in relation to such activities. Unless indicated otherwise, by signing the ACM Consent Form for Applicants Under the Age of 18 the parent or guardian gives consent for the student to take part in these activities on that basis.

4.5 Evening events and activities: Like most higher education providers, ACM operates extended hours, which may include lectures and contact time with tutors, access to studios or rooms, or ACM-related events, any of which could extend past 6:30pm. ACM cannot undertake to supervise any student travelling to their place of residence or elsewhere either later into the evening or early morning.

4.6 Sale of alcohol and other restricted goods and services: It is illegal in the UK for alcohol and other restricted goods or services to be sold to, or bought for, students who are under the age of 18. ACM expects all students to act responsibly and abide by all applicable laws and cannot undertake to supervise any individual student.

4.7 Holding Office: Students who are under the age of 18 are encouraged to join ACM’s clubs and societies but are not able to hold office until after their 18th birthday. This is because Officers can carry legal responsibilities. The participation of under-18s in certain activities may be limited.

4.8 Relationships with staff: Under the Sexual Offences (Amendment) Act 2000, it is a criminal offence for any person in a position of trust (which may include members of ACM staff) to engage in sexual activity with someone who is under 18 years of age. ACM complies with Office for Students (OfS) Condition E6 Harassment and Sexual Misconduct, and publishes a single comprehensive source of information (SCSI) detailing all policies on harassment, sexual misconduct, and reporting procedures.

4.9 Placements: Where a student who is under 18 is required to undertake a placement as a mandatory part of the programme of study, appropriate arrangements will be made with the workplace to safeguard the student and to ensure compliance with relevant legislation, (such as Health and Safety and Working Time Regulations).

4.10 Provision of IT services: ACM offers email and internet services for all its students. These services are provided on an unsupervised basis. Students are expected to act in an adult and responsible manner when using these facilities and are required to abide by ACM’s regulations relating to the use of information technology facilities, including ACM’s Acceptable Use of IT and Online Safety Policy, and other relevant policies available at www.acm.ac.uk/policies

4.11 Non-academic Activities: Non-academic activities – a student is responsible for informing the organisers of non-academic activities in which they wish to participate that they are under the age of 18. In such cases the organiser will normally undertake a risk assessment and discuss with the student any particular concerns that arise, which may result in the student not being permitted to participate, or only with the express consent of the parent/guardian. The organiser will make any necessary special arrangements if required.

4.12 Data Protection: It is ACM’s usual policy to communicate directly with students (with whom it has a contractual relationship) and not with parents/guardians, and this approach will also apply to students who are under the age of 18 years. Although those under 18 are regarded as children under the law, they still have the right under the Data Protection Act for information about them not to be disclosed without their consent. This means that ACM is not able to give information to parents regarding the student’s progress, results or most other personal circumstances. However, if the student fails to pay any sums agreed on contracts, then it may be necessary to disclose this to any guarantor and, where applicable, to a debt collection agency.

4.13 Notification: The relevant academic department and professional services personnel will be notified, prior to registration, of any student who will be under the age of 18 on entry to ACM. Teaching and other staff will not routinely be made aware of a student’s age. A departmental risk assessment will be undertaken to ensure that appropriate safeguarding is in place for the individual student on their course. Once the student reaches the age of 18 this policy will no longer apply. At this point the student will become liable and responsible with regard to all matters.

ROLES AND RESPONSIBILITIES

5.1 The Admissions Team is responsible for ensuring that any applicant under 18 for the year they are joining receives an ACM Consent Form for Applicants Under the Age of 18 and that it is signed by the applicant, and the parent or guardian where they are accepting an offer.

5.2 In the event that the form is not signed a further reminder will be sent. A student will not be able to complete registration without the completed form.

5.3 The Admissions Team will liaise with the relevant ACM team to inform the relevant academic and professional services colleagues, prior to enrolment, of any student who will be under the age of 18 on entry to ACM.

5.4 The relevant Pathway Leader (or their delegate) will ensure that appropriate and proportionate safeguarding considerations are reflected at a departmental level for any student who is under the age of 18, including in relation to course delivery and any associated activities such as off-campus events or activities. This does not imply that ACM assumes parental responsibility. Once the student reaches the age of 18, this policy will no longer apply.

RESPONSIBLE PARTIES

6.1 The policy lead is responsible for the cyclical monitoring and review of the policy in liaison with the Policy Review Committee. The Admissions Policy lead is:

Admissions Manager

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

Admissions Manager
Admissions Officers
Academic Registrar
Executive Dean of Education
Head of International Student Affairs

REFERENCE POINTS

7.1 Internal:

Admissions Guidance
Complaints and Grievances Policy
Data Access and Protection Policy
Equality and Diversity Policy
Safeguarding Policy
Criminal Convictions Policy
Additional Needs Policy
Fitness to Study Policy

7.2 External:

ACM University Regulations, B. General Regulations for Admissions
UALab Admissions Policy
OfS Conditions B1 – B6
Data Protection Act 1998
General Data Protection Regulation (GDPR)
Public Interest Disclosure Act 1998
Crime and Disorder Act 1998
Human Rights Act 1998
Regulation of Investigatory Powers Act 2000
Rehabilitation of Offenders Act 1974
The Freedom of Information Act 2000
Protection of Freedoms Act 2012

DATE OF APPROVAL AND NEXT REVIEW

Version:	1.0
Approved on:	28 April 2026
Approved by:	Academic Board
Next Review:	August 2027

Download this policy: POL_081 Under-18 HE Admissions

Policy_080 ACM-Metropolis Visitor Student Code of Conduct

POL-080 ACM-Metropolis Visitor Student Code of Conduct

ACM’s long-standing partnership with Metropolis Studios in London gives our students access to one of the most iconic creative spaces in the world. As one of the world’s leading commercial studios, Metropolis boasts a prestigious client list which includes Kendrick Lamar, Clean Bandit, Ed Sheeran, Madonna, Amy Winehouse, Rolling Stones, Adele, Led Zeppelin, Beyonce, The Clash, Rihanna, Queen and Michael Jackson.

The ACM-Metropolis relationship is built on shared values: artistic excellence, innovation, and a commitment to nurturing the next generation of music professionals. Together, we offer experiences that go far beyond the classroom, connecting education with the heartbeat of the global music industry.

When you step into Metropolis Studios, you step into music history. The energy of that legacy is felt the moment you walk through the door, and we want every ACM student to experience the inspiration that comes from working in a space used by some of the most influential figures in modern music.

At the same time, Metropolis is a working commercial environment, and students visiting the studios are expected to treat the space – and the people within it – with the professionalism it deserves. These opportunities are not only exciting, they are a chance to practice the behaviours, standards, and etiquette expected in top-tier creative workplaces. By approaching each visit with respect and professionalism, students strengthen both their craft and their future career prospects.

With this in mind, it’s important that all students understand the expectations that accompany access to such a world-class facility. Metropolis Studios welcomes ACM students into its spaces as emerging professionals, and in return, we ask that everyone conducts themselves in a way that reflects positively on both ACM and the studio.

To ensure that every visit runs smoothly, safely, and professionally, we have outlined the core behaviours and standards required of all students attending courses, sessions, events or recording opportunities at Metropolis. These guidelines are designed to help you make the most of your experience, by respecting the people and projects around you, and by upholding the level of professionalism expected in a high-profile creative workplace.

The following points set out those expectations and should be followed at all times when representing ACM within Metropolis Studios.

Professional Studio Etiquette & Behaviour

Arrive prepared, punctual, and ready to work or observe, and be sure to represent ACM in a professional manner at all times.
Respect everyone’s role – engineers, producers, assistants, artists, runners, and other creatives.
Do not approach, speak to, or attempt to interact with Metropolis clients unless explicitly invited to do so.
Do not post about Metropolis clients on social media, and respect confidentiality regarding any projects, clients, or conversations you encounter.
Do not wander into any studio unless these are booked by ACM or you have been given explicit permission to do so.
Seek permission before touching equipment or instruments, and be sure to handle all gear carefully and only as instructed.
Observe without interrupting if you are invited to sit in on a session.
Avoid unsolicited feedback or opinions unless you are specifically invited to contribute.
Do not record or photograph anyone or anything without explicit permission.
Switch mobile devices to silent and limit their use to breaks or permitted areas.
Respect the studio schedule – break times, set-ups, and resets often run to tight timelines.
Stay aware of your surroundings, especially when people are moving equipment or running cables.
Keep food and drink away from consoles, instruments, technical areas and equipment.
Treat everyone courteously and professionally.
Avoid distracting behaviour, such as side conversations or excessive movement in control rooms.
Follow health and safety guidance, including safe lifting and awareness of fire exits, and report any issues or accidents immediately to staff or studio personnel.
Be willing to learn – take notes, observe workflows, and ask questions at appropriate times.

Please be aware that ACM’s policies continue to apply during any event, session, or opportunity held at Metropolis Studios. Failure to adhere to this ACM-Metropolis Student Visitor Code of Conduct may result in disciplinary action being taken under ACM’s Student Conduct and Disciplinary Policy, which remains fully in effect at off-campus locations. Any behaviour that breaches ACM standards while at Metropolis will be treated in the same way as if it occurred on campus, ensuring transparency, consistency and accountability across all ACM-related environments.

Policy Owner

Monitoring of the ACM-Metropolis Student Visitor Code of Conduct will be undertaken by ACM’s Head of Industry Partnerships.

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

Metropolis Studios CEO
Metropolis Studios General Manager
ACM Head of Industry Partnerships
ACM Executive Dean of Education
ACM Quality Assurance and Enhancement Manager

Supporting Policies

ACM Student Charter (Code of Conduct)
ACM Student Conduct and Discipline Policy

Document History and Next Review

Version	1.0
Approved on	25 November 2025
Approved by	Academic Board
Date of next review	August 2026

Download: POL_080 ACM-Metropolis Visitor Student Code of Conduct

Policy_ 079 Staff and Student Relationships

Policy 079: STAFF AND STUDENT RELATIONSHIPS

PURPOSE

1.1 The Office for Students (OfS) is the regulator for higher education in England. General ongoing condition of registration E6 was introduced by the OfS on 1st August 2025 and covers subject matter relating to incidents of harassment and/or sexual misconduct which affects one or more students, including the conduct of staff towards students, and/or the conduct of students towards students. Providers must maintain a single comprehensive source of information (SCSI) which sets out policies and procedures on subject matter relating to incidents of harassment and sexual misconduct, including intimate personal relationships between relevant staff members and students. This Policy and Procedure forms part of ACM’s response to condition E6.

1.2 This Policy aims to safeguard students and staff from:

Conflicts of interest (actual or potential)
Perceived conflicts of interest
Intentional abuse of power
Unintentional abuse of power
Misconduct
Alleged misconduct

1.3 This Policy forms part of ACM’s single comprehensive source of information (SCSI), which brings together information for current and prospective students and staff about how the ACM prevents and responds to harassment and sexual misconduct. It includes clear information about the ACM’s policies, how to get support, how to raise concerns, and what to expect from the processes followed by the company.

1.4 Staff should familiarise themselves with the SCSI so they can help signpost students to appropriate support and resources and understand their responsibilities in creating and maintaining an inclusive community, where students, staff and other persons are able to report behaviour that may amount to harassment and/or sexual misconduct and know this will be taken seriously.

1.5 This policy does not cover:

Staff relationships with other staff
Sexual harassment

1.6 Failure to comply with the company’s Staff and Student relationships policy may result in disciplinary action.

SCOPE

2.1 This Policy applies to all permanent, fixed term employees, variable hours workers and casual workers (unless otherwise stated within the document) except for student workers. It also applies to all those working on a self-employed basis or through a temporary contract with a recruitment agency.

2.2 This Policy supersedes all other guidelines previously issued. This Policy and related Procedure are not contractual and do not form part of the contract of employment.

2.3 This Policy does not apply to students. Their attention, however, is drawn to this Policy and the terms and requirements placed on members of staff as defined above. In particular, students’ attention is drawn to Section 9 (9.3), Section 11 and Section 12.

2.4 The company’s policies and associated documents help set out guidelines for conduct and behaviour within the working environment. There is an implied culture of two-way trust and confidence within the organisation, which governs the way in which we do things and enables colleagues to come to work with clarity regarding their priorities and decision making.

2.5 Other Policies to be read by staff in conjunction with the Disciplinary Procedure:

Investigation and Disciplinary Policy and Procedure
Staff Code of Conduct
Sexual Harassment Policy and Procedure
Safeguarding Policy and Procedure

AIMS

3.1 This policy and procedure aim to:

Set out clear expectations as to staff relationships with students
Act as part of ACM’s SCSI
Safeguard students and staff from acts of misconduct, abuse of power and conflicts of interest or allegations of these natures

CONTENTS

5 Definitions

6 Roles and Responsibilities

7 Disclosures of Relationships

8 Close Personal Relationships

9 Relationships with Students who are under 18 or are Vulnerable Adults 10 Admissions and Student Recruitment

11 Non-consensual Relationships and Behaviours

12 Advice for Students

13 Review and Ownership of the Policy

14 Further Contact and External Support

DEFINITIONS

Abuse of Power

5.1 Abuse of power is where a position of power or authority is used in an unacceptable manner. This can take various forms and may include, but is not limited to, grooming, manipulation, coercion and pressurising others to engage in conduct they do not feel comfortable with.

Close Personal Relationships

5.2 Close personal relationship excludes intimate relationships, but means a relationship where the nature, content, involvement and/or frequency of interactions and/or communications between a staff member and a student transgress the boundaries of professional conduct or may be reasonably perceived to do so.

Cooling Off Period

5.3 The Cooling Off Period, refers to the 12 month period after a student completes their course with ACM.

Grooming

5.4 A deliberate process by which someone builds a relationship, trust, and emotional connection with a child, young person, or adult at risk, in order to manipulate, exploit or abuse them.

Heads of Education

5.5 Members of Senior Management and Heads of Department that oversee the Education delivery and development, including but not limited to Academic Registrar, Executive Dean of Education, Principal of FE, Dean of Academic Practice and Quality Manager.

Intimate Relationship

5.6 Intimate relationship means a consensual relationship that involves one or more of the following elements:

Physical intimacy including isolated or repeated sexual activity;
Romantic or emotional intimacy, which may be conducted in person and/or online and/or via electronic or any other form of communication;
This includes brief relationships and one-off occurrences, through to marriage or life partnerships, regardless of gender, gender identity or sexual orientation.

Member of Staff

5.7 Any person completing work for ACM. Including those on working on a permanent, fixed term, variable hours or casual worker contract, irrelevant of department within the business.

5.8 For the purpose of this policy, member of staff also applies to those self-employed or working through a recruitment agency.

Relevant Staff

5.9 Relevant staff member means a member of staff who has direct or indirect academic responsibilities, or other direct professional responsibilities, in relation to that student.

Responsibility for a Student

5.10 Responsibility for a student is defined widely and includes any teaching, professional, pastoral or administrative responsibility or authority over a student, whether temporary or permanent, whether formally conferred on or voluntarily assumed by the staff member and whether the responsibility arises as part of the student’s involvement with ACM. This includes but is not limited to lecturing, teaching classes, overseeing projects or events, mentoring, and setting and/or marking of examinations or other assessments of any type.

Sexual Misconduct

5.11 Any unwanted or attempted unwanted behaviour of a sexual nature. More information can be found within ACM Sexual Harassment Policy and Procedure.

Student

5.12 Any person currently studying any course or qualification at ACM either onsite or virtually, or on any course arranged by ACM. This includes visiting students, applicants, and offer-holders. It covers those completing work experience or work placements. It covers all students who are registered for a course even if their status is suspended but does not include former students who have finished their courses, unless they are current applicants or offer holders for another ACM course.

Vulnerable Adult

5.13 A vulnerable adult (also referred to as an Adult at Risk) refers to a person aged 18 or over who:

Has care and support needs
Is experiencing or at risk of abuse or neglect
As a result of support or care needs is unable to protect themselves

ROLES AND RESPONSIBILITIES

6.1 All Workers:

To abide by the company’s policies and procedures
To support their fellow members of staff and students where possible
To direct students to the SCSI
To not withhold information

6.2 The Line Manager:

To ensure their team members understand and are working in line with the company’s policies and procedures
To ensure matters of concern are disclosed correctly and to act with appropriate confidentiality

6.3 HR Department:

Provide advice to line managers and members of staff in relation to the company policies and procedures.
To ensure the policy and procedure are reviewed periodically, or in line with employment law updates or changes in OfS guidance.
To support Heads of Education in their management of any disclosures made.

6.4 Heads of Education:

To support the review of this policy periodically, or in line with employment law updates or changes in OfS guidance.
To ensure that up-to-date records of declarations and conflicts of interests are maintained; and for determining and recording how to manage each.

PROHIBITION AND DISCLOSURES OF RELATIONSHIPS

7.1 From 1st September 2025:

Relevant staff members are prohibited from pursuing or entering into an intimate relationship with any current student or with any student during the cooling off period. Failure to comply with this Policy will be considered as a disciplinary matter.
Relevant staff members are strongly discouraged from having any close personal relationship with any current student or with any student during the cooling off period and must declare to the Executive Dean of Education if such a relationship has developed, is developing or appears likely to develop between them and any student. A failure to declare will be considered as a disciplinary matter.

7.2 From 1st September 2025, Relevant staff members must not take on or assume a professional responsibility for a student:

with whom they are in an existing intimate relationship or with whom they previously had such a relationship;
with whom they are in any close personal relationship or with whom they previously had such a relationship without first declaring this to the Executive Dean of Education, to enable them to assess the risk of conflicts of interest and put appropriate measures in place as necessary.

7.3 If on 1st September 2025, a Relevant staff member is already in an intimate or any close personal relationship with any student or has previously been in an intimate or any close personal relationship with any student, they should declare that relationship to the Executive Dean of Education immediately, even if the relevant responsibility for the student has ended.

7.4 If a member of staff is in an intimate or any close personal relationship with a student for whom they do not currently have any direct or indirect academic responsibilities, or other direct professional responsibilities, but where the student and member of staff are both engaged with ACM; the relationship should be disclosed to the Executive Dean of Education so they may assess the risk of any conflict of interest and put appropriate alternative and/or protective measures in place as necessary.

7.5 If it is found this Policy has been breached unintentionally, for example where a member of staff is unaware that the other party is a student, and had no reasonable basis to suspect it, the member of staff should inform the Executive Dean of Education as soon as they become aware of the situation. If a member of staff is unsure whether a relationship with a student should be disclosed under this Policy, the member of staff should disclose it.

7.6 Disclosure should be made by way of email to the Executive Dean of Education and include the following information:

Staff member’s name
Staff member’s job title
Staff member’s line manager
Student name
Student’s ID number (if known)
Student course (if known)
Nature of the relationship
When the relationship began (approx.)
Any other information the staff member feels is relevant

CLOSE PERSONAL RELATIONSHIPS

8.1. Close personal relationships are strongly discouraged and must be disclosed under paragraph 7.3 of this Policy. However, ACM recognises that the nature of the industry means it may be appropriate for staff and students for whom they have responsibility to jointly participate in informal, social activities or events, providing careful consideration is given to potential conflicts of interest, professional norms and boundaries, and to how any such behaviour might be perceived. For any queries or concerns as to whether an event or social activity could form risk, please contact the Executive Dean of Education.

8.2 This policy cannot be explicit as to every area which may be considered a risk but it is generally recognised that a situation may be considered a risk:

where a student is dependent on the member of staff in some way, which could be emotionally, practically or financially;
where the situation could be considered, or could lead to accusations of, favouritism.
Staff must be mindful of professional boundaries in all relationships with students and must act in a way which safeguards student welfare and ensures standards of academic integrity are upheld.

8.3 Even where a staff member does not have and is not likely to have responsibility for a student, staff should be very aware of and consider the potential for an actual or perceived imbalance of power or authority, accusations of bias or exploitation. The risks of such are likely to be heightened where there is a significant age difference between the staff member and the student; where the student is an undergraduate; and/or where the student is more vulnerable for any reason.

RELATIONSHIPS WITH STUDENTS WHO ARE UNDER 18 OR ARE VULNERABLE ADULTS

9.1 Members of staff who have responsibility for any students must never enter into an intimate relationship with a student or any other person under eighteen years of age or with a student who is an adult at risk, irrespective of whether the member of staff has any responsibility for the student or other person.

9.2 Staff are reminded that intimate relationships involving students (including applicants or offer-holders) under the age of eighteen where the staff member is in a position of trust or where the student is a vulnerable adult could fall within the scope of the Sexual Offences Act 2003.

9.3 Any person (staff, student or external) with any concerns as to an inappropriate relationship between an ACM member of staff and a student under the age of 18 or a vulnerable adult should raise their concerns to the safeguarding team via dsl_inbox@acm.ac.uk and consult ACM’s Safeguarding Policy and Procedure.

ADMISSIONS AND STUDENT RECRUITMENT

10.1 If an intimate or close personal relationship is pre-existing between any member of staff who has a role in selection of candidates for admission to ACM and a candidate seeking admission, that member of staff must inform the Executive Dean of Education at the outset of the admissions exercise so steps can be taken to avoid any conflict of interest. The matter will, as far as possible, be handled in a way that respects confidentiality to ensure there is no detriment to the candidate.

NON-CONSENSUAL RELATIONSHIPS AND BEHAVIOURS

11.1 If a student experiences inappropriate behaviour in breach of this Policy, is involved in a relationship that they do not consider to be consensual, or if they consider that they have been adversely affected by a misuse of power, authority, or conflict of interest, they should make a report to the Executive Dean of Education or raise a complaint through the Student Complaints procedure.

11.2 Students who need additional support or advice should contact ACM’s safeguarding team (dsl_inbox@acm.ac.uk) or ACM’s wellbeing team (wellbeing@acm.ac.uk)

11.3 Staff who believe they have experienced inappropriate sexual behaviours from a student should follow ACM’s staff Sexual Harassment policy.

ADVICE FOR STUDENTS

12.1 Members of staff should be able to direct students as to the terms of this policy and the responsibilities it places on staff. This policy will also be made available for students to view at www.acm.ac.uk/policies/

12.2 All members of staff should be able to direct students to the SCSI as required.

12.3 All staff should be aware of and be able to direct students to the Student Conduct and Discipline Policy

12.4 If an intimate or close personal relationship has developed contrary to this Policy, even if it predates the 1st September 2025, and/or the student is not sure that the member of staff has disclosed it, the student is encouraged to advise their Executive Dean of Education or any of the other Heads of Education whom they feel able to approach. However, there will be no disciplinary consequences for the student if they do not do so. The member of staff to whom the disclosure was made will be responsible for reporting the matter to the Executive Dean of Education.

12.5 Staff should be able to direct students to ACM’s Safeguarding Policy via www.acm.ac.uk/policies/

12.6 Students should pay attention to the Non-Consensual Relationships and Behaviour section of this policy (Section 11) and should be aware of the support services available through ACM and listed in paragraph 11.2

12.7 Inappropriate behaviour by a student towards a member of staff or another student that amounts to sexual misconduct, physical misconduct or abusive behaviour, or otherwise breaches ACM’s student guidelines on behaviour, may lead to action being taken under the Student Conduct and Discipline Policy.

FURTHER CONTACTS AND EXTERNAL SUPPORT

13.1 ACAS

ACAS can provide further information for members of staff relating to your rights in the workplace. For the ACAS helpline call 0300 123 1100

13.2 Police (UK)

If you or someone you know are in immediate danger, call 999
If you wish to make a non-urgent report, call 101

REVIEW AND OWNERSHIP OF THIS POLICY

14.1 This policy is owned and reviewed by the HR Department.

14.2 This policy will be reviewed by the HR Department in conjunction with the Senior Management Team on an annual basis. If there are changes in law or OfS guidance which affect this policy prior to the review date, modification may be made sooner.

14.3 If you have a concern that this policy is not being followed, you should report this at the earliest possible time to the HR Manager (hrrequests@acm.ac.uk ) or the COO.

14.4 This policy will be widely promoted via the company’s intranet, HR Self- Service System, onboarding processes and held within the company’s offices.

14.5 If you have any questions surrounding this Policy, these should be raised to a member of the HR Department via hrrequests@acm.ac.uk

Version	1.0
Approved on	01 September 2025
Approved by	Senior Management Team (SMT)
Date of next review	August 2026

Download: POL_079_Staff and Student Relationships

Policy 078: Personal Data Processed by Students

POLICY 078: PERSONAL DATA PROCESSED BY STUDENTS

PURPOSE

1.1 This guidance is intended for students undertaking research or other work involving information about living, identifiable individuals as part of their programme of study at ACM.

POLICY DETAILS

2.1 The UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 protect the rights of individuals when you process personal data about them, including obtaining, holding and destroying it.

2.2 The definition of personal data is highly complex. For day-to-day purposes, it is best to assume that all information about a living, identifiable individual is personal data. This includes any expression of opinion by or about the individual.

2.3 Students use personal data for two main reasons:

To maintain a personal life, for example to communicate with family and friends.
To pursue a course of study with the university, for example to research and write an essay, report or thesis.

2.4 Students may use many different methods to process personal data, such as maintaining an email account, a computer database, or using social media accounts.

POLICY SCOPE

3.1 Only in very limited and specific circumstances is ACM responsible for personal data processed by students (see 3.11 to 3.15), and only in these specific circumstances does it become the data controller for that data. A data controller is the person who determines the purposes for which, and the manner in which, any personal data is or is not to be processed. Therefore, ACM is only responsible for the personal data processed by its students when the students process data for the university’s purposes. In all other circumstances students process data for their own purposes and not ACM’s.

Personal, domestic and household purposes

3.2 Personal data processed in the course of a purely personal or household activity, with no connection to a professional or commercial activity, falls outside the scope of UK and EU GDPR (Recital 18). This means that where personal data is used for such things as writing to friends and family or taking pictures for your own enjoyment, students are not subject to the GDPR even if they are using ACM email accounts.

3.3 ACM is not the data controller for personal data processed by students in the course of their personal life, as ACM does not determine the purpose of the processing. The fact that students may choose to use their ACM-provided email account to pursue their personal life does not make ACM responsible for the processing of personal data for that purpose.

3.4 ACM does not determine the purpose so cannot be the data controller. Students are the data controller and may claim the so-called ‘purely personal or household activity’ exemption. Use of this exemption has the effect that data protection laws do not apply to the processing activity.

Use of personal data in pursuit of a course of study

3.5 Where a student processes personal data in order to pursue a course of study with ACM, ACM is not the data controller for the personal data processed by that student.

3.6 Students undertake a course of study with ACM for their own personal purposes, most obviously to obtain a qualification. Students are not employees or agents of ACM and neither do they act on behalf of ACM. Students decide what work they will do, the way in which they will do it and what they will include in their final submission. They must make these decisions themselves in order to prove that they are capable of Bachelors degree-level or Masters degree-level work. They do this work on behalf of themselves and not ACM. Thus, ACM cannot be the data controller for the personal data processed by students in the course of their studies.

3.7 However, the student will still be bound by the ACM’s policy and procedures due to their student contract with ACM. This means that when students are processing personal data as part of their work to pursue a course of study, ACM’s Data Access and Protection Policy (and Research Ethics Policy) applies to them, and they will be required to ensure that their work complies with the data protection principles.

3.8 This contractual duty to comply with the ACM’s Data Protection Policy extends to all work related to the course of study, even if the student contract has expired, such as a promise to inform research participants of results after the dissertation has been submitted and approved.

3.9 If a student subsequently uses the work generated during their course of study as the basis for a post as academic researcher at ACM, then ACM is the data controller for this follow-on work.

3.10 Students using personal data in their dissertation research must complete the ACM Research Ethics Form and a Participant Consent Form.

Personal data submitted to ACM as part of an assessment

3.11 When a student submits a piece of work containing personal data to ACM for assessment (e.g. a dissertation or thesis), ACM and the student become joint data controllers for the personal data contained within the submitted piece of work from the point at which it is submitted.

3.12 Once the work has been submitted, ACM is jointly responsible for the personal data within the document. For example, the member of ACM staff who marks the work is processing the personal data contained within it (by reading it) for the purpose of determining what grade ACM should award the student. This is ACM’s purpose. The legal basis for ACM using this data falls under ‘Public Task’ in Article 6 of the UK GDPR.

3.13 If the work is then transferred to the ACM library to be put on reference (for example if it is a PhD thesis), ACM is responsible for any processing of the personal data associated with the document being placed on reference. This is because providing a reference service is a university purpose.

University-led postgraduate research groups

3.14 In cases where a research student processes personal data whilst working on a project led by a university research group, the university is the data controller for personal data processed by the student. This is because the student processes personal data for the purposes laid down by the project, the remit of which has been decided by the university (or the university-employed project leader), not the student. In this scenario, the student is an agent of the university. This is the case whether the student is funded by the research project or whether the student is self-funding. The legal basis for ACM using this data falls under ‘Public Task’ in Article 6 of the UK GDPR.

University-sponsored studies

3.15 In cases where a university is a sponsor or co-sponsor of a study, and where a research student processes personal data in order to pursue a course of study in connection with that (co-)sponsored study, the university is the data controller. The legal basis for ACM using this data falls under ‘Public Task’ in Article 6 of the UK GDPR.

GOOD PRACTICE IN USING PERSONAL DATA RESPONSIBLY

4.1 The following steps are examples of good practice in using personal data responsibly:

Before you start your research, consider carefully what personal data you need to collect for your dissertation or thesis and obtain the consent of your supervisor.
Obtain ethical consent from the data subject. For research this will usually be in writing. Discuss with your supervisor any concerns about obtaining consent before collecting personal data. Be aware that collecting personal data before consent is obtained may be treated as academic misconduct.
Give a clear explanation of what you are going to do with the data to the people participating in your research.
Do not collect or keep data that is not necessary for your research. Anonymise data where possible by removing names and other identifying information.
Ensure that all personal data, especially opinions, is recorded accurately.
Respect reasonable requests to update or delete data you have collected.
Store personal data securely. Password protection and restricting access to drives is good practice. If you are using information that is already public knowledge such as the names of Grammy award winners, you will not need to take any security measures. However if you are recording less public information, you must ensure that the information is secure.
Do not disclose personal data to anyone except the individual concerned.
Securely destroy personal data when it is no longer necessary for your research. Consult the Assessment Regulations to confirm how long you will need to retain research data for (usually one calendar year).
Be aware of required safeguards for international transfers of personal data outside of the UK.

5. RELATED POLICIES

5.1 Internal

Data Access and Protection Policy
Research Ethics Policy

5.2 External

Data Protection Act 2018 (DPA 2018)
UK General Data Protection Regulation (GDPR)

POLICY OWNER

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:

Quality Assurance and Enhancement Manager
ACM Research Ethics Chair
ACM Research Supervisors

DOCUMENT HISTORY AND NEXT REVIEW

Version	1.0
Approved by	Academic Board
Approved on	20 March 2025
Review due	August 2026

Download: Policy_078 Personal Data Processed by Students

Procedure 077: Emergency Lockdown

Procedure 077: EMERGENCY LOCKDOWN

Purpose:
This emergency lockdown procedure is designed to ensure the safety of students and staff in the event of a major incident outside of ACM buildings. The procedure will be enacted upon notification from the police or relevant authority that an emergency lockdown is necessary.

Please note: where ACM uses premises operated or managed by a third party, e.g. Brixton House and The Bridge, the lockdown procedures of the building management shall be followed.

What is lockdown?

Instigating lockdown means locking doors and other physical barriers to restrict entry to and/or exit from a site or one or more zones within a site. It is sometimes referred to as `dynamic lockdown’.

Why instigate lockdown?

Analysis of historic attacks, including the attack on London Bridge and Borough Market in 2017 and research conducted by the Centre for the Protection of National Infrastructure (CPNI) have shown that instigating lockdown in the event of a marauding terrorist attack (MTA) can be a highly effective way of reducing casualties.

It is typically most useful when an attack begins outside a site or building, where lockdown can delay attackers from entering an area or deter them altogether. The aims of lockdown are to reduce the immediate threat of harm by:

Delaying attackers’ progress in finding and killing victims;
Preventing people inadvertently putting themselves into the path of attackers.

1. Initiating the Lockdown

Upon receiving notification from the police or other relevant authority that an emergency lockdown is required, or when we assess the need ourselves, ACM’s security or designated person will immediately inform key stakeholders in each of ACM’s buildings via the walkie-talkie system.
The key stakeholders in each building (e.g. senior staff, designated lockdown coordinators) will communicate the lockdown to all staff and students within their respective buildings.
It is recommended that students and staff follow the instructions of the key stakeholders as part of this lockdown procedure. However, Article 5 of the Human Rights Act 1998 protects the right not to be deprived of liberty or freedom unless it is in accordance with the law. It should therefore be understood that all individuals have the right to make their own decisions at any time as to whether they remain on ACM premises under lockdown or not.

2. Securing the Premises

The designated staff in each building will secure the premises as follows:

Buildings with a single entrance/exit: the designated staff member will secure the front door.
Buildings with multiple entrances/exits: designated staff will simultaneously secure each entrance and exit.

All external doors will be locked where possible to prevent entry.
Windows must be closed and locked where possible.
Blinds or curtains should be drawn where available.
All individuals must move away from windows and doors, remaining out of sight where possible.
Internal movement should be minimised; individuals should remain in classrooms, offices, or designated safe areas.
Staff and students should remain calm and quiet to avoid drawing attention.

3. Communication During Lockdown

The lockdown status will be maintained through ongoing communication via the walkie-talkie system.
ACM’s security and/or safeguarding team will liaise with the police for updates and guidance.
Staff should monitor their emails and other official communication channels for further instructions.
Mobile phones should be placed on silent mode to prevent unnecessary noise but kept accessible for emergency use.

4. Registering Students

Each classroom/office should take a register of all present individuals and report any absentees to the designated lockdown coordinator via email or internal communication systems.
Any discrepancies should be reported to the safeguarding team, who will liaise with the police if necessary.

5. Students or Staff Outside the Building

Whilst every care will be taken to safeguard students, it is important to note that ACM does not act in loco parentis for students.
Any students and staff visible outside at the time of locking down should enter, or will be instructed to enter, the nearest ACM building immediately.
Students or staff who are not in view and are off the premises should follow the ProtectUK guidance:
- Run: If there is a safe route, escape to a place of safety.
- Hide: If escape is not possible, hide and stay silent.
- Tell: Once safe, inform the police by calling 999.

6. Lifting the Lockdown

The lockdown will only be lifted when it is deemed appropriate to do so, such as from direct instruction from the police or relevant authority.
ACM security will communicate the all-clear signal via the walkie-talkie system.
The designated staff will relay the all-clear message to staff and students in each building.
A final headcount will be conducted to account for all students and staff before resuming normal operations.

7. Post-Lockdown Actions

A debrief session will be held for staff and key stakeholders to evaluate the lockdown response.
Students will be offered appropriate support, including counselling if required.
Any necessary amendments to the procedure will be made based on feedback and lessons learned.

Review and Training

This procedure will be reviewed annually and updated as required.
Regular training will be conducted to ensure preparedness.

Supporting Information for this Procedure

10.1 Internal

ACM Run, Hide, Tell Policy
ACM Prevent Policy

10.2 External

ProtectUK Advice and Guidance on Emergency Preparedness

https://www.protectuk.police.uk/about-protectuk

Document History and Next Review

Version	1.0
Approved on	01 September 2025
Approved by	Academic Board
Date of next review	August 2026

Download: PRO_077 Emergency Lockdown_v1.0

Policy 075: Student Use of Artificial Intelligence

POLICY 075: Student Use of Artificial Intelligence

SCOPE

1.1 This policy applies to all students enrolled on programmes at ACM, including all FE provision and all HE provision, including Foundation programmes, Integrated Masters programmes and Masters programmes.

INTRODUCTORY STATEMENT AND POSITION

2.1 ACM believes that AI tools are transformative and disruptive, and that they will feature in many academic and professional workplaces. As an institution, ACM is committed to exploring ways in which it can utilise AI to support and facilitate deeper learning.

2.2 Rather than seek to prohibit the use of AI tools, ACM will support students in using them effectively, ethically and transparently. Tools such as ChatGPT, Quillbot, CoPilot and Grammarly can help students in a number of ways. Examples might include:

Drafting your own ideas, and planning or structuring written materials.
Generating graphics, images and visuals to support your work
Helping to improve grammar and writing structure – especially helpful if English is a second language.
Deriving explanations.

STUDENT RESPONSIBILITIES

3.1 Whilst AI tools are powerful and easy to use, they can negatively impact your learning as they can detract from the reflection and critical engagement that are essential for deep and meaningful learning.

3.2 AI tools can also easily provide misleading or incorrect information. Students who rely on these tools too much risk losing their own skills and expertise, and may struggle to study or work without them.

3.3 Students should be aware that tools such as those listed in 2.2, whilst useful, can lead a student to commit academic misconduct if content is created that is not the student’s own. These tools, and others, are multi-functional. It is the student’s responsibility to use these tools in a way that upholds academic integrity and to ensure you do not commit academic misconduct.

Academic Integrity

3.4 To our students we say: Be enquiring, be conscientious, be honest. Although the use of AI simplifies studying in many ways, it must not lead you to neglect your study efforts and rely on the outputs provided by these tools – keep academic integrity uppermost in your mind because academic misconduct can negatively impact your progression and final award.

3.5 Students must always ensure they demonstrate academic integrity in their work. This means employing good judgement to ensure that AI has been used appropriately and without gaining an inappropriate advantage. It is crucial that you do not use AI tools to generate work, including sections of written work, and submit it as if it was your own. This will be considered academic misconduct. As a result, submission of such work may result in your work receiving a fail grade, having to redo your work with a penalty to your grade, or even withdrawal from the course.

Know the Limitations of Artificial Intelligence

3.6 The use of AI has clear limitations. For example, currently available AI tools can:

Only simulate understanding.
‘Hallucinate’ to create plausible sounding but factually incorrect answers.
Inherit bias and viewpoints from the training material.
Use information that is not always up to date.

3.7 AI tools are not reliable sources. Think of them as the equivalent of asking a random stranger on the street something: the information they provide might be taken from any number of inaccurate, misleading, or misremembered sources, but made to sound convincing.

Writing Style and Academic Writing

3.8 ACM is aware that students, especially those new to Higher Education, may struggle with Academic Writing and the purpose of such writing as a skill set. Academic writing is about presenting existing, trusted sources that support your own ideas, which are themselves based on your research and/or your experiences throughout your learning.

3.9 The academic writing approach allows you to deliver this as a body of work that is coherent and easily accessible by a university marker. But this is different to, and does not mean, using unnecessarily fancy words to make your work sound ‘smarter’. In fact, we have already seen instances of student work that has supposedly been ‘improved’ by AI actually become less coherent, or less in line with the Assessment task, due to an over-reliance on sounding ‘academic.’

3.10 Make sure you focus on the substance required of the assessment brief and the learning outcomes. Speak to your tutors, who are there to support you, about what the assessment is actually asking for.

3.11 It is a breach of academic integrity to blend AI-generated content with your own content.

Declaration of AI Use

3.12 Students should never pass off ideas or text taken from AI as their own, and there should be a clear acknowledgement of how AI has been used in the work. Your assessment briefs require you to complete a Declaration of Authenticity. This includes a statement on the use of AI and now takes the form of a Canvas ‘Quiz’.

3.13 Completing the Declaration of Authenticity is a mandatory requirement of the submission process. You should complete this declaration whether you have used AI in your submission or not. It is important to be aware that any suspected AI use in a submission that is not accompanied by an appropriate declaration will be flagged for potential Academic Misconduct.

AI Detection Tools

3.14 ACM employs the latest AI detection software, which includes Turnitin’s AI detector tool, as a component of our academic compliance procedure, though this is not our sole point of reference.

Keeping Drafts of your work

3.15 Should you feel the need or desire to improve your work through AI in an acceptable manner, such as those outlined in paragraph 1.3 above, it is good practice and in your own interests to keep drafts of your work before the influence of AI. This will be requested as a part of the Academic Misconduct investigation should there be any suspicion of over-reliance on AI in your work, particularly where there is no Declaration of Authenticity apparent. Being able to show how your drafts led to the finished work is a positive way of working with the academic integrity process.

3.16 ACM provides unlimited storage in Google Drive to every student. It is good practice and in your own interest to create, draft and store your work in your Google Drive, thereby maintaining transparency and a clear record of document creation.

OTHER RELEVANT DOCUMENTS

4.1 Internal Documents

Policy 007 Academic Integrity
Policy 012 Learning, Teaching, Assessment and Attainment
Policy 061 Student Engagement and Participation
Harvard referencing guide found on the student Canvas page

DATE OF APPROVAL AND NEXT REVIEW

5.1 This policy applies to Academic Year 2024-25

Version	1.0
Approved on	01 September 2025
Approved by	Academic Board
Date of next review	August 2026

Download: POL_075 Student Use of Artificial Intelligence

Policy 064: Sexual Misconduct

Policy 064: SEXUAL MISCONDUCT

1. PURPOSE

1.1 This Policy outlines ACM’s approach to providing a campus environment in which all members of our community feel safe from sexual misconduct.For the purposes of this policy, this includes sexual harassment, whether explicitly stated or not.

1.2 This Policy sets out our expectations around the unacceptability of sexual misconduct.

1.3 This Policy makes clear the ways in which ACM supports students who have experienced any form of sexual misconduct.

2. POLICY DETAILS

2.1 The Academy of Contemporary Music (ACM) is committed to safeguarding and promoting the welfare of all students, staff, visitors and guests and acknowledges its particular responsibilities to children, young people and adults at risk.

2.2 All staff within ACM have a responsibility to be involved in contributing to a culture in which safeguarding is embedded, discussed openly and risk proactively reduced. Every member of staff is DBS checked prior to commencing employment, and again every three years, and all staff members must complete training in the following areas:

Safeguarding Young People
Mental Health Awareness in Children & Young People
An introduction to GDPR
Health and Safety in Education Awareness
The Prevent Duty
First Aid Essentials

Members of the ACM safeguarding team also have further awareness and training regarding the following areas:

Protecting Children from Child Sexual Exploitation
Sexual Violence and Harrasment between Children and Young People
Understanding and Working with people affected by Sexual Abuse

2.3 ACM takes a zero tolerance approach to sexual misconduct and sexual harassment, and will support anyone in the ACM community who is subject to any form of sexual misconduct, as per the details in the accompanying Sexual Misconduct Procedure.

2.4 ACM will ensure that reporting parties are responded to in a safe, supportive and trusting environment, as per the details in the accompanying Sexual Misconduct Procedure.

2.5 ACM will educate and support all staff and students to understand:

what sexual misconduct is and that it is not tolerated;
what consent is; and
when consent is, and is not, given.

2.6 ACM will make clear how to disclose sexual misconduct, in person, online and anonymously, what options are available and the support that can be provided, via a clear and robust procedure.

2.7 ACM will ensure that all relevant staff are informed of how to receive and signpost a disclosure of sexual misconduct in a sensitive way. Empower those who disclose an experience to choose which options are best for them and provide access to expert professional support

2.8 ACM will set out all options and processes clearly and transparently. This includes the option to not make a formal complaint.

2.9 ACM will ensure that all relevant staff are provided with training to enable them to support and advise a student who has experienced sexual misconduct.

2.10 ACM will respect the sensitivity of disclosures of sexual misconduct and their consequences, and treat any disclosure confidentially, in line with our Data Protection Policy and the ACM’s duty of care under safeguarding.

2.11 Within Disciplinary Proceedings, ACM will ensure fairness to both Reporting and Responding parties.

2.12 ACM will ensure that all communications are sufficiently clear and detailed, and accurately reflect any decisions made.

2.13 ACM will learn from our experiences and regularly review this policy informed by data trends and with input from independent external experts to ensure it remains relevant.

3. POLICY SCOPE

3.1 The policy applies to all members of the ACM community, including students at all levels and campuses, staff, applicants, associate members, visitors, contractors and volunteers.

3.2 This Policy applies to sexual misconduct which:

occurs on ACM’s property and/or land;
occurs whilst a student is engaged in any ACM related activity (including placements and trips);
occurs via electronic means including, but not limited to: internet, email, social media sites, chat rooms, text messages and instant messaging;
results in a legal or police investigation, charge or conviction of an offence;
in the view of ACM poses a serious risk or disruption to the institution or members of its community.

3.1 ACM recognises that sexual misconduct can be experienced by any individual, regardless of sex, gender, sexual orientation, relationship status, age, disability, faith, race, ethnicity, nationality or economic status.

3.2 Experiences of sexual misconduct may intersect with other forms of discrimination and harassment, for example in relation to sex, gender, sexual orientation, relationship status, age, disability, faith, ethnicity, nationality or economic status.

3.3 ACM has policies on Equality, Discrimination and Inclusion and does not tolerate any forms of bullying or harassment. ACM does not tolerate behaviour or attitudes supportive of sexual misconduct.

Freedom of Speech

3.4 ACM has a statutory duty to protect the lawful speech of all staff, students and visiting speakers, which includes protecting the right to express views that are controversial or unpopular. However, vigorous debate does not mean students should be expected to tolerate harassment. Speech or other expression that amounts to harassment is not protected. ACM promotes a culture that is open and tolerant of differences, and students can expect to be able to take part in all aspects of university life without being harassed.

4. RELATED POLICIES

Safeguarding Policies
Safeguarding Procedures
Staff Code of Conduct
Staff-Student Relationship Policy
Student Charter
Data Protection Policy
Prevent Policy
External Speaker and Events Policy
Acceptable Use of IT and E-Safety Policy
Social Media Policy
Student Disciplinary Policies
Student Complaints and Grievances Policy
Equality & Diversity Policy
Staff Recruitment Policy
Health & Safety Policy
Whistleblowing Policy
Criminal Convictions Policy

5. POLICY OWNER

5.1 The responsibility for this Policy falls under the remit of the Designated Safeguarding Lead, overseen by the Student Experience and Opportunity Board.

5.2 The responsible committee will ensure the cyclical review of this Policy is carried out under ACM’s Quality Assurance Framework.

6. DEFINITIONS

Sexual Misconduct: Sexual Misconduct covers a broad range of inappropriate and unwanted behaviours of a sexual nature. It covers all forms of sexual violence, including sex without consent, sexual abuse (including online and image-based abuse), non-consensual sexual touching, sexual harassment (unwanted behaviour of a sexual nature which violates your dignity; makes you feel intimidated, degraded or humiliated or creates a hostile or offensive environment), stalking, abusive or degrading remarks of a sexual nature, and a vast range of other behaviours.

Consent: Consent is the agreement to participate in a sexual act where the individual has both the freedom and capacity to make that decision. Consent cannot be assumed on the basis of a previous sexual experience or previously given consent, and consent may be withdrawn at any time.

Freedom to consent: For consent to be present, the individual has to freely engage in a sexual act. Consent is not present when submission by an unwilling participant results from the exploitation of power, or coercion or force, regardless of whether there is verbal or physical resistance.

Coercion or Force includes any physical or emotional harm or threat of physical or emotional harm which would reasonably place an individual in fear of immediate or future harm, with the result that the individual feels compelled to engage in a sexual act.

Capacity to consent: Free consent cannot be given if the individual does not have the capacity to give consent. Incapacitation may occur when an individual is asleep, unconscious, semi-conscious, or in a state of intermittent consciousness, or any other state of unawareness that a sexual act may be occurring. Incapacitation may also occur on account of a mental or developmental disability, or as the result of alcohol or drug use.

Alcohol and/or Drug Use: Incapacitation arising from alcohol or drug consumption should be evaluated on the basis of how the alcohol/drugs have affected the individual; signs of incapacitation may include, but are not limited to, one or more of the following: slurred speech, unsteady gait, bloodshot eyes, dilated pupils, unusual behaviour, blacking out, a lack of full control over physical movements, a lack of awareness of circumstances or surroundings, and/or an inability to communicate effectively. Intoxication is never a defence for committing an act of Sexual Violence and Misconduct, or for failing to obtain consent. If there is any doubt as to the level or extent of one’s own or the other individual’s incapacitation, the safest approach is to not engage in a sexual act.

Disclosure: Disclosure means that an individual tells a member of the ACM community that they have experienced Sexual Misconduct (this is different from a formal Complaint).

Formal Complaint: Submitting a formal Complaint to ACM regarding an individual’s experience of Sexual Misconduct is an instruction for ACM to take appropriate action. The Complaint will allow ACM to investigate the misconduct as set out in this Policy and the accompanying processes.

Reporting Party: The Reporting Party is the person(s) who has made a formal Complaint regarding an experience of sexual misconduct.

Responding Party: The Responding Party is the person(s) named in a formal Complaint who is alleged to have committed an act of sexual misconduct.

Safeguarding: Safeguarding is the action that is taken to promote the welfare of all people and protect them from harm.

Sexual Harassment: Under the Equality Act 2010, sexual harassment is unwanted conduct of a sexual nature. It has the purpose or effect of violating the dignity of a worker, or creating an intimidating, hostile, degrading, humiliating or offensive environment for them. Something can still be considered sexual harassment even if the alleged harasser didn’t mean for it to be. It also doesn’t have to be intentionally directed at a specific person.

Abuse: any action that intentionally harms or injures another person

DSL: Designated Safeguarding Lead is the member of staff that coordinates all safeguarding concerns and oversees all referrals.

DDSL: Deputy Designated Safeguarding Lead is the member of staff who supports the DSL in maintaining the function of safeguarding throughout all campuses.

LADO: Local Authority Designated Officer

7. PROCEDURES

7.1 The details of the procedures relating to this Policy can be found in the accompanying procedure document.

8. EXHIBITS/APPENDICES/FORMS

8.1 This Policy has been written with reference to the following statutory guidance and legislation. For the avoidance of doubt, it should be noted that UK law carries ultimate authority:

Keeping Children Safe in Education (DfE, 2021)
Working Together to Safeguard Children (HM Government, 2018)
What to do if you’re worried a child is being abused (DfE, 2015)
Child sexual exploitation; definition and guide for practitioners (DfE, 2017)
Sexual violence and harassment between children in schools and colleges (DfE, 2018)
The Children Act 2004 (with later amendments),
Safeguarding Vulnerable Groups Act 2006
The Sexual Offences Act 2003
Guidance for English Higher Education Institutions (HEIs) (DIUS, 2007)
Protection of Freedoms Act 2012
Children and Families Act 2014
Care Act 2014
Equality Act 2010
Protection from Harassment Act 1997
Office for Students (OfS) condition E6 Harassment and Sexual Misconduct;
Information sharing: advice for practitioners providing safeguarding services to children, young people, parents and carers (HM Government, July 2018)

9. SUPPORTING INFORMATION

9.1 There are no further supporting documents to this Policy.

10. DOCUMENT HISTORY AND NEXT REVIEW

Version: 1.2

Approved on: 01 Sep 2025

Approved by: Academic Board

Date of next review: August 2026

Download: POL064_Sexual Misconduct Policy

Procedure 064: Sexual Misconduct

1. PURPOSE

1.1 This procedure outlines ACM’s approach to providing a campus environment in which all members of our community feel safe from sexual misconduct. For the purposes of this procedure, this includes sexual harassment, whether explicitly stated or not.

1.2 This procedure sets out our expectations around the unacceptability of sexual misconduct and sexual harassment.

1.3 This procedure makes clear the ways in which ACM supports students who have experienced any form of sexual misconduct or sexual harassment.

2. PROCEDURE DETAIL

This document outlines our specific Process for handling allegations of sexual misconduct and sexual harassment.

Making a Disclosure
2.1 A disclosure is made when someone tells a member of ACM Safeguarding Team that they have experienced sexual misconduct or sexual harassment. A disclosure can be made in person, online or via other means such as phone or email.

2.2 Students can make disclosures of sexual misconduct or sexual harassment via ACM’s online reporting disclosure link. Where a member of staff has received a disclosure in person or via other means, they may submit a disclosure on behalf of the person who has disclosed via ACM’s online reporting disclosure link.

2.3 The person who has chosen to disclose does not need to provide the full details of their experience if they do not wish to. They will not be pressured to make a formal complaint.

2.4 If the incident is historical, the person who has experienced it can still disclose it to the ACM safeguarding team and receive support. They can access Wellbeing Support Services, which will be offered.

2.5 Disclosure does not create a formal complaint and is not an instruction for ACM to take action. The person who has disclosed will have the opportunity to be heard and to consider their options before proceeding with any further steps. No action will be taken immediately by ACM unless there is a concern about immediate safety or if ACM has a duty under safeguarding.

2.6 Where a person chooses to disclose anonymously via ACM’s online reporting tool, no action will usually be taken on the basis of their disclosure. Anonymised data will help ACM to understand patterns in behaviour and inform future policy.

2.7 Where a person chooses to disclose, with contact details, via ACM’s online reporting tool, their disclosure will be received by the ACM safeguarding team. The person who has made the disclosure will be contacted by a member of the safeguarding team as soon as is practical to do so.

2.8 Where a disclosure is made but is not submitted via ACM’s online reporting tool, the person who has disclosed can still access support via Wellbeing Support Services.

2.9 The Academy of Contemporary Music recognises the importance of privacy for disclosures and formal complaints of cases of sexual misconduct and will only share information on a confidential, need-to-know basis. All personal data is recorded and held in accordance with the Data Protection Act 2018. ACM will retain anonymised data to understand patterns of behaviour and to inform future policy.

2.10 Confidentiality is not absolute secrecy. There may be circumstances where it is necessary or appropriate to share information either within ACM or with external organisations/bodies, for example to:

Allow a case to be appropriately considered and investigated;
Ensure those who disclose an experience or are alleged to have committed misconduct receive appropriate academic and pastoral support;
Safeguard members of the ACM community and fulfil ACM’s duty of care;
Discharge ACM’s duties or as required by law.

3. IMMEDIATE THREATS TO SAFETY

3.1 If after reviewing a disclosure submitted via the ACM’s online reporting tool, the ACM safeguarding team believes that there is a danger to the person who has disclosed or to anyone else, they will refer the disclosure to the ACM executive team along with a risk assessment.

3.2 If the ACM executive team decides via a risk assessment that it is necessary to take precautionary action, it will make a recommendation to the Registrar who will enact these measures. Such measures may include issuing a suspension of rights to restrict the person alleged to have committed the misconduct contact with the person who has disclosed, including restriction of access to campus facilities, and making a recommendation to the ACM safeguarding team regarding appropriate action.

3.3 If a suspension of rights is issued, the person alleged to have committed the misconduct will be informed in writing and, wherever possible, in person. They will be told what they need to do in order to comply with the suspension of rights. They will be assigned a member of the student services team, who will be their main point of contact.

3.4 If no suspension of rights is required, the person alleged to have committed the misconduct will not be informed of the disclosure or assigned a member of the student services team unless the person who has disclosed chooses to either pursue an informal resolution or submit a formal complaint to ACM.

4. STUDENT SUPPORT

4.1 ACM will assign a member of the student support team to the person who has made the disclosure. The member of the student support team will be the main point of contact throughout any subsequent steps, and will be able to help the person who has disclosed to make informed decisions about what happens next.

4.2 The member of the student support team does not represent the person they are assigned to within any subsequent Discipline Committee hearings. They are available to listen, to provide information and to facilitate practical support.

4.3 The member of the student support team will take into account the communications preferences of the person they are assigned to, and wherever possible will communicate key information in person, unless the person they are assigned to wishes otherwise.

4.4 The member of the student support team will contact the person who has made the disclosure as soon as is practical to do so to arrange a First Discussion Meeting between them and the member of the student support team. This will enable the person who has disclosed to talk about what they would like to happen. The member of the student support team will help them to consider the options and support available, to understand the role of the student support team, and to explore possible outcomes.

4.5 The outcome of an investigation, Discipline Committee hearing or Appeal will be shared with both parties and this will include setting out the rationale for the decision.

5. MALICIOUS REPORTS

5.1 Whilst extremely rare, the possibility of malicious reporting is recognised. ACM takes every disclosure seriously but reserves the right to cease consideration of a disclosure if it considers it to be malicious, vexatious or frivolous. In such cases, a member of the Safeguarding Team or its nominee will write to the reporting party explaining why consideration of the disclosure is being halted. This decision will be final.

6. CONDUCT

6.1 ACM recognises the possibility of retaliation against any individuals associated with a disclosure or formal complaint of sexual misconduct, including the Reporting Party, witnesses, the Responding Party, and staff.

6.2 Any retaliation will be dealt with under ACM disciplinary procedure as per policy.

6.3 If there is a further incident of sexual misconduct, anti-social behaviour or any other behaviour which breaches ACM’s regulations that occurs whilst an investigation is being conducted under the Sexual Misconduct Policy, this may be considered as an aggravating factor and taken into account during decision-making.

7. OPTIONS FOLLOWING DISCLOSURE

7.1 After disclosure there are several options available to the person who has disclosed their experience. They can choose the level and types of support that are right for them.

7.2 After discussion with their member of student support the person who has disclosed may choose to:

7.2.1 Take no further action at this time: In this case advice will be provided regarding the preservation of evidence which may be needed if they subsequently decide to make a report to the Police or to submit a formal complaint to ACM. They will also be informed of the ongoing support available to them via the student support team, Wellbeing Support Services and the safeguarding team.

7.2.2 Undertake an informal resolution: This option is dependent on the person alleged to have committed the misconduct being willing to participate. The member of student support assigned to the person who has disclosed will facilitate an informal resolution in collaboration with services such as Wellbeing Support Services and the safeguarding Team.

7.2.3 Make a report to the Police: In this case no disciplinary action will normally be taken by ACM whilst a Police investigation and legal proceedings are taking place, although ACM reserves the right to investigate and take action if it deems it necessary. Support will however still be available from the Wellbeing Support Services and the Safeguarding team.

7.2.4 Make a formal complaint to ACM: If the person who has disclosed chooses this option they will be asked to confirm that they wish ACM to proceed with a formal investigation. Support will be available from the Wellbeing Support Services and the Safeguarding team.

8. INFORMAL RESOLUTION

8.1 The person who has disclosed can always choose to make a formal complaint even if they have chosen informal resolution, and vice versa.

8.2 Where an informal resolution is appropriate, a member of student support will be assigned to the person alleged to have committed the misconduct. This will be a different member of student support to that assigned to the person who has made the disclosure.

8.3 The member of student support will arrange for the informal resolution to take place, in collaboration with services such as Wellbeing Support Services and the safeguarding team.

8.4 Informal resolution can only go ahead on the mutual agreement of both parties. The member of student support will follow up to check that the informal resolution has taken place, however as the allegation has not been proven they cannot enforce compliance.

8.5 Informal resolution may include, but is not restricted to, the following outcomes:

8.5.1 Written apologies

8.5.2 Attendance at awareness sessions

8.5.3 Participation in behavioural change programmes

8.5.4 No contact agreements

8.5.5 Any other penalties which are not punitive in nature

9. POLICE INVESTIGATION AND LEGAL PROCEEDINGS

9.1 If the person who has disclosed has made an independent report to the police they may still make a formal complaint to ACM.

9.2 ACM does not have the legal investigatory powers of the Police, and is not able to make a determination of criminal guilt.

9.3 Any disciplinary action is undertaken as a breach of ACM’s Sexual Misconduct Policy and is not a substitute for a Police investigation or a criminal prosecution.

9.4 The fact that criminal proceedings have been instituted or have concluded does not preclude ACM from taking its own disciplinary action, if it is thought fitting or necessary to do so.

9.5 The fact that the Police are unable or unwilling to proceed does not preclude ACM from taking its own disciplinary action.

9.6 A case which does not progress through legal channels, where a decision to take no further action has been made, and/or a ‘not guilty’ verdict has been returned, does not mean that the person has made a malicious or vexatious report.

9.7 The fact that criminal proceedings have returned a ‘not guilty’ verdict does not preclude ACM from taking its own disciplinary action.

9.8 If a student has been convicted of a criminal offence or accepts a Police caution in relation to behaviour that falls within the scope of ACM’s Sexual Misconduct Policy, then ACM will accept this as conclusive evidence that the behaviour took place. It may not be necessary for a further full investigation to take place and the complaint will be deemed proven and proceed directly to mitigation.

10. MAKING A FORMAL COMPLAINT TO ACM

10.1 The person who has experienced sexual misconduct may choose to make a formal complaint to ACM under the Sexual Misconduct Policy, and thereby seek a resolution via the ACM Disciplinary Procedure. A formal complaint is different to disclosure; it is a document informing ACM that something has happened and that the person who has made the complaint wishes ACM to take action. From this stage onwards, the person who has submitted the complaint is referred to as the Reporting Party, and the person who is alleged to have committed the misconduct is referred to as the Responding Party.

10.2 The complaint must be submitted via the online disclosure link. The complaints form may be completed by the Reporting Party, or if they prefer, someone can complete it on their behalf. The safeguarding team and Wellbeing Support Services can all provide help in completing the form.

10.3 The complaints form does not need to include in-depth detail about the experience. There does however need to be enough information so that ACM can take the complaint forward and understand what has happened.

10.4 The complaints form will be referred to the Student Discipline team. ACM will not take any action without the involvement of the Reporting Party unless there is an immediate threat to safety.

10.5 The Reporting Party has the right to withdraw their complaint and to stop the formal Sexual Misconduct Disciplinary Process at any time.

Freedom of Speech

10.6 ACM has a statutory duty to protect the lawful speech of all staff, students and visiting speakers, which includes protecting the right to express views that are controversial or unpopular. However, vigorous debate does not mean students should be expected to tolerate harassment. Speech or other expression that amounts to harassment is not protected. ACM promotes a culture that is open and tolerant of differences, and students can expect to be able to take part in all aspects of university life without being harassed.

11. PROCEDURE SCOPE

11.1 The procedure applies to all members of the ACM community, including students at all levels and campuses, staff, applicants, associate members, visitors, contractors and volunteers.

11.2 This procedure applies to sexual misconduct which:

occurs on ACM’s property and/or land;
occurs whilst a student is engaged in any ACM related activity (including placements and trips);
occurs via electronic means including, but not limited to: internet, email, social media sites, chat rooms, text messages and instant messaging;
results in a legal or police investigation, charge or conviction of an offence;
raises questions about the fitness of the student on a fitness to practice programme; or
in the view of ACM poses a serious risk or disruption to the institution or members of its community.

11.1 ACM recognises that sexual misconduct can be experienced by any individual, regardless of sex, gender, sexual orientation, relationship status, age, disability, faith, race, ethnicity, nationality or economic status.

11.2 Experiences of sexual misconduct may intersect with other forms of discrimination and harassment, for example in relation to sex, gender, sexual orientation, relationship status, age, disability, faith, ethnicity, nationality or economic status.

11.3 ACM has policies on Equality, Discrimination and Inclusion and does not tolerate any forms of bullying or harassment. ACM does not tolerate behaviour or attitudes supportive of sexual misconduct.

12. RELATED POLICIES

Safeguarding Policies
Safeguarding Procedures
Staff Code of Conduct
Student Charter
Data Protection Policy
Prevent Policy
External Speaker and Events Policy
Acceptable Use of IT and E-Safety Policy
Social Media Policy
Student Disciplinary Policy
Student Complaints and Grievances Policy
Equality & Diversity Policy
Staff Recruitment Policy
Health & Safety Policy
Whistleblowing Policy
Criminal Convictions Policy

13. PROCEDURE OWNER

13.1 The responsibility for this Policy falls under the remit of the Designated Safeguarding Lead, overseen by the Student Experience and Opportunity Board.

13.2 The responsible committee will ensure the cyclical review of this Policy is carried out under ACM’s Quality Assurance Framework.

14. DEFINITIONS

Coercion or Force includes any physical or emotional harm or threat of physical or emotional harm which would reasonably place an individual in fear of immediate or future harm, with the result that the individual feels compelled to engage in a sexual act.

Alcohol and/or Drug Use: Incapacitation arising from alcohol or drug consumption should be evaluated on the basis of how the alcohol/drugs have affected the individual; signs of incapacitation may include, but are not limited to, one or more of the following: slurred speech, unsteady gait, bloodshot eyes, dilated pupils, unusual behaviour, blacking out, a lack of full control over physical movements, a lack of awareness of circumstances or surroundings, and/or an inability to communicate effectively. Intoxication is never a defence for committing an act of Sexual Violence and Misconduct, or for failing to obtain consent. If there is any doubt as to the level or extent of one’s own or the other individual’s incapacitation, the safest approach is to not engage in a sexual act.

Disclosure: Disclosure means that an individual tells a member of the ACM community that they have experienced Sexual Misconduct (this is different from a formal Complaint).

Reporting Party: The Reporting Party is the person(s) who has made a formal Complaint regarding an experience of sexual misconduct.

Responding Party: The Responding Party is the person(s) named in a formal Complaint who is alleged to have committed an act of sexual misconduct.

Safeguarding: Safeguarding is the action that is taken to promote the welfare of all people and protect them from harm.

Abuse: any action that intentionally harms or injures another person

DSL: Designated Safeguarding Lead is the member of staff that coordinates all safeguarding concerns and oversees all referrals.

DDSL: Deputy Designated Safeguarding Lead is the member of staff who supports the DSL in maintaining the function of safeguarding throughout all campuses.

LADO: Local Authority Designated Officer

15. EXHIBITS/APPENDICES/FORMS

15.1 This procedure has been written in accordance with, and with reference to, the following statutory guidance and legislation:

Keeping Children Safe in Education (DfE, 2021)
Working Together to Safeguard Children (HM Government, 2018)
What to do if you’re worried a child is being abused (DfE, 2015)
The Prevent Duty (DfE, 2015, updated 2019)
Child sexual exploitation; definition and guide for practitioners (DfE, 2017)
Sexual violence and harassment between children in schools and colleges (DfE, 2018)
The Children Act 2004 (with later amendments)
Safeguarding Vulnerable Groups Act 2006
The Sexual Offences Act 2003
Office for Students (OfS) Condition E6 Harassment and Sexual Misconduct
Guidance for English Higher Education Institutions (HEIs) (DIUS, 2007)
Protection of Freedoms Act 2012
Children and Families Act 2014
Care Act 2014
Information sharing: advice for practitioners providing safeguarding services to children, young people, parents and carers (HM Government, July 2018)

16. SUPPORTING INFORMATION

There are no further supporting documents to this procedure.

17. DOCUMENT HISTORY AND NEXT REVIEW

Version: 1.2

Approved on: 01 September 2025

Approved by: Academic Board

Date of next review: August 2026

Download: PRO_064_Sexual Misconduct Procedure

Policy 063: Research Ethics Policy

PURPOSE

1.1 The ACM Research Ethics policy sets out the requirements for ethical considerations for all research activity conducted at ACM. ACM is committed to ensuring that research conducted by either ACM staff or students meets legal requirements and ethical best practice.

1.2 The ACM Research Ethics policy should be formally incorporated into the delivery of any research-based modules within all undergraduate or postgraduate programmes delivered at ACM.

POLICY SCOPE

2.1 This policy acts as a framework for ethical procedure across all programmes and campuses at ACM.

2.2 This policy covers staff and student research and all research practice including practice based/led research.

2.3 This policy outlines core principles and the approach to ethics taken at ACM as well as the responsibilities of the Ethics Committee, Researchers and Supervisors.

2.4 This policy sits within a broader framework of research and best practice at ACM.

2.5 The policy conforms with all related legislation and is consistent with ethical best practice.

2.6 Academic integrity of research and academic freedom is supported within this policy without contravening ethical best practice and legal and statutory requirements.

2.7 Ethical approval is required for all research carried out by students and staff across all ACM campuses.

2.8 Research which involves human participants will always require ethical approval. The level of risk related to this type of research will vary, however the following will be considered to be of high risk:

Research involving vulnerable groups
Research involving children or adults that are unable to give informed consent
Research where participants have participated in or are discussing illegal activity

2.9 The following topics will be considered to be of risk and will require approval by the ACM Research Ethics Committee (REC):

Research into terrorism
Research that investigates illegal activities including drug use or attendance at illegal raves
Research involving deception
Research where the researcher is investigating outside of their specialism

ETHICAL PRINCIPLES

3.1 Prevention of harm

3.1.1 Both researchers and supervisors are responsible for ensuring that participants are safe from physical and psychological harm during the research.

3.1.2 Where there is a risk to participants of physical or psychological harm, this is not absolved through informed consent.

3.1.3 Researchers must include a risk assessment within their ethics form which must include a plan to reasonably mitigate any physical or psychological risks within the research.

3.1.4 Researchers must not claim expertise in an area that is reasonably beyond their specialism particularly in high risk areas related to medical or psychological expertise.

3.1.5 Any safeguarding or PREVENT concerns must be reported through ACM’s safeguarding channels, in line with ACM’s safeguarding policies

3.2.6 Participants must be given the option to anonymise their personal data and information. This is particularly important for participants who are disclosing sensitive data that may put them at risk. Participants must be told how the information will be anonymised. At any point prior to submission a participant must be able to request for their data to be anonymised.

3.2 Free and informed consent

3.2.1 Participants must be given all information about the study needed to give informed consent. This must include the aims and objectives of the study and how their data will be processed in line with GDPR.

3.2.2 Information about the study should be provided in a written format for participants so that they can refer back to information during the study. Information sheets must include contact details for the student’s supervisor and it must be made clear to participants that they can contact supervisors if they have concerns about the study. A template information sheet will be provided for students on Canvas.

3.2.3 Written consent to participate must be gained through consent forms. Template consent forms will be provided for students on Canvas.

3.2.4 Where a participant is unable to give informed consent (e.g. if a participant is under the age of 16 or is unable to understand the constraints of the study). All steps must be taken to provide the participant with information needed to understand the study. The participant should be included in the decision to participate in agreement with the person with legal responsibility for them. The person with legal responsibility can give consent for them to participate in the study. The participant has the right to disagree with this decision.

3.2.5 Coercion should not be used to promote engagement with research. This includes, but is not limited to, providing incentives to participate in a study or pressuring family members, students, employees and friends to be participants.

3.2.6 Potential participants must not be disadvantaged by not taking part in a study e.g. where a study is placed within an education setting a suitable alternative should be provided for those who choose not to engage with the study.

3.3 Right to withdraw from a study

3.3.1 All participants must be given the right to withdraw from a study at any point prior to submission.

3.3.2 How a participant requests to withdraw must be made clear within the participant information sheet prior to starting the study.

3.3.3 Where the researcher has an existing relationship with the participant (this includes, but is not limited to, participants being a family member, friend, student or employee) then an independent third party must be used as the contact to withdraw from the study. This can be the supervisor for the research project.

3.3.4 Participants must not be put under any undue pressure for requesting to withdraw from a study, including, but not limited to, being told that their withdrawal will be detrimental to a student’s final grade on a project.

3.3.5 Participants must not be disadvantaged by withdrawing from a study e.g. for studies taking place in classrooms participants who withdraw from the study must still have access to the same education experience.

3.4 Conflict of interest

3.4.1 To protect academic integrity, it is important that the researcher maintains their independence and that research is not impacted by conflicts of interest. This includes, but is not limited to, funders, employers, personal relationships and sponsorship.

3.4.2 ACM recognises that researchers may be sponsored to undertake research or study with ACM. Sponsors must not influence any final outcomes of research or data produced through research.

3.4.3 Any conflicts of interest (actual, potential or perceived) must be disclosed in writing to the chair of the Ethics Committee. These will be considered by the committee and a conflict of interest management plan will be put in place with the researcher to prevent damage to the reputation of the researcher or ACM.

3.4.4 Where conflicts cannot be managed the ACM reserves the right to prevent the research from being undertaken.

ACM RESEARCH ETHICS COMMITTEE

4.1 The ACM Research Ethics Committee, which reports to the ACM Quality and Standards Committee, provides ethical approval and oversight for all student and staff research at ACM.

4.2 The ACM Research Ethics Committee is responsible for ensuring that research meets ethical best practice and aligns with statutory and legal commitments.

4.3 The ACM Research Ethics Committee meets twice per term to consider:

ACM Research Ethics Forms submitted by ACM students which have been deemed at-risk by the Supervisor
Any staff-led research conducted by ACM staff whilst in their capacity as an ACM member of staff.

4.4 The ACM Research Ethics Committee is made up of a combination of academic and professional staff from across ACM.

4.5 Research supervisors are required to present on behalf of the student for any ethical applications which are deemed at-risk.

ACM RESEARCH ETHICS PROCESS

5.1 ACM students undertaking primary research must submit an ACM Research Ethics Form.

5.2 ACM will appoint a research supervisor to all students undertaking primary research projects. Supervisors will be selected based on having appropriate research knowledge in a relevant area.

5.3 Supervisors are responsible for the initial review of all submitted ACM Research Ethics Forms and for determining the risk level of the research being proposed. The Supervisor Declaration and accompanying ACM Research Ethics Committee Tracking Document must be completed by the supervisor within one working week of receipt of submission.

5.4 Supervisors can sign off low risk applications. Applications deemed at-risk must be referred to the ACM Research Ethics Committee in a timely manner.

5.5 Where a student has failed to provide enough relevant information on their ACM Research Ethics Form they will be asked to resubmit their form.

5.6 Supervisors are responsible for communicating approval to students with low risk research projects.

5.7 The ACM Research Ethics Committee (REC) will communicate their decision and requirements directly to students (with Supervisors on copy) within one week of the ethics committee.

5.8 A student may appeal against the decision of the ACM Research Ethics Committee in line with the Academic Appeals Policy and Procedure.

RESEARCHER RESPONSIBILITY

6.1 No research can be started without ethical approval

6.2 Researchers are responsible for ensuring that the information provided on their ACM Research Ethics Form is accurate and includes all details of their methodology and research approach.

6.3 Researchers are responsible for submitting their ACM Research Ethics Form with enough time to be reviewed by the ACM Research Ethics Committee (REC) prior to starting their primary research.

6.4 If a researcher is unsure of recommendations mabe by either their supervisor or the ACM Research Ethics Committee (REC), the researcher must seek clarification in advance of starting primary research.

6.5 Researchers are responsible for ensuring that personal and sensitive data is stored in line with GDPR requirements.

6.6 Any researcher who starts primary research without ACM ethical approval will be investigated under ACM’s Academic Integrity Policy.

6.7 Researchers must ensure that the research they are undertaking sits within their specialism and does not involve using research techniques or approaches outside of their reasonable research specialism, e.g. a person with a creative arts background must not undertake research into medicine.

6.8 Researchers must ensure all participants receive information about the study and are able to give full, informed consent prior to participation.

6.9 In order for participants to be able to give informed consent, researchers must provide a participant information sheet which outlines the aims, outcomes and methods of the study. There is an ACM template which may be used for this purpose – ACM Participant Information Sheet and Informed Consent Template.

6.10 Researchers are responsible for declaring any and all potential conflicts of interest including partner organisations involved in research.

RESEARCH SUPERVISOR RESPONSIBILITY

7.1 Research Supervisors are responsible for ensuring that students under their supervision understand ethical best practice and legal requirements including GDPR.

7.2 Research Supervisors are expected to keep up to date on ethical best practice and relevant legislation, supported by the ACM Research Ethics Committee.

7.3 Research Supervisors are required to support their students through the ACM Research Ethics process, this includes supporting the student to complete the ACM Research Ethics Form.

7.4 Where a student is believed to be acting unethically in research, a supervisor must report this to the ACM Research Ethics Chair.

7.5 Research Supervisors can give feedback on research ethics prior to a student submitting their ethics forms.

ACM RESEARCH RESPONSIBILITY

8.1 ACM is responsible for the ethical conduct in research undertaken by students while studying at ACM and staff who have a research provision within their contract at ACM.

8.2 ACM cannot accept responsibility or liability for research started prior to a student starting a course or a researcher having received a contract from ACM.

8.3 In the case of students who have joined a course part way through study and research has been started prior to joining ACM, the student must provide the ethical approval from their previous institution and a disclaimer must be included in the student’s research submission stating that some research was undertaken outside of ACM’s supervision.

BIOETHICS

9.1 ACM is not a medical specialist institution and will endeavour to partner with the relevant specialist organisations where research engages with medical or psychological research practices.

9.2 ACM cannot give consent to the storage and use of human organs and tissue from the living, and the removal, storage and use of tissue and organs from the deceased, for specified health-related purposes including medical research.

ACADEMIC MISCONDUCT AND RESEARCH ETHICS

10.1 Misconduct within research and research practices is defined as:

Failure to obtain appropriate permission to conduct research;
Deception in relation to research proposals;
Unethical behaviour in the conduct of research;
Unauthorised use of information that was acquired confidentially;
Deviation from good research practice, where this results in unreasonable risk of harm to humans, other animals or the environment;

Fabrication, falsification or corruption of research data;
Distortion of research outcomes, by distortion, manipulation or omission of data that do not fit expected results;
Dishonest misinterpretation of results;
Publication of data known or believed to be false or misleading;
Plagiarism or dishonest use of unacknowledged sources;
Misquotation or misrepresentation of other authors;
Inappropriate attribution of authorship;
Attempting, planning or conspiring to be involved in research misconduct;
Collusion in or concealment of research misconduct by others;
Failure to comply with relevant legislation, including that relating to health and safety, data protection, intellectual property, and animal experimentation.

This list is not exhaustive and other misconduct specifically related to research activity may be dealt with under the Academic Integrity procedure.

RELATED POLICIES

Academic Integrity
Student Disciplinary
Academic Appeals

POLICY OWNER

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:

Head of Quality and Standards;
Research Lecturers;
Research Supervisors;
Registrar.

SUPPORTING INFORMATION

There is no further supporting information in relation to this Policy.

DOCUMENT HISTORY AND NEXT REVIEW

Version: 2.0

Approved on: 01 September 2025

Approved by: Academic Board

Date of next review: August 2026

Download: 063 POL_063_Research Ethics Policy

Procedure 011: Fitness to Study

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Procedure 011: FITNESS TO STUDY

Purpose and Scope

1.1 This procedure describes how the Academy of Contemporary Music (ACM) ensures that there is a consistent and supportive approach when assessing an individual’s capacity to satisfactorily participate and fully engage as an ACM student.

1.2 This procedure may apply to all current and prospective students including students that have interrupted and/or deferred their studies (herein referred to as ‘the student’) and refers to their time as an ACM student.

1.3 Fitness to study will be assessed in a timely manner ensuring that students are treated in a fair and equitable manner, with discretion and consideration of individual needs.

Procedure

2.1 ACM and its wider staff are committed to supporting student wellbeing and achievement amongst all students. Intervention should only take place where there is a level of need, and should take place discreetly and at the earliest opportunity. ACM recognises that a positive approach to the management of student needs is crucial to student learning and academic achievement.

2.2 A unified and non-judgmental approach to physical and mental health, and any arrangements that may affect a student or prospective student’s ability to exercise suitable fitness to study should be exercised and demonstrated at all stages of consideration of a student’s fitness to study.

Informal Stage (Standard Interventions)

Stakeholders: Programme Admins, Registry Manager, Student Services, Tutors, Pathway Leads and Personal Tutors.

2.3 It is recognised that studying at Higher Education level comes with a series of natural stresses such as working to meet multiple deadlines, potentially experiencing financial stresses, as well as dealing with difficult personal circumstances. As such, a student receiving support with their studies would not necessarily be put through the FTS process as a first step.

2.4 Students who come to the attention of ACM where a need for support is identified, whether that be through referrals made by staff or the student themselves, will be referred to the appropriate team to receive support relevant to the difficulties they are facing. The support implemented can include, but is not limited to:

– Wellbeing support;

– Tutorials with a tutor/Pathway Lead;

– Advice to apply for EC’s;

– Advice and support with applying for DSA (where relevant);

– Hardship loans (pending approval);

– Consultation with Registry and/or Programme Administrator on their academic standing and support in constructing a plan of action.

2.5 The interventions administered at this stage would not be logged as part of a formal FTS process, but would be logged to show the attempts made by ACM to support the student at that time.

2.6 If concerns persist over the student’s engagement or wellbeing, the decision would be made to refer the student to a Stage 1 Fitness to Study.

Stage 1 Fitness to Study

Stakeholders: Designated Programme Administrators and DSL relevant to student’s campus.

2.7 When referred to a Stage 1 FTS, the student will be sent a letter at least 7 working days before the proposed date to notify and invite them to the panel. If the student is unable to attend the proposed date then it is expected of them to inform the FTS panel in the first instance in order for a new date to be arranged.

2.8 The purpose of a Stage 1 FTS panel will be to discuss with the student the support that has already been implemented, what reasons there may be for this support not being effective, and the concerns that ACM now has regarding the continuation of their studies. Following this discussion, the panel and the student will explore what the most appropriate next steps will be to ensure the student’s wellbeing is treated as the priority. The two possible outcomes at this stage will be a choice of the following:

– Continuation of study with the implementation of further support and an Individual Learner Arrangement;

– A request made by the student for a change of circumstance, i.e., an interruption or withdrawal.

2.9 Should the student wish to continue with their studies, it will be permitted based on the student being administered an Individual Learner Arrangement (ILA). Under this arrangement the student will receive further interventions of support from ACM, which can include but will not be limited to:

– Continued wellbeing sessions;

– Referrals for a series of set counselling sessions;

Bespoke tutorials with tutor/pathway lead;

– The application of EC’s for upcoming assessments where appropriate based on the provision of necessary supporting documentation.

2.10 The conditions set for the ILA will be that the student must engage with their upcoming assessments following the Stage 1 FTS panel in order to show that they have engaged with the support set and that it has been effective in helping them re-engage with their studies.

2.11 As part of the ILA, the student will undergo a period of monitoring by their personal tutor and the Programme Administrator Team as outlined in the Individual Learner Arrangement Policy. The student will continue to be expected to inform their personal tutor and the relevant support staff of any issues that are continuing to pose prohibitive to the student’s engagement to ensure that support can be adjusted where necessary.

2.12 If following the given assessment period the conditions of the ILA are met, the student will be signed off as a Fitness to Study and following a short period of academic monitoring, no further action will be taken.

2.13 In the event that the terms of the ILA are not met, the result will be a progression to a Stage 2 FTS panel and would be notified accordingly.

2.14 Where a mutually agreed outcome is reached the matter will not be escalated further. All agreed arrangements should be documented and the student may still be subject to a period of academic monitoring at the discretion of the panel.

Stage 2

Stakeholders: Registry Manager, Group Lead on Student Experience, and Designated Safeguarding Lead

2.15 Following the decision to proceed to a Stage 2 FTS, the student will be sent a letter at least 7 working days before the proposed date to notify and invite them to the panel. If the student is unable to attend the proposed date then it is expected of them to inform the FTS panel in the first instance in order for a new date to be arranged.

2.16 Prior to the panel taking place, a pre-stage 2 consultation will take place between the members of the Stage 1 panel and the Stage 2 panel to discuss the student’s journey throughout this process in order to provide context for the Stage 2 panel to deliberate the most appropriate outcome. The potential outcomes are as follows:

Interruption – If the continuation of the student’s studies are not feasible at this time, but given a period of respite there could be scope for the student to return, the panel will conclude that the student will be put on an interruption for a maximum period of up to 12 months. The conditions of the student’s return and the most appropriate date of return will also be set and shared with the student.

De-registration – if the Panel concludes, taking into account the individual circumstances of the case and any supporting medical evidence, that there is no reasonable prospect of the student re-engaging with their programme or that doing so would pose a significant risk or disadvantage to a student’s mental or physical well being, a decision will be made that the student is terminated from their programme of studies. This decision should only be made in the most serious cases, and where all avenues of recourse, support mechanisms or arrangements have been exhausted or are deemed inappropriate.

Any other action considered to be appropriate and proportionate.

2.17 The Stage 2 FTS panel will consist of members of staff who have had limited to no involvement in the student’s situation in order to remain impartial in their decision making.

2.18 The student will normally be required to attend the panel to discuss their case. If the student does attend, they will have the right to bring a friend or student representative to the meeting for support.

2.19 The student may be permitted to be accompanied by a support worker, for example in cases of visual or hearing impairment, where this is appropriate to their needs.

2.20 When the panel takes place, the student will take part in the discussion surrounding their circumstances, what may have lead to all previous interventions not being effective and will then be informed of the outcome that has been reached by the panel.

2.21 In the event that the student in question is under the age of 18, a parent, guardian or nominated adult with responsibility for the student will be required to attend proceedings with the student

2.22 Any individuals who attend the hearing in support of the student, will not be included to influence or act as an intervention to any decisions or proceedings arising from the hearing. Students are advised that individuals who attend hearings will not be considered representative of the student in a formal or legal capacity.

2.23 Following the conclusion of the panel, the student will be informed of what the next steps are depending on the outcome reached and any relevant changes of circumstance will be actioned with immediate effect.

Emergency FTS Panel

Stakeholders: Registry Manager, Group Lead on Student Experience, and Designated Safeguarding Lead

2.24 Referrals for an Emergency Fitness to Study can only be made by a Designated Safeguarding Lead. If there are concerns held by a member of staff wherein they feel an Emergency FTS is appropriate, they must disclose these concerns to their campus DSL in the first instance.

2.25 In the event where a disclosure is made that – in line with the Fitness to Study policy – leads to an Emergency FTS, the panel will sit within 48-working hours of the disclosure being made.

2.26 The student concerned will be invited to attend the panel and will be notified by letter of the time and date in the first instance. However due to the serious nature of this stage, the panel will sit without the student’s attendance if it comes to it.

2.27 The Emergency FTS Panel will consist primarily of the Stage 2 panel with potential attendance from additional staff who have provided relevant support to the student.

2.28 An outcome will be reached based on the circumstances disclosed prior to the panel. Once this outcome has been decided all relevant changes of circumstances, should there be any, will be processed with immediate effect.

Actioning CoC’s prior to Stage 2 or Emergency FTS

2.29 Making the decision to interrupt a student on their behalf is usually reserved for Stage 2 and Emergency FTS Panels. However, ACM reserves the right for an interruption to be implemented for a student at Stage 1 if there are immediate and substantial concerns where the student’s wellbeing & safety are clearly seen to be at risk.

2.30 The decision to action a change of circumstance (CoC) prior to Stage 2 or an Emergency FTS can only be actioned by the Designated Safeguarding Lead, Registry Manager, or Group Lead on Student Experience at their discretion.

Return to Study

Stakeholders: Registry Manager, Group Lead on Student Engagement, and Designated Safeguarding Lead

2.31 Following the end of the student’s interruption, a reintegration meeting will be set prior to the student’s expected date of return to discuss the student’s eligibility to return. An outcome is not reached in this panel but will be concluded once the panel has sat.

2.32 The student will be welcome to have a friend, parent or guardian, or support worker be in attendance to provide support in a personal capacity.

2.33 The conditions set prior to the interruption will be reviewed and the student will be expected to provide authoritative documentation that evidences these conditions being met.

2.34 Following the reintegration meeting, all information shared and supporting documentation provided will be reviewed and considered with a decision being made as to whether or not the student will be permitted to return to study. This outcome will be shared with the student and their re-enrolment will be processed in the first instance.

2.35 If in the event that the panel concludes the student is not fit to return to study, they will make a decision on an outcome that can include, but will not be limited to:

A request for further/updated supporting documentation that pertains to evidencing the student’s fitness to return. A follow up reintegration meeting would be arranged to give the student adequate time to source the requested documentation.

An extension of the student’s interruption might be actioned if the panel concludes that a return to study at the original date set will not be conducive to the student’s wellbeing.

2.36 The outcome of all FTS panels and reintegration meetings will be communicated to the student within 48-working hours of the panel being held to ensure that they are aware of what the next steps will be. A post-Emergency FTS consultation can also be arranged to discuss the outcome with the student if they couldn’t attend the panel itself.

2.37 All FTS panels and reintegration meetings will be recorded and minuted in order for an accurate record to be kept. Should the student request a copy of either they will be welcome to do so. Any informal discussions and undertakings made by the staff that are managing this process will be held on file for a period of 6 years.

Right of Appeal

2.38 If the student does not agree with the outcome(s) and wishes to contest or appeal any or all of the decisions made in the FTS panel(s) or the Reintegration meeting, they may refer to and utilize the Appeals Policy.

Applicants who are refused a place at ACM

2.39 Prospective students and applicants should follow ACM’s Admissions Complaints Policy and Procedure if they wish to make a complaint.

Responsible Parties

3.1 The Procedure lead is responsible for the cyclical monitoring and review of the policy and procedure in liaison with the Quality Assurance and Enhancement Manager. The Fitness to Study Procedure lead is:

Registry Manager

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

Academic Registrar
Group Lead on Student Experience
Designated Safeguarding Lead(s)
Additional Needs & Disabilities Coordinator
Pathway Lead(s)
Head of Education
Programme Administrator(s)
Designated Safeguarding Lead(s)

Related Documentation

Fitness to Study Policy
Appeals Policy
Student Disciplinary Policy
Risk Assessment Policy
Safeguarding Policy
Finance Policy
Attendance Policy
Extenuating Circumstances Policy
Interruption of Studies Form

Date of Approval and Next Review

Version: 1.1

Approved on: 01 September 2025

Approved by: Academic Board

Next Review: Aug 2026

Download: PRO_011_Fitness to Study

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