External Speaker Code of Conduct

1. Introduction:

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

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

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

2. Freedom of speech:

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

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

3. Conduct 

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

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

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

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

4. Segregation

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

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

5. Date of Approval and Next Review

Version:                        1.3

Approved on:               01 Sep 2025

Approved by:               Academic Board

Next Review:               August 2026

Download this code of conduct

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

 

 

 

 

 

 

 

 

 

Policy 017: Finance Policy

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

Policy 017: FINANCE 

  1. PURPOSE 

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

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

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

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

  1. POLICY DETAILS 

Tuition fee charges 

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

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

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

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

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

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

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

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

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

Tuition Fee payment types. 

2.9 There are three tuition fee payment types: 

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

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

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

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

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

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

Tuition Fee Liability 

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

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

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

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

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

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

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

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

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

Fee Liability, Change of Circumstances and Withdrawal from Programme

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

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

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

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

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

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

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

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

Fee waivers, Scholarships and Bursaries 

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

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

Debt policy and procedures 

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

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

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

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

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

De-registration for nonpayment of tuition fees 

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

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

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

Late payment charges 

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

Financial Holds 

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

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

Returning students with debt 

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

External debt collection agencies 

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

Refunds 

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

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

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

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

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

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

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

Anti-money laundering regulations 

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

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

Library Charges, Materials and Other Equipment 

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

Fee Complaints 

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

  1. POLICY SCOPE 

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

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

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

  1. RELATED POLICIES 
  • Withdrawal Interruption and Internal Transfer Policy 
  • Refunds and Compensation Policy 
  • Student Protection Plan 
  1. POLICY OWNER 

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

  1. DOCUMENT HISTORY AND NEXT REVIEW 
Version 2.3
Approved on 01 September 2025
Approved by Academic Board
Date of next review August 2026

 

Download: 017 POL_017_Finance_202407

Policy 020: Data Access and Protection

Policy_020: Data Access and Protection

  1. Purpose and Scope

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

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

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

  1. Policy Statement

Data Protection

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

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

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

The Six Principles

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

1. Lawfulness, fairness and transparency:

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

2. Purpose limitations:

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

3. Data minimisation:

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

4. Accuracy:

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

5. Storage limitations:

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

6. Integrity and confidentiality

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

General Data Protection Regulation (GDPR)

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

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

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

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

Collection Notices

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

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

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

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

Fair Collection and Processing

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

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

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

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

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

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

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

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

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

Security

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

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

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

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

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

Data Sharing

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

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

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

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

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

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

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

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

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

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

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

Next of Kin/Emergency Contact Details

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

Sensitive personal data/Special categories of personal data

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

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

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

Extenuating Circumstances Applications

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

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

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

Access

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

2.39 All data subjects have a right to:

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

This is known as a Subject Access Request.

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

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

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

Links with the Freedom of Information Act 2000

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

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

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

Student Responsibilities

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

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

 Addresses and student contact details

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

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

Student Email Addresses

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

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

Students’ Assessed Work

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

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

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

Transcripts and Degree Certificates

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

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

Retention of Information

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

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

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

2.60 Archive boxes should be clearly labelled with:

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

Information Commissioner’s Register of Data Controllers

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

2.62  ACM’s Registration Number is Z6627433.

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

The Academy of Contemporary Music

Rodboro Buildings

Bridge Street

Guildford

Surrey

GU1 4SB

United Kingdom

  1. Responsible Parties

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

  • ACM Data Protection Officer

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

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

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

4.1 Internal:

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

4.2 External:

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

Version:                         1.3

Approved on:               01 Sep 2025

Approved by:               ACM Data Protection Officer

Next Review:                August 2026

Download – POL_020_Data Access and Protection_202209

Supplier Fair Processing Notice

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

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

Separate Fair Processing Notices are available for the Public, contracted Students and contracted Staff. If you are working for ACM under a self-employed/freelance contract, ACM may require and process your personal data in accordance with the Staff Fair Processing Notice.

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

For the purpose of your data protection, ACM is the recognised ‘controller’ of your data. A number of legal entities trade as ACM. These include ACM Commercial Ltd, ACM Education Ltd, The Academy of Contemporary Music Ltd, ACM Guildford Ltd, ACM London Ltd, ACM Birmingham Ltd and Industrication Ltd. Regardless of which legal entity you liaise with, we make the same Data Protection Officer available to you, who can be contacted about any of the content held herein via:

Postal Address:

Data Protection Officer
The Academy of Contemporary Music Rodboro Buildings
Bridge Street
Guildford
Surrey
GU1 4SB
United Kingdom

Telephone: +44 (0) 1483 500 800 Email: dpaofficer@acm.ac.uk

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

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

  • ○  “For the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.” This means the information is needed for the delivery and administration of your relationship with ACM.
  • ○  “For compliance with a legal obligation.” This means ACM is legally required to share some information about you, for example with HMRC. More information on this is covered below.
  • ○  “To protect the vital interests of a data subject or another person.” This means that in some rare circumstances it may be necessary to share information about you, for example to the emergency services.If you cease to be a supplier of ACM, the legal basis for continuing to process your information would then be:

○ “Necessary for the purposes of legitimate interests pursued by the controller or a third party, except where such interests are overridden by the interests, rights or freedoms of the data subject.” This means it is reasonable to expect that ACM would contact you if it had a query about any products or services you supplied to ACM, a

matter relating to a time in which you were supplying those products/services and/or in relation to another statutory/legal obligation it may have.

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

○ ○

○ ○ ○ ○ ○ ○

GDPR ○

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

builds on these requirements and states that from 25 May 2018 information must be: processed lawfully, fairly and in a transparent manner in relation to individuals;

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

GDPR also requires that:

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

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

How and why does ACM use personal data?

Supplier personal data is processed primarily for, but not limited to, the following purposes:

  • ●  the general administration of our relationship with you, including for financial reasons;
  • ●  the selection process of suppliers;
  • ●  administration of non-ACM staff contracted to provide services on behalf of ACM;
  • ●  planning and management of ACM’s workload or business activity;
  • ●  disputes and disciplinary matters;
  • ●  training and development;
  • ●  vetting checks;We may disclose your data to certain outside organisations as outlined in this Fair Processing Notice.

We may use copies of the data, including sensitive personal data, which we hold about you for the purpose of testing our IT systems. If your data is used for system testing, it will be copied to a test environment and used with data on other students to test changes to our IT systems in a realistic way. This is done to ensure that changes will be effective and will not cause loss or damage to data. The data about you which we hold in our live systems will not be affected. Your data will not be kept in the test environment for longer than is necessary for testing purposes. Data in that environment will not be used for purposes other than testing. We will also apply appropriate security precautions to the data.

What personal data does ACM collect?

ACM collects the following information from suppliers, which is outlined below:

  • ○  name and address
  • ○  contact details (telephone number, email address)
  • ○  Details and dates of usage of the products/services being supplied
  • ○  payment / bank detailsCCTV

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

Who else has access to my my data?

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

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

Your data may also be sent to different companies/departments within the ACM group where this is necessary for our day to day administration. The full list of ACM Group companies is: The Academy of Contemporary Music Ltd, ACM Commercial Ltd, ACM Education Ltd, ACM Guildford Ltd, ACM London Ltd, ACM Birmingham Ltd, Industrication Ltd, Metropolis London Music Ltd.

ACM will make some statutory and/or routine disclosures of personal data to third parties where appropriate. These third parties include:

  • ●  HM Revenue and Customs (HMRC)
  • ●  Financial Auditors
  • ●  Other organisations who have asked us for a reference of your services.
  • ●  Communications Platforms to facilitate marketing and communications of ACMservices (governed by GDPR compliant data sharing agreements):
    • ○  Facebook for re-marketing of ACM services to you via its channels;
    • ○  Clickatell for SMS (text message) services; and
    • ○  Mailchimp and Mandrill for campaign and transactional email servicesPersonal data may also be disclosed when legally required or where there is a legitimate interest, either for ACM or the data subject, taking into account any prejudice or harm that may be caused to the data subject.

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

      How long do you keep data for?

      Data we hold that is only relevant to current suppliers (such as bank information) will be deleted within 1 year of your last supply to us. All other relevant correspondence in relation to the supply of products/services will be held on file and retained for 6 years after an employee has left ACM, in accordance with HMRC recommendation, after which time it will be securely disposed of. Basic information about a supply of service (ie a log that the service was provided) will be

retained indefinitely, along with any other data we are required to hold indefinitely for legal/statutory reason.

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

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

An individual has the right to be informed about data collection via a Fair Processing Notice. This is that notice.

An individual has the right to ask ACM what personal data we hold about them , and to ask for a copy of that information. ACM reserves the right to ask you to provide proof of identification and for you to clarify your request if it is unclear in the first instance. You will receive a reply no longer than 30 calendar days from the date you make the request in writing. If you are unhappy with the initial response you can ask ACM to undertake a further search if there is specific information you have good reason to believe exists but that hasn’t been delivered to you.

You have the right to rectify data that is incorrect. If you believe ACM holds information about you that is factually incorrect please email our HR department to provide the correct information, and ACM should update it within one month.

You have the right to be forgotten. Where there is not a legal / statutory obligation for ACM to hold data about you, you have the right to be forgotten.

You have the right to data portability where the personal data is processed with the consent of the data subject, not where the personal data has been collected using any of the other legal basis for processing.

You have the right to restrict processing.
You have rights in relation to automated decision making and profiling.

You also have the right to object / withdraw consent from the processing of your personal data by ACM at any time , if your consent was sought initially to use your personal data.

You also have the right to complain to the UK Regulator the Information Commissioner’s Office (the ICO) if you believe you request has not been dealt with properly or you have a complaint to raise against ACM for any other data protection related issue. A complaint can be raised via the ICO’s website at www.ico.org.uk or by writing to the following address:

The Office of the Information Commissioner Wycliffe House
Water Lane
Wilmslow

Cheshire SK9 5AF

How do I exercise my rights under GDPR?

For the purpose of your data protection, ACM is the recognised ‘controller’ of your data. A number of legal entities trade as ACM. These include ACM Commercial Ltd, ACM Education Ltd, The Academy of Contemporary Music Ltd, ACM Guildford Ltd, ACM London Ltd, ACM Birmingham Ltd and Industrication Ltd. Regardless of which legal entity you liaise with, we make the same Data Protection Officer available to you, who can be contacted if you would like to exercise any of your rights under GDPR:

Postal Address:

Data Protection Officer
The Academy of Contemporary Music Rodboro Buildings
Bridge Street
Guildford
Surrey
GU1 4SB
United Kingdom

Telephone: +44 (0) 1483 500 800 Email: dpaofficer@acm.ac.uk

What are my responsibilities?

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

Student and Alumni Fair Processing Notice

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

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

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

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

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

For the purpose of your data protection, ACM is the recognised ‘controller’ of your data. A number of legal entities trade as ACM. These include ACM Commercial Ltd, ACM Education Ltd, The Academy of Contemporary Music Ltd, ACM Guildford Ltd, ACM London Ltd, ACM Birmingham Ltd and Industrication Ltd. Regardless of which legal entity you liaise with, we make the same Data Protection Officer available to you, who can be contacted about any of the content held herein via:

Postal Address:

Data Protection Officer
The Academy of Contemporary Music Rodboro Buildings
Bridge Street
Guildford
Surrey
GU1 4SB
United Kingdom

Telephone: +44 (0) 1483 500 800 Email: dpaofficer@acm.ac.uk

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

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

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

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

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

○ “Necessary for the purposes of legitimate interests pursued by the controller or a third party, except where such interests are overridden by the interests, rights or freedoms of the data subject.” This means it is reasonable to expect that ACM would contact you once you have finished your studies.

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

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

○ Not transferred outside the European Economic Area unless certain conditions are met

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

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

accidental loss, destruction or damage, using appropriate technical or organisational measures.

GDPR also requires that:

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

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

How and why does ACM use personal data?

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

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

    We may use copies of the data, including sensitive personal data, which we hold about you for the purpose of testing our IT systems. If your data is used for system testing, it will be copied to a test environment and used with data on other students to test changes to our IT systems in a realistic way. This is done to ensure that changes will be effective and will not cause loss or damage to data. The data about you which we hold in our live systems will not be affected. Your data will not be kept in the test environment for longer than is necessary

for testing purposes. Data in that environment will not be used for purposes other than testing. We will also apply appropriate security precautions to the data.

What personal data does ACM collect?

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

Personal data:

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

Course related data:

  • ○  Information from your application process
  • ○  Your academic background and qualifications
  • ○  Your academic record while at ACM (including measures of attendance,engagement and attainment)
  • ○  Details of any degrees which you are awardedFinance data:
  • ○  Fee information
  • ○  Bursary or sponsorship details
  • ○  Payment / Bank details.Other data:
  • ○  Any disciplinary action taken against you
  • ○  Information relating to any academic appeals or complaints raised by you
  • ○  Attendance warnings issued to you
  • ○  Official letters requested by you during your studies, for example Council Taxexemption
  • ○  Your use of ACM’s facilities, such as the Library
  • ○  Online identifiers, such as your ACM username that is used to access our systemsSome of this information, such as your ethnicity, medical information and information about disabilities, is classed as “sensitive” personal data under the Data Protection Act. Under the

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

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

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

Your Student Profile

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

provided access to your non-ACM contact details, only as necessary. This may extend to sharing of emergency contact details, if the need arises.

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

ACM Communications Platforms

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

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

CCTV

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

Who else has access to my my data?

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

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

Your data may also be sent to different companies/departments within the ACM group where this is necessary for our day to day administration. The full list of ACM Group companies is: The Academy of Contemporary Music Ltd, ACM Commercial Ltd, ACM Education Ltd, ACM Guildford Ltd, ACM London Ltd, ACM Birmingham Ltd, Industrication Ltd, Metropolis London Music Ltd.

The information below outlines the key partners with whom ACM shares personal data with on a periodic basis:

● Professional and Funding Bodies:

  • ○  Validation of registrations and awards; and
  • ○  Approval of funding applications.
  • ○  Partner institutions such as Middlesex University (Guildford and Birmingham HE), Falmouth University (London HE), East Surrey College (Guildford FE), University of the Arts London Awarding Body (Guildford and Birmingham FE) and/or Walsall Studio School (Birmingham FE);
  • ○  External examiners connected to the awards we operate for examination, assessment and moderation purposes.
  • ●  National/Local Government Departments and other public bodies:
    • ○  Higher Education Statistics Agency (HESA) to produce a variety of statistical reports about higher education that are required to be published in the public interest for which a separate data collection notice can be found at https://www.hesa.ac.uk/about/regulation/data-protection/notices#student ;
    • ○  The Office Of The Independent Adjudicator to review student complaints;
    • ○  The Office for Students during institutional audits and other qualityassessment exercises;
    • ○  the Student Loans Company in connection with grants, fees, loans andbursaries;
    • ○  the courts, the police and other organisations with a crime prevention or lawenforcement function (subject to the proper entitlements);
    • ○  Local authorities for the purposes of assessing and collecting council tax.
  • ●  Communications Platforms to facilitate marketing and communications of ACM services (governed by GDPR compliant data sharing agreements):
    • ○  Facebook for re-marketing of ACM services to you via its channels;
    • ○  Clickatell for SMS (text message) services; and
    • ○  Mailchimp and Mandrill for campaign and transactional email services.
  • ●  Service Platforms to facilitate the administration and distribution of ACM services (governed by GDPR compliant data sharing agreements):
    • ○  Canvas Virtual Learning Environment for your online learning tools;
    • ○  Turnitin plagiarism detection software for verifying the originality of yoursubmitted work; and
    • ○  Music Gateway for your professional development opportunities.
  • ●  Other individuals / organisations:
    • ○  International recruitment consultants and agents (for relevant internationalstudents);
    • ○  Housing providers for students;
    • ○  ACM’s insurers and legal advisers for the purpose of providing insurancecover or in the event of a claim;
    • ○  Employers who request a reference from ACM (for relevant staff andstudents).
    • ○  If you leave ACM owing money to ACM, we may at our discretion pass thisinformation to a debt collection agency.
    • ○  We may disclose information for the purpose of verifying data about you heldby ACM, held by another higher education institution, or held by government

      agencies.

    • ○  We may disclose information if there are concerns regarding studentvulnerability and susceptibility to radicalisation as part of our responsibilities under the Counter Terrorism and Security Act 2015.

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

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

How long do you keep data for?

ACM takes its obligations under GDPR very seriously in terms of not holding onto personal data for any longer than is necessary. ACM has a retention schedule in place for the different categories of data it holds.

After you leave ACM we will continue to hold data about you in digital and paper form. Some information, such as your dates of attendance and your qualification achievements, will be retained permanently. Other data will be disposed of from time to time in accordance with ACM’s data retention policies. For example:

  • ○  Data relating to your application – retained for 6 years after you leave ACM
  • ○  Anonymised records which don’t identify you which are used for data analysispurposes – retained indefinitely
  • ○  Records relating to applications for Extenuating Circumstances – retained for 1 yearafter the end of the academic year in which the application is made
  • ○  Your contact details – ACM is required by statute to retain these to enable the Higher Education Statistics Agency’s national survey of Graduate Outcomes
  • ○  Data relating to your assessment and degree outcome – retained indefinitely to be able to provide academic transcripts
  • ○  Data relating to any student complaints or academic appeals – retained for one year post completion of complaint and appeal procedures
  • ○  Financial data relating to payments received from you or paid to you – there is a mandatory requirement to keep financial data for at least seven years for audit purposesBy enrolling as a ACM student, you agree to ACM processing data relating to you after you leave ACM for any purposes connected with your studies, your status as a former student and for other legitimate reasons.

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

  • ○  To provide evidence of your academic achievements when requested to do so: e.g. transcripts, confirmation of qualifications and references
  • ○  To provide information to regulatory bodies and other agencies to whom we are legally required to supply data
  • ○  To produce management statistics
  • ○  To maintain contact with you as a ACM alumnus/alumna
  • ○  For audit and quality assurance purposesWe may contact you for a limited range of research purposes after you leave ACM.

We are required by statute to maintain and share your contact details to enable the carrying out of surveys conducted by or on behalf of HESA, the Office for Students or other official agencies. Where we report a variety of data to HESA, a separate data collection notice can be found at https://www.hesa.ac.uk/about/regulation/data-protection/notices#student. We may also contact you to carry out our own research into your experiences at ACM and after leaving ACM, in order to evaluate the effectiveness of our courses and improve our services to students. If you do not want to be contacted for these purposes, please notify dpaofficer@acm.ac.uk

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

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

  • ●  to be able to verify qualifications with future employers;
  • ●  to be able to respond to safeguarding responsibilities;A full schedule concerning data retention and disposal is available via the policies section of our website.

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

    An individual has the right to be informed about data collection via a Fair Processing Notice. This is that notice.

    An individual has the right to ask ACM what personal data we hold about them , and to ask for a copy of that information. ACM reserves the right to ask you to provide proof of identification and for you to clarify your request if it is unclear in the first instance. You will

receive a reply no longer than 30 calendar days from the date you make the request in writing. If you are unhappy with the initial response you can ask ACM to undertake a further search if there is specific information you have good reason to believe exists but that hasn’t been delivered to you.

You have the right to rectify data that is incorrect. If you believe ACM holds information about you that is factually incorrect please email our registry department to provide the correct information, and ACM should update it within one month.

You have the right to be forgotten. Where there is not a legal / statutory obligation for ACM to hold data about you, you have the right to be forgotten.

You have the right to data portability where the personal data is processed with the consent of the data subject, not where the personal data has been collected using any of the other legal basis for processing.

You have the right to restrict processing.
You have rights in relation to automated decision making and profiling.

You also have the right to object / withdraw consent from the processing of your personal data by ACM at any time , if your consent was sought initially to use your personal data.

You also have the right to complain to the UK Regulator the Information Commissioner’s Office (the ICO) if you believe you request has not been dealt with properly or you have a complaint to raise against ACM for any other data protection related issue. A complaint can be raised via the ICO’s website at www.ico.org.uk or by writing to the following address:

The Office of the Information Commissioner Wycliffe House
Water Lane

Wilmslow Cheshire SK9 5AF

How do I exercise my rights under GDPR?

For the purpose of your data protection, ACM is the recognised ‘controller’ of your data. A number of legal entities trade as ACM. These include ACM Commercial Ltd, ACM Education Ltd, The Academy of Contemporary Music Ltd, ACM Guildford Ltd, ACM London Ltd, ACM Birmingham Ltd and Industrication Ltd. Regardless of which legal entity you liaise with, we make the same Data Protection Officer available to you, who can be contacted if you would like to exercise any of your rights under GDPR:

Postal Address:
Data Protection Officer
The Academy of Contemporary Music Rodboro Buildings
Bridge Street
Guildford
Surrey
GU1 4SB
United Kingdom

Telephone: +44 (0) 1483 500 800 Email: dpaofficer@acm.ac.uk

What are my responsibilities?

ACM will make every reasonable effort to keep your details up to date. However, it is your responsibility to provide us with accurate information about yourself when you provide it. It

is also your responsibility to let us know of any subsequent changes to your details. You must also abide by ACM’s Data Protection Policy when handling any personal data you come into contact with for which ACM is responsible.

Procedure 003: Complaints and Grievances Procedure

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

Procedure 003: COMPLAINTS AND GRIEVANCES

1. PURPOSE

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

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

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

2. PROCEDURE STATEMENT

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

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

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

Stage 1: Early Resolution

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

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

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

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

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

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

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

Stage 2: Formal Stage

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

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

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

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

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

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

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

2.14 The lead investigator shall:

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

2.15 The Quality Assurance team will:

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

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

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

Stage 3: Validating Body/ Partner Institution Review

Middlesex University Provision

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

2.18 If a student considers that:

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

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

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

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

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

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

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

Stage 4: (HE students only)

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

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

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

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

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

East Surrey College (FE)

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

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

Groups of Complainants

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

Student Progression

2.31 Until the complaint is concluded, the student:

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

3. POLICY OWNER

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

  • Quality Assurance and Enhancement Manager

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

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

4. SUPPORTING INFORMATION

4.1 Internal Documents

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

4.2 External Documents

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

5. DOCUMENT HISTORY AND NEXT REVIEW

5.1 This procedure applies to Academic Year 2024-25

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

 

Download:                Procedure 003 Complaints and Grievances AY2024-25

Gender Pay Gap Reporting for 2021 / 22

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

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

Policy 041: Lone Workers

 

  1. Purpose and Scope

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

  1. Policy Statement

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

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

2.3       Some of the key hazards are:

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

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

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

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

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

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

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

Risk Assessment

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

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

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

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

2.13 The risk assessment must take into account:

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

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

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

  1. Responsible Parties

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

  • Human Resources Operations Manager

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

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

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

4. Reference Points

4.1 Internal

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

4.2 External

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

 

  1. Date of Approval and Next Review

Version:                       1.2

Approved on:              01 Sep 2025

Approved by:               Academic Board

Next Review:                August 2026

Click to download this policy

Policy 022: Health and Safety Policy

Policy 022: Health and Safety Policy

1. Purpose and Scope

1.1 This policy outlines ACM’s approach with regard to health and safety responsibilities and meets the legal duties for the health and safety of all members of the ACM community and others affected by the activities of ACM.

1.2 In accordance with the duty under Section 2 (3) of the Health and Safety at Work etc, Act 1974, and in fulfilling our obligations to our staff, students and others who may be affected by our activities, the Academy of Contemporary Music (ACM) has produced the following Health and Safety Policy.

2. Policy Statement

2.1. The Executive Team and Senior Management Team will lead by example in communicating and promoting this policy and will seek continuous improvement in health and safety performance.

2.2. ACM expects all ACM employees and students to fully commit to achieving the objectives of this policy.

2.3. The provision of a healthy and safe working and learning environment is central to the commitment of ACM in the development of a positive working environment that stimulates, inspires and supports academic achievement.

2.4. As a part of that commitment ACM recognises its legal duty to provide a safe and healthy workplace for staff, students, visitors and others who may be affected by ACM activities.

Assurances by ACM

2.5. Through its Health and Safety Policy ACM will, so as far as is reasonably practicable: 

  • Ensure adequate resources are provided to meet ACM health, safety and fire obligations. 
  • Ensure the systematic identification and assessment of our hazards and the development and implementation of proactive measures aimed at eliminating those risks. 
  • Provide an environment in which everyone can carry out their tasks without fear of intimidation, harassment, violence or undue stress 
  • Ensure the management team afford health and safety matters equal priority to other management functions;
  • Ensure machinery, plant, equipment and systems of work are maintained in a safe condition. 
  • Provide and maintain safe systems in connection with the use, handling, storage and transport of articles and substances 
  • Provide such information, instruction, training and supervision as is necessary, to ensure the health and safety of staff, students and others 
  • Maintain effective communication and consultation with all staff and students on health and safety issues 
  • Ensure that this documentation and supporting information is made accessible, primarily through the ACM induction and training for staff
  • Ensure that students receive full health and safety information through the induction process 
  • Monitor, evaluate and audit the effectiveness of ACM health and safety performance, plans and strategies to ensure continuous improvement and provide reports to the ACM Executive 
  • Review the Health and Safety Policy Statement, Organisation and Arrangements at least once every three years or more often if circumstances so require. 

3. Responsible Parties

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

  • Facilities Manager

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

  • Human Resource Management
  • Facilities Manager
  • Senior Management
  • Executive Management

4. Reference Points

4.1 Internal:

  • Lone Workers Policy 
  • Critical Incident Policy 
  • Equality and Diversity Policy 
  • Safeguarding Policy
  • Student Disciplinary 
  • Risk Assessment Policy 

4.2 External:

  • Health and Safety at Work, Act 1974
  • Health and Safety Act 1999

5. Date of Approval and Next Review

Version:                        1.2

Approved on:              01 September 2025

Approved by:               Academic Board

Next Review:                August  2026

Download POL_022_Health and Safety

Policy 004: Student Conduct and Discipline

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

Policy 004: STUDENT CONDUCT & DISCIPLINE

  1.   Introduction 

1.1 Statement of Student Conduct – as an ACM student, you are expected to conduct yourself at all times in a manner which demonstrates respect for the institution, your fellow students and its staff. You are an ambassador for the institution and you are expected to behave in a way that enhances the reputation of ACM and all of its students and graduates, and in a way that is sensitive to our culturally diverse environment. You are encouraged, with the support of ACM, to engage actively in the learning process, to be fully committed to your studies and determined to succeed. 

1.2 This policy describes the procedure ACM uses for dealing with incidents of non-academic misconduct (hereafter referred to as ‘misconduct’). Within the rules, types of misconduct and consequences are described as the warning and sanction system. 

  1.   Rationale for the Rules

2.1 These Rules are intended to provide fair and orderly procedures for maintaining reasonable student conduct and behaviour whilst enrolled at ACM. The rules and regulations of the institution, which require students to conduct themselves appropriately and which enable ACM to discipline students in the event of misconduct, form part of the terms of the contract between the parties, which students become a party to on enrolment to ACM. 

2.2 These Rules should also be read in conjunction with the Student Charter (Code of Conduct) which sets out what a student can expect from ACM and what ACM expects of its students.

2.3 The Rules will be used to protect the right of all students to pursue freedom of speech within the law, argument, discussion and activities proper to their study in further and higher education, whichever is applicable to their status. All students are encouraged to participate in debate and in a wide range of activities, whether this is directly related to their own study programmes or to matters of wider community and public interest. Equally, all students are expected to respect the rights of others to study, to work and to participate freely in the life of the institution. This is consistent with ACM’s values, with the traditions of further and higher education, and with freedoms of speech and association in a democratic society.

2.4 ACM is committed to treating all students fairly and to not make presumptions prior to collating evidence. ACM recognises the various duties and obligations it has to all students, including applying the principles of natural justice, i.e. the right of students to a fair hearing before an impartial decision-maker or decision-makers. 

2.5 It is the intention of these Rules to encourage the development of mutual respect between all members of the ACM community. To this end, it is important that students exercise their rights responsibly and with respect for others, thereby contributing to the orderly running of the institution as a whole. This is the context in which these Rules and procedures should be read and used. 

2.6 The Rules are set out in clear stages so as to be a guide to students and to staff. Except in the case of serious offences, the penalties are intended to operate as a series of warnings. 

2.7 ACM seeks to process disciplinary cases in a timely manner through considered escalation of concerns as outlined in this procedure. Cases will normally be completed within 90 calendar days, including any appeal stage. If the normal timeframe needs to be extended, ACM will inform the student, explain why and update them regularly on progress. 

  1.   Types of Student Misconduct and Consequences 

3.1 The table below sets out the types of behaviours which ACM defines as non-academic misconduct. These are separated into misconduct against ACM, misconduct against property, misconduct against a person, and misconduct against the community. It is important to note that the behaviours listed in the table are not exhaustive. 

3.2 ACM uses a system of sanctions (warning points) ranging from 0-4 to quantify the level of consequence as a result of the misconduct. The final column in the below table gives an indication of the range of the number of warning points such a behaviour is likely to carry. The number of warning points indicated next to the behaviour is for guidance purposes only as an indication to the gravity of the misconduct. Section 9 provides further information on the warning system. 

3.3 Table of types of misconduct and consequences 

Misconduct against ACM 
Types of Misconduct Examples of Misconduct Level of Warning
Obstruction of the working of ACM
  • Acts/omissions/statements intended to deceive the institution (e.g. withholding information required for statutory purposes). 
  • Disruption of the functions, duties or activities of any student or employee of ACM or any authorised visitor to the institution 
  • Disruption of the workings of ACM: 
  • Administrative (e.g. refusal to present a student ID card when requested by an employee of the institution or misuse of a student ID card 
  • Breach of booking/guest policies/procedures 
  • Breach of exclusion/suspension conditions 
  • Academic (e.g. disruption of teaching or learning environment through the usage of a mobile phone)
  • Extra-curricular or social (e.g. disruption at an ACM-related internal or external event) 
0 – 2  

0 – 4 

0 – 2 

0 – 4 

0 – 4 

0 – 4 

0 – 4 

Reputational damage
  • Behaviour which could damage the reputation of ACM or bring ACM into disrepute (e.g. anti-social behaviour within the community). 
  • Behaviour which has damaged the reputation of the ACM or brought ACM into disrepute.
0 – 2 

2 – 4

Fraudulent or 

deceitful behaviour

  • Fraud/attempted fraud, bribery, deceit, deception or dishonesty in relation to ACM or its staff or in connection with holding any office in the institution or in relation to being a student of ACM. 
  • Knowingly making a false and vexatious allegation against ACM or against any student or staff member. 
  • Use or issue of fraudulent documentation relating to qualifications and academic performance. 
  • Use or issue of fraudulent documentation NOT relating to qualifications or academic performance. 
  • Coercion or attempted coercion.
  • Blackmail or attempted blackmail. 
0 – 4

2

3

4

4

4

 

Misconduct against Property
Types of Misconduct Examples of Misconduct Level of Warning
Damage to property
  • Causing damage or defacement to ACM of associated property or the property of students, employees or visitors to ACM, caused by: 
  • Misuse/inappropriate use of property 
  • Negligence 
  • Reckless behaviour 
  • Intentional behaviour

0 – 1 

0 – 2 

2 – 3 

3 – 4

Unauthorised or Inappropriate Use of Property
  • Misuse of ACM premises or property, for example, using a studio for a social gathering.
  • Unauthorised use of/entry onto ACM premises or property, including computers and studio equipment. 
  • Unauthorised recording of a learning activity. 
  • Unauthorised publication of a recorded activity (e.g. on YouTube, Facebook etc.) including malicious or defamatory comment.
  • False activation of a fire alarm. 
  • Deliberate misuse of the ACM computer network, e.g. hacking, uploading of unauthorised or inappropriate data. 
  • Unauthorised use of intellectual property.
  • Infringement of copyright materials (e.g. selling or uploading materials to an essay mill).
0- 2 

0 – 2 

3 – 4 

2 – 4 

2 – 4 

Taking of property
  • Taking property belonging to another person without permission. 
  • Stealing personal property, excluding cash.
  • Stealing or non-return of ACM property
  • Stealing cash and goods.
  • Repeated act of stealing.
1 – 2 

1 – 4

Causing a Health or Safety concern
  • Act/omission that did cause or could have caused a health and safety concern on ACM premises, including external facilities used for ACM purposes (for example, smoking cigarettes in non-designated areas).
  • Act/omission that did cause or could have caused serious harm, injury or impairment of safety on ACM premises, including  external facilities used for ACM purposes, or during ACM activities (for example, disabling fire extinguishers, or covering up a smoke detector). 
  • Possession of an object which may cause harm, alarm and/or distress, including offensive weapons e.g. bladed articles, pepper spray, firearms, all replicas and any object intended or adapted for such purpose, such as the use of acid in a water pistol or a snooker ball. Note: possession is irrespective of intent to harm. 
1 – 4 

2 – 4 

2 – 4 

Illegal Substances
  • Consumption of and/or possession of illegal substances or associated paraphernalia on ACM premises, including  external facilities used for ACM purposes.
  • Dealing, including intent to supply, illegal substances on ACM premises, or outside of ACM premises whilst a registered student, including external facilities used for ACM purposes. 
0 – 2

4

 

Misconduct against People
Types of Misconduct Examples of Misconduct Level of Warning
Physical Misconduct
  • Pushing and/or shoving
  • Pulling hair
  • Inappropriate physical contact 
  • Punching
  • Kicking
  • Slapping
  • Biting

The above includes where actions have been motivated for self-defence reasons though this may be taken into account as a mitigating factor when considering sanctions.

0 – 2 

0 – 2

0 – 4

2 – 4 

2 – 4 

2 – 4 

2 – 4 

Abusive Behaviour
  • Use of inappropriate language (violent, aggressive, abusive, threatening, defamatory or offensive language), directly or indirectly or online. 
  • Sending inappropriate messages by email, text or on social media.
  • Acts of stalking, including following a person, watching or spying on them or forcing contact directly, indirectly or online.
  • Repeatedly contacting another person (by phone, email, text or on social networking sites) against the wishes of the other person. 
  • Any form of bullying or harassment* directly, indirectly or online, including acting in an intimidating and hostile manner. 
  • Any form of repeated harassment in person, writing, by email, via the internet (including social media) or otherwise.
  • Threats to hurt another person or retaliate, directly, indirectly or online.
  • Abusive comments relating to an individual’s sexual orientation, religion or age, directly or indirectly or online.
  • Intimidation: verbal or physical, directly, indirectly or online. 
0 – 4 

0 – 2 

1 – 4 

1 – 4 

2 – 4 

2 – 4 

2 – 4 

3 – 4

Sexual Misconduct
  • Making unwanted remarks of a sexual nature, directly, indirectly or online.
  • Inappropriately showing naked or semi-naked images to another person, for example, via social media.
  • Intimate contact without consent (e.g. touching, kissing, invading another person’s personal space). 
  • Indecent public exposure (e.g. flashing).
  • Sharing sexualised materials of another person (whether fully naked or not) without consent, directly, indirectly or online.
  • The taking or making of images of a person of a sexualised nature (e.g. photographs or AI-generated images). 
  • Sexual harassment, stalking or persecution (virtual or real) of someone with unwanted and obsessive attention.
  • Bullying or harassing behaviour (physical or non-physical) based on a person’s sexuality or gender, directly, indirectly or online.
  • Attempted sexual assault or rape.
  • Sexual assault.
  • Sexual intercourse or engaging in a sexual act without consent.
0 – 4 

1 – 4 

1 – 4 

3 – 4 

3 – 4 

2 – 4

2 – 4 

*harassment – unwanted conduct which has the purpose or effect of either violating the claimant’s dignity, or creating an intimidating, hostile, degrading, humiliating or offensive environment for them. 

Misconduct against the Community
Types of Misconduct Examples of Misconduct Level of Warning
Antisocial behaviour on campus
  • Smoking/E-smoking on ACM premises, other than in designated smoking areas.
  • Consumption of alcohol in a teaching/learning environment unless explicit permission has been granted (e.g. as part of a private viewing or event). 
  • Excessive printing or copying, or other unauthorised use of printing or copying facilities. 
1 – 2

1 – 2

1

Antisocial behaviour in any location
  • Environmental damage including littering, dumping of rubbish, inappropriate usage of bins, fly-tipping. 
  • Inconsiderate or inappropriate use of vehicles or travel conveyances, including e-scooters, bicycles and motorcycles, inconsiderate or inappropriate parking and vehicle noise. 
  • Misuse of fireworks. 
  • Repeated inconsiderate behaviour towards others, including the use of e-scooters, bicycles and motorcycles.
0 – 2 

0 – 2 

2 – 4

3.4 Penalties are determined depending upon the gravity of the case and/or the ongoing nature of the misconduct. The greater the severity of the misconduct, the greater the number of warning points and the greater the severity of the penalty. The range of penalties available include: a formal warning, restrictions/conditions, a written apology, suspension or deregistration. 

  1. Rationale and Scope of the Rules on Student Conduct and Discipline 

4.1 Action taken under these Rules shall supersede any action taken under any other rules relating to the conduct of those enrolled with ACM. 

4.2 Students accept, subject to their signed agreement as part of the enrolment process, that they will comply with the policies and procedures of ACM, and the academic regulations of ACM and, where applicable, its validating partners (e.g. in the case of FE). 

4.3 Students shall observe all lawful regulations or directions in relation to their attendance and their studies which may be made or given by staff of ACM acting by authority of the Executive. Breach of the provisions of the Policies, Codes, Rules and Regulations of ACM or failure to comply with a previously imposed warning under this Code or any other Policies, Codes, Rules and Regulations of ACM may result in disciplinary action. 

4.4 Students shall observe all lawful regulations or directions in relation to the effective organisation and management of ACM, which may be made or given by staff of, or contractors to, the institution, acting on the authority of the Executive (for example, regulations or directions in relation to health and safety, the use of facilities, the use of computers, refreshments, entertainment events and the payment of fees and charges). 

4.5 The conduct covered within these Rules shall constitute misconduct if it takes place on ACM property or premises or elsewhere if the student concerned was involved in an ACM activity, was representing ACM or was present at that place by virtue of their status as a student of ACM, including any work placement. 

4.6 It shall also constitute misconduct in any location whatsoever if the actions bring or have potential to bring ACM into disrepute, through reputational damage or other harm.  

4.7 The Student Conduct and Discipline rules extend to alleged misconduct by a student occurring on or off ACM premises (including via social media) where the alleged victim is ACM itself, a student or employee of ACM or others visiting, working or studying at the institution and to alleged misconduct occurring during institution activities (including placements and field trips). 

4.8 ACM is committed to putting in place measures to ensure students are dealt with fairly and impartially. Part of this commitment includes the ability to bring representation to meetings under this policy, and our commitment to enable students to continue with their studies wherever possible. 

4.9 This policy/procedure relates to all ACM provisions, including at our London, Guildford and Birmingham campuses. 

4.10 Definitions 

(a) ‘Suspension’ is a temporary precautionary measure that refers to forbidding attendance at, or access to, any parts of ACM and any participation in ACM activities. The suspension may be subject to qualification, such as permission to attend for the purpose of assessment. The exact details of the exclusion will be specified in writing. 

(b) ‘Exclusion’ involves selective restriction on attendance at, or access to ACM, or forbidding carrying out the functions or duties of any office or committee membership in ACM or the Student Voice Committee. The exact details of the exclusion will be specified in writing. 

(c) ‘Deregistration’ involves the permanent withdrawal of the student from all activities concerned with ACM. 

(d) ‘Risk Assessment’ is an assessment carried out in accordance with section 4.13 below, to evaluate what if any risks there might be in allowing a former student to be readmitted to ACM for any course offered by the institution. 

(e) ‘Reporting’ student, person or party refers to the person who reports the alleged breach of the Student Conduct and Discipline rules. 

(f) ‘Reported’ student, person or party refers to the person who is alleged to have breached the Student Conduct and Discipline rules.

4.11 Evidence 

Evidence is: 

(a) any statement(s) and other supporting information received from the reporting student(s) or reporting party; 

(b) any statement(s) and other supporting information received from the reported student(s); 

(c) any statement(s) and other supporting information received from other witnesses.

Normally, unless the reporting student objects, their evidence will be shared with the reported student. If the reporting student does not wish to have their evidence shared, ACM will respect that decision and the report will then be viewed as an anonymous report, which may affect the investigation and the outcome. 

ACM does not consider character references as evidence. 

If the matter has been referred to the police, the reporting student should provide their crime reference number or CAD number to ACM within 10 working days of reporting the incident. The reporting student should keep ACM updated on the police investigation. 

Failure to provide the requested information may result in ACM being unable to investigate the alleged misconduct. It is the responsibility of the reporting student to cooperate fully with ACM. 

4.12 Timeliness 

ACM will normally conclude the procedure pertaining to the alleged misconduct within 90 calendar days of the start of the investigation stage. 

4.13 Readmission Risk Assessment 

(a) The Academic Registrar (or nominee) will identify an appropriate panel of staff to carry out the Risk Assessment. 

(b) The panel’s evaluation will take into account all information that it considers is relevant to the Risk Assessment, including how serious the previous misconduct was. The panel may request a meeting with the former student, and/or other relevant individuals. The panel may decide the following outcomes when it has completed the Risk Assessment: 

  • Conclude that there is no risk to the applicant being readmitted; 
  • Reject the student’s application for admission based on the assessed risk(s) to admission, and the conclusion that the risks cannot be adequately managed if the student was readmitted. Such a decision is final; 
  • Conclude that there are risks, but that the student may be readmitted taking into account actions that ACM can take to manage the risk. 

5   The Disciplinary Procedure

Stage 1: Early Resolution and Reporting 

• Misconduct resolved at local level by a member of staff (by sanctioning a penalty of 0 warning points, i.e. a warning letter). 

• If resolution at local level is not possible or inappropriate, the misconduct is reported to the Student Conduct Investigatory team. 

 

Stage 2: Investigation 

• The Student Conduct Investigatory team gathers evidence (e.g. written statements, reports, emails). 

• The student may attend an investigatory meeting to answer questions and present their version of events. 

 

• The Academic Registrar (for HE) or the Principal of Further Education (for FE)  (or their nominee) considers the evidence and determines the following: 

o To take no further action; 

o To issue a Formal Written Warning, including sanctions; 

o To order the making good or restitution of damage or loss; 

o To suspend, pending further investigation, or to exclude; 

o To set up a disciplinary panel.

 

Stage 3: Disciplinary Panel 

• The student is advised in writing that a disciplinary panel will be formed to consider the alleged misconduct.

• The student is invited to a disciplinary hearing in front of a panel to answer questions about the alleged misconduct and give an account of their version of events. 

• The student has the right to be accompanied for the purposes of support (see paragraph 6.5). 

• Within 5 working days of the disciplinary hearing taking place, the disciplinary panel convenes to consider all evidence presented before it and to decide an outcome (more than one of the following may apply): 

o To take no further action; 

o To issue a written warning, including sanctions; 

o To order the making good or restitution of damage or loss; 

o To suspend or exclude the student; 

o Where 4 or more warning points have been reached or exceeded, a verdict decision of suspension or deregistration to be reached.

 

Stage 4: Appeal 

• The student has the right to appeal to the Executive Dean of Education (or nominee) via appeals@acm.ac.uk and within 10 working days if aggrieved by the verdict made by the disciplinary panel, the decision to suspend, exclude or deregister, or by an order to make good of damage or loss. 

• The Executive Dean of Education (or nominee) will consider the case. 

• The verdict of the Executive Dean of Education (or nominee) marks the completion of ACM’s internal procedures. At this point, the student will be issued with a Completion of Procedures letter, which allows recourse to the Office of Independent Adjudicator (OIA). 

Stage 1: Early Resolution and Reporting 

5.1 Where a student engages in any activity which may constitute misconduct under the ACM’s Student Conduct and Discipline rules, the following procedures shall apply. 

5.2 Where issues concerning student conduct and behaviour arise in the day to day running of the institution, where possible, these issues are to be resolved at a local level by a member of staff or a contractor normally within 21 working days of the date of the incident. 

5.3 With respect to student conduct and behaviour in a learning or teaching environment, appropriate managers are empowered, on an individual basis, to issue a written warning (0 warning points). Managers do not have the authority, on an individual basis, to impose sanctions greater than 0 warning points. All sanctions greater than 0 warning points shall only be imposed by a disciplinary panel. 

5.4 If it is not possible and/or appropriate to deal with an issue at a local level or the issue concerns misconduct which appears to be actually or potentially serious i.e. is deemed to warrant a sanction greater than 0 warning points (warning letter), the matter shall be reported to the attention of the Student Conduct Investigatory team. 

5.5 If a concern is reported to the Student Conduct Investigatory team, the student will normally be informed of this. 

5.6 Depending on the nature of the concern and the information available, a decision will be made by the Academic Registrar (or nominee) on whether or not to suspend or exclude the student pending further investigation. A risk-based approach may be used to inform this decision. 

5.7 ACM is committed, where possible, to ensuring students can remain engaged with their studies whilst disciplinary proceedings are ongoing. 

5.8 ACM will consider any reasonable adjustments for investigatory meetings and disciplinary hearings if they are provided by the student not less than 24 hours prior to the meeting. 

5.9 Suspension/De-registration is most likely to be used only if the seriousness of the case warrants it.

5.10 A student who is suspended or excluded during an investigation into their conduct will have the opportunity to request a suspension/exclusion review. The panel will not normally enter into discussion about the substantive nature of the allegation with the student as this will be reserved for the Investigation stage of the Disciplinary process. A request for a suspension/exclusion review should normally be made in writing and will normally take place within 5 working days from the date of the request.. In addition, the student may at any stage request a review of the suspension/exclusion decision by the Academic Registrar (for HE) or Principal of Further Education (for FE) (or their nominee) if there is a material change in circumstances. 

5.11 In a suspension/exclusion review, the panel will consider: 

  • any relevant reports, documents and records; 
  • the student’s response to the allegation; 
  • any relevant witness statements; and 
  • the seriousness (and frequency) of misconduct. 

It is the panel’s responsibility to determine the outcome of the suspension/exclusion review and to decide one or more of the following options: 

  • to lift suspension and take no further action; 
  • to lift the suspension and impose exclusion conditions; 
  • to keep the suspension/exclusion conditions in place, pending further investigation; 
  • to progress to a disciplinary hearing. 

A risk-based approach may be used to inform any of the above outcomes.

5.12 Should the student not attend a review when requested, the review panel shall continue in the student’s absence. The Academic Registrar (for HE) or Principal of Further Education (for FE) (or their nominee) will contact the student in writing thereafter regarding the panel’s decision. 

5.13 When a concern is reported, the Student Conduct Investigatory team will progress the disciplinary process to Stage 2 and commence investigatory proceedings.

6   Stage 2: Investigation and Investigatory meeting

6.1 The Student Conduct Investigatory team will commence the investigation stage, which constitutes gathering information and collating evidence relating to the allegation of misconduct. 

6.2 Evidence is likely to be, but not exclusively, in the form of a written statement from the reported party/parties; statements from other parties, for example, from a member of staff; reports from, for example, Security; other forms of evidence, such as CCTV footage, emails, text messages, messaging on social media, mobile phone screenshots. In addition, a student may be invited to attend an investigatory meeting where they will be asked questions relating to the alleged misconduct and provided the opportunity to present their version of events. 

6.3 In the absence of a written statement from the reporting party and/or where permission to share a statement with other parties has not been given, the investigation can proceed on the basis of the evidence that is available. At the investigatory meeting, the investigatory officers may pose questions based on the available evidence (i.e. a statement that has not been shared). The reporting party will be advised that, in them not consenting to sharing a statement, the investigation may be impaired to a degree. Depending upon the severity of the case, investigations would normally be completed within 21 working days. Parties will be updated if the timescale cannot be adhered to. 

6.4 If an investigatory meeting is required, the student will be requested in writing to attend. The purpose of the investigatory meeting is for the student to answer questions pertaining to the alleged misconduct. 

6.5 At an investigatory meeting, students are entitled to be accompanied by a friend, parent, mentor, or other representative. Students under the age of 18 or adults at risk must be accompanied by their parents, guardians or adults who have a position of responsibility for the student’s welfare. Any other representation is not normally allowed except with express permission from the lead investigator or Chair of the Disciplinary panel. Legal representation is not permitted. 

6.6 Helping a student to speak for themselves during the disciplinary procedure and ensuring that they are heard is known as ‘advocacy’. It is the responsibility of ACM to ensure that a student is provided with appropriate support where it is needed. Students are encouraged to make use of the support and guidance of Student Services.

6.7 On conclusion of the investigatory proceedings, the Academic Registrar (for HE) or the Principal of Further Education (for FE) (or their nominees) shall consider the gravity of misconduct and determine the following (more than one may apply): 

  • To take no further action; 
  • To issue a written warning including sanctions; 
  • To order the making good or restitution of damage or loss i.e. to impose a fine; 
  • To exclude or suspend the student; 
  • To set up a disciplinary panel. 

A risk-based approach may be used to inform any of the above outcomes. 

6.8 Further breaches of the Student Conduct & Discipline rules will be considered at a Disciplinary Panel.

7   Stage 3: Disciplinary Panel 

7.1 A disciplinary hearing is a meeting whereby a student will be required to discuss allegations against them in front of a panel and answer questions relating to the allegation of misconduct. 

7.2 The panel will be made up of stakeholders with the suitable expertise to fairly, impartially and carefully consider the case and will be comprised as follows: 

  • Chair (Academic Registrar or nominee)
  • Education representative 
  • Student Services representative (e.g. Safeguarding or Additional Needs and Disabilities team member)  

7.3 The disciplinary panel will consider the evidence before it, including any statements that have been made and any evidence that has been submitted by the reported student at the investigatory meeting or in writing. 

7.4 At the disciplinary panel, the panel will consider: 

  • the evidence presented before them; 
  • the student’s response to the allegation; 
  • any witness statements, including those provided to the panel in person; 
  • and, the gravity (and frequency) of misconduct. 

It is the panel’s responsibility to determine  the outcome of the disciplinary hearing and to decide one or more of the following options: 

  • to take no further action; 
  • to issue a written warning including sanctions; 
  • to order the making good or restitution of damage or loss 
  • to exclude or suspend the student; 
  • to revoke Alumni benefits; 
  • to deregister the student. 

A risk-based approach may be used to inform any of the above outcomes. 

7.5 The student will normally be informed of the panel’s decision within 5 working days of the disciplinary hearing. 

7.6 Should the student choose not to attend the panel they have the right to provide representation in the form of a written statement. 

7.7 Should the student choose not to attend, the disciplinary panel shall continue in the student’s absence. The Academic Registrar (or nominee) will contact the student in writing thereafter regarding the panel’s decision. 

7.8 Meetings are not normally recorded. Should a recording of the meeting be required, it may take place only with the consent of all attendees. 

8   Stage 4: Appeal 

8.1 The student shall have the right of appeal to the Executive Dean of Education (or nominee) by submitting their appeal in writing within 10 working days, giving the grounds for the appeal, if: 

  • The student is aggrieved by the decision reached at the investigatory stage (see section 6.5); 
  • The student is aggrieved by the panel’s decision from a disciplinary hearing (see section 7.7); 
  • The student is aggrieved by the decision to suspend or exclude (see section 5.11); 
  • The student considers that the procedures were not followed properly; 
  • The student has new material evidence that they were unable, for valid reasons, to provide earlier in the process; 
  • There is bias or reasonable perception of bias during the procedure. 

8.2 If the Executive Dean of Education (or nominee) considers for any reason that the panel’s decision needs to be referred back for further consideration (for example, student provides new material evidence or there is evidence of bias during the disciplinary procedures) the Executive Dean of Education (or nominee) may refer the matter back to the Academic Registrar or nominee to consider the evidence and to decide whether or not it would result in a change to the outcome. 

8.3 The Executive Dean of Education (or nominee) may seek clarifications to enable them to make a decision on whether to uphold or amend the decision. The purpose of the clarifications would not be to consider any new evidence; rather, it would be to help the reviewer at the appeal stage to understand any information that exists that is not clearly understood by the reviewer. 

8.4 Working day refers to a day on which ACM is normally open: it does not include Saturday, Sunday, Bank Holidays or other designated periods of closure outside the academic terms. 

8.5 The Executive Dean of Education (or nominee) shall consider the appeal and shall decide whether to uphold or amend the decision made. The decision of the Executive Dean of Education or nominee shall be final. 

8.6 Following an appeal to the Executive Dean of Education (or nominee), these procedures will now be complete. For FE students, the procedure will now be complete. For HE students, they may wish to consider approaching the Office of the Independent Adjudicator (OIA). 

8.7 Where the student is an HE student, an appeal to the Office of the Independent Adjudicator should be made in writing to the address below within one year of the student receiving notification that the internal procedures of ACM have been completed. They should enclose a copy of ACM’s final decision and state the reasons for seeking redress from the Higher Education Independent Adjudicator. 

Email enquiries may be sent to enquiries@oiahe.org.uk. The website address is www.oiahe.org.uk

9   Warning Points System 

9.1 Where a student’s behaviour is being considered by the Academic Registrar (or their nominee), either at Stage 2: Investigation or Stage 3: Disciplinary hearing, then warning points may be used as a penalty (either alone or in combination with other penalties), if considered reasonable and proportionate in the circumstances. Warnings, where considered appropriate, are recorded according to the seriousness and nature of the behaviour. There is no requirement that ACM apply warnings where a warning is considered inappropriate to the circumstances and an alternative penalty is applied. 

9.2 Offences, for the purpose of warnings, fall into different levels of seriousness classified on a four-point scale: minor — serious — grave — suspension/deregistration. 

9.3 A guide to the type of warning which might be issued is provided in paragraph 3.4 ‘Table of types of misconduct and consequences’. However, this is only a guide and it is expected that the Academic Registrar (or their nominee) will use their discretion and take into account the individual circumstances of each offence and vary the type of warning and/or penalty issued accordingly. 

9.4 Warnings recorded remain on the student record for the duration of the student’s enrolment at ACM. 

Accumulation of warnings 

9.5 Each level of warning is scored on a 0 to 4 basis as follows: 

Number of Warning Points: 

0  Written 

1  Minor 

2  Serious 

3  Grave 

4  Suspension and/or Deregistration  

9.6 Where the student has reached or exceeded 4 warning points on their student record, a decision about suspension, exclusion or deregistration must be made, and the student should normally be notified within two months after the most recent warning point is awarded. 

Relationship with other penalties / warnings 

9.7 ACM, independent of these Rules, separately has financial and other penalties which may be imposed such as library fines, use of facilities for which a charge is made, refusal to provide information required by law, reimbursement for loss or damage to ACM or personal property of staff, students or visitors, and whereby the use of facilities is regulated. Action taken by ACM under those arrangements does not automatically, but may, lead to reference to the Academic Registrar (or their nominee) for consideration of a warning or for other action under the Rules on Student Conduct and Discipline, with any such warning to be additional to any of the foregoing penalties, charges or reimbursement. 

9.8 ACM may record the existence of warnings on any reference supplied. 

9.9 If an applicant has had previous study terminated as a result of misconduct, ACM reserves the right to not consider their application to any programme of study.

10   Misconduct which is also a criminal offence 

10.1 There may be instances where an alleged act of misconduct may also constitute a criminal offence. 

10.2 The nature and scope of ACM’s internal disciplinary process and the nature and scope of a criminal process are fundamentally different. It is important to maintain a clear distinction between them: 

  • Under the criminal process, the allegations will be treated as a potential criminal offence; under the disciplinary process, the allegations will be treated as a potential breach of discipline. 
  • The criminal process is an external procedure. It deals with allegations that a student has committed a criminal act. The allegation has to be proven beyond reasonable doubt. A judge can impose a wide range of sanctions on an individual who is found to have committed a criminal offence, the most serious sanction being imprisonment. 
  • The internal disciplinary process is a civil matter conducted internally at the institution. It is based upon an allegation that a student has breached the ACM’s rules and regulations. The allegation has to be proven on the balance of probabilities. The most serious sanction that can be applied is permanent expulsion from the institution (deregistration). 
  • Any adverse finding in the criminal process could result in the student having a criminal record and that subsequently could have a serious, detrimental effect on the future of the individual concerned at ACM.

10.3 The criminal process takes priority. If the matter is being dealt with under the criminal process, then save for taking any necessary precautionary action, the disciplinary process will be suspended until the criminal process is at an end. In that way, the disciplinary process does not duplicate the criminal process. 

10.4 If the matter is not being dealt with under the criminal process or where the criminal process has concluded, then ACM will consider whether a breach of discipline has occurred and, if so, will consider the matter through ACM’s Student Conduct and Discipline procedure.

11   Procedures for Misconduct which may constitute a criminal offence 

Reporting Incidents 

11.1 Anyone can make a report of criminal activity to the police. Where the victim of a criminal offence is the reporting student, ACM will usually take the position that the decision to report a criminal offence is a matter for the reporting student. It is not the responsibility of ACM to inform a student about a police investigation. 

Precautionary Measures 

11.2 Where an offence under criminal law is reported to ACM, action under this Policy will be deferred pending any police investigation or prosecution (the student will be required to provide ACM with a written update of any police investigation) save for taking any necessary precautionary measures: 

  • to ensure that a full and proper investigation can be carried out (either by police or by an ACM investigator); and/or 
  • to protect the reporting student or others while the allegation is being dealt with as part of a criminal process or a disciplinary process. 

Such precautionary measures would be considered by ACM at the point at which the reported student is made aware that a police investigation is being pursued. These measures would remain in place whilst the police investigation is ongoing. 

11.3 Precautionary measures may be put in place if they are reasonable and proportionate and may include: 

  • Imposing conditions on the accused student (for example, requiring the accused student not to contact the reporting student and/or certain witnesses) 
  • Suspending the accused student from his/her studies on a full, qualified or partial basis 
  • Excluding the accused student (for example, prohibiting the accused student from attending certain ACM events or activities, or exclusion from specified locations). 

11.4 ACM has the right to review a case if no information has been forthcoming from the student and/or the police regarding the progress of the case. ACM may come to a conclusion based on the evidence available. 

Criminal Investigation / Prosecution 

11.5 Where the offence under criminal law is reported to the police, action under this Policy will be deferred pending any police investigation or prosecution. Where ACM makes a finding of misconduct and the student has also been sentenced by a criminal court in respect of the same facts, the court’s penalty shall be taken into consideration in determining any warning points under this Policy. A risk-based approach may be used to assess whether a student may return to study.

Disciplinary Investigation / Charge 

11.6 If the reporting student will not report the matter to the police or will not cooperate in their enquiries, or the accused student is acquitted following a criminal process, ACM may consider the matter as a potential breach of student conduct and may consider sanctions. Only in exceptional circumstances will ACM report an alleged crime to the police contrary to the wishes of the reporting student. 

11.7 Depending on the nature of the concern, ACM may refer the misconduct which constitutes a criminal offence to the police. 

11.8 Sanctions for misconduct involving an illegal act include the following: 

  • Consumption of and/or possession of illegal substances on ACM premises or at an ACM event or activity (0-2 Warning Points) 
  • Dealing illegal substances on ACM premises or at an ACM event or activity (4 Warning Points)

Supporting Students 

11.9 ACM will make available appropriate assistance and relevant information and support to all students involved in disciplinary matters which may constitute a criminal offence, from the time when the incident is first reported to ACM up until the time when the relevant criminal and/or disciplinary process has been concluded and, in some cases, beyond that.

11.10 In cases involving allegations made by one student against another student, ACM will afford the same duties and obligations to both students so as to ensure both are treated fairly. Due regard will be taken, for example, to exercise a duty of care, apply the principles of natural justice, i.e. the right to a fair hearing before an impartial decision-maker, comply with equality law duties and uphold human rights and freedom of speech. 

11.11 It is ACM’s priority to ensure, where possible, that the disciplinary process does not impinge a student’s academic studies. This may mean, for example, the implementation of no-go areas on the ACM campus, in place of suspending a student. 

11.12 Advice and support is available to all students involved in disciplinary matters, in which they may reach out to the ACM’s Student Support services, such as the wellbeing or safeguarding teams. These teams are available at wellbeing@acm.ac.uk and safeguarding@acm.ac.uk 

  1. DOCUMENT HISTORY AND REVIEW
Version 1.5
Approved on 01 September 2025
Approved by Student Experience and Opportunity Board
Date of next review August 2026

 

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