Policies

Bath Spa University Statement on Modern Slavery and Human Trafficking

Bath Spa University is proud of its vision to be a leading university in creativity, culture and enterprise.  Underpinning this vision is a principle to act ethically; the University is therefore committed to establishing practices to combat slavery and human trafficking.

The University is a Fairtrade University.  Increasing the range of products bearing the Fairtrade Mark that are sold by the University ensures that the relevant parts of its supply chain are more likely to meet Fairtrade standards that protect workers’ rights and guarantee payment of a minimum price.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the University’s slavery and human trafficking statement for the financial year ending 31 July 2018.

Our structure

Bath Spa University is a higher education corporation established pursuant to the Education Reform Act 1988.  It is also an exempt charity regulated by the Office for Students.  The University’s principle place of business is at Newton Park, Newton St Loe, Bath BA2 9BN.  The University has approximately 1,000 employees, the majority of which are based in the United Kingdom.

The University has two subsidiary companies, Bath Spa U Limited and Bath Spa Venues Limited.  The annual turnover of the consolidated accounts of the University is in the region of £83,000,000.

The University comprises of three distinct academic units: Bath Spa School of Art and Design (BSAD); The College of Liberal Arts (CoLA); and The Institute for Education (IfE).  Sitting within each of these units are departments and fields of study such as the Bath Business School, which operates as a field within CoLA.

Several professional service departments exist to provide services to the students, the academic units, departments and fields.  These include finance, human resources, student services, academic services, estates, compliance, international relations, marketing, legal and others.

Within Finance there is a specialist Procurement office, which deals with the University’s supplier implementation; within Estates, there is a Sustainability team, which leads on Supplier engagement and review in relation to compliance with the Act.  

Our supply chains

Our supply chains include: suppliers registered under Government procurement contracts, including Crown Commercial, The Energy Consortium, Estates contractors, suppliers of ICT equipment and related services and other professional advisors. The University also procures through a number of Frameworks, including the Southern Universities Procurement Consortium (SUPC).     

Due diligence processes for slavery and human trafficking

As a first step, all suppliers to the University are asked to confirm that they comply with the Modern Slavery act. Further engagement with the suppliers is subject to review dependent on this confirmation step.

The University works to identify potential risk areas within its supply chains, monitor and mitigate any identified risk and to protect whistle-blowers raising concerns.

Supplier adherence to Bath Spa University values and ethics

To ensure all those in the University and its supply chain and its contractors comply with our policies and procedures the University has put in place a supply chain compliance programme.  This consists of procurement procedures, contract reviews and renewal of due diligence on contract renewal.

The University is committed to sustainable procurement and plans to implement ISO 20400 by 2025; a key part of this is the undertaking of a review of the University’s current procurement framework.

Training

To ensure an understanding of the risks of modern slavery and human trafficking in University business and its supply chains, appropriate staff will be trained.

The process all University personnel must follow in the engagement of a new supplier and its inclusion of querying the suppliers’ efforts and steps taken to ensure compliance with the Act, acts as an engagement tool to encourage staff to access the resources made available in the provision of compliance.  

The publication of this statement and the University’s approach to ensuring compliance with the Act is shared with Staff via news and updates annually in line with the publication of the financial statements.  

Steps taken for 17/18 and 18/19

The University is developing a dedicated Compliance Risk Register to complement the University Strategic Risk Register. This is a cross departmental initiative which will receive reports from the various corporate legislative requirements, to include risk assessment and review of the University’s responsibilities within the Act.

A small working group, led by Sustainability in conjunction with Compliance and Procurement meets no less than twice a year to feed into the Compliance Risk Register

Note: We have detailed privacy information in our new Privacy section.

Privacy notice

Bath Spa University of Newton Park, Newton St Loe, Bath BA2 9BN is the data controller for the purpose of the Data Protection Act 2018, and associated data protection laws.

By proceeding to use our website you consent that we may process the personal data (including sensitive personal data) that we collect from you in accordance with our Data Protection Policy. In particular, we will use information we hold about you enable us to:

• Provide education and support services to our students and staff
• Advertise and promote the university and the services we offer
• Publish the university magazine and alumni relations
• Undertake research and fundraising
• Manage our accounts and records and
• Provide commercial activities to our clients.

We also process personal information for the use of CCTV systems to monitor and collect visual images for the purposes of security and the prevention and detection of crime. We use smart cards to provide access to buildings and services for staff and students and an audit trail is maintained for some services.

Our website uses cookies such as Facebook Pixel, Google Tag Manager and Google Analytics to analyse use of our website. To find out more, read the Google Analytics Privacy Policy.

Videos on our web pages are embedded mostly from YouTube and Vimeo. These third-parties might be gathering usage information and setting their own cookies. Details of their privacy policies can be found here:

• YouTube Privacy Policy (with links through to Google's main policy page)
• Vimeo Privacy Policy

Some of our web pages contain social networking buttons and functions, from providers such as Facebook, Twitter and Google, to enable the sharing of pages. The scripts used to generate these buttons come from from third-party websites and the third-parties might be gathering usage information and setting their own cookies. Details of some of their privacy policies can be found here:

• Facebook Privacy Policy
• Twitter Privacy Policy
• Instagram Privacy Policy
• Google + Buttons Privacy Policy

The privacy implications will vary across the social networks and will be dependent on the privacy settings you have chosen on these networks.

You agree that we have the right to transfer, store and process the data that we collect from you at a destination outside the European Economic Area (”EEA”).

Please email any questions, comments and requests regarding our data processing practices to the Data Protection Officer.