Policies – Bath Spa University

Find out more about how we work and the standards to which we hold ourselves.

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General policies

Establishing University Policies and Procedures

The purpose of this Policy is to establish a consistent approach to the development of University policies and procedures to ensure that members of the University community and other users have ready access to well-developed and clear policies.

Anti-slavery statement

Bath Spa University Statement on Modern Slavery and Human Trafficking

Dated 31 July 2020

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.

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 principal place of business is at Newton Park, Newton St Loe, Bath BA2 9BN. The University has approximately 900 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 £82,000,000.

The University comprises of eight academic schools: Bath Business School, Bath School of Art, School of Creative Industries, Bath School of Design, School of Education, School of Humanities, Bath School of Music and Performing Arts and the School of Sciences.

Several professional services departments exist to provide services to the students and the University as a whole. These include Human Resources, Academic Planning, Student Experience, Finance and Infrastructure, External Affairs, the University Secretary’s Office, Research and Graduate Affairs. Within Finance and Infrastructure, the procurement function supports academic schools and departments in ensuring the University obtains value for money in all the goods and services it purchases, in-line with the University's Financial Regulations and the Public Contracts Regulations 2015.

Our Policies

We have a zero tolerance to slavery and human trafficking. The University maintains policies relating to procurement, sustainability, equality, wellbeing and diversity which together form a robust institutional effort to combat slavery and human trafficking. Where relevant, our policies extend to our suppliers in expectations of adherence to external regulations and University principles.

The University’s procurement policies are concerned with adherence to the conditions outlined elsewhere in this statement and in ensuring due diligence, and include a sustainable procurement policy.

The University is committed to conducting its business with honesty and integrity, and it expects all staff to maintain high standards. Staff are encouraged to raise concerns of a public interest or make a public interest disclosure as part of the Whistleblowing Policy which is designed to allow concerns of a public interest arising in relation to the University to be raised, investigated and where appropriate, acted upon.

Our supply chains

To ensure all those in our supply chain and contractors comply with our policies, we have in place a supply chain compliance programme. Wherever possible our supply chain is made up of suppliers who are registered under framework agreements such as Southern Universities Purchasing Consortium, Crescent Purchasing Consortium, Crown Commercial Services and Health Trust Europe.

Consultancies and construction work are also lodged under framework agreements to ensure compliancy with legislation.

Due diligence processes for slavery and human trafficking

Supply chain management from the consortia is routine throughout the contractual term and it is common for staff to manage contracts throughout the term to ensure value for money. On the occasions where a framework agreement cannot be used the University carries out due diligence on all new suppliers prior to placing a purchase order, as standard, this includes question pertaining to modern slavery compliance. Further engagement with the suppliers is subject to review dependent on this confirmation step and the University’s standard contractual clauses explicitly require adherence by all suppliers to the Modern Slavery Act 2015.

The University works to identify and assess 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 a high level of understanding of the risks of modern slavery and human trafficking in University business and its supply chains, the University offers training to all appropriate staff.

The process all University staff must follow, in the engagement of a new supplier and inclusion of querying the suppliers' efforts and steps taken to ensure compliance with the Act, acts as an engagement tool to ensure that staff 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 in line with the publication of the University’s financial statements.

Further steps

Going forward, the University’s Sustainability Group will work closely with colleagues across the University including Procurement, Finance and Estates functions to monitor higher risk areas within the University’s supply chain.

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 2020. It was approved by the Board of Governors of Bath Spa University on 25 November 2020.

Equality

We value diversity and we recognise that different people bring different ideas, knowledge and culture, and that difference can bring strength, creativity and innovation.

We believe that discrimination or exclusion based on individual characteristics and circumstances, such as the below, represents a waste of talent and a denial of opportunity for self-fulfilment:

  • age
  • disability
  • caring or dependency responsibilities
  • gender or gender identity
  • marriage and civil partnership status
  • political opinion
  • pregnancy and maternity
  • race
  • colour
  • caste
  • nationality
  • ethnic or national origin
  • religion or belief
  • sexual orientation
  • socio-economic background
  • trade union membership status or other distinctions.

We recognise that patterns of under-representation and differences in outcomes at Bath Spa University can be challenged through positive action programmes.

We respect the rights of individuals, including the right to hold different views and beliefs. We will not allow these differences to be manifested in a way that is hostile or degrading to others.

We expect commitment and involvement from all our staff, students, partners and providers of goods and services in working towards the achievement of our vision.

Read the full Equality policy.

Harassment

The Vice-Chancellor has responsibility and accountability for Equality throughout the institution and is also responsible implementing and monitoring this policy through the Equality and Diversity Steering Group. However, all members of the University, both staff and students, have a duty to ensure that individuals do not suffer from any form of harassment and that if they do, they are supported in seeking to eliminate it and in pursuing any legitimate complaint about the harassment.

Read the full Harassment policy.

Safeguarding, Wellbeing and the Prevent Duty

As part of the UK Government's strategy to reduce terrorism, the Counter-Terrorism and Security Act 2015 introduced a statutory duty on Higher Education Institutions to have "due regard to the need to prevent people from being drawn into terrorism". This legislation is called the Prevent Duty and applies to all forms of extremism, including the Far Right, Islamist groups and animal rights groups. Prevent is one of the Government's four strands of counter-terrorism strategy (CONTEST) and aims to stop people becoming terrorists or supporting terrorism.

Read the full Safeguarding, Wellbeing and Prevent Duty policy.

Sexual Violence and Misconduct

The University is committed to providing a safe and secure environment for all its students and staff. The following policies set out how the University will deal with incidents and allegations of Sexual Violence and Misconduct against members of the student and staff communities.

Trans

Bath Spa University is committed to being a fair and inclusive employer and will not discriminate against an applicant, employee or student who identifies as trans. Trans employees and students are entitled to be treated with respect and permitted to perform their roles free from harassment and unfair discrimination. Bath Spa University views harassment or discrimination against any student or employee on any grounds as a serious disciplinary offence.

Read the full Trans policy.

Policy themes

Academic and Student

*This framework comes into effect for new enrollments from July 2019.

Finance and Risk

*The Contract Management Policy will not apply to Bath Spa University precedent contracts (such as contracts of employment) that:

(i) have been approved as an exception by the University Secretary pursuant to the Financial Regulations; and
(ii) have not been substantially varied.

Supporting documentation: How To Guide and Contract Review Sheet.

Staff

Accessibility statements

We're committed to improving the accessibility of our website and other platforms and systems, in accordance with the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018.

Accessibility statement for our website

Introduction

Bath Spa University is committed to making its website accessible, in accordance with the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018.

This website is not compliant with the Web Content Accessibility Guidelines version 2.1 AA standard. The non-accessible sections are listed below.

Issues with PDFs and other documents

The majority of PDFs on our website are partially compliant, but many have the following issues: 

  • The Bath Spa University logo does not have an alt-tag in the Programme Documents PDFs.
  • There are no running headers and footers.
  • There are no bookmarks
  • Many PDFs do not use the H1 tag on the title page.

Some of these errors are due to using programmes other than MS Word to generate the PDFs. We are experimenting with ways we might be able to improve the PDF output from our document management system. 

Issues with images, video and audio

Many images on our website are compliant, however we are aware of the following issues:

  • Some images are missing alt-text tags. 
  • Some third party applications such as the cookie manager, pixel tag images, social share buttons etc are missing alt-tags. Some of the third party inclusions may be beyond our control to amend.
  • The videos on our site are hosted via YouTube and use automatically generated closed captioning. This may not be 100% accurate captioning.
  • Transcripts have not been provided.

Issues with interactive tools and transactions

We are aware of the following issue:

  • The search filters on the right side panel of our global search and course search do not yet have separate label tags, which may make it harder for accessibility tools to understand. We have arranged for this work to be completed as soon as possible.

How we tested this website

We tested the site ourselves with the European Internet Inclusion Initiative (EIII) checker. 

We tested:

What we're doing to improve accessibility

The website was designed with basic accessibility features such as responsive content, use of appropriate hierarchical heading tags, a preference for on-page text rather than attachments wherever feasible. However, we are aware that there is much more we can do to improve our site's ability to work with accessibility tools. We are committed to undertaking this improvement work in a methodical way, as far as possible within our resource and budget allowance.

  • We are currently working on a project to add ARIA tags added to the appropriate areas of our pages, to help accessibility tools negotiate the individual pages. We began our accessibility improvement with this project as our Funnelback site assessment tool deemed this the single biggest difference we could make to the site. This is helping improve the accessibility of our site, but will take some time to complete. Once this project is complete, we will continue to work through the issues with the goal of prioritising the removal of the most widespread or significant issues as recommended by Funnelback accessibility auditor tool. 
  • We are working through images our media library to check for and fix missing alt-text tags.
  • We are working with our support provider to have these search facets amended to include the label tags. 

This statement was prepared on . It was last updated on  

As at the day of writing, we have removed about 40% of the accessibility errors recorded at the same time last year. We acknowledge that we have a lot more work to do.

How accessible is our website?

What to do if you can't access parts of the website?

Reporting accessibility issues

Our website has been developed using responsive design so most content will be accessible on different device sizes and font sizes can be adjusted using the browser magnification settings. This includes content such as social media posts embedded in the site. The site has also be designed to be printed to a neat PDF, and this works even when the font sizes are increased significantly using the browser. 

If you cannot access parts of the website or need some content provided in a different format to help you access it, please contact us to discuss. 

Please report accessibility issues by email at web-accessibility@bathspa.ac.uk or by phone on +44 (0)1225 875875 or in person at our Newton Park campus reception. If you are unhappy with how we respond, please contact the Equality Advisory and Support Service (EASS).

Privacy notices

We're committed to the security of your personal data, and to enabling your rights under the Data Protection Act 2018, GDPR, and associated data protection law.

Privacy statement

The University is registered as Data Controller with the Information Commissioners Office, registration number: Z7222773.

This notice and any other documents referred to in it set out the basis on which we will process any personal data we collect from data subjects, or that is provided to us by data subjects or other sources.

We may update our Privacy Notices at any time. The current version of all of our Privacy Notices can be found below, and we encourage you to check back here regularly to review any changes.

Unless specific time periods are given in the relevant Privacy Notice, your data will be kept in-line with the University's Records Retention Schedule.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Contact the Data Protection Officer

The University has appointed a Data protection Officer:

Postal address:

Data Protection Officer
Bath Spa University
Newton Park
Newton St Loe
Bath
BA2 9BN
United Kingdom
Email: data-protection@bathspa.ac.uk.

What is personal data?

"Personal data" is defined as information relating to a living individual that enables that individual to be identified either from the data.

Personal data may contain “special categories of data” as described under the new law. Such “special categories of data" may include information about your racial or ethnic origin, religious beliefs or other beliefs, physical or mental health or, in relation to DPA only, other conditions and information concerning any criminal offences or criminal proceedings.

How you're protected under data protection law

Data protection law means that any processing undertaken by us must be done for specified purposes (outlined within these privacy notices) and that we have a relevant lawful basis for the processing. Under the new rules there are six possible bases:

  1. Consent: on occasions where the University will only process certain data for a specific purpose, subject to you having provided clear and affirmative consent. This is always required if we're processing special categories of personal data.
  2. Contract: it may be necessary to process your personal data to fulfil the contract we have with you or you have asked us to take specific action before entering into a contract with us.
  3. Legal obligation: the processing of your data is necessary for us to comply with the law (not including contractual obligations).
    Vital interests: the processing of your data is necessary to protect someone’s life.
  4. Public task: the processing of your data is necessary for us to perform a task that is in the public interest or for official functions, and the task or function has a clear basis in law.
  5. Legitimate interests: the processing of your data is necessary for the legitimate interest of the University or a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.

Your rights, including access to information and correction

Right of notification

All data subjects (students, applicants, visitors to our website, and others as specified in our privacy notices) have the right to be informed about the collection and use of data. As Data Controller, the University is required to provide you with information about how we process your data and your rights under the new data protection law.

You also have the Right to be notified of data rectification and erasure, such as in the event of a data breach.

Right of access/ portability

You have the right to find out what information we hold about you, and you are able to request that information from us by submitting a Subject Access Request via our Data Protection Officer.

You also have the right to request data we hold to be provided to you in a format suitable to transferring to other data controllers, which is your right to portability.

Right to rectification

You have to right to contact us to rectify any information we hold about you and you can do this at any time either via the self-service portal, available to students and staff, or by contacting data-protection@bathspa.ac.uk

Right to erasure

You have the right to request that we delete your information at any point, which we must do unless the information is necessary (such as your academic record if you are a student)

Right to restriction of processing

If you think there's a problem with the accuracy of the data we hold about you, or if you think we're using data about you unlawfully, you can request that any current processing is suspended until a resolution is agreed.

Right to object

You have a right to object to how we use your data if we do so on the basis of "legitimate interests" or "in the performance of a task in the public interest" or "exercise of official authority" (a privacy notice will clearly state this if this is the case). Unless we can show a compelling case why our use of data is justified, we have to stop using your data in the way that you've objected to.

Right to not be subject to automated decision making

If any decision has been about you based on automated software (such as segmentation or suitability a bursary) you have the right to request a human being review the decision.

Withdrawing your consent

Where we have your consent to any processing (made clear within our privacy notices or at the time of collecting your data) you have the right to withdraw your consent at any time.

Exercising your rights, queries and complaints

For more information on your rights, if you wish to exercise any right, for any queries you may have, or if you wish to make a complaint, please contact our Data Protection Officer: data-protection@bathspa.ac.uk.

Complaint to the Information Commissioner

You have a right to complain to the Information Commissioner's Office (ICO) about the way in which we process your personal data. You can make a complaint on the ICO website.

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