The University of Wolverhampton (the University) aims to foster a community with an atmosphere of trust, harmony, and mutual respect. Good standards of communal life need to be maintained for the benefit of all members. Students are expected to show proper concern in their behaviour generally and where this might reflect on the reputation of the University, and of its members.

The University recognises that there are occasions where a student’s conduct or engagement falls below the expected standards fully or partially, as a consequence of an underlying health and/or wellbeing concern. This includes those circumstances where there are substantial concerns relating to a student’s health and/or behaviour that is having a detrimental impact on themselves and/or other members of the University community.

The University has a duty to respond appropriately to such situations and provides a comprehensive and well-established range of services which are available to support the health and wellbeing of students.

The aim of the Support to Study Policy is to provide a framework and procedures aimed at enabling students, to participate, with reasonable adjustments where necessary, in their studies and/or in university life in general without negatively impacting the safety or wellbeing of themselves or others, and with full opportunities to meet the learning outcomes for their programme.

The University of Wolverhampton is committed to creating a supportive working, learning, and living environment. This policy is intended to support staff and students when a student’s health, wellbeing and/or behaviours are having a detrimental impact on their ability to progress academically at the University and seeks to ensure, wherever possible, that students can participate effectively in their academic studies and other aspects of their student experience.

1.1 Our Commitment to Student Mental Health and Wellbeing

Our Student Mental Health and Wellbeing Strategy (2022-2023) acknowledges that inclusivity, belonging, and wellbeing reinforce each other. The strategy treats wellbeing as a form of social capital that is embodied and accumulated through an individual’s life journey.  Wellbeing needs to be an integral to how we study and work every day.

The strategy is based on seven pillars: Leadership, Transitions, Collaboration and Partnerships, Data and Research, Support and Prevention, Support and Intervention, and Staff. 

This Support to Study Policy is directly linked to the Support and Intervention pillar, spanning a continuum of whole-population awareness and signposting, self-help, and early intervention, through to focused support and intervention where mental health and wellbeing difficulties arise. This includes crisis and safeguarding intervention.  

In addition, the University’s Access and Participation Plan (2020/25) aims to eradicate award and non-continuation gaps between students with protected and non-protected characteristic groups by 2030.

The University Access and Participation plans can be found at this following link: Access and Participation Plans - University of Wolverhampton (wlv.ac.uk).

Each student who does not progress in their studies, represents someone who has possibly not achieved what they set out to do, and has possibly not been able to fulfil the realisation of their ambitions. Each of them should be reflected back to the Academic Board as a red flag.

Every member of the University community has a responsibility to support others in creating a safe environment which is conducive to study, live and work. Staff are encouraged to address any concerns about a student’s health and wellbeing through early intervention and positive support.  This is delivered through the Academic Coach, Personal Tutoring and Supervision systems as well as through dedicated student support teams.

This policy supports the aims of our Access and Participation Plan by fostering a collaborative and pro-active whole population support system which can identify and implement support for students who need it.

• Definition of Support to Study

The University defines Support to Study as the means by which we support and enable students, to participate, with reasonable adjustments where necessary, in the programmes of study and/or in university life in general, without negatively impacting the safety or wellbeing of themselves or others, and with full opportunities to meet the learning outcomes for their programme.

• Purpose

This policy is intended to support students and staff in managing students’ complex needs in relation to their ability to engage in their studies. The procedure is in place to encourage a collaborative approach which enables students to move forward with their studies in a proactive way, with the primary concern being their wellbeing.

In certain circumstances, students may be referred by other teams, for example the Conduct and Appeals Unit Conduct and Appeals - University of Wolverhampton (wlv.ac.uk), for review under the Support to Study policy.  Information and guidance will be made available University wide.  This will be done when it is considered to be more appropriate for the student to be assessed under this policy, rather than under other University regulations/policies, to enable due consideration to be given to their health and wellbeing.

This does not remove the principle that students are responsible for their actions but does recognise that a more holistic and supportive approach needs to be applied to manage the situation. Similarly, students may also be referred from the Support to Study policy to other teams for consideration if it is felt necessary. It is also possible for a student to be involved in both the Support to Study policy and Student Conduct procedures concurrently.

The other teams that a student may be referred to for support and guidance are:

• Conduct and Appeals Unit
• Mental Health and Wellbeing
• Safeguarding
• Disability and Inclusion
• Doctoral College
• Accommodation
• Hardship
• Finance
• Security

1.4 Principles: Aims and Objectives

Given the scoping and consultation exercise that has been conducted to devise this policy, the University will adopt the term Support to Study. It is intended that this policy will foster a robust and supportive protocol for causes of concern to be raised and supported via a pro-active case-by-case approach, nurturing inclusivity, individuality, and intentionality to be supportive and not punitive.

This Support to Study Policy seeks to ensure the University’s commitment to delivering inclusive, timely, equitable and meaningful support to students when issues relating to health, wellbeing or behaviour may impact their academic progress and/or general participation in university life.

This policy seeks to offer a holistic and supportive framework to ensure a proportionate, appropriate, and coordinated approach is enacted on every occasion that a cause for concern is raised. Underpinned with an aim of early intervention and active collaboration, the expectation is that students will engage in decision-making processes about their capability to study, where possible.

This policy seeks to ensure that all staff involved in support:

• Are aware of their responsibilities in the support to study process.
• Engage fully with the support to study process; and,
• Are enabled to support the student as needed.

The following are example scenarios and should not be seen as an exhaustive list. A cause for concern can relate to a range of different elements that are impeding a student’s ability to successfully complete their studies. This policy uses a rounded approach and therefore although the goal is successful academic accomplishments, we acknowledge that disruptions can occur within all aspects of a student’s university life.

Scenario One:

A pattern of repeated mitigation claims is occurring which risks progression and attempts to engage a student with support and signposting have not been successful.

Scenario Two:

A Students conduct and behaviour in class is repeatedly causing disruption and concern for university staff and fellow students. Upon assessment, a conduct and appeals approach may not be the most suitable way forward to address and support the student and the situation.

Appendix One provides a flow chart of the process for students who are referred to either Stage One or Stage Two of the Support to Study Policy.

Appendix Two provides a second flow chart that follows the process for Stage Three of the Support to Study Policy.

This policy may be used for students whose ability to cope with university life and to study and progress on their programme, is seriously compromised as the result of their health, wellbeing, or disability.  This applies to all registered students at all levels, including both campus-based, Transnational Students (TNE) and Apprentices. It will inform the processes for prospective students where required.

Students studying certain disciplines (e.g., Nursing, Social Work or teaching which are subject to the requirements of Professional, Statutory and Regulatory Bodies) may be subject to separate and over-riding obligations to declare significant health issues. Where there is a Fitness to Practice issue, the Fitness to Practice Policy or the regulations of the relevant Professional, Statutory and Regulatory Bodies, as applicable, will take precedence. This policy may also be used in conjunction with other university policies such as those under the remit of safeguarding, including PREVENT.

These policies and guidance can be located via the following links:

WLV Policies - University of Wolverhampton.

Safeguarding - University of Wolverhampton (wlv.ac.uk)

Where there are concerns for a Postgraduate Research student that also has a staff contract, each case will be considered on an individual basis which will include whether consideration needs to be given under their respective staff contracts and relevant Human Resource (HR) policies.

HR policies can be located via the following link: WLV Policies - University of Wolverhampton; on the internal staff site.

This Support to Study policy has three Stages, with a fourth stage covering return to studies. The initial three stages are based on the degree of concern and the perceived seriousness of the situation, informed by an assessment of the case. A cause for concern can enter and be resolved at any stage and students may move between the stages depending on the nature of the concerns. Flow Charts are provided in Appendix 1 (Stage One and Two) and Appendix 2 (Stage Three).

At all stages, a student will be treated with dignity and respect, and will be strongly encouraged to engage in discussions and decisions as much as is reasonably practicable. During any meeting, students will be given the opportunity to discuss their experiences and support needs and agree a suitable plan to manage the situation effectively.

In order to ensure a timely response takes place with any causes of concern, the Support to Study Coordinator will monitor the Cause for Concern referral pathway daily.  The Support to Study Coordinator will assess if cases ned to be referred to the weekly Cause for Concern Group or other University Student Support Services. The Cause for Concern Group will meet every Monday to assess cases that require to be referred to the Support to Study stages, Appendix 1 and 2.  

If the decision to use the Support to Study Policy has been made with a student, a log will be kept of all staff interaction with that student. Appendix 4 details the log which will be used throughout the interactions with the student under the Support to Study Policy.  These will be kept in line with university retention periods, information and guidance on retention periods can be located here: Document Retention Schedule 2012 (wlv.ac.uk).

Following Stage One of the Support to Study process, if a case enters the next stage of the procedure(s), as outlined below in the procedure section of this policy, providing the student has grounds, they may appeal against a decision made at Stage Two, Three or Four of the Support to Study Policy.  Please see the Appeals Procedure detailed in Appendix 5.

The grounds for appeal are:

• That there is evidence of a procedural error or material irregularity which affected the decision.
• That there is new material evidence which for valid reasons was not available to the decision makers.
• That the decision makers reached an unreasonable decision, based on the available evidence.
• That there is evidence to suggest bias or a reasonable perception of bias during the procedure.

Appeals must be submitted within 10 working days of receipt of the written decision and should be made in writing to: The Conduct and Appeals Unit; Email: Conductandappeals@wlv.ac.uk

Appeals submitted more than 10 working days after receipt of the written decision may be considered where there is independent evidence to demonstrate that the student lacked the capacity to submit an appeal within the published deadline.

Detailed guidance on the steps involved with all the stages of this policy can be located in the procedural section below.

Concerns for a student’s wellbeing and engagement will first be raised with Student Support Services through the Cause for Concern Microsoft Form https://forms.office.com/e/VNmT65mwQY .  There is also be an email inbox: causeforconcern@wlv.ac.uk .

In cases where there is an immediate risk to students, staff must follow guidance which can be located here: https://www.wlv.ac.uk/current-students/student-support/mental-health-and-wellbeing-advice/staff-guidance/

These concerns may arise from the below stakeholders:

• Raised by the academic department.
• Via another university process (for example, Academic Appeals and Complaints)
• Raised by University staff.
• Raised by peers.
• Raised by self‐disclosure from student.

Guidance in relation to confidentiality and information sharing can be found below.

A cause for concern may be raised about a student due to any number of factors, they may include:

• A student’s academic progress and an inability to engage as a student.
• A student’s health and/or wellbeing.
• A student’s ability to live safely and independently whilst at university.
• How a student’s behaviour may be impacting on other students and staff.

The Cause for Concern Group (CCG) membership meets weekly, here they will review the concerns detailed within the referral and then identify the appropriate stage of the policy to enact.

The Cause for Concern Group is a centrally situated operational group of university services which meets regularly to ensure student cases are appropriately managed, coordinated and risk assessed. These cases are what are known as amber cases, where taking a coordinated and proactive approach to supporting and mitigating known risks is aimed to prevent them from becoming red flags.

An Amber case is something that needs to be discussed as multidisciplinary panel review. Examples of this might be complexity safeguarding, or accommodation.

Stage Three of this policy can only be instigated by the Academic Lead for Mental Health and Wellbeing or their nominated deputy, where there are significant and persistent concerns for a student’s wellbeing and or the impact of their wellbeing or behaviour on others. This stage will only be considered following review of the incident(s), circumstance(s) and steps taken so far.  The number of cases being considered in this stage in each academic year is expected to be low.

Reasonable adjustments will accompany the operationalisation of every stage this policy and will be made in line with our legal responsibilities for disabled students under the Equality Act 2010 or for those with additional needs, or to allow for other factors that would otherwise place a student at a disadvantage.

All stages of this policy will consider the impact the student’s behaviour is having on the wider University community and any subsequent actions will seek to mitigate this as much as possible.

Student Support will be at the centre of this policy and will underpin its intentionality. Students will be supported through the process by our central Student Support Services and can receive impartial support through the Students’ Union Advice Service.

All decisions made in this process will be taken in the best interests of the student and to ensure the best outcome for the student’s wellbeing.

Any student that is detained under the Mental Health Act 1983, will be considered under Stage 1 of the policy in the first instance, with the case progressing through the stages depending upon the length of detainment and varying intricacies of the case, considered on a case-by-case basis.

At all stages, consideration will be given to whether the Student Trusted Person Notification Procedure (Appendix 6) needs to be initiated. In cases where there is deemed to be sufficient concern and where such contact is deemed to assist the student and mitigate known risk, this protocol will be followed.  Detailed information on the trusted person notification procedure can be located within the Appendices.

Below is a list of key teams/people who may be involved in the process; their involvement will be considered on a case-by-case basis:

• Relevant Head of Programme/Personal Tutor/Supervisor/Academic Coach/ Course Lead
• Student Support Services
• Health and Safety Officer
• Student and Academic Services
• Estates and Facilities Services
• Students’
• Deans and Registrar (at Stage three)
• Registrar and Secretary
• Occupational Health (for students on professionally regulated courses)
• Chaplains
• External providers of support for example: community mental health teams, the police, relevant members of the local Channel group or other “Prevent” specialists, family of student, social workers.
• Conduct and Appeals Unit

The outcomes from all three stages may include the below recommendations:

• To take no action.
• To monitor the situation (including regular review meetings with a named member of staff).
• To establish and monitor specific support (internally or externally), internal support available can be located here: Student Support - University of Wolverhampton (wlv.ac.uk), external support available will be discussed according to the circumstances involved, but can be located here: Community support services - University of Wolverhampton (wlv.ac.uk) .
• A review letter detailing the current situation, support available and the steps that will be taken moving forward, in addition to timescales involved accompanied by an action plan, which will provide support throughout this process (a template is available, please see Appendix 3).
• Require the student to take a Leave of Absence or withdraw from the course. The latter outcome will be decided at Stage three of the process.
• Any period of leave would normally be reviewed within four weeks and the review may include a recommendation to convene a Support to Study Panel. Further details on the support to study panel can be located below in the procedure section).
• To issue notice of imposed Leave of Absence.
• Temporary Suspension or exclusion: A temporary suspension of studies (TSS) is when a student stops studying at the University for an extended period, usually no longer than one academic year (Period of suspension will be determined on a case by case basis and details will be confirmed in writing).
• Other outcomes as determined by the panel (e.g. refer to Conduct & Appeals).

1.      Stage One – Preliminary Concerns

Where there are initial or moderate concerns for a student’s wellbeing, which may include sustained disengagement, continuous mitigation claims or non-submission of academic work, the Cause for Concern Group will identify the needs of the student based on the concerns presented and a review of known facts, and coordinate support for the student.

Examples of initial or moderate concerns might include:

• A deterioration in physical or mental health.
• Pronounced change in presentation and or behaviour.
• Unexplained absence and/or engagement with the University environment.
• Inability to engage with studies, for example meet deadlines and complete assessments.
• Continuous submission of mitigation claims and or non-submissions of academic work which would indicate a longer-term issue than a short-term extension.

Students have the right to request a companion, this could be their personal tutor, academic coach, or another trusted person from the University such as a member of the student union, or it could be a fellow student, friend, carer/parent or a specialist provider of health or wellbeing support.  It will be the responsibility of the student to make the appropriate arrangements for the required companion to attend.  Details of who will be in attendance should be provided by the student prior to any meeting taking place.  

In discussion with the student, the student will be encouraged to engage with relevant support services and/or staff with a specific support role, this will initiate the Support to Study process.

• The nature of the concern will be identified, encouraging the student to reflect on the issues, including the potential impact on themselves and others.
• The student, the Support to Study Coordinator and the nominated staff member (this may be a member of the Cause for Concern Group (CCG), or a member of the faculty as decided by the CCG) should discuss if change is needed and if the student is willing and able to make changes to address the concerns.
• The student should be supported in considering solutions and be guided towards obtaining additional support or reasonable adjustments. A Support to Study Action Plan (Appendix 3) will be written in conjunction with the student and its outcomes agreed at the Support to Study meeting with the student. In order to ensure that appropriate reasonable adjustments are discussed and put in place, support may be obtained from other services available such as the Disability and Inclusion.

An individual Support to Study face to face case meeting., will be convened if detailed information regarding the concerns for a student have been received, following the initial interaction. The student will be sent a meeting invite through the appropriate means (can be a home address or email address, depending on the information available and the requested method of communication).  The meeting will consist of the Support to Study Coordinator, the member of staff who will lead the support to study process at this stage and the student concerned. 

If a student is unable to attend the University campus for this meeting to take place, an alternative meeting date and time will be arranged.   If the student is unable to attend a face to face meeting and has a valid reason for this, alternative arrangements can be made where possible, such as an online call, if all parties involved agree.  

The meeting will allow all parties present to discuss the reason(s) for the meeting taking place, why certain individuals are present, what the support to study process involves, what will be included in the action plan and what will happen following the meeting.  Contact details should be confirmed with student during this meeting and a method of communication for letters/emails should be agreed.  

Following this meeting an action plan will be agreed by all parties present offering support, timescales and will document the necessary steps required moving forward, in addition to the possible consequences of not engaging or agreeing to the plan. 

All stages of this policy are intended to foster a collaborative approach to find ways to work together in moving forward and should be seen as the start of a process to re-engage the student with their studies.

The aim of the meeting will be to agree on the type, stage, or extent of change the panel expects to see and within what time frame. The student should be informed that if the concerns/risk continue, any additional cause for concern arises, or they refuse to engage in the process, this could result in further consideration of their issues within the Stage Two procedure.

Colleagues within the school or course should also consider and agree on what support is required from the University to support the resolution of the concern (if appropriate; examples might include module tuition, consideration of assessment choice).

1.1   Review of the Stage One Action Plan following the Support to Study Meeting:

The Support to Study lead, in conjunction with the Support to Study Coordinator will initiate the review process in line with the agreed timeframes that were detailed in the action plan above.  The first review period will take place within 2-4 weeks of the Support to Study meeting and will involve meeting with the student concerned to evaluate progress.  The action plan will be updated accordingly, and any additional actions identified will be agreed and implemented moving forward.  The meeting can take place face to face or virtually and can take place sooner support to study lead or Support to Study Coordinator feels it may be necessary.

A date for the next review meeting should be discussed in this meeting and students should be reminded that non-engagement during the identified period of review of this stage and/or continuation of the same or any additional concerns/risks could result in escalation to Stage two of the procedure.  

The Action Plan will normally be in place for 1 month before a decision is made as to whether the plan and review periods need to continue.  The action plan can be in place indefinitely, with appropriate reviews.  If at any point the Support to Study lead deems that the Action Plan is not working or the student is not engaging with the process, the next stage of the process will be instigated where support and been provided but concerns continue whether it is a negative change in engagement/continuous non-engagement, or other issues have been identified as advised above. The Action Plan can also be closed out if the Support to Study lead or coordinator feel this is an appropriate course of action.

Following the initial 1 month period the Support to Study Coordinator and the member(s) of the CCG will determine review and conclude any further action is needed, as outline below.

Possible outcomes from the Stage One Support to Study process could include:

• No follow up action necessary and the action plan can be closed, however support in some areas may continue
• Continue to monitor the situation if further support is required, using the 2-4 weekly monitoring where appropriate until the cause for concern is resolved during the agreed period, or escalated to Stage Two.
• Referral to appropriate support services such as:
• Conduct and Appeals Unit
• Mental Health and Wellbeing
• Safeguarding
• Disability and Inclusion
• Doctoral College
• Accommodation
• Hardship
• Finance
• Security

Following discussions with the Head of Student Experience Projects and Support Manager or Academic Lead for Mental Health and Wellbeing, referral by the lead colleague, to Stage Two of this process.

All outcomes will be reported back into the Cause for Concern Group weekly meeting.  These will be reported back to the student in writing within 5 working days either after the Support to Study student review meeting (if no follow up action necessary) or within 5 working days of the follow up timescales agreed within the agreed and specified period within the action plan.  

2.      Stage Two- Formal Review

A collaborative approach to find ways to move forward will be the primary objective of Stage Two with the student's wellbeing at the core of the process.

Stage Two will be initiated where:

• Other interventions at Stage One have not resolved the concerns for the student,
• Where the concern raised is too serious to be dealt with at Stage One. Examples might include disengagement with assessments accompanied by disruptive behaviour within teaching sessions, concerns related to emotional distress which has necessitated repeated crisis intervention from academic staff and/or,
• Where there are serious emerging concerns which necessitate a more formal response from the University.

The concerns may be addressed through the Faculty or University Fitness to Practice procedures.  Where this occurs the Fitness to Practice procedures will take precedence.  This will be determined following a discussion between the Support to Study Coordinator and the member(s) of the CCG.

The Cause for Concern Group will convene to consider the needs of the student and coordinate support with agreement on a review and feedback schedule.

The student should be familiar with the Support to Study process, following Stage One. The Support to Study Coordinator will coordinate Stage Two. The student will be invited to attend a Stage Two – Formal Review meeting. This will be convened with mutual agreement of time/date with the student and the Stage Two Formal Review panel. The date, time and reasons for the meeting will be sent to the student in writing at least 5 working days in advance of the meeting.

The meeting will take place face to face, if a student is unable to attend the University campus for this meeting, an alternative meeting date and time will be arranged.   If the student is unable to attend a face-to-face meeting and has a valid reason for this, alternative arrangements can be made where possible, such as a virtual call, if all parties involved agree.  

The meeting will allow all parties present to discuss the reason(s) for the meeting taking place, why certain individuals are present, what the next steps will be and what the possible outcomes will look like following the case review.

Students have the right to request a companion, this could be their personal tutor, academic coach, or another trusted person from the University such as a member of the student union, or it could be a fellow student, friend, carer/parent or a specialist provider of health or wellbeing support.  It will be the responsibility of the student to make the appropriate arrangements for the required companion to attend.  Details of who will be in attendance should be provided by the student prior to any meeting taking place.  

The Stage Two Formal Review Panel will include:

• Support to Study Coordinator (Chair)
• Student
• Staff member who made the referral
• Academic Coach/Personal Tutor (if appropriate)
• A Companion if requested

The outcome will be agreed verbally within the meeting and stated on the new Action Plan (Appendix 3) and will be sent to the student within 3 working days of the meeting.

The Stage Two Formal Review Panel is a supportive process and will include:

Identification/explanation of the issue/concern/risk (providing clear and specific examples), and any past relevant information (including the previous action plan).

An opportunity for the student to give their perspective on the issues and if appropriate a history of events, past experiences and helpful strategies or support for managing these issues.

A review of the student’s standing at the University (academic and in relation to other processes such as academic misconduct, student discipline, academic warnings/non-engagement) and the implications thereof.

Clarification of the student’s responsibility at the University (e.g.to be ‘well enough’ to study and to be respectful of others).

Consideration of what would be helpful or make a difference to the student in relation to their support and to minimise the concerns/risks and what may have prohibited improvement at Stage One

Information in relation to appropriate support available and, if necessary, referral to any support services as appropriate.

Consideration as to whether the case should be referred for consideration under the Fitness to Practice Panel if applicable.

Identification of an action and support plan) to support the student with clear targets to be reviewed within 2-4 weeks with an agreed date set within the action plan.

Clear guidelines on the Support to Study Policy with possible outcomes (where appropriate) resulting from their case moving to Stage Three.

2.1 Potential Outcomes

The potential outcomes from the meeting would be one or more of the following:

1. Resolution, may be as a result of insufficient information to proceed with Stage Two of the process, resulting in the student entering into their normal terms and attending campus as normal
2. Drawing up of a Stage Two Action Plan, to be reviewed within 2-4 weeks to include details of the steps the student will need to take to improve the situation and the requirement to attend regular monitoring meetings during the period of review.
3. Referral to appropriate support services as mentioned previously.
4. Referral to fitness to practice (if applicable).
5. Leave of absence to be agreed with the student.
6. No further action at Schools discretion.
7. Escalation (if appropriate) of the case to Stage Three of this process.

NB: Where the case has not already been referred to the Conduct and Appeals Unit or Fitness to Practice Panel (only on programmes where applicable), a referral can be made (in consultation with the Head of School or Academic Lead for Mental Health and Wellbeing or nominee) as one of the possible outcomes at this Stage.

Any outcome will be reported back to the student in writing within 5 working days either after the meeting (if no follow up action necessary) or within 5 working days of the follow up timescales agreed within the agreed and specified period within the action plan. 

An agreed action plan will initially be adopted for 2 months , with appropriate reviews agreed , Stage Three of the process will be initiated where there has been little or no engagement in the process, where there have been additional concerns/incident(s) reported or where there has been no improvement following the 2 month period.

Where a student does not agree to the terms of the Action Plan, the possible consequences should be discussed in this meeting, as detailed below.

The student has the right to appeal against an outcome as detailed below of this policy in section 7 appeals process.

2.3 Review of the Stage Two action plan:

The review of the Stage Two Action Plan will be undertaken by the lead colleague identified in the Action Plan and the Support to Study Coordinator, in collaboration with the Chair of the Stage Two review panel. If the situation has not been resolved, one of the following options should be considered:

• Recommendation for additional support services to enable the student to resolve the situation.
• Recommendation for a specific academic arrangement, for example extended deadlines, alternative assessments (such recommendations should be agreed and actioned by the student’s School and where appropriate the student).
• Referral to Stage Three Support to Study Panel. This should be agreed with the Academic Lead for Mental Health and Wellbeing and will only be appropriate in serious cases. Examples can include where there is evidence of a high risk to the health and safety of the student or others in the University community.
• Referral, if appropriate and applicable, to the Fitness to Practice or Conduct and Appeal This should be agreed in liaison with the Head of the student’s School to ensure it is the right course of action (this course of action would be used when it is considered that a temporary leave of absence or termination of studies may be the appropriate course of action or if the student has not agreed to a recommendation or action plan made under Stage two). Through the Fitness to Practice outcome, consideration of alternative courses, depending on the circumstances and risk may be considered.
• No further action if student is no longer engaging. This may be either due to the student terminating their studies or that they are no longer engaging but poses no risk to themselves or others.

3.     Stage Three- Exceptional Review

Stage Three of this Support to Study policy will be initiated where a student’s behaviour is causing significant concern for their own safety and wellbeing, and may be affecting the learning, teaching or experience of other students or is negatively affecting the day-to-day activities of the University to include staff wellbeing.

A significant concern is one which a University member of staff may have about a student which could either lead to non-completion of studies or danger to own life and/or others.

In most cases escalation to this stage will follow attempts to address concerns through Stages One and Two.

However, in some cases (examples listed below) it may be appropriate to proceed directly to Stage Three.

In all cases the decision to convene a Stage Three Support to Study Panel will ordinarily be made by the Head of the student’s School in partnership with the Academic Lead for Mental Health and Wellbeing.

Exceptionally, it may be appropriate to refer a student to Conduct and Appeals Unit for consideration within the Student Code of Conduct and Disciplinary procedures.  Any decision to make such a referral will be made by the Head of the student’s School in partnership with the Academic Lead for Mental Health and Wellbeing and the Head of the Conduct and Appeals Unit.

Examples of when it may be appropriate to either proceed directly to Stage Three or be referred to by the Conduct and Appeals Unit are:

• Where a health care professional/occupational health advisor considers that the health, wellbeing, and ability to study is significantly affected by the students’ condition.
• Where there are serious concerns regarding risk to the health and safety of the student and/or where there is a perceived threat and risk to themselves and others within the university community.
• Where an immediate temporary suspension is considered to be in the best interests of the student or the University.
• Where a student falsifies or provides falsified documents as part of the support to study process
• Where a students’ behaviour towards staff during the process is not conducive to continue with the supportive process at that time.

A Support to Study Panel will be convened within 5 working days (or sooner if perceived a higher risk) to review all action that has been taken so far and to ensure the University has considered all possible support options to enable the student to continue with their studies.

Each panel will consist of three members, one of whom will act as Chair, all of whom are impartial, meaning that they have had no prior involvement with that student via any process of the Support to Study policy, and will have undertaken appropriate training.  Appropriate training will be provided where necessary, this will be provided by the Support to Study Coordinator.

The Panel should include: 

• Academic Lead MH and Wellbeing who will act as chair.
• Head of the student’s School or nominee.
• In the case of a combined honours student, representation from both Schools.
• The lead person from Stage One or Two.

Additional panel members may be appointed at the discretion of the Chair according to the nature of the case under consideration and, if necessary, where particular expertise is required. For example: accommodation, disability, and inclusion.

Students have the right to request a companion, this could be their personal tutor, academic coach, or another trusted person from the University such as a member of the student union, or it could be a fellow student, friend, carer/parent or a specialist provider of health or wellbeing support.  It will be the responsibility of the student to make the appropriate arrangements for the required companion to attend.  Details of who will be in attendance should be provided by the student prior to any meeting taking place.    

Students will be informed that the companion cannot represent the student or attend if the student is not present.  

The meeting will take place face to face, if a student is unable to attend the University campus for this meeting, an alternative meeting date and time will be arranged.   If the student is unable to attend a face-to-face meeting and has a valid reason for this, alternative arrangements can be made where possible, such as a virtual call, if all parties involved agree.   If there is no contact from the student and non-attendance following various attempts to make, contact a decision will be made in their absence.

The meeting will allow all parties present to discuss the reason(s) for the meeting taking place, why certain individuals are present, what the next steps will be and what the possible outcomes will look like following the case review.

3.1 Notifying the Student

Students will be given at least 5 working days’ notice of the Stage Three Support to Study Panel meeting.  The invitation to attend will include the following:

• Date, time, and location of the meeting. At the discretion of the Chair, meetings may be in person (on campus) or virtual, depending on individual circumstances.
• The purpose of the meeting,
• A request for any specific documentary evidence (e.g., medical evidence, where appropriate).
• An outline of the members of staff present at the meeting.
• Reference to the student’s entitlement to be accompanied at this meeting.

In some cases where an immediate risk of harm is presented, it may be appropriate to undertake immediate action to safeguard the student/others at risk. This action will only be undertaken when it is deemed necessary to prevent harm. Where appropriate due consideration will be given to the University’s Safeguarding Policy (Safeguarding - University of Wolverhampton (wlv.ac.uk).

In these cases, the Academic Lead Mental Health and Wellbeing will call an immediate case conference to ensure a thorough risk assessment is undertaken. .

An outcome of this case conference may be a formal request to the Vice Chancellor or their nominee for an immediate temporary suspension of the student in accordance with the Guidelines for the Temporary Suspension of Students.

Additional outcomes may include contacting an external party, including (but not limited to) the Police, relevant NHS service and/or the student’s Trusted Person emergency contact.

The case conference can be carried out prior to the Support to Study Panel but does not replace it.

3.2 Prior to the meeting

The University may seek additional evidence where appropriate in relation to the student’s circumstances which will be provided to the student before the meeting.

The student should be encouraged to prepare in advance for the meeting by speaking to key staff, including their course lead, the Students Union Advice Service.  The student may additionally wish to write a short summary report for the meeting.

The Support to Study Panel will convene prior to arrival of the student to familiarise members with the circumstances.

Once the student (with their representative and/or support worker) is present, the panel will consider the following:

• A summary of presenting situation, concern(s) being raised, and past relevant information.
• The perspective of the student to include the summary written report by the student outlining the current issues, history of events, past experiences and helpful strategies or support for managing the issues.
• Identification of achievements made from a previous action plan(s) relating to this process.
• The expectations of the student’s personal responsibility at the University.
• Any further information such as medical evidence (this may be required where a student has; or is suspected of having a health condition and may require medical treatment).
• Options available to the student at this stage e.g., part-time study with support, a voluntary leave of absence, or a recommendation for termination of studies of the student, and their implications.
• Referral to any relevant University Support Services (as previously mentioned above) from which they may benefit.
• Explicit clarification of the consequences of failing to complete the agreed actions, and/or a Continuation of the causes for concern.
• Agreement of any interim monitoring or measures, if appropriate. (x) the agreement of a date to meet again to review the situation.

3.3 Potential Outcomes

The panel will make a recommendation to the Deputy Vice Chancellor where appropriate for the final outcome of the Stage three panel.

Possible outcomes are as follows:

• Resolution no follow up action necessary, may be as a result of insufficient information to proceed with stage 3 of the process, resulting in the student entering into their normal terms and attending campus as normal
• Recommendation for additional support services to enable the student to resolve the situation. This would be in the form of an action plan (Appendix 3) as in previous stages.
• Temporary suspension until such time as the student has been assessed by a medical professional, accessed support services both within and outside of the University; evidence provided is deemed appropriate by the CCG panel or until the University has obtained further information where necessary. A student who is suspended from the University may be prohibited from participating in university activities and may either be prohibited from entering the University premises or have restricted rights to enter the premises. This will be decided on a case by case basis by the CCG Panel and issued in writing following a verbal conversation.
• Compulsory leave of absence. The terms of the period of any compulsory leave of absence will be notified to the student in writing, depending on the circumstances of the case. If a leave of absence is recommended the panel should make sure that both they and the student are fully aware of the implications (this may include visa and financial issues). The student should be given a clear indication of the proposed return date and regular reviews should be built in. Any leave of absence under these circumstances should be greater than 15 days’ duration but normally no more than 12 months’ duration, during which time a student is not undertaking any study. The student will be required to complete their award within the maximum period of registration
• Termination of studies. If the Stage Three Support to Study Panel concludes, considering the individual circumstances of the case and any supporting medical evidence, that there is no reasonable prospect of the student re-engaging with their programme, a recommendation will be made to the Deputy Vice-Chancellor that the student is permanently terminated from their studies from the University. This recommendation should only be made in the most serious cases and be based on an assessment of all available evidence, including all information presented by the student, and information obtained from University staff which have contributed to the case file and has been considered and evaluated by the Stage Three Support to Study Panel.
• Any other action considered to be appropriate and proportionate. NB: In cases where the cause for concern is raised which has possible implications regarding a student’s fitness to practice in line with their professional registration, the Chair of the Stage 3 panel will refer the decision to the Fitness to Practice Committee to make a recommendation for the final outcome to be made.

All Stage Three outcomes must have an outcome letter. In cases of a temporary suspension, an interim letter   should be sent.

Any outcome will be reported back to the student in writing within 5 working days either after the meeting (if no follow up action necessary) or within 5 working days of the follow up timescales agreed within the agreed and specified period within the action plan. 

The student has the right to appeal against an outcome as detailed below of this policy in Section 7: appeals process.

3.4 Keeping in touch

Any student taking a Leave of Absence from their course should be viewed as navigating a potentially difficult and isolating transition point. There is a risk that the relationship between the university and the student may deteriorate or drift. This places a risk to the wellbeing of the student and the likelihood of successful return to studies. With this considered, this policy promotes principles of keeping in touch arrangements for students taking a leave of absence via this policy. For students who have been considered via Stage Three of this Support to Study Policy and are taking a Leave of Absence or who we have suspended from their studies, a keep in touch and support plan will be explored and is a requirement of their engagement and preparation to return to study.

Both parties should consider and agree on the below factors:

• How often contact should be made,
• If this contact will be by email, phone, or face to face,
• Who will make contact from the University.

This will enable:

• Welfare checks to be carried out,
• Allow any support to be put into place,
• Allow discussions to take place about any changes taking place at the University (including any course updates).

Where absence is due to a mental health condition, it will be important to consider whether less or more frequent contact is required.  Any information discussed and dates of meetings/calls can be added to the existing support and action plan (Appendix 3).

4.     Stage Four- Return to Study Following Leave of Absence

A Return to Study panel will be convened within 6 weeks prior to their intended return to their studies (this timeframe may be decreased depending on the circumstances where the leave of absence is a short period), and will lead a review of the students’ progress, documentary evidence they have submitted that is related to the student’s wellbeing. These intricacies will be considered and contextualised with the demands of the course and discussions will centre on if the student is able to return to their studies at that time.  Ideally this will be the same panel members that discussed the student’s case prior to their leave of absence.  If this is not possible any changes to the panel members will be discussed with the student concerned and advised why these changes have taken place.

The precise nature of the evidence required from the student will be dependent on the individual circumstances in each case, but in most cases, it is expected that this will involve a report from a recognised independent professional with sufficient knowledge about the health and wellbeing of the student during the period of leave, and the potential impact that returning to study might have. Examples might include a mental health professional within primary or secondary care, a General Practitioner, or an occupational health professional.

This panel is intended to be collaborative; this is to ensure the best outcome for the student and as such, will include representation from the school and support staff as well as other key members of staff who have already been involved with the process for the individual student, this will ensure that feedback is obtained from individuals who have full case details and can assess progress effectively.

The outcome from the panel may be one of the following:

• Student returns to their studies with no conditions attached to this.
• Student returns to their studies with a plan for ongoing monitoring over a specified period as agreed between the student and the Support to Study team.
• Student returns to their studies with a support package which is developed collaboratively with relevant Support Services and is reviewed at agreed regular intervals following return to study.
• Student has a phased or bespoke return to their studies which is decided with relevant parties
• Student is withdrawn from their studies based on significant circumstances where it would not be in the best interest for the student to continue their studies
• Student does not return at that time but instead extends their Leave of Absence of studies and the possibility of their return is reviewed at a later agreed date. If this means that a student has fallen outside the academic regulations, this will be flagged as part of the case management of the support to study plan and will be reviewed on a case-by-case basis. Any leave of absence should not exceed 12 months.

The meeting will take place face to face, if a student is unable to attend the University campus for this meeting, an alternative meeting date and time will be arranged.   If the student is unable to attend a face-to-face meeting and has a valid reason for this, alternative arrangements can be made where possible, such as a virtual call, if all parties involved agree.   If the student fails to engage with this process, then they can be referred to Conduct and Appeals.

The student has the right to appeal against an outcome as detailed below of this policy in Section 7 appeals process.

5.     Respect for Confidentiality and Confident Information Sharing

Respect for confidentiality will treat information relating to the health and welfare of a student as special category  data and must be kept confidential and only disclosed with the students explicit consent. This policy is underpinned by such respect for confidentiality, but also recognises the need to support confident information sharing to support its intentions. Therefore, it will also set out the basis for dealing with exceptions to that general rule.

The UK GDPR defines special category data as: personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

For colleagues who are in a position of advising students and offering them general pastoral support, should consider at the outset of a discussion whether it would be helpful to make clear whether the content is to be confidential and the extent of the confidentiality which can be afforded to any disclosures. For example – if a crime is disclosed or a safeguarding issue relating to children, then confidentiality cannot and should not be upheld.

When discussing confidentiality with students, the following should be made clear:

• Confidentiality will be respected, wherever possible.
• Consent will be sought, wherever possible, to any onwards disclosure of information; and
• There are limited circumstances in which information might be shared with a third party, e.g., taking account of the vital interests of others, or where an individual lacks capacity to consent.
• Only in such circumstances will members of the Mental Health and Wellbeing, and Disability and Inclusion teams share confidential information with other parties (both internal and external bodies as appropriate), although they may use their own judgment on what to share with each other

Where concerns are raised by university staff, they should record consent at the point of student disclosure or at least a record of how such consent was provided and when, so that the University would be able to demonstrate that the student had specifically agreed to the processing of their sensitive personal data in particular ways. This is a specific question in the Cause for Concern Microsoft Form – if a member of staff they are requested to detail whether they have the student’s consent to raise the concern.  If they do have consent, a copy of the form will be sent to the student. If they do not have consent, the concern can still be raised, but the Cause of Concern Group will review the next steps.

Once consent has been obtained and a record made, it is the responsibility of the person passing on special category data to ensure it is done in accordance with the student’s explicit wishes.

Transfer of such information should also be carried out in an appropriate secure manner to reduce the risk of inadvertent disclosure to unauthorised persons. This includes anyone within the University who does not need this information to offer support to the student.

Secure methods of transfer may include password protection of encryption and sharing files via a link through SharePoint or OneDrive. For advice regarding secure methods of transfer you may contact dataprotection@wlv.ac.uk.

5.1 No Student Consent

If the student chooses not to provide explicit consent to share their special category data or chooses to withdraw consent, this decision should be respected in most instances. In this scenario, the implications of not sharing their data in terms of additional support available from, for example the University’s Student Support Services or other parts of the University with a need to know all or some part of such information to provide support, should be made clear.

However, there are exceptional circumstances when the student’s consent is withheld, or it is impracticable to try to obtain it, when confidentiality may lawfully be broken, and disclosure can be made to Student Support Services, processes relating to professional regulated courses and/or to external agencies. These include:

• When the student’s health has deteriorated to the extent of threatening their personal safety or that of others.
• When the student is at risk of serious abuse or exploitation.
• When the student’s behaviour is adversely affecting the rights and safety of others.
• Where the member of staff would be liable to civil or criminal procedure if the information were not disclosed (e.g., if a crime had been committed)
• Where the student is either under 18 years or a vulnerable adult (see University Safeguarding Policy)
• In extreme circumstances, in the student’s ‘vital interests’ and where the University has justifiable concerns for the safety and/or life of the student, the University will disclose information as required.

5.2 Seeking advice

Where there is no immediate risk, staff should first consult the Cause for Concern referral route if they believe there is a need to break the commitment to confidentiality.  There will also be weekly drop in sessions (alternating online and in person) run by the Support to Study Coordinator, the times and locations will be detailed on the Support to Study webpages.  These drop in sessions will be for both staff and students who may want to discuss a potential referral without disclosing student information.

Initial discussion should not identify the student until the grounds for breaking confidentiality have been established and agreed upon

Those to whom information has been given in confidence, or who have acquired information which they regard as confidential, may not always be sure whether they should disclose this information or not. This can pose a risk to the student if the sharing of such information might be in their best interests. It should also be noted that having no place to go to check out concerns, might be of detriment to staff members wellbeing.

In these circumstances staff are required to seek advice/ approval before any disclosure seeking advice from the Mental Health and Wellbeing Team Manager, a Safeguarding Lead or the Disability and Inclusion Manager. This consultation should be done without divulging the name of the student concerned in the first instance. Within this space, there is scope to offer an outline of the concerns, the story, and details of the case – here guidance can be obtained as to the most appropriate next steps, which might include an instruction to give further details due to the seriousness of the case.

Under no circumstances other than a medical emergency or imminent risk of harm where a 999 response is required, should any university staff member make referrals to outside agencies without prior discussion with the above-named team(s).  

With the above considered, it is generally not appropriate to give absolute assurances of confidentiality to those who may wish to talk about health or safeguarding-related matters.

6.     Data Protection Compliance

The University and its staff are governed by the requirements of the Data Protection Act 2018 (in alignment with the provisions of the UK General Data Protection Regulation  (‘GDPR’).

Under this Act, data relating to an identifiable person’s health is regarded as special category  data and must be handled with extreme care because of the sensitive nature of this data. For the purpose of the data protection legislations, all information shared in confidence by students with the University concerning a student’s ill health or disability, including physical or mental health conditions are deemed to be special category data.

The University processes all personal information in line with the  Privacy Notice’s available on the University website, which all students are provided at the point of Registration. The University also complies with the University’s Data Protection Policy, which can be located via the following link: WLV Policies - University of Wolverhampton.

The University may raise specific data sharing agreements with external and internal partners when considered appropriate to facilitate lawful and confidential sharing of data to support students throughout the process.

All cases where, from the view of the member of staff, it would be in the student’s best interests to disclose sensitive information and special category data to the University’s support services and/or to an external agency (e.g., so that appropriate support may be provided) the student’s informed and explicit consent to such disclosures should be obtained where possible.

6.1 Support to Study Record Keeping

At all stages of this procedure factual and detailed record keeping will be maintained.

Action planning

Action and support planning will be documented, and copies shared with all appropriate colleagues, and the student themselves. A blank action and support plan document has been prepared and is located at Appendix 3. An Action and Support Plan is intended to be a supportive measure which clearly sets out agreed actions and a time frame for their implementation and review. Through collaborative working, agreements with the student will be made that in their best interest they will need to satisfy particular academic requirements or engage with particular types of support. The Action and Support Plan will be reviewed at a specified date and discussions will also identify the consequent actions if the plan is not followed.

Recording information

A Support to Study log template is available at Appendix 4.  This will be initiated by the Support to Study coordinator at the point of referral. All communications, documentation of meeting and any other details related to the case will be captured via this log. This will also ensure all communication received and sent will be recorded in chronological order and may support a lesson learned reviews and or an appeal process.

Providing the student has grounds, as defined below, they may appeal against a decision made at Stage Two, Three or Four of the Support to Study Policy.

The grounds for appeal are:

• That there is evidence of a procedural error or material irregularity which affected the decision
• That there is new material evidence which for valid reasons was not available to the decision makers
• That the decision makers reached an unreasonable decision, based on the available evidence
• That there is evidence to suggest bias or a reasonable perception of bias during the procedure

Appeals must be submitted within 10 working days of receipt of the written decision and should be made in writing to:

The Conduct and Appeals Unit

Email: Conductandappeals@wlv.ac.uk

Appeals submitted more than 10 working days after receipt of the written decision may be considered where there is independent evidence to demonstrate that the student lacked the capacity to submit an appeal within the published deadline.

Support to Study Appeal Review

The Head of the Conduct and Appeals Unit (or nominee) will review the request for an appeal to determine whether the appellant has demonstrated valid grounds for an appeal to proceed.  The reviewer, who will have had no previous involvement in the case may request additional documentation/evidence from the student or the relevant decision-making panel to assist with their review. The reviewer may:

• Uphold an appeal directly where the evidence fully demonstrates that it would be reasonable and, in the student’s, best interests to do so

or

• Refer the case to a Support to Study Appeal Panel, this will be a new Support to Study Panel with distinct members from any panel which has met previously, but have not been involved in the case so far.

or

• Conclude that there are no grounds for further consideration of the appeal.

The outcome of the Appeal Review will be communicated in writing to the student via email and/or via post if necessary (method of communication should be agreed).

Where the student has been asked not to attend site as part of any outcome(s) delivered at the above stages two, three or four of the support to study process and appeals that decision, they will be asked to remain off campus and only attend where necessary for face-to-face meetings until the appeal process has concluded.   

An appeal review should normally be completed in no more than 20 working days.

If the reviewer concludes that there are no grounds for further consideration of the appeal a Completion of Procedures letter will be issued, in accordance with the format prescribed by the Office of the Independent Adjudicator for Higher Education[1].

The completion of procedures letter will be issued to notify the student that the University’s internal process(es) have now ended and there are no further steps that can be taken internally.  The letter will be issued as soon as possible, but always within 28 days, after the internal processes have ended. 

Support to Study Appeal Panel Hearing

The membership of an Academic Misconduct Appeal Panel will be:

• Chair - a Dean or Associate Dean of a Faculty other than that to which the student belongs, or their nominee.
• A senior member of academic staff from a School other than that to which the student belongs.
• A Students’ Union Officer.

Members of the appeal panel will not have been involved in the original decision.

Also present will be:

• The student (and friend/representative) – to present the appeal.
• Academic Lead MH and Wellbeing to present a response to the appeal.
• A senior member of staff from the Conduct and Appeals to provide procedural and regulatory advice to the panel.
• A note taker, normally from the Conduct and Appeals Unit

A digital recording will also be taken. Students who would prefer not to have a recording made will be required to request this in advance.

Both parties may call witnesses to appear before the panel.  It will be their responsibility to arrange for those witnesses to attend.

The student must be given written notice, at least 5 working days prior to the hearing, of the date and place of the hearing, and a copy of the Support to Study procedure, drawing attention to their rights under the procedure.  A civil standard and burden of proof will be applied.

Students will be advised to contact the Students’ Union for advice and support. Details of the Students’ Union Representation Service will be included in the invite letter.

At least 5 working days before the hearing, all parties will be provided with the appropriate documentation.  The student may also provide a written statement to the panel, which must be submitted at least 2 working days before the panel to the Support to Study Coordinator. The student’s statement can be read out on behalf of the student if they wish.

The student has the right to appear before and be heard by the Panel.  Students have the right to request a companion, this could be their personal tutor, academic coach, or another trusted person from the University such as a member of the student union, or it could be a fellow student, friend, carer/parent or a specialist provider of health or wellbeing support.  It will be the responsibility of the student to make the appropriate arrangements for the required companion to attend.  Details of who will be in attendance should be provided by the student prior to any meeting taking place.   The role of the individual can be either to provide support (in which case they would not be expected to speak) or to act as a representative (in which case the student would attend but the representative would speak on their behalf).  In all cases the student will be expected to answer questions put to them by the panel.

The student will be responsible for notifying the Conduct and Appeals Unit of the identity of the friend or any witnesses they wish to call not less than 2 working days prior to the hearing.

The student will normally be expected to attend the meeting. If the student fails to attend the meeting without a valid reason, another opportunity will be provided for the student to attend, if the student fails to attend, make comment, or submit written representation, then a decision will be taken in their absence.  Students who do not wish to attend the meeting may submit written representations which should be received no later than 2 working days prior to the hearing.

The Chair of the panel shall have discretion to manage the conduct of the hearing including to adjourn, continue or postpone a hearing and to limit the length of the hearing, the questioning of witnesses, and the number of witnesses called.

The student and the Academic Lead Mental Health and Wellbeing may present evidence and call witnesses, who may be questioned by the other party and by the Panel. The student will always be afforded the opportunity to make a final closing statement.

The panel will consider its decision in private. The panel, at the end of its deliberation will either uphold the appeal in full or part or dismiss the appeal in full or part.  Where the appeal is upheld, the panel will make recommendations for an alternative outcome in line with the potential outcomes available in the Support to Study Policy.

The decision taken by this panel will be final.

The student will be informed of the outcome and reasons in writing within 5 working days of the hearing. Where the appeal is not upheld a Completion of Procedures letter will also be issued to the student, in accordance with the format prescribed by the Office of the Independent Adjudicator[1]. It is anticipated that the full appeal process will take no longer than 90 calendar days to conclude.

Burden of Proof

At all stages of this process decisions will be made on the balance of probabilities where clear evidence and information is not provided or is available.

Office of the Independent Adjudicator

If having exhausted all Stages of the University’s internal procedure, the student considers that the University has failed to consider and respond to their appeal appropriately, they can refer the case to the Office of the Independent Adjudicator (OIA). This office provides an independent scheme for the review of student complaints and appeals.

In order to refer their case to the Office of the Independent Adjudicator they will require a Completion of Procedures Letter. A Completion of Procedures letter will be issued when all applicable stages of the procedure have been exhausted. The letter will be issued in accordance with the format prescribed by the Office of the Independent Adjudicator.

Details of the rules of the scheme and information about how to make an application for review by the OIA are available at their website:

www.oiahe.org.uk 

Students are advised to contact the Students’ Union for advice and support prior to submitting a complaint to the OIA. The Students’ Union Advice & Support Centre can be contacted via email to advice.wolvesunion@wlv.ac.uk or by calling 01902 322038.

[1] [2] Further details of the review scheme operated by the Office of the Independent Adjudicator for Higher Education (OIA) are available at their website:  www.oiahe.org.uk

The policy should be read in conjunction with other University of Wolverhampton policies, procedures, and guidelines, as necessary.

https://www.wlv.ac.uk/about-us/governance/legal-information/regulations-codes-of-conduct-and-bye-laws/

All policies can be found in the  University Policy Hub:

WLV Policies - University of Wolverhampton

Please see below link for Leave of Absence Guidelines:

https://www.wlv.ac.uk/media/departments/office-of-the-vice-chancellor/documents/LOA-GUIDELINES-JAN16.pdf

• Equality Act 2010 • Data Protection Act 2018 • Mental Health Act 1983 and Mental Capacity Act 2005

This log may be useful to record “real time” information which will assist with decision making, and to maintain an audit trail.

It may also help to designate information as:

I              Information                                    D            Decision                                           A               Action

Student Name

Student Number

Case Reference Number

1.      Introduction

The Student Trusted Person Notification Procedure summarises how student emergency contact details are collected and updated, the circumstances under which the university will use emergency contact details, decision making and who will make contact. The document has been introduced to provide clarity for staff, students and nominated Emergency Contacts, and to ensure that correct action is taken in emergency and emerging need circumstances. This procedure is also intended to complement our already established Student Agreement in relation to accessing our Mental Health and Wellbeing Services.

Thanks are due Hannah Bannister of Imperial College London for the support she offered during the scoping stages of developing this procedure. Also, to James Murray, Lee Fryatt and the LEARN group of bereaved family members campaigning to prevent further deaths by suicide. Both James and Lee have been supportive of the University of Wolverhampton (the University), assisting us to develop our own Student Trusted Person Notification Procedure.

The LEARN group of bereaved family members have developed an Information Sharing PEACE framework, which very much underpins the intentionality of our own guidance and procedure:

Proactive The information sharing policy sits within a suicide-safer framework and is informed by evidence, compassion, and openness.

Empowering Staff are confident in their roles and responsibilities, know when to act, act within their limits and share and record decisions.

Agency Students are at the centre of decisions about their care including when trusted contacts may be involved.

Contacts Universities collect and refresh trusted contacts within a conversation about why and how they may be involved.

Easy The information sharing policy must be easy to grasp and well understood by staff, students, and trusted contacts.

The duty of care of the University is to deliver its educational and pastoral services to a standard of reasonable competence and to act to protect the health, safety, and welfare of its students. In practice, the University should take reasonable steps to remove or reduce the risks of which the University is aware of, or of which it ought reasonably to be aware of (Abrahart vs University of Bristol, 2022)

1.2  Our Commitment to Student Mental Health and Wellbeing

Our Student Mental Health and Wellbeing Strategy acknowledges that inclusivity, belonging, and wellbeing reinforce each other. The strategy treats wellbeing as a form of social capital that is embodied and accumulated through an individual’s life journey.  Wellbeing needs to be an integral to how we study and work every day.

The strategy is based on seven pillars: Leadership, Transitions, Collaboration and Partnerships, Data and Research, Support and Prevention, Support and Intervention, and Staff. 

This Student Trusted Person Notification Procedure is directly linked to the Support and Intervention pillar, spanning a continuum of whole-population awareness and signposting, self-help, and early intervention, through to focused support and intervention where mental health and wellbeing difficulties arise. This includes crisis and safeguarding intervention.  

In addition, the University’s Access, and Participation Plan (2020/25) aims to eradicate award and non-continuation gaps between students with protected and non-protected characteristic groups by 2030.

Please see link to access University Access and Participation Plans: https://www.wlv.ac.uk/about-us/corporate-information/access-and-participation-plans/ 

Each student who does not progress in their studies, represents someone who has possibly not achieved what they set out to do, and have possibly not been able to fulfil the realisation of their ambitions. Each of them should be reflected back to the Academic Board as a red flag.

Every member of the University community has a responsibility to support others in creating a safe environment which is conducive to study, live and work. Staff are encouraged to address any concerns about a student’s health and wellbeing through early intervention and positive support.  This is delivered through the Academic Coach, Personal Tutoring and Supervision systems as well as through dedicated student support teams. This procedure supports the aims of our Access and Participation Plan by fostering a collaborative and pro-active whole population support system which can identify and implement support for students who need it.

Please see link for guidance and support: Student Support and Wellbeing (SSW) - University of Wolverhampton (wlv.ac.uk)

2. A Social Support Map

As a university, we recognise that any one of our students will have varying layers of support available to them, whether support needs are present or not. We also recognise that friends, carers and families (trusted people) can be essential in creating positive support networks. This support map will possibly change and grow as students’ progress through their studies. Some of these trusted people include university-based colleagues and others will include external contacts such as friends and family.

This procedure recognises the need to view the whole student and when concerns are raised and/or are founded about their safety and welfare, other people may need to be notified to mitigate risk and offer a robust support mechanism around that student.  

Families, carers, and trusted contacts can play an essential part in supporting a student who is at risk or about whom there may be serious concerns. Referred to as the triangle of care, this asserts that care is best delivered when trusted contacts, people needing support and professionals work together to ensure the best outcome.

In 2021, the Department for Health and Social Care (DHSC) published a consensus statement on information sharing and suicide prevention. It developed the statement together with professional bodies, including the British Psychological Society and the Royal College of Psychiatrists.

It said:

‘We strongly support working closely with families. Obtaining information from and listening to the concerns of families are key factors in determining risk. We recognise however that some people do not wish to share information about themselves or their care.

Practitioners should therefore discuss with people how they wish information to be shared, and with whom. Wherever possible, this should include what should happen if there is serious concern over suicide risk.’

Therefore, opening up a dialogue with students, where talking openly about the university’s process for sharing information will help students understand what to expect. It also gives students the opportunity to reflect on what they would like to happen in the case of an emergency. This can help make sure that their choices, their privacy, and their dignity are given proper weight in the decision-making process.

We also advocate proactive safety planning for all students, underpinned with a philosophy that emotional distress can beset any one of us at any point in our life. Safety planning is a structured and proactive way to help people plan a range of activities and sources of support we can use at the right time to help us prevent or manage a developing crisis. Safety planning should be seen as part of overall care, crisis, and contingency planning.

A Safety Plan is our own document which aims to acknowledge our own warning signs of emerging emotional intensity and distress, as well as techniques to help keep us safe and supported. It is best to consider this plan before we need to enact it, it is also usually best to compile this safety plan in collaboration with someone we trust, where we can explore strategies for support, to include contacts of those we wish to call up on.  

Please visit www.stayingsafe.net to view other examples of safety plans can be found via Samaritans or Papyrus. A safety planning mobile app can also be found here. 

3. Definition of a Trusted Person

All students are currently required to provide details of an emergency contact when registering for their programme. This information is held on the University’s student record system (SITs), in accordance with the University’s Enrolment Privacy Notice and with the Data Protection Act 2018 (DPA).

Students can nominate anyone (non-university colleague) they choose to be their emergency contact. Many of our students are mature learners, may be estranged from their family or have relationship dynamics that would make this optionality incredibly important. For some of our students the emergency contact will be a parent or guardian. However, students should be aware that it could be another responsible individual of their choosing and does not have to be their legally defined Next of Kin. In line with our commitment to inclusivity, we do not use the term Next of Kin within our systems.

Students should ensure that the emergency contact is aware that they have been nominated and that their contact details will be given to the University. Students should also ensure that the emergency contact has given permission to be an emergency contact. Wherever possible, students should give a mobile phone number as well as a landline so that contact can be made quickly.

Students are asked to keep these details up to date and may change these and other personal details at any time by logging onto E:vision. The University will assume that the information is up to date and may need to use it without being able to check with the student first. Therefore, it is important that students review it regularly. A Students Academic Coach, Personal Tutor or Research Supervisor are encouraged to prompt this reflection and E:vision task at least once per semester.

4. Purpose

As a Higher Education Institution, the University of Wolverhampton has a duty to care for all its community members and includes the responsibility to act reasonably to protect the health and safety of all its students and staff. Our duty to care must be finely balanced with our obligations under the UK General Data Protection Regulation (GDPR), the DPA and other relevant legislation. The University has an obligation to process student data in accordance with the DPA and the GDPR. Strict regulation is in place which covers the information that we may share with a third party about a student, including their parent, guardian, family members or legal guardians unless that student is a minor.

The University collects emergency contact details up on enrolment and re-enrolment which are held securely and confidentially in line with relevant UK legislation. The purpose of this procedure is to set out guidance in relation to the implementation and ongoing use of this Student Trusted Person Notification Procedure, including specific detailed guidance for those staff members in roles that are part of the escalation and decision-making process.

The SHARE guidance, produced by the Zero Suicide Alliance, provides practical advice for professionals navigating these conversations about confidentiality, information sharing, and consent.

The purpose of this procedure is underpinned by some guiding principles outlined in this document, which are:

• Seek consent to share information
• Have regard to the law, rules & regulations
• Always act in the person’s best interest
• Record all discussions and activities
• Ensure confidentiality is respected

In September 2021, the Information Commissioner’s Office (ICO) published a short guide which relates to the issue of confident information sharing within our context, saying:

‘We know that universities and colleges work hard to provide support to students who are struggling. That means that universities and colleges often have to handle sensitive personal information about them. And we are aware that, sometimes, universities and colleges are hesitant to share students’ personal data in an urgent or emergency situation, citing data protection as the problem. That should not be the case.’

In summary, the University is bound by law to protect confidential (personal and special category) information about individuals, unless there is significant risk to the individual, the public or children. When a significant risk to safety is imminent and not sharing information appears likely to result in death or serious injury, then relevant information can and should be shared with those people for whom consent has been given to share. Consent is not necessary where it would be in the individuals vital interests to process/share data.  Vital interests are intended to cover only interests that are essential for someone's life and generally only applies to matters of life and death. Put simply, the University should do whatever is necessary and proportionate to protect someone’s life. Data protection law allows organisations to share personal data in an urgent or emergency situation, including to help them prevent loss of life or serious physical or emotional harm.

The legal framework relevant to sharing information and suicide prevention in universities includes:

• The university’s duty of care under contract law
• UK General Data Protection Regulations (UK GDPR)
• Data Protection Act 2018
• The common law of confidentiality
• Medical Capacity Act 2005
• Human Rights Act 1998
• Care Act 2014

5. Scope

This procedure applies to all registered students at all levels, including both campus-based, Transnational Students (TNE) and Apprentices. It will inform the processes for prospective students where required.

Where there are concerns for a Postgraduate Research student that also has a staff contract, each case will be considered on an individual basis which will include whether consideration needs to be given under their respective staff contracts and relevant HR policies.

Please see link to view HR policies: WLV Policies - University of Wolverhampton

The University collects ‘emergency contact details’ for its students which are held securely and confidentially. These may only be accessed under specific conditions as outlined in relevant UK legislation and this procedure.

This procedure does not apply in any circumstances in which a student provides details of someone that they wish a member of staff to contact on their behalf. In this instance, direct consent has been given. The member of staff should ensure that they keep records in an appropriate secure manner for later reference if needed. This is usually best achieved by writing up a summary of the conversation to include explicit reference to the request from the student, and email this to them. That staff member should then keep that email in a secure folder.

This procedure applies to the usual day-to-day study or living arrangements for students at university premises. Where students are required to study away from the University, for example on field trips, placements or study at another Foundation Education or Higher Education Institution, this guidance and procedure should also be followed which aims to offer governance and inclusion.

Where there is concern raised about a student away from university premises, advice can be sought from the Academic Lead for Mental Health and Wellbeing (clare.dickens@wlv.ac.uk) or nominee. During a referral under the Support to Study Policy and procedure (which can be located here: WLV Policies - University of Wolverhampton), if it is considered appropriate to also contact the student’s emergency contact, this procedure will be followed.

6.      Respect for Confidentiality and Confident Information Sharing

Respect for confidentiality will treat information relating to the health and welfare of a student as special category data and must be kept confidential, and only disclosed with consent, unless the vital interests of a student require protection. This policy is underpinned by such respect for confidentiality, but also recognises the need to support confident information sharing to support its intentions. Therefore, it will also set out the basis for dealing with exceptions to that general rule.

For colleagues who are in a position of advising students and offering them general pastoral support, should consider at the outset of a discussion whether it would be helpful to make clear whether the content is to be confidential and the extent of the confidentiality which can be afforded to any disclosures. For example – if a crime is disclosed or a safeguarding issue relating to children, then confidentiality cannot and should not be upheld.

When discussing confidentiality with students, the following should be made clear:

• Confidentiality will be respected, wherever possible.
• Consent will be sought, wherever possible, to any onwards disclosure of information; and
• There are limited circumstances in which information might be shared with a third party, e.g., taking account of the vital interests of others, or where an individual lacks capacity to consent.
• Only in such circumstances will members of the Mental Health and Wellbeing, Safeguarding, and Disability and Inclusion teams share confidential information with other parties, although they may use their own judgment on what to share with each other.
• If a crime is disclosed, this will be shared with the Police

Where concerns are raised by university staff, they should record consent at the point of student disclosure or at least a record of how such consent was provided and when, so that the University would be able to demonstrate that the student had specifically agreed to the processing of their sensitive personal data in particular ways.

Once consent has been obtained and a record made, it is the responsibility of the person passing on special category data to ensure it is done in accordance with the student’s explicit wishes.

Transfer of such information should also be carried out in an appropriate secure manner to reduce the risk of inadvertent disclosure to unauthorised persons. This includes anyone within the University who does not need this information to offer support to the student.

Secure transfers can include using password protection or encryption or sharing information via a link from OneDrive or SharePoint. Further information on secure transfers can be sought by contacting dataprotection@wlv.ac.uk

6.1  No Student Consent

If the student chooses not to provide explicit consent to share their personal or special category data (data concerning health) or chooses to withdraw consent, this decision should be respected in most instances. In this scenario, the implications of not sharing in terms of additional support available from, for example the University’s Student Support Services or other parts of the University with a need to know all or some part of such information to provide support, should be made clear.

However, there are exceptional circumstances when the student’s consent is withheld, or it is impracticable to try to obtain it, when confidentiality may lawfully be broken, and disclosure can be made to Student Support Services, processes relating to professional regulated courses and/or to external agencies. These include:

• When the student’s health has deteriorated to the extent of threatening their personal safety or that of others.
• When the student is at risk of serious abuse or exploitation.
• When the student’s behaviour is adversely affecting the rights and safety of others.
• Where the member of staff would be liable to civil or criminal procedure if the information were not disclosed (e.g., if a crime had been committed)
• Where the student is either under 18 years or a vulnerable adult (see University Safeguarding Policy)
• In extreme circumstances, in the student’s ‘vital interests’ and where the University has justifiable concerns for the safety and/or life of the student, the University will disclose information as required.

Please see link to the University Safeguarding Page for guidance and support: Safeguarding - University of Wolverhampton (wlv.ac.uk)

6.2 Seeking advice 

Those to whom information has been given in confidence, or who have acquired information which they regard as confidential, may not always be sure whether they should disclose this information or not. This can pose a risk to the student if the sharing of such information might be in their best interests. It should also be noted that having no place to go to check out concerns, might be of detriment to staff members wellbeing.

Where there is no immediate risk, initial discussions should not identify the student until the grounds for breaking confidentiality have been established and agreed upon.

In these circumstances it may be sensible to seek advice from the Support to Study Coordinator through the causeforconcern@wlv.ac.uk inbox.  This consultation should be done without divulging the name of the student concerned in the first instance. Within this space, there is scope to offer an outline of the concerns, the story, and details of the case – here guidance can be obtained as to the most appropriate next steps, which might include an instruction to give further details due to the seriousness of the case.  There will also be weekly drop in sessions, alternating online and in person, details of theses can be found on the Support to Study web pages.

With the above considered, it is generally not appropriate to give absolute assurances of confidentiality to those who may wish to talk about health or safeguarding-related matters.

7.1  Record Keeping

At all stages of this procedure factual and detailed record keeping will be maintained.

Action planning

Action and support planning will be documented, and copies shared with all appropriate colleagues, and the student themselves. A blank action and support plan document has been prepared and is located at Appendix 1.  An Action and Support Plan is intended to be a supportive measure which clearly sets out agreed actions and a time frame for their implementation and review. Through collaborative working, agreements with the student will be made that in their best interest they will need to satisfy academic requirements or engage with particular types of support. The Action and Support Plan will be reviewed at a specified date and discussions will also identify the consequent actions if the plan is not followed.

Recording information

An information sharing log template is available at Appendix 2.  This will be initiated by the Support to Study coordinator at the point of referral. All communications, documentation of meeting and any other details related to the case will be captured via this log. This will also ensure all communication received and sent will be recorded in chronological order and may support a lesson learned reviews and or an appeal process.

8.      Circumstances where an emergency contact would be utilised

Generally, there are two types of instances in which the university may use the emergency contact details on the student record.

These are:

• in a student’s ‘vital interest’ (life or death situations), or 2) where the university has a serious concern for their wellbeing.

Vital interest: Vital interest is a legal definition which relates to acting where it is necessary to protect someone’s life or that of another person. Under data protection legislation, we may disclose personal information about a student without their consent when it is in their ‘vital interest’ to do so. This would normally mean providing details about a student, including their emergency contact details, to a third party such as a member of the emergency services in the event of an accident or emergency medical admission.

The University may also decide to contact a student’s named emergency contact directly to inform them of a vital interest situation, for example if a student was experiencing a prolonged mental health crisis and was not engaging with University or NHS support services.

Serious concerns: A serious concern about a student under this policy means where a member of the University believes based on the information available to them that a student is close to a crisis in their mental or physical heath, or they have fears for the student’s safety that do not meet the ‘vital interest’ criteria.

If a member of staff is concerned about a student and is unsure if this procedure would apply, additional guidance is available from the Support to Study Coordinator or the Mental Health and Wellbeing Manager  contact can be made through the causeforconcern@wlv.ac.uk inbox.

These examples are provided to give a benchmark of the seriousness of a concern that falls under this procedure and is not exhaustive, if staff are in any doubt, they are advised to check it out:

• A student has attended or been admitted to hospital for non-routine treatment.
• A student has suffered a serious physical injury, including an episode of self-harm, for example where this has resulted in needing significant medical intervention.
• A student ceases to engage with their studies or has not attended their placement, and we have been unable to contact them.
• A student has not recently been seen in their hall of residence and we have been unable to contact them.
• A student has an ongoing illness, and they appear to be significantly deteriorating.
• A student appears to be approaching a significant mental health crisis.

Please be aware that this procedure notes that many of the examples above may escalate to a ‘vital interest’ concern if intervention does not occur.

8.1 Raising a Concern

This procedure, in most instances does not advocate or permit all university staff to contact a student’s trusted/emergency contact. Such a devolved operational way of working may invite inconsistent practice and lack of support for colleagues. Academic staff and others working outside of university support services can feel uncertain when responding to a student who has disclosed that they are at risk of harm. Some staff may avoid taking any action, and others may feel a responsibility to try to provide support that goes beyond the boundaries of their role and ability.

A decision to contact a student’s trusted contact, will in most cases fall to a central panel of colleagues via the Support to Study Coordinator.  A Cause for Concern can be raised through the completion of the Microsoft form: https://forms.office.com/e/VNmT65mwQY   

These concerns may arise from the below stakeholders:

• Raised by the academic department.
• Raised by University staff.
• Raised by peers.
• Raised by self‐disclosure from student

A cause for concern may be raised about a student due to any number of factors, they may include:

• A student’s academic progress and an inability to engage a student
• A student’s health and/or wellbeing
• A student’s ability to live safely and independently at university
• How a student’s behaviour may be impacting on other students and staff

For out of hours concerns, staff are encouraged to Call 01902 325 555 (or 5555 from any internal phone) to contact Campus Security, who are available 24/7. 

8.2 Roles and Responsibilities

The Cause for Concern group membership meets weekly, here they will review the concerns detailed within any referral and then identify the appropriate action, such escalations will be reviewed daily. 

The Cause for Concern group is a centrally situated operational group of university services which meets regularly to ensure student cases are appropriately managed, coordinated and risk assessed. These cases are what are known as amber cases, where taking a coordinated and proactive approach to supporting and mitigating known risks is aimed to prevent them from becoming red flags.

More detailed information on this can be located in the Support to Study Policy: WLV Policies - University of Wolverhampton

All decisions made in this process will be done in the best interests of the student and to ensure the best outcome for the student’s wellbeing.

Below is a list of key people who may be involved in the process; their involvement will depend on the intricacies of each case:

• Relevant Head of Programme/Personal Tutor/Supervisor/Academic Coach/ Course Lead.
• Student Support Services.
• Health and Safety Officer.
• Student and Academic Services.
• Estates and Facilities Services.
• Deans and Registrar
• Academic Registrar and Registrar and Secretary.
• Occupational Health (for students on professionally regulated courses).
• Chaplains
• External providers of support for example: community mental health teams, the police, relevant members of the local Channel group or other “Prevent” specialists, family of student, social workers. 

The principles guiding a decision to notify a student’s trusted contact are as follows:

• The UK GDPR, the DPA and Human Rights laws are not barriers to justified information sharing but provide a framework to ensure that personal information about living individuals is shared appropriately.
• In all cases, we will aim to be open and honest with students (and or their trusted contact where appropriate) from the outset about why, what, how and with whom information will, or could be shared, and seek their agreement, unless it is unsafe or inappropriate to do so.
• The Cause for Concern Group membership will always seek advice from other colleagues to build a better picture and will call up on university governance colleagues if they are in any doubt about the legitimacy of sharing the information concerned.
• Where possible, we will always share information with consent, and where possible, respect the wishes of those who do not consent to having their information shared.
• Decisions will be guided by the fact that Under the UK GDPR and the DPA, we may share information without consent if, in our judgement, there is a lawful reason to do so, such as where safety may be at risk. We will always base this judgment on the facts of the case.
• Where possible, we will share concerns with consent and, where possible, respect the wishes of those who do not consent to having their information shared.
• When sharing or requesting personal data (as defined in section 7) from a student, we will be clear of the basis upon which we are doing so. Where we do not have consent, we will be mindful that an individual might not expect information to be shared.
• We will always consider safety and well-being and will base our information sharing decisions on considerations of the safety and wellbeing of the individual and others who may be affected by their actions.
• Any disclosure will be necessary, proportionate, relevant, accurate, timely and secure. We will ensure that the information we share is necessary for the purpose for which we are sharing it, is shared only with those people who need to have it, is accurate and up to date, is shared in a timely fashion, and is shared securely
• We will keep a record of our decision and the reasons for it - whether it is to share information or not. If we decide to share, then a record of what we have shared, with whom and for what purpose will be logged within the Cause for Concern Group, the log will be managed by the Support to Study Coordinator. 

Linked Policies, Procedures, Guidelines and Legal Framework  

The policy should be read in conjunction with other University of Wolverhampton policies, procedures, and  guidelines, as necessary.

https://www.wlv.ac.uk/about-us/governance/legal-information/regulations-codes-of-conduct-and-bye-laws/

WLV Policies - University of Wolverhampton

https://www.wlv.ac.uk/media/departments/office-of-the-vice-chancellor/documents/LOA-GUIDELINES-JAN16.pdf

• The university’s duty of care under contract law
• UK General Data Protection Regulations (UK GDPR)
• Data Protection Act 2018
• The common law of confidentiality
• Medical Capacity Act 2005
• Human Rights Act 1998
• Care Act 2014