Personal Relationships Policy

Definitions

6. Abuse of power
Abuse of power is where someone uses their position of power or authority in an unacceptable manner. Abuse of power can take various forms and may include, but is not limited to, grooming, manipulation, coercion, putting pressure on others to engage in conduct they do not feel comfortable with.  

7. Adult at risk
An adult at risk is someone over the age of 18 who receives or may need community care services by reason of disability or illness and because of those needs is unable to protect himself or herself against significant harm or exploitation. This can relate to physical, mental or psychological wellbeing or the potential to be drawn into sexual or criminal exploitation and activity.

8. Close friendship: a relationship between two people where there is a regular and sustained closeness inside or outside of the UCL environment that goes beyond a professional relationship or acquaintanceship.

9. Family relationship: a relationship between two people who are related, including adoptive and step-relationships; partners, and the family of partners; close family friends.

10. Financial Relationship: a relationship where there is financial dependence due to one person receiving monetary support or income from the other, that does not fall within the scope of the Disclosure of Conflict and Declaration of Interest Policy.

11. Grooming: when a person in a position of power or authority builds a relationship with someone so they can abuse them and/or manipulate them into doing things they may not be comfortable with and may also make it less likely that the abusive behaviour is reported or rejected. 

12. Indirect Academic Responsibility: when a member of staff has some degree of oversight of a student’s academic studies or progression (for example, Head of Department, Dean or assessor of a student’s work).

13. Intimate relationship: a relationship that involves one or more of the following elements:
 physical intimacy including isolated or repeated sexual activity; or
 romantic or emotional intimacy.

14. Personal relationships: this is a generic term covering the following relationships:
i.   Intimate relationships
ii.  Close friendships
iii.  Financial relationships
iv.  Family relationships
    
15. Professional relationship: a relationship between individuals that is established and maintained within a formal university or workplace setting, or any setting that arises during university activities and is focused on achieving shared work or educational goals. It is characterised by mutual respect, clear boundaries, and the avoidance of actual or perceived personal conflicts to ensure a productive and respectful environment.

16. Relevant Staff Member: 
 A member of staff who has direct or indirect academic responsibilities, or other direct professional responsibilities, in relation to that student. This may include, for example but not limited to, teaching staff, personal tutors, technicians, heads of department, deans, pastoral support staff, and security staff.

17. Staff: all employees of, and other individuals working at, UCL, including agency workers, honorary staff, emeritus staff, visiting staff, external collaborators, contractors and consultants, and the staff and directors of UCL’s subsidiary companies. This includes students who are employed temporarily or permanently as staff.

18. Student: any individual registered as a student at UCL. 

Intimate Relationships with students or staff under the age of 18 or who are an "adult at risk"

19. Staff must not be in, or enter into, an intimate relationship with a student or staff member under the age of 18, or a student or staff member who is known or suspected to be an adult at risk.

20. The Sexual Offences Act 2003 makes it a criminal offence for a person to engage in sexual activity of any kind with a person under the age of 18 or an adult at risk, where the person is in a position of trust.  

21. Anyone suspecting a staff member or student of engaging in sexual activity with or acting inappropriately towards a student or staff member under the age of 18 or an adult at risk should immediately refer to the Safeguarding of Children and Adults at Risk Policy and contact the Designated Safeguarding Officer, who may contact the local authority designated officer and/or the police. 

Intimate Relationships between staff and students 

22. Staff members must not enter into an intimate relationship with a student, in relation to whom they are a Relevant Staff Member.  

23. Where such a relationship was established before both individuals joined UCL, or before the staff member became a Relevant Staff Member to that student, this must be notified at the point the staff member becomes a Relevant Staff Member with respect to that student, whether that is upon either individual joining UCL or at a later point in time. 

24. Staff members who begin an intimate relationship with any student outside this prohibition, must notify UCL of this to enable UCL to assess whether any actual, potential or perceived abuse of power or conflict exists. 
In recognition that some of our students are employed as staff, the only exception to this notification requirement is where that staff member is also a student. 

25. Staff members who commence an intimate relationship with an individual who has completed or withdrawn from their studies at UCL within the past 12 months and for whom they were a Relevant Staff Member within the 12 months preceding the individual completing or withdrawing from their studies at UCL must also complete a notification. This will enable UCL to evaluate any actual, potential or perceived conflict, abuse of power, favourable or detrimental treatment that occurred during their period of study. 

Close friendships between staff and students 

26. Staff members must not enter into a close friendship with a student, in relation to whom they are a Relevant Staff Member. 

27. Where such a relationship was established before both individuals joined UCL, or before the staff member became a Relevant Staff Member to that student, this must be notified at the point the staff member becomes a Relevant Staff Member with respect to that student, whether that is upon either individual joining UCL or at a later point in time. 

Financial relationships between staff and students

28. Staff members must not enter into a financial relationship with a student, in relation to whom they are a Relevant Staff Member. 

29. Where such a relationship was established before both individuals joined UCL, or before the staff member became a Relevant Staff Member to that student, this must be notified at the point the staff member becomes a Relevant Staff Member with respect to that student, whether that is upon either individual joining UCL or at a later point in time. 

Family relationships between staff and students

30. Staff members who have or enter into a family relationship with a student in relation to whom they are a Relevant Staff Member, must notify UCL of the relationship. 

31. Where such a relationship was established before both individuals joined UCL, or before the staff member became a Relevant Staff Member to that student, this must be notified at the point the staff member becomes a Relevant Staff Member with respect to that student, whether that is upon either individual joining UCL or at a later point in time. 

Personal Relationships between staff 

32. Entering into a personal relationship with another member of staff where one has direct or indirect authority over another, or where it may give rise to an actual, potential or perceived abuse of power, conflict or favourable or detrimental treatment, is strongly discouraged. Both members of staff must notify UCL about the relationship in these circumstances. 

33.  The notification must be submitted at the outset of that personal relationship or at a later date where a new work situation means that one person in the relationship now has direct or indirect authority over another, or where it may now give rise to an actual, potential or perceived conflict. 

Advice for staff and students 

34. Staff who are unsure whether they have a personal relationship within the scope of this policy and/or where the other party does not wish to notify UCL about the relationship, should seek advice from their line manager, Head of Department or HR People Partner. 

35. Students who are unsure whether they have a personal relationship with a staff member within the scope of this policy or where the other party does not wish to notify UCL of the relationship, should seek advice from their personal tutor, Head of Department, or Student Support and Wellbeing Team. 

Notification of personal relationships

36. The staff member must complete a Personal Relationship Notification Form as soon as reasonably practicable and always within one month of the situation giving rise to the requirement to make a declaration.

Click here for Personal Relationship Notification form

37. The form will be automatically submitted to their HR People Partner/s, who will discuss the details with the staff member(s), their Line Manager(s), or student’s Head of Department, as appropriate.

38. The HR People Partner and the Line Manager(s) or Head of Department, will review the notification form and where appropriate, a Personal Relationships Management Plan will be implemented. 

39. As the notification contains sensitive personal data it will be managed in compliance with data protection legislation. Such notifications will be treated confidentially and the wishes of both parties respected, as far as possible. 

Personal relationships already declared under previous versions of this policy

40. Any personal relationships which have already been declared under the previous UCL Personal Relationships policy, must be redeclared, by completing a notification form within one month of the effective date of this new and updated policy. 

Personal Relationships Management Plan

41. When deciding measures to include in a Personal Relationships Management Plan, the following non-exhaustive factors may be considered:
•    any known vulnerability of the individuals involved;
•    when the relationship commenced;
•    the degree of responsibility, involvement or influence over the student or staff member;
•    the nature of the individuals’ interactions within UCL;
•    the extent of the power imbalance between the two individuals.

42. The following is a non-exhaustive list of measures which may form part of the Personal Relationships Management Plan:
•    allocating an alternative personal tutor or PI to the student
•    changing reporting lines
•    redeploying the staff member 
•    amending the duties of the staff member 
•    restricting the data which the staff member has access to about the student or other staff member
•    disallowing the staff member to be part of any panel that facilitates promotional or academic opportunities for the other staff member or student
•    disallowing the staff member to provide references for the other staff member or the student. 

Change of Circumstances

43. It is the responsibility of the staff member to inform their line manager and their HR People Partner as soon as reasonably practicable when there is a change in circumstances, including where the personal relationship comes to an end. 

44. It may be necessary to review or remove the Personal Relationships Management Plan if, for example, the staff member changes department or role, or if the staff member or student leaves UCL. 

45. Where a personal relationship ends, both parties are expected to continue to conduct themselves in a professional manner and avoid personal disputes which may impact on the working or learning environment, or on other colleagues and students. It may be appropriate for the Personal Relationships Management Plan to continue for a time following the end of the relationship. The individuals involved will be informed of this and required to comply with reasonable actions requested of them. 

Professional Boundaries 

Between staff and students
46. To maintain professional relationships with students and to help protect them from harm and reduce the risk that they or staff members face allegations of actual, potential or perceived unfairness, abuse of power or conflict, staff must:

a.    Maintain an appropriate physical and emotional distance from students for whom they are a relevant staff member;
b.    Ensure that meetings and discussions with students for whom they are a relevant staff member occur on campus or other premises booked by UCL, wherever possible. Where not possible, ensure the meeting occurs in a public venue, such as a library or a café; 
c.    Perform their duties in the best interests of UCL without favour towards any individual student(s) over another;
d.    Not enter into a close friendship or financial relationship with students where the staff member is a relevant staff member, as this may be considered or perceived as grooming, and create the potential for favourable treatment or conflict;
e.    Use a UCL email account, UCL work phone, UCL software such as Microsoft Teams and applications and internet access for communications with students where possible. Personal one to one direct messaging (such as WhatsApp, Messenger or X) should not be used in general, but may be used where there is no UCL channel available, for example while on a field trip, or the situation is pressing. However, group messaging with other students and staff is acceptable. 
f.    Avoid contacting students outside reasonable working hours;
g.    Write and communicate with students in a professional manner; 
h.    Adhere to the same guidelines when participating in fieldwork or conferences with a student, and any other UCL related activities whilst away from the usual workplace.
g.    Consider the potential for inappropriate behaviours, actual or perceived when organising and holding events, in particular where alcohol may be provided.   
h.    Refer students with support needs to a relevant UCL support service and limit your role in providing personal support to a student where this is not part of your role;
i.    Not seek personal or intrusive information from a student or ask inappropriate questions except as required by a UCL process (e.g. medical information for special consideration, or personal circumstances information as part of an academic progress process).

47.    The following is a non-exhaustive list of behaviours towards students by a relevant staff member that is always unacceptable:

a.    Physical touching, that could be reasonably construed as sexualised (e.g. touches of the shoulder or squeezes of the leg), or comments or questions of a very personal and / or sexual nature (whether verbally or electronically).
b.    Paying undue special attention to a particular student which may reasonably be seen as grooming or amounting to a close friendship and could create the potential for favourable treatment or conflict.  
c.    Giving gifts to a student or accepting gifts from a student, unless it is following final assessment completion and deemed to be a minor token of thanks in accordance with the UCL gift policy;
d.    Inviting an individual student to your home or accommodation, or visiting their home or accommodation, including while at conferences, on field trips, or on placement.
e.    Asking a student to care for your child, to tutor your child, or to house-sit whilst away, or perform any other personal services when not formally employed or engaged by UCL, or a third party, to do so. 

Between staff members
48.    To maintain professional relationship with colleagues and peers, and help reduce the risk of actual, potential or perceived abuse of power or conflict, staff should:

a.    Maintain an appropriate physical and emotional distance from other staff while working;
b.    Perform their duties in the best interests of UCL without favourable or detrimental treatment towards any individual staff members over another;
c.    Avoid paying undue special attention to a particular staff member which may reasonably be seen as grooming and could create the potential for favourable treatment or conflict;
d.    Use their UCL email account, Microsoft Teams, and internet access for work-related communications with staff, wherever possible and maintain professional communications;
e.    Write all emails and work-related instant messages or communications in a professional manner;
f.    Adhere to the same guidelines when participating in fieldwork, conferences and other UCL activities away from UCL premises;
g.    Where possible, ensure that meetings and discussions about UCL matters occur at UCL, other appropriate premises or via UCL communication channels such as Microsoft Teams. 
h.    Signpost or refer colleagues with support needs to a relevant UCL support service, such as Workplace Health or the Employee Assistance Programme and be mindful to limit your role in providing personal support to a staff member where this is not part of your role. 

Sources of Advice and Support

49. A student or staff member should seek advice immediately if they feel they have been subject to unprofessional or inappropriate conduct from a student or staff member, by speaking to their personal tutor or line manager, Head of Department, Faculty Dean, Student Wellbeing or HR People Partner to ensure appropriate support is provided. They can also report such conduct via the mechanisms outlined in UCL’s Prevention of Bullying, Harassment and Sexual Misconduct Policy.

50. They can also access the Employee Assistance Programme or student counselling services as needed. 

Breach of policy

51. Any breach or suspected breach of this policy may be investigated and treated as a disciplinary matter. 

Training

52. All staff must undertake mandatory training in respect of the purpose and principles of this policy. All staff will be auto enrolled into this training at the appropriate time.    

53. This policy will be drawn to the attention of all students as part of the training they undertake during induction. 

Review of policy

54. This policy is not contractual and may be varied from time-to-time following consultation with UCL’s recognised trade unions.

Related procedures
•    Prevention of Bullying, Harassment and Sexual Misconduct Policy
•    Disclosure of Conflict and Declaration of Interest Policy 
•    Student Disciplinary Code
•    Staff Disciplinary Policy and Procedure
•    Statute 18
•    Safeguarding of Children and Adults at Risk Policy