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A response to HM Government's 'Prevent duty guidance' consultation

Prevent duty guidance: a consultation

On 17th December 2014, the Home Office released its "Prevent duty guidance: a consultation" document, outlining binding guidance which is set to be issued by the Home Secretary for various kinds of institutions when putting into action the Government's "Prevent" counter-terrorism strategy as set out in the Counter-Terrorism and Security Bill.

Amongst others, higher education institutions like my university, the London School of Economics and Political Science, where I am active in the LSESU Christian Union, are subject to specific duties for the purpose of preventing radicalisation.

The way that the Government is suggesting that these duties should be implemented is a personal cause of concern, both in terms of administrative burden for faith societies like the Christian Union, the preservation of freedom of speech and the need to effectively counter terrorist threats to the United Kingdom.

See below for my response sent to the Government for consideration:

Dear Sir/Madam,

I am writing to you in response to the invitation in the document "Prevent duty guidance: a consultation" to participate in consultation on the Government's planned Prevent counter-terrorism strategy.

In particular, I am concerned by plans outlined in the section in the document on higher education, starting from p. 17, and especially by plans for dealing with "Speakers and events" in Point 66 on p. 19.

To provide background background, I am involved in the Christian Union at the London School of Economics and Political Science, part of the Students' Union there. We are an organisation which aims to share the Gospel message about Jesus Christ on campus, desiring that everyone might have a chance to hear and respond to that message. However, I only write this response in a personal capacity.

Point 66 especially concerns me, outlining minimum necessary procedures for assessing speakers events, including advance notice of their content, such as slides and summaries, as appropriate:

"Universities must take seriously their responsibility to exclude those promoting extremist views that support or are conducive to terrorism. We would expect the policies and procedures on speakers and events to include at least the following:

• Sufficient notice of booking (generally at least 14 days) to allow for checks to be made and cancellation to take place if necessary;
• Advance notice of the content of the event, including an outline of the topics to be discussed and sight of any presentations, footage to be broadcast etc;
• A system for assessing and rating risks associated with any planned events, providing evidence to suggest whether an event should proceed, be cancelled or whether mitigating action is required (for example a guarantee of an opposing viewpoint in the discussion, or someone in the audience to monitor the event); and
• A mechanism for managing incidents or instances where off-campus events of concern are promoted on campus."

My concern here is three-fold:

First of all, the procedures outlined in the Guidance will create an excessive administrative burden for faith societies and will disrupt their usual operations which are generally considered an integral part of university societies through the United Kingdom. Faith societies like the LSESU Christian Union will tend to invite in outside speakers who have very busy schedules, often speaking at many universities every week as well as being involved in speaking at churches and other locations. Being forced to prepare their content far in advance - 14 days ahead from what the consultation suggests - will reduce the ability of faith societies to run events and fulfil their purposes, especially in the case of societies like ours which have outside speakers every week of the academic year for regular meetings of members. Having to provide substantive details on these events ahead of time, specifying exactly what will be taught, will create administrative burden for those running faith societies and will cause significant difficulties for outside speakers, meaning that events may have to be run less frequently and that more time will be required to organise them.

Secondly, the proposed procedures are liable to lead to arbitrary deprivations of freedom of speech. Whilst I have no doubt that HM Government's intention in bringing forward this guidance as regulations alongside the proposed Counter-Terrorism and Security Bill are honourable in seeking to fight radicalisation and the terrorist threat in the United Kingdom, this must be done in a way that respects and upholds the important and universally recognised British value of freedom of speech. Forcing upon universities the responsibility for acting as arbiters of what may be said and what may not threatens this important value. In particular, universities' desire to achieve compliance is likely, in my view, to engender an excessively conservative approach to applying the guidelines which will mean preventing speakers from sharing ideas which are key tenets of Christianity (as well as other religions) when approached from a biblically-faithful perspective. It makes little sense for universities to be arbiters of free speech and it is unclear where they would develop the capabilities to do this efficiently and fairly and in a way that upholds religious exercise and freedom of speech. Another clear issue alongside this is why this kind of legislation is set to be applied to educational institutions and prisons and the like when we do not require religious places of worship to have pre-approved what they are going to teach - we usually provide freedom here out of a desire to uphold important rights as enshrined in Article 9 of the European Convention on Human Rights (as implemented in UK law by the Human Rights Act) and it seems a questionable and illiberal move not to extend these freedoms to an educational setting. Any attempt to implement the kind of guidance that is being suggested for religious societies in educational institutions in the context of religious places of worship would certainly be deplored by the public.

Thirdly, I do not believe that the guidelines proposed will be effective in achieving the Strategy's aims as outlined in point 4:

"The Prevent strategy has three specific strategic objectives:
• Respond to the ideological challenge of terrorism and the threat we face from those who promote it;
• Prevent people from being drawn into terrorism and ensure that they are given appropriate advice and support; and
• Work with sectors and institutions where there are risks of radicalisation that we need to address."

I believe that the proposed guidelines will be ineffective because the submission of summaries of content and presentations and like is simply not a fool-proof system, and will still require onerous monitoring to be effective, to the extent that the best response would be to require notice of speakers names and details (as suggested in Point 66) with only irregular evaluation of the substantive content of events. Whilst a society like the one in which I am involved in would be honest in its submissions to the university about what it is teaching, societies which wish to promote subversive and dangerous views which promote terrorism are unlikely to do so. There is nothing to prevent them from providing false information. Avoiding this will require resource-intensive monitoring and makes it unlikely that the proposed guidelines will achieve the goals of preventing the dissemination of ideologies which promote terrorism significantly better than an alternative without the need to submit outlines of topics, presentations, etc.

In conclusion, I do not believe that the procedures proposed for higher education institutions in Point 66 of the consultation will be effective in achieving the goals of the Prevent Strategy; they will require illiberal and arbitrary restrictions on freedom of speech and they will place an onerous burden on the valuable religious exercise of faith societies.

Please acknowledge receipt of my submission.

Yours faithfully,

Timothy Rogers

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