Policies

PREVENT DUTY AND ANTI-RADICALISATION POLICY

Organisation: Boxology Limited
Trading names: Boxology® Academy and Boxology® Online
Company number: 10523458
Responsible person: Cathy Brown – Director and Designated Safeguarding Lead
Deputy Safeguarding Lead: Greg Williams – Director
Version: 2.0
Effective date: 3 August 2026
Review date: 3 August 2027, or sooner where legislation, guidance, CIMSPA requirements or activities change

1. Purpose

Boxology Limited is committed to safeguarding learners, participants, staff, tutors, volunteers and contractors from all forms of abuse, exploitation and avoidable harm, including the risk of being drawn into terrorism or supporting terrorism.

This policy explains how Boxology Limited will:

  • promote safe and respectful learning environments;

  • recognise concerns relating to radicalisation;

  • respond proportionately and without discrimination;

  • report concerns through appropriate safeguarding routes;

  • support learners who may be susceptible to radicalisation;

  • manage online, programme and partnership risks; and

  • meet applicable legal, contractual and CIMSPA requirements.

Prevent is treated as part of Boxology Limited’s wider safeguarding arrangements rather than as a separate disciplinary or surveillance process.

2. Status of the Prevent Duty

The Prevent Duty arises under the Counter-Terrorism and Security Act 2015 and applies to specified authorities and education providers that fall within the statutory scope.

Boxology Limited will comply with the statutory Prevent Duty where it applies directly to a particular activity or delivery arrangement.

Where Boxology Limited is not itself acting as a specified authority, it will nevertheless follow the relevant safeguarding principles as good practice and comply with any appropriate requirements arising from:

  • its work as an education and training provider;

  • CIMSPA partnership and endorsement requirements;

  • a contract or commissioning agreement;

  • work delivered for a school, college, local authority or other specified authority;

  • a HEADGUARD or community programme; or

  • another partner’s safeguarding arrangements.

The aim of Prevent is to stop people from becoming terrorists or supporting terrorism. It is based on early intervention and safeguarding.

3. Organisational identity and separation

Boxology® Academy and Boxology® Online are trading names of Boxology Limited.

Boxology Limited is legally and financially separate from:

  • HEADGUARD C.I.C., company number 16212678; and

  • any separate HEADGUARD Charitable Incorporated Organisation that may be registered in the future.

Boxology Academy Limited, company number 10803282, was dissolved on 25 June 2019 and has no current role. Current use of “Boxology Academy” refers to the trading brand operated by Boxology Limited.

Where Boxology Limited delivers training for HEADGUARD C.I.C. or another organisation, the written delivery arrangements should identify:

  • which organisation is responsible for the programme;

  • the applicable safeguarding and Prevent procedures;

  • the designated safeguarding contacts;

  • referral and information-sharing arrangements; and

  • responsibility for staff, venues, online platforms and participants.

Any future HEADGUARD CIO will require its own trustee-approved safeguarding and Prevent arrangements following registration.

4. CIMSPA alignment

Boxology Limited is a CIMSPA Training Provider Partner and delivers specific educational products that are endorsed and quality assured by CIMSPA.

This policy supports Boxology Limited’s responsibility to maintain safe and appropriate arrangements for its learners and its CIMSPA-endorsed provision.

Boxology Limited remains responsible for:

  • its learners and participants;

  • the conduct of its personnel;

  • safeguarding within its delivery;

  • staff awareness and training;

  • assessing and recording concerns;

  • making appropriate referrals; and

  • monitoring the effectiveness of this policy.

CIMSPA endorsement does not replace Boxology Limited’s safeguarding responsibilities or the role of the police, local authorities or other statutory services.

5. Scope

This policy applies to:

  • directors and staff;

  • tutors, assessors and coaches;

  • contractors and freelancers;

  • volunteers;

  • learners and members;

  • children and young people participating through approved programmes;

  • adults at risk;

  • parents, guardians and carers;

  • partner representatives; and

  • anyone acting on behalf of Boxology Limited.

It applies during:

  • face-to-face courses;

  • online courses and learning;

  • practical and written assessments;

  • workshops and events;

  • mentoring;

  • digital and social-media communication;

  • community programmes;

  • HEADGUARD programmes;

  • overseas projects; and

  • delivery commissioned by another organisation.

Boxology’s ordinary commercial professional courses are normally for adults. Children and teenagers may participate through specifically designed and approved HEADGUARD, school, community or partner programmes.

6. Definitions

Prevent

Prevent is part of the United Kingdom’s counter-terrorism strategy. Its purpose is to stop people from becoming terrorists or supporting terrorism.

Radicalisation

For this policy, radicalisation refers to a process through which a person may come to legitimise, support or become involved in terrorism or terrorist violence.

Susceptibility to radicalisation

Susceptibility means that circumstances, influences or personal factors may place someone on a pathway towards terrorism or supporting terrorism.

There is no single profile of a person who may become radicalised and no single pathway towards terrorism. Concerns must therefore be assessed individually and in context.

Extremism

For the purposes of this policy, concern about extremist ideas becomes relevant to Prevent where there is a credible connection to terrorism, terrorist ideology, support for terrorist violence or a pathway towards terrorist activity.

Holding strong, controversial, unpopular, political or religious views does not by itself establish a Prevent concern.

Terrorism

Terrorism has the meaning given by applicable UK law. Boxology staff are not expected to make legal determinations about whether an offence has occurred. Suspected criminal or immediate security concerns must be referred to the police.

7. Safeguarding principles

Boxology Limited will:

  • place safety and welfare first;

  • respond to concerns proportionately;

  • consider the individual circumstances of each person;

  • avoid stereotyping or profiling;

  • respect lawful freedom of expression, religion and belief;

  • challenge hatred, harassment and encouragement of violence;

  • take online and in-person concerns seriously;

  • distinguish safeguarding support from punishment;

  • protect confidentiality as far as reasonably possible;

  • record decisions and reasons;

  • share relevant information only where lawful and necessary; and

  • work with safeguarding and Prevent professionals where appropriate.

Prevent concerns must not be based solely on:

  • race or ethnicity;

  • nationality;

  • immigration status;

  • religion or lack of religion;

  • political opinion;

  • appearance or clothing;

  • disability;

  • mental health;

  • trauma history; or

  • association with a particular community.

8. Factors that may increase susceptibility

There is no checklist that can determine whether someone is being radicalised.

Factors that may contribute to susceptibility can include:

  • exposure to terrorist propaganda;

  • contact with people promoting terrorism;

  • grooming or manipulation;

  • social isolation;

  • a desire for identity, belonging or status;

  • personal or political grievances;

  • experiences of discrimination or injustice;

  • family or relationship difficulties;

  • trauma or significant loss;

  • transitions or major life changes;

  • coercion;

  • online echo chambers;

  • fascination with violence or mass-casualty attacks; or

  • a need for protection, purpose or acceptance.

These factors are not proof of radicalisation. Many people experience isolation, trauma, mental-health difficulties or identity concerns without becoming involved in terrorism.

Concerns must be based on the overall context and any credible connection to terrorism or terrorist-supporting ideology.

9. Possible indicators of concern

Possible indicators may include:

  • accessing or distributing terrorist propaganda;

  • expressing support for a proscribed terrorist organisation;

  • justifying terrorist violence;

  • expressing an intention to participate in terrorist activity;

  • encouraging others to support or commit terrorism;

  • attempting to recruit or groom others;

  • seeking instructions associated with terrorist activity;

  • becoming involved in extremist networks linked to terrorism;

  • repeated interest in weapons, attacks or mass violence combined with other concerns;

  • threatening people who reject a terrorist ideology;

  • significant behavioural changes accompanied by terrorism-related material;

  • concealing concerning online contacts or activity;

  • using symbols directly associated with terrorist organisations; or

  • expressing a desire to travel for terrorism-related purposes.

A single change in behaviour, belief, friendship, dress or internet use does not necessarily indicate radicalisation.

Official guidance confirms that there is no definitive checklist and that referrals must be based on relevant information and genuine concern about susceptibility to terrorism.

10. Freedom of expression, belief and respectful discussion

Boxology Limited supports lawful:

  • freedom of expression;

  • religious belief;

  • political discussion;

  • debate;

  • disagreement; and

  • critical examination of social issues.

Learners and staff must be able to discuss difficult or controversial matters without being treated as a safeguarding risk merely because their views are unpopular.

Freedom of expression does not include:

  • harassment;

  • threats;

  • intimidation;

  • encouragement of terrorism;

  • incitement to violence;

  • targeted hatred;

  • unlawful discrimination; or

  • deliberate creation of an unsafe learning environment.

Boxology Limited will seek to manage concerns without unnecessarily closing down legitimate discussion. Official Prevent guidance requires an appropriate balance between safeguarding, equality, data protection and lawful freedom of expression.

11. Online safety

Radicalisation may take place online as well as in person.

Boxology Limited will take proportionate steps to manage risks arising through:

  • online-learning platforms;

  • course discussion areas;

  • messaging groups;

  • social media;

  • livestreams;

  • shared digital resources;

  • external links; and

  • recorded content.

Staff, tutors and learners must not use Boxology platforms to:

  • distribute terrorist propaganda;

  • glorify or encourage terrorist violence;

  • recruit or groom others;

  • threaten or harass people;

  • share unlawful extremist material;

  • promote hatred or violence; or

  • direct others towards terrorist organisations or resources.

Staff must report concerning online activity to the Designated Safeguarding Lead and must not attempt to investigate private accounts or devices themselves.

Where material may be unlawful or connected to an immediate threat, it should not be unnecessarily copied, downloaded or redistributed. Advice should be sought from the police or appropriate authority.

12. External speakers, materials and events

Where Boxology Limited invites an external speaker, tutor, contributor or organisation, proportionate checks may be undertaken where there is a reasonable safeguarding or reputational risk.

Checks may include:

  • confirming identity and experience;

  • reviewing the proposed subject and materials;

  • clarifying the purpose and audience;

  • checking publicly available information;

  • agreeing appropriate conduct;

  • arranging supervision;

  • limiting recording or distribution; and

  • setting conditions for the event to proceed.

A speaker or event will not be restricted merely because the subject is controversial.

Boxology Limited may cancel, postpone or impose conditions where a credible risk cannot be managed, including a risk of:

  • terrorism-related recruitment;

  • encouragement of violence;

  • unlawful hatred;

  • serious harassment;

  • safeguarding harm; or

  • unlawful activity.

13. Staff responsibilities and training

All staff, tutors, assessors, contractors and volunteers must:

  • understand that Prevent is part of safeguarding;

  • remain alert to relevant concerns;

  • avoid assumptions and discriminatory profiling;

  • know how to report a concern;

  • record facts rather than speculation;

  • preserve confidentiality;

  • not conduct their own investigation;

  • complete appropriate safeguarding or Prevent awareness training; and

  • follow local or partner procedures where these apply.

Training should be proportionate to the person’s role and may include:

  • understanding Prevent;

  • recognising susceptibility to radicalisation;

  • online radicalisation;

  • notice, check and share principles;

  • referral procedures;

  • equality and freedom of expression;

  • information sharing; and

  • responding to disclosures or concerns.

Staff with safeguarding responsibilities should be familiar with the current government Prevent-awareness resources and relevant local referral arrangements.

14. Designated Safeguarding Lead

The Designated Safeguarding Lead is:

Cathy Brown
Director, Boxology Limited
Email: info@boxology.academy

The Deputy Safeguarding Lead is:

Greg Williams
Director, Boxology Limited

The Designated Safeguarding Lead is responsible for:

  • receiving Prevent concerns;

  • assessing the available information;

  • checking whether there is a credible terrorism-related concern;

  • considering other safeguarding needs;

  • obtaining advice where required;

  • deciding whether a referral is appropriate;

  • making or coordinating referrals;

  • recording the concern and decision;

  • liaising with partner safeguarding leads;

  • ensuring confidentiality and lawful information sharing;

  • supporting staff; and

  • reviewing recurring risks or training needs.

Where a concern relates to Cathy Brown, it should be reported to Greg Williams or directly to the appropriate external authority.

Where a concern relates to both directors or cannot safely be reported internally, the concern should be raised directly with the police, local-authority Prevent team or other appropriate safeguarding service.

15. Reporting a concern

A concern should be reported to the Designated Safeguarding Lead as soon as reasonably possible.

The report should include:

  • the name of the person concerned;

  • the date, time and location;

  • what was seen, heard or disclosed;

  • the person’s own words where possible;

  • the specific reason the concern may relate to terrorism or radicalisation;

  • any relevant online activity;

  • the wider context;

  • any immediate safety risk;

  • witnesses or other relevant people;

  • action already taken; and

  • the reporter’s name and contact details.

The person reporting should:

  • remain calm;

  • listen carefully;

  • avoid leading or accusatory questions;

  • not promise complete confidentiality;

  • not confront suspected recruiters or associates;

  • not attempt to seize or search a device;

  • not undertake surveillance;

  • preserve relevant evidence safely; and

  • report facts rather than rumours or assumptions.

A concern does not need to be proven before it is reported.

16. Assessing and responding to concerns

The Designated Safeguarding Lead will consider:

  • the specific behaviour or information causing concern;

  • whether there is a credible terrorism-related element;

  • the source and reliability of the information;

  • the person’s circumstances;

  • whether another form of harm or exploitation may be involved;

  • whether discrimination or misunderstanding may explain the concern;

  • the urgency and seriousness of the risk;

  • whether specialist advice is needed;

  • whether another safeguarding route is more appropriate; and

  • whether a Prevent referral is necessary and proportionate.

Possible responses include:

  • recording the concern with no further action;

  • speaking with the person in an appropriate way;

  • seeking further factual information;

  • providing ordinary learner or wellbeing support;

  • consulting a partner safeguarding lead;

  • obtaining advice from a local Prevent team;

  • making a referral to children’s or adult services;

  • making a Prevent referral;

  • contacting the police; or

  • taking immediate protective action.

The Designated Safeguarding Lead must not attempt to determine whether the person is guilty of terrorism or conduct a counter-terrorism investigation.

17. Prevent referrals and Channel support

Where there is a genuine concern that someone may be susceptible to becoming involved in terrorism or supporting it, the Designated Safeguarding Lead may seek advice or make a Prevent referral through the relevant local route.

The police initially assess Prevent referrals to determine:

  • whether there is an immediate security threat;

  • whether there is a genuine terrorism-related concern;

  • whether Prevent is the appropriate route; or

  • whether another form of support is more suitable.

Where the Prevent threshold is met, the person may be considered for Channel, a multi-agency early-intervention programme.

Channel support is voluntary. Consent is required before support is provided, normally from the person or, for someone under 18, their parent or guardian, subject to safeguarding and capacity considerations.

A referral does not mean that:

  • an offence has been committed;

  • the concern has been proven;

  • the person will automatically enter Channel;

  • the person should be disciplined; or

  • the person should automatically be excluded from a course.

Boxology Limited will cooperate with relevant professionals while continuing to consider the person’s welfare and any appropriate ordinary safeguarding support.

18. Immediate danger or suspected criminal activity

Where there is an immediate danger to life, an imminent threat, a weapon, suspected attack planning or urgent criminal activity:

Call 999 immediately.

Where the concern is not an immediate emergency but may involve terrorism-related criminal activity, advice should be sought from the police through the appropriate non-emergency or counter-terrorism reporting route.

Staff must not:

  • confront a person believed to present an immediate risk;

  • attempt to disarm anyone;

  • search belongings without lawful authority;

  • independently investigate criminal conduct; or

  • circulate sensitive details unnecessarily.

19. Confidentiality and information sharing

Prevent information will be handled in accordance with the Boxology Limited Privacy Notice and Safeguarding Policy.

Information will be:

  • accurate and relevant;

  • limited to what is necessary;

  • shared only with people who have a legitimate reason to receive it;

  • stored securely; and

  • retained in accordance with applicable record-retention arrangements.

Information may be shared without consent where there is an appropriate lawful basis and sharing is necessary and proportionate to:

  • protect the person or another individual;

  • prevent serious harm;

  • obtain safeguarding or Prevent advice;

  • make a lawful referral;

  • assist the police;

  • comply with a legal obligation; or

  • respond to an immediate threat.

Absolute confidentiality cannot be promised.

Information will not automatically be shared between Boxology Limited, HEADGUARD C.I.C. and any future HEADGUARD CIO. The receiving organisation must have a legitimate role and lawful basis for receiving it.

20. Records

Prevent concerns and decisions will be recorded accurately.

Records should include:

  • the original concern;

  • factual information received;

  • the reason the matter was or was not considered relevant to Prevent;

  • advice obtained;

  • the decision made;

  • action taken;

  • information shared;

  • the lawful and safeguarding reason for sharing;

  • any referral;

  • follow-up action; and

  • the date the matter was reviewed or closed.

Prevent and safeguarding records should be stored securely and separately from ordinary learner records where appropriate.

A referral that does not progress must not be treated as proof that the person posed a terrorism risk.

21. Equality and protection from unfair treatment

Boxology Limited will not tolerate:

  • Islamophobia;

  • antisemitism;

  • racism;

  • religious hatred;

  • discrimination;

  • harassment;

  • homophobia;

  • transphobia;

  • hostility based on nationality or immigration status; or

  • any other unlawful discrimination.

A person will not be treated unfairly merely because:

  • a concern was reported about them;

  • a Prevent referral was considered;

  • a referral did not progress;

  • they received voluntary support;

  • they raised a concern in good faith;

  • they hold a lawful religious or political belief; or

  • they belong to a particular community.

Any decision affecting participation, employment or access must be based on evidence, safety and the applicable policy rather than assumptions.

22. HEADGUARD, community and partner programmes

Where Boxology Limited delivers within a HEADGUARD or partner programme, safeguarding and Prevent arrangements must be confirmed before delivery.

The written arrangements should identify:

  • the local safeguarding and Prevent contacts;

  • the person responsible for referrals;

  • the role of Boxology Limited;

  • the role of HEADGUARD or the partner;

  • participant supervision;

  • online and social-media controls;

  • information-sharing arrangements;

  • emergency procedures; and

  • reporting requirements.

HEADGUARD programmes delivered by Boxology are safe, trauma-informed, non-contact and non-clinical.

A participant’s trauma history, displacement, experience of war, religion, nationality or immigration status must not itself be treated as evidence of radicalisation.

23. Overseas delivery

The UK Prevent Duty does not automatically apply in the same way to activity delivered overseas.

However, Boxology Limited will continue to apply proportionate safeguarding, professional-boundary and anti-exploitation standards.

Before overseas delivery, Boxology Limited and the responsible partner should consider:

  • local law and security advice;

  • local safeguarding arrangements;

  • risks of violence or extremist activity;

  • safe venues and transport;

  • communication and emergency procedures;

  • local referral options;

  • staff conduct;

  • online and media risks;

  • confidentiality; and

  • the safety of participants, staff and partners.

Boxology Limited will not conduct counter-terrorism investigations overseas. Any credible security concern will be referred to appropriate authorities or professional advisers.

24. Breaches of this policy

A breach of this policy may be considered under the relevant:

  • Safeguarding Policy;

  • Complaints Policy;

  • Malpractice and Maladministration Policy;

  • staff or contractor procedure;

  • learner code of conduct; or

  • partner agreement.

Possible action may include:

  • additional training;

  • increased supervision;

  • restriction of platform access;

  • removal of unlawful material;

  • suspension from an activity;

  • ending a contractual or volunteer relationship;

  • referral to a partner;

  • safeguarding action; or

  • reporting to an appropriate authority.

A person will not be sanctioned merely because a safeguarding concern was raised about them. Any decision must follow a fair and proportionate process, subject to immediate protective action where required.

25. Monitoring and review

Boxology Limited will monitor:

  • Prevent concerns and outcomes;

  • online-safety incidents;

  • training completion;

  • patterns of discriminatory reporting;

  • weaknesses in partner arrangements;

  • external-speaker risks;

  • safeguarding and referral practice; and

  • relevant changes to legislation, government guidance and CIMSPA requirements.

This policy will be reviewed at least annually and sooner where:

  • Prevent legislation or guidance changes;

  • CIMSPA requirements change;

  • Boxology’s activities change;

  • a significant concern or incident occurs;

  • HEADGUARD or partner delivery changes;

  • an internal review identifies a weakness; or

  • new online or operational risks emerge.

26. Contact

Designated Safeguarding Lead: Cathy Brown
Deputy Safeguarding Lead: Greg Williams

Boxology Limited
Trading as Boxology® Academy and Boxology® Online
Company number 10523458
Registered office: Brook Cottage, High Street, Paulerspury, Towcester, England, NN12 7NR

Email: info@boxology.academy

27. Related policies

This policy should be read alongside the Boxology Limited:

  • Safeguarding Children and Adults at Risk Policy;

  • Equality, Diversity and Inclusion Policy;

  • Privacy Notice and Data Protection Policy;

  • Complaints Policy and Procedure;

  • Malpractice and Maladministration Policy;

  • Online Terms and Conditions; and

  • Legal Identity and Organisational Separation Statement.

 
 

Boxology® Company number 10523458