Dr Anna Bull discusses the Office for Student’s E6 requirements and addressing harassment and sexual misconduct in PGE

Dr Anna Bull is a Senior Lecturer of Education and Social Justice at the University of York and a founding member of The 1752 Group. Her research focuses on gender and class inequalities in music education and higher education. She led the study, Higher Education After #MeToo, and worked with the National Union of Students on behalf of The 1752 Group in producing the report ​‘Power in the Academy: staff sexual misconduct in UK higher education’ in April 2018. In 2021, industry publication Times Higher Education named her as one of their ​‘Faces of 2021’, noting that her research ​‘has made a substantial contribution to our understanding of the problem’ of sexual misconduct in universities. 

The 1752 Group is a research and campaigning organisation that addresses sexual misconduct in higher education. The 1752 Group is partnering with the UK Council for Graduate Education — supported by funding from the Enhancing Research Culture fund at the University of York — to produce a toolkit for higher education institutions setting out what these requirements mean for postgraduate researchers and supervisors. From August 2025, all higher education institutions in England will be required by the regulator, the Office for Students, to comply with a set of conditions around tackling harassment and sexual misconduct.

With the Office for Students recent publication of E6 – which comes into effect from the 1st of August 2025 – could you provide a summary of what will be required of Higher Education Institutions (HEIs) come August?

The new regulations include a range of requirements for higher education institutions relating to addressing harassment and sexual misconduct. These include stipulations on training, which needs to be in place for all staff and students so that they can recognise harassment and sexual misconduct and so that they’re aware of what the institution has in place to tackle this issue. It also includes specialist training for staff involved in dealing with disclosures and reports. 

There are also requirements for HEIs to prevent abuses of power between staff and students. This is something that we at The 1752 Group have been researching and writing about for years; our research report with the National Union of Students back in 2018, Power in the Academy, found that most students, particularly women students, are uncomfortable with staff and relationships with students. So, we are very pleased to see the regulator require HEIs to need to take steps to prevent abuses of power, which could be, for example, a policy prohibiting staff-student relationships. 

E6 also includes various other stipulations, for example, making sure that all prospective and current students can easily access information about how their institution is addressing harassment and sexual misconduct. In addition, as of August 2024, HEIs must not use nondisclosure agreements for students in cases of harassment and sexual misconduct. 

HEIs must also ensure that appropriate support services are available for students who experience harassment or sexual misconduct; that there are effective and fair reporting mechanisms; and that institutions share decisions at the end of an investigation with students who are affected by those decisions. 

You are currently working on a toolkit for Doctoral Deans and Directors in partnership with us at the UKCGE. Can you say a bit about what you hope to achieve with that toolkit?

We need to make sure that PGRs aren’t forgotten about when institutions are implementing their requirements for E6. It’s a huge ask for institutions to train all staff and students and to put in place these requirements, and there’s a danger that the focus will be on undergraduate and postgraduate taught students, and that PGRs will be side-lined.

PGRs, of course, have quite different needs and experiences of higher education than other student groups. They also have different experiences of harassment, for example, they’re more likely to be targeted for harassment from staff than other groups of students. They are also more at risk of harassment from people outside the institution, whether that’s at conferences, external mentors, or others in their disciplinary communities, so there are some distinct issues that need to be addressed.

The toolkit is aimed primarily at Doctoral Deans and Directors, as well as PGR leads within departments or Schools, to upskill them about what should be in place for PGRs under the new regulatory requirements from the Office for Students. We hope that the toolkit will also be useful for staff in student services or HR who are responsible for implementing these requirements, to help them think through what’s needed from the perspective of PGRs. The toolkit will also be useful in opening conversations between Deans and Directors, and central student services and HR staff.

Ultimately, the goal of this toolkit is to make harassment and sexual misconduct less likely to happen for PGRs, but when it does occur, to ensure that they’re supported, and that institutions are ready to handle it.

In all sectors, but in HE in particular, defining what constitutes harassment and sexual misconduct is really challenging. Could you please describe what constitutes harassment and sexual misconduct within the HEI sector? Do you think there are misconceptions in the sector about harassment and sexual misconduct?

The Office for Students has chosen a slightly narrower formulation of harassment and sexual misconduct than they might have done. Harassment refers to harassment on the basis of all protected characteristics under the Equality Act: that could be sexual harassment, racial harassment, harassment on the basis of gender identity, sex, sexuality, faith, disability, or age.

As well as this, sexual misconduct is explicitly named in the regulatory requirements. According to the Office for Students, this includes sexual violence and stalking and, of course, sexual harassment. We would have preferred a broader term such as gender-based violence to ensure that, for example, domestic abuse would be explicitly covered. In the toolkit, we recommend that a broad approach to defining sexual misconduct is taken, and indeed many HEIs are addressing domestic abuse as part of their implementation of E6.

The most problematic misconception in the sector about harassment and sexual misconduct is perhaps that it’s rare. In fact, just thinking about sexual misconduct and sexual harassment alone, this affects thousands, possibly even tens of thousands of postgraduate researchers each year. We don’t have great data on this in the UK, but internationally, around 15% of postgraduate students experience sexual harassment every year — we don’t have specific data on the prevalence among PGRs. And racial harassment, again, we don’t have data specifically for PGRs, but the ​‘Universities Challenged’ report from the Equality and Human Rights Commission from 2019 documented the extent and impacts of racial harassment in higher education. It’s not rare, unfortunately.

Another misconception is assuming that behaviours such as verbal harassment are not serious. In fact, it is well documented that so-called ​‘low-level behaviours’ such as verbal harassment or unwanted sexual attention led to deleterious impacts such as post-traumatic stress disorder, and people having to leave their institution, change programs, or change supervisors, among other impacts.

In addition, it’s crucial to be aware that these behaviours are almost never a one-off; they tend to be repeated. So, we are talking about ongoing experiences of degrading, humiliating behaviour that wear people down and signal to them they don’t belong, and that they shouldn’t be here.

You recently had two articles come out with Dr Erin Shannon on reporting and the processes surrounding reporting. Could you please speak to how institutions can better support reporters and why issues around disclosures might arise?

This issue of how to handle formal reports of sexual misconduct, in particular, has been on HEIs’ radars most recently in 2016 when the Changing the Culture report was produced by Universities UK which included guidance on handling formal reports. But of course, HEIs have had formal legal obligations under equalities legislation since the 1970s, and in relation to sexual harassment, since the 1980s when this issue was first dealt with in case law in Great Britain. It is not as if these duties are new. But we’re still seeing many institutions really struggling to handle these reports, sometimes because this work isn’t an institutional priority and there isn’t a commitment to it from senior leadership; sometimes because reports are very complex; or simply because the institution doesn’t have staff with relevant skills and expertise or these staff aren’t being appropriately supported to enable them to carry out this demanding, difficult work. Particularly for staff-student cases, effective systems to handle reports aren’t always in place. In the current financial climate, these challenges are of course exacerbated.

The good news is that we’ve seen an increase in professionalism over recent years with many HEIs hiring specialist staff, particularly in student services, but also in HR departments. But this is still a work in progress. My research has shown that systems for handling reports are still, in many HEIs, in development, and work in this area is very uneven across the UK.

So how can institutions better support reporting parties? This is a complex area. Institutions need to be prepared; I like to use the analogy of disaster planning in relation to preparing for how complex, high-profile reports are going to be handled. Given the level of harm and fall-out that can eventuate from such reports, putting some resources into disaster planning is, I think, justified.

In the toolkit we’ve got some examples of good practice. For example, Cambridge University has recently introduced the option of ​‘university-instigated investigations’ as part of its staff Dignity at Work policy. This means that the university doesn’t have to wait for a formal report for the university to open a formal investigation. This is particularly important for PGRs because they are more likely to experience harassment from staff, and PGRs often don’t report staff because – as they assume correctly – they are at risk of victimisation if they report. HEIs are unfortunately not good at protecting reporting parties from victimisation. So, we need HEIs to take some of that risk and responsibility from students or people who have been harmed and carry it themselves. One way in which that can happen is through this idea of university-instigated investigations.

Another good practice example comes from University of Bath, who are implementing some steps to make reporting processes fairer, for example, sharing the investigation report with the reporting party – which, unbelievably, doesn’t necessarily happen – and continuing an investigation to the conclusion even when a staff member leaves during it.

It’s good to see that more HEIs are taking this work seriously, but there remain significant challenges and unfortunately, we are also still seeing people who report harassment and misconduct to their institution being deeply harmed by the reporting process.

How can supervisors better support their PGRs who might be experiencing harassment or sexual misconduct?

The biggest thing that supervisors can do is know the institutional processes and use them, or if they are ineffective, lobby to improve them.

From August 2025 mandatory training should be in place for all HE staff in England on addressing harassment and sexual misconduct. This means that staff will be upskilled in understanding institutional systems for handling this issue. HEIs should also have in place specialist support for students sexual misconduct, although this is not necessarily in place for racial harassment or other forms of harassment, unfortunately.

Supervisors should first and foremost try and use those existing systems. If those systems aren’t working, which unfortunately is sometimes the case, the toolkit gives Deans and Directors and PGR leads within departments the tools to ask questions of HR and student services to find out where the institutional practice is at and support improvements. Deans and Directors and PGR leads may sometimes need to become activists in their own institution to push for the changes that are needed. But in an ideal world where when a student is experiencing harassment or sexual misconduct, there will be the systems in place in the institution to support that student and to make sure the issue is addressed.

The other thing that supervisors can do, which institutional training should cover, is to know how to recognize harassment and sexual misconduct. Nearly eight years after #MeToo, you’d assume that people now recognize sexual harassment when it occurs, or five years on from the Black Lives Matter movement that people would recognize racial harassment. That’s not always the case. A common experience is for something to happen that’s described as ​‘annoying’, ​‘weird’, or ​‘uncomfortable’ but people – including staff — do not necessarily know how to label these experiences. Supervisors, if they’re able to recognize and label harassment or sexual misconduct, can help with making sure that PGRs get support and advice.

What are a few ways staff, supervisors, and practitioners in HEI can better support the PGRs within their institutions on top of the regulatory requirements set out in E6? What steps can supervisors take to better enact good professional boundaries with their PGRs?

The Office for Students E6 requirements should be a work in progress; no HEI is going to be in a position where this is all done and dusted as of 1st August 2025. On top of this, another regulatory requirement came into force in October 2024, the Worker Protection Act, which means that all employers have a duty to prevent such sexual harassment in the workplace for employees. If PGRs are also working for their institution, that applies to them. So, we are seeing a sea change in how HEIs are required to tackle harassment, which should be leading to substantial changes – and ongoing reflection and shared learning – across the sector.

In the toolkit we’ve outlined ways that institutions can go beyond a simple compliance approach to take seriously their duties to prevent and respond to harassment and sexual misconduct. One of the ways that we’d really like to see cultures shift is towards more discussion of professional boundaries, particularly between staff and students. The Office for Students regulation talks about professional boundaries only in terms of staff-to-student intimate relationships; it suggests they could potentially be prohibited. But we need to think about professional boundaries much more broadly.

Our research has found that PGRs and other students can be subject to boundary blurring behaviours from staff, which they often label as ​‘grooming’. These behaviours can then escalate to sexual misconduct.

We’ve also found that Black and other racially minoritised students prefer to have clearer personal boundaries with academic staff than white students, which might include not meeting outside office hours or not having meetings that involve alcohol, for example.

We’d like to see more discussion of these wider ​‘boundary’ issues. We’d like to see staff participating in discussions about what professional boundaries mean in their department or in their disciplinary community. This should be a combination of a top-down institution-wide approach, alongside a bottom-up approach that draws on perspectives from staff and PGRs across the institution, to ensure that everyone is heard and invested in these discussions. When we’ve run training for PGR supervisors and PGRs in this area, we always find that people have thought a lot about professional boundaries because they’re having to negotiate these issues in their professional practice as supervisors, or for PGRs, in their relationships with supervisors. But these reflections are happening individually; there are rarely spaces within institutions or disciplines to develop a shared, communally-held understanding of professional boundaries.

We know from other professions, such as social work, that professional boundaries are most effective when they are shared across a community. In the toolkit, in order to facilitate this, we have included a discussion guide for PGRs and PGR supervisors, which can be used within departments to open discussions and hopefully feed into institution-level work in this area.

It’s important to add that professional and disciplinary societies also have a role to play in this work. To this end, the toolkit includes a case study from the Royal Geographical Society to show the excellent work that’s been done by them in this area.

What’s one step that urgently needs to happen to address harassment and sexual misconduct experienced by PGRs?

One of the areas that I’m appalled that we haven’t seen more progress in recent years is around what is sometimes called ​‘pass the perpetrator’. This is the idea that a staff member can be reported for sexual harassment or other forms of abuses of power, can be investigated, with an upheld finding, and they then leave their job and get another job either during or after the investigation. We’ve seen cases of people trying to share information about these kinds of cases with the hiring institution and then being sued for defamation simply for sharing information in an attempt to keep other students and staff at the new institution safe. That’s the situation we are still in today. We are still seeing staff moving between institutions during and after investigations with absolute impunity because we do not have safe hiring practices in higher education.

Luckily, we have got a ready-made solution for higher education institutions internationally for this issue — and it has to be international because academia is international – the Misconduct Disclosure Scheme. The Misconduct Disclosure Scheme was set up in 2018 in the humanitarian sector after the Oxfam scandals at that time.

The Misconduct Disclosure Scheme is open to all employers. It’s already got over 200 international organisations signed up to it and all it asks is that employers commit at the point of hiring to asking whether there are any ongoing or upheld disciplinary findings relating to sexual misconduct for staff and then to providing that information to other employers about your own staff. It’s free to join. It doesn’t commit institutions to any steps on receiving this information; they can decide what they’re going to do if they receive information about staff that they may be hiring.

My research project, Higher Education After #MeToo, found that, even in a relatively small-scale study, the most common outcome of a disciplinary investigation or a complaint process was the reported party leaving the institution during the investigation. So, this is problematic that we haven’t tackled this yet. I’d love 2025 to be the year where we finally stopped passing-the-perpetrator.