Managing Disclosures of Pre-Existing Staff and Student Relationships
Purpose
The University of Wolverhampton's Personal Relationships Policy requires staff members to disclose pre-existing intimate relationships, familial relationships, and close friendships with students where the relationship falls within the scope of the policy.
As a line manager, you may be informed of such a disclosure and asked to support the completion of the associated risk assessment process.
The purpose of this guidance is to help managers approach disclosures consistently, professionally, and sensitively.
Key Principles
When a disclosure is made:
- Treat the disclosure confidentially.
- Approach the discussion without judgment.
- Focus on professional responsibilities rather than personal circumstances.
- Consider actual and perceived conflicts of interest.
- Prioritise safeguarding, fairness and transparency.
- Ensure any necessary controls are proportionate.
The existence of a pre-existing relationship does not automatically indicate wrongdoing.
The purpose of disclosure is to ensure appropriate safeguards are considered and implemented where necessary.
What Is My Role as a Line Manager?
Your role is to:
- Meet with the staff member.
- Understand the nature of the relationship being disclosed.
- Complete the University's Risk Assessment Form.
- Identify any actual or perceived conflicts of interest.
- Consider whether any safeguarding concerns arise.
- Agree on any appropriate management actions.
- Forward the completed documentation to the relevant HR Business Partner and safeguarding@wlv.ac.uk.
You are not expected to investigate the relationship or make judgments about the individual's private life.
Arranging the Discussion
The discussion should take place as soon as reasonably practicable following disclosure.
The meeting should be:
- private;
- respectful;
- supportive;
- focused on professional implications rather than personal details.
Managers should only seek information necessary to complete the assessment and determine whether safeguards are required.
Completing the Risk Assessment
The University's risk assessment form requires consideration of whether the member of staff is currently involved, or may become involved, in any aspect of the student's University experience.
This includes:
- teaching or learning activities;
- assessment and marking;
- pastoral support;
- academic decision-making;
- student selection processes;
- research supervision;
- non-academic activities;
- any other aspect of the student's University experience.
For each identified area, managers should consider:
- whether a conflict of interest exists;
- whether a conflict could reasonably be perceived to exist;
- What measures may be required to remove or manage the conflict?
Examples of Possible Management Actions
Depending on the circumstances, actions may include:
- allocating marking to another member of staff;
- removing involvement in progression decisions;
- transferring personal tutor responsibilities;
- changing supervisory arrangements;
- restricting access to confidential information;
- Recording the disclosure with no further action required.
The least intrusive and most proportionate approach should always be adopted.
Safeguarding Considerations
Whilst many disclosures will not raise safeguarding concerns, managers should remain alert to:
- significant power imbalances;
- professional boundary concerns;
- undeclared relationships that have existed for a period of time;
- concerns raised by third parties;
- evidence of coercion, exploitation, or abuse of power.
Where safeguarding concerns arise, advice should be sought immediately from the Safeguarding Team.
Managers should not attempt to investigate safeguarding concerns themselves.
Confidentiality
Information relating to disclosures should be handled sensitively and only shared with those who require access as part of the process.
Completed assessments should be shared with:
- the relevant HR Business Partner; and
- safeguarding@wlv.ac.uk
The staff member should also receive a copy of the completed assessment.
What If a Staff Member Is Unsure Whether Disclosure Is Required?
Managers should encourage disclosure.
Where uncertainty exists, it is generally preferable to disclose and seek advice rather than risk a failure to disclose a relationship that falls within the scope of the policy.
Advice can be obtained from:
- Human Resources; and/or
- safeguarding@wlv.ac.uk
Failure to Disclose
Failure to disclose a relationship that falls within the scope of the Personal Relationships Policy may result in:
- safeguarding review;
- conflict of interest assessment;
- formal investigation;
- disciplinary action where appropriate.
Managers who become aware of an undeclared relationship should seek advice from HR and the Safeguarding Team without delay.
Manager Checklist
□ Meet with the staff member promptly.
□ Complete the Personal Relationships Risk Assessment Form.
□ Consider actual and perceived conflicts of interest.
□ Identify and record any required management actions.
□ Consider safeguarding implications.
□ Share the completed form with the staff member.
□ Send the completed assessment to the relevant HR Business Partner and safeguarding@wlv.ac.uk.
□ Review arrangements periodically if circumstances change.
Remember
The purpose of disclosure is not to regulate private relationships.
It is to protect students, staff and the University by ensuring transparency, safeguarding, fairness and professional integrity.
Early disclosure and open discussion are almost always preferable to managing concerns retrospectively.