Imperial is committed to upholding the fundamental rights of lawful freedom of speech, and academic freedom (as defined in the Higher Education and Research Act 2017). In ensuring these rights are upheld, it is necessary to recognise the wider legal framework in which they operate. This Code of Practice and Events Procedure support free speech within the law.

1.1 Event: any activity or activities organised by students or staff of Imperial (“Events”), whether they are held on University premises, external premises (including outdoor spaces), or virtual spaces on online platforms. The Code applies equally to events (and associated advertising communications) where external speakers are present and those where no external speakers are present. This includes:

• • Debates, speeches, talks, public meetings
  • Receptions, seminars, lectures, exhibitions
  • Protests, demonstrations, rallies

1.2 Event Organiser: the individual responsible for the on-campus, off-campus or online event being organised.

1.3 External speaker: an individual or organisation who has been invited to speak at an event. who is not a current student or staff member at Imperial College London or the Imperial College Union.

1.4 Visitor(s): an individual or organisation invited to Imperial who is not a current student or staff member at Imperial College London or the Imperial College Union. This may include visiting researchers, visitors from partner organisations and consultants.

1.5 Working day: Monday to Friday not including bank holidays or University Closure Days.

1.6 Event Request Form: the formal record to be completed for each Imperial event where the conditions in paragraph 4.2 apply.

2.1 Freedom of speech is an important right for all in our community, but it is not an unqualified right. It is important to remember that a person’s right to freedom of speech means lawful freedom of speech. Whilst the starting point is that speech is permitted unless it is restricted by law (for example, there is a legal prohibition on supporting proscribed terrorist organisations), expression of views which amount to racial or religious hatred, incitement to violence or public disorder, harassment, or unlawful discrimination are examples of speech that is not within the law.

2.2 Whether speech (or other expressions, such as signs), are likely to be unlawful is often a question of judgement and will be context specific. It is a complex and evolving legal area, and so we encourage everyone in our community to engage in debate in respectful ways, always being mindful of the effect our words might have on others.

2.3 Imperial’s responsibility is to create an environment in which everyone feels safe, whilst ensuring we take into account all of our legal duties and the competing rights of all those involved. To assist us in this aim, staff and students are expected to adhere to the relevant Codes of Ethics and/or Conduct and Imperial’s Values when engaging in debates or expressing views. Staff and Students are expected to familiarise themselves with this Code (and the Events Procedure where needed), which are issued in pursuance of Imperial’s duties laid down in Section 43 of the Education (No 2) Act 1986 (see Annex A) in order to take the steps which are reasonably practicable to ensure that freedom of speech within the law is secured for students and staff of Imperial and for visiting speakers.

3.1 For the purposes of this Procedure, an “event” as defined in paragraph 1.1 may include staff, students, external speakers, visitors, or any combination of these that is held in any venue or location in the UK for which Imperial is directly responsible, permanently or temporarily, or hosted online on any Imperial provided platform (such as Teams or Zoom when using Imperial log in details). This includes external premises (including outdoor spaces) and events organised on a Imperial campus by third parties, e.g. those using the space on a commercial basis.

3.2 So far as is reasonably practicable freedom of speech within the law will be secured for students and staff of Imperial, and for any visiting speakers. Where events are held – whether or not visiting speakers are involved - approval for events will not be denied to any individual or body of persons proposing to hold a lawful meeting on any ground connected with:

1. The beliefs or views of that individual or that body; or
2. The policy or objectives of that body.

3.3 Imperial must take account of its wider legal obligations with regard to what is said at events which might lead to an infringement of the law, for example by incitement to violence or breach of the peace, incitement of racial or religious hatred, or which might otherwise transgress the bounds of lawful speech.

3.4 It is essential to the Mission of Imperial that opportunities for free and open discussion shall be safeguarded. Students and staff of Imperial, as well as all other persons attending events must refrain from acting in a manner likely to prevent or disrupt the purpose for which the event is held.

4.1 The Event Procedure applies to events as defined above. For events being organised by a student, student group or staff member within the Imperial College Union (ICU), the ICU Events Process must be followed. If an event organised by ICU members is to take place on the University’s premises (including outdoor spaces), the event will be subject to Imperial’s Code of Practice. Organisers of conferences should refer to this policy in conjunction with the Imperial’s Conferences Policy.

4.2 By the authority of the Council of Imperial the procedure set out below must be followed by students and staff of Imperial in respect of:

a) Events falling within those defined in paragraph 1.1 above and where any of the circumstances listed below apply:

Any event where there is a real likelihood that speakers and other participants may:

b) not be able to enter or leave the premises safely, and/or

c) breach the law as described in section 2, or otherwise and/or be unable to deliver speeches and participate in debate or discussion in good order, and/or

d) that a breach of the peace may occur.

Infringements of or departures from the procedures in whatever respect may render those responsible liable to disciplinary proceedings.

4.3 Additionally, if any such actions apparently involve breaches of the law the University authorities will decide whether to report the matter to the Police.

4.4 Imperial in establishing the Event Procedure appoints the Director of Legal and Regulatory Affairs on its behalf to ensure that, as far as is reasonably practicable, all students and staff of Imperial, visiting speakers and members of the public comply with the provisions of this Code.

4.5 Rooms and lecture theatres in Imperial buildings may be booked for events through various routes, including through the Conference & Events Office and through self-service booking systems. If a self-service booking is made for an event that falls within the circumstances outlined in paragraph 4.2 above, the event organiser has a duty to comply with the Event Procedure, including completing the Event Request Form.

4.6 The booking of outdoor spaces on Imperial campuses can be made via the Community Safety and Support Team by emailing: security.control@imperial.ac.uk. As is the case for all events taking place on Imperial premises, if the event falls within the circumstances outlined in paragraph 4.2 above, the event organisers for outdoor events shall ensure that at least ten working days’ notice of the proposed event is given via the Event Request Form (see Section 5).

4.7 In the case of rooms in the Union Building, bookings are normally made direct through the Imperial College Union Office. A booking for an event requested by staff or students of Imperial will generally be accepted if the invitation is made by:

a) An Imperial-based club, society or project recognised by Imperial College Union; or

b) A body otherwise recognised by the University or approved by a Head of Department or Director of Legal and Regulatory Affairs.  

4.8 Imperial has sole discretion about the acceptance of any booking requested by an outside organisation or a body that is not recognised by the University or Imperial College Union.

5.1 Organisers of an event which falls within the circumstances set out in 4.2 should complete the Event Request Form (link below), and refer the request to the Director of Legal and Regulatory Affairs. The organiser(s) shall ensure that a single person is appointed as principal organiser of the event for the purposes of the referral.

5.2 The Event organiser shall ensure that at least ten working days’ notice of the proposed event is given to the Director of Legal and Regulatory Affairs as the Council's appointed officer. This is to ensure that appropriate risk assessments can be undertaken. Notice shall be provided via the Event Request Form. Such notice shall contain a written statement of:

• The title of the event and brief summary of the event subject;
• The names of any speaker(s) and/or any high profile invited participant(s), and the details of the organisation(s) which each represent;
• Details of any organisations that the speaker is associated with (but not necessarily representing at the event);
• Whether the person(s) listed under (b) have attended an event at Imperial before and if so when (if known);
• Other establishments the person(s) listed under (b) have spoken at, attended before, when there have been incidents of protest, public order, illegal activities, significant publicity or where permission to speak has been refused;
• The date, time and proposed venue for the event;
• The precise timing of arrival and departure of the persons listed at (b);
• Details of any known security threats;
• Details of any personal security arrangements;
• Potential for controversial or illegal aspects of the talk or for the incitement of controversial or illegal actions;
• Potential for public order issues; such as details of any circumstances which may give rise to the possible concern about potential disturbance or otherwise preventing the event taking place peaceably, or that it is likely that the event will attract unauthorised attendance by the public or any section thereof, or that it may be picketed.
• Details of any known or likely media interest in the proposed event;
• Draft copy of the proposed notice, leaflet, social media or other material announcing or advertising the event and details of any proposed advertising campaign;
• Details of any members of the public who have either been invited to attend, or are expected to attend, the event (that are not listed at (b));
• The anticipated number of attendees;
• Details of any requested seating arrangements;
• Whether the event will be filmed or recorded, and how such recording may be distributed;
• Name, email address and telephone number of the principal organiser of the event and the name of the chairperson; and;
• For events in open/outdoor spaces, details of any consideration that has been given to keeping fire exits clear for surrounding premises and escape routes, minimising noise disruption and impact on other organised events etc. 

5.3 Within five days of receiving such notice, the Director of Legal and Regulatory Affairs (or their delegate), will provide written confirmation that either grants or withholds approval for the event; approval may be conditional, e.g. stipulating that the event shall take place in premises other than those proposed by the principal organiser. Events which fall within the scope of paragraph 4.2 shall be the subject of consideration by the Director of Legal and Regulatory Affairs for decision.

5.4 Permission to hold an event may be granted subject to such mitigations as the Director of Legal and Regulatory Affairs (or their delegate) considers reasonably necessary to secure the fulfilment of the University’s statutory responsibilities concerning the protection of freedom of speech within the law.

5.5 The principal organiser and every other person concerned with the organisation of any event for which permission has been granted shall be required to comply with any and every mitigation stipulated by the Director of Legal and Regulatory Affairs under the provisions of this Code and Procedure.  Such mitigations may include one or a number of requirements that:

• The public may not be invited or admitted;
• The audience may not include persons other than students and staff of Imperial;
• Admission be restricted and controlled by tickets, identity cards or both, or password protected for virtual events;
• If guests of attendees are allowed to attend only those whose identity is known to the organisers may be admitted. This may include use of an event platform where event tickets are booked using an Imperial email address and ID is checked upon arrival
• All advertising will be in the English language;
• Speakers shall enter and leave by specified routes and be escorted under specified arrangements to be made by the organisers;
• Conditions on seating arrangements may be made;
• An adequate number of stewards shall be available before, during and after the event as to whose suitability the Director of Legal and Regulatory Affairs must be satisfied; and/ or
• Additional security staff will be deployed to maintain good order at a cost which may be borne by the organisers.

5.6 Organisers have a duty to see that nothing in the preparations for or conduct of an event infringes the law, e.g. by conduct likely to cause a breach of the peace or incitement to illegal acts.

5.7 The chairperson of the event is required to secure as far as possible that both the audience and any speakers act in accordance with the law during the event. In cases of unlawful conduct the chairperson is required to give appropriate warning and in cases of continuing unlawfulness to require the withdrawal or removal of the person(s) concerned by the stewards or security staff, or to close the event and to call the police as necessary; or, in the case of a virtual event held on an online platform, to remove the person(s) concerned from the Chat and/or the Call.

5.8 No articles such as banners or objects which might be used as missiles may be taken inside the building where an event is taking place or taken or used elsewhere on the premises in circumstances likely to lead to injury or damage.

5.9 Premises and outdoor spaces used for events must be left in a clean and tidy condition in default of which the organisers may be charged for such additional cleaning and/ or repairs that are subsequently required. An advance deposit or evidence of ability to pay towards the costs may be required.

5.10 The mitigations prescribed by the Director of Legal and Regulatory Affairs (or their delegate) under paragraph 5.5 above and paragraph 5.11 below may include mitigations concerning admission or exclusion of press, television or broadcasting personnel.

5.11 In addition to the mitigations set out in paragraph 5.5 above, the Director of Legal and Regulatory Affairs (or their delegate) has discretion to stipulate further mitigations, if appropriate, dependent upon the size of the event and potential impact on safety, security, operations.. For example, the event may be designated public because of attendant circumstances (which would permit a police presence); arrangements may be made for Imperial staff to be responsible for all security arrangements connected with the event and to appoint a member of staff as “controlling officer” for the occasion. If not satisfied that adequate arrangements can be made to maintain good order the Director of Legal and Regulatory Affairs may refuse or withdraw permission for the event. Such a step would normally only be taken on the advice of the police. The Director of Legal and Regulatory Affairs will report the circumstances of such incident to the next meeting of the Council.

5.12 Appeals against the decision of the Director of Legal and Regulatory Affairs may be made to the Chief Operating Officer whose decision shall be final but must be reported to the next meeting of the Council.

5.13 Any complaints relating to freedom of speech or academic freedom may be lodged using Imperial’s complaints procedures.

5.14 Personal data processed under the procedures of this Code will be processed in accordance with Imperial’s Privacy Notice.

Review

5.15 The Code of Practice and Event Procedure will be subject to annual review and in the light of circumstances will be subject to amendment by the Council.

Annex A

The Education (No. 2) Act 1986, Section 43

(1) Every individual and body of persons concerned in the government of any establishment to which this section applies shall take such steps as are reasonably practicable to ensure that freedom of speech within the law is secured for members, students and employees of the establishment and for visiting speakers.

(2) The duty imposed by subsection (1) above includes (in particular) the duty to ensure, so far as is reasonably practicable, that the use of any premises of the establishment is not denied to any individual or body of persons on any ground connected with:

(a) the beliefs or views of that individual or of any member of that body; or

(b) the policy or objectives of that body.

(3) The governing body of every such establishment shall, with a view to facilitating the discharge of the duty imposed by subsection (1) above in relation to that establishment, issue and keep up to date a code of practice setting out:

(a) the procedures to be followed by members, students and employees of the establishment in connection with the organization
(i) of meetings which are to be held on premises of the establishment and which fall within any class of meeting specified in the code; and
(ii) of other activities which are to take place on those premises and which fall within any class of activity so specified; and

(b) the conduct required of such persons in connection with any such meeting or activity;
and dealing with such other matters as the governing body consider appropriate.

(4) Every individual and body of persons concerned in the government of any such establishment shall take such steps as are reasonably practicable (including where appropriate the initiation of disciplinary measures) to secure that the requirements of the code of practice for that establishment, issued under subsection (3) above, are complied with.

(5) The establishments to which this section applies are:

(a) any university; 

(b) any establishment which is maintained by a local education authority and for which section 1 of the 1968 (No. 2) Act (government and conduct of colleges of education and other institutions providing further education) requires there to be an instrument of government; and 

(c) any establishment of further education designated by or under regulations made under section 27 of the 1980 Act as an establishment substantially dependent for its maintenance on assistance from local education authorities or on grants under section 100 (1) (b) of the 1944 Act.

(6) In this section:
"governing body", in relation to any university, means the executive governing body which has responsibility for the management and administration of its revenue and property and the conduct of its affairs (that is to say the body commonly called the council of the university);
"university" includes a university college and any college, or institution in the nature of a college, in a university.

(7) Where any establishment:

(a) falls within subsection (5) (b) above; or 

(b) falls within subsection (5) (c) above by virtue of being substantially dependent for its maintenance on assistance from local education authorities; the local education authority or authorities maintaining or (as the case may be) assisting the establishment shall, for the purposes of this section, be taken to be concerned in its government.

(8) Where a students' union occupies premises which are not premises of the establishment in connection with which the union is constituted, any reference i n this section to the premises of the establishment shall be taken to include a reference to the premises occupied by the students' union.