Guidance

Prevent duty: core standards for healthcare commissioners and providers

Published 3 October 2024

Applies to England

Introduction

Prevent is part of the government’s counter-terrorism strategy (CONTEST) and aims to reduce the threat to the UK from terrorism by stopping people becoming terrorists or supporting terrorism.

The Prevent duty under the Counter-Terrorism and Security Act 2015 requires specified authorities such as education, health, local authorities, police and criminal justice agencies (prisons and probation) to help prevent the risk of people becoming terrorists or supporting terrorism. Specified health authorities have a core role in leading health in multi-agency initiatives to counter terrorism at a local level and support people at risk of radicalisation.

The specified health authorities in England referenced in schedule 6 of the Counter-Terrorism and Security Act 2015 are:

• NHS trusts
• NHS foundation trusts

As set out in the Prevent duty guidance for England and Wales, all specified authorities must comply with the Prevent duty and will be expected to maintain appropriate records to show compliance with their responsibilities, as well as providing reports when requested. Within the NHS, the Prevent duty guidance for England and Wales sets out the expectation that local safeguarding forums, including local commissioners and providers of NHS services, have oversight of fulfilling the Prevent duty and ensuring effective delivery. This is also set out in the NHS safeguarding accountability and assurance framework.

The core standards have been designed to provide practical information to support commissioners and providers of NHS healthcare in their work to protect people who are vulnerable and/or susceptible to radicalisation. This guidance is intended for use by:

• NHS organisations
• commissioners of NHS services
• organisations working on behalf of the NHS
• organisations providing services for the NHS or NHS patients

It supplements the Prevent duty guidance for England and Wales and will assist in contracting in line with the NHS standard contract.

For more general information about the Prevent duty in healthcare, see Prevent duty: guidance for healthcare professionals.

Prevent governance in the NHS

Regional safeguarding leads (RSLs) are responsible for raising awareness of and promoting best practice in Prevent to commissioners and providers of NHS services. This includes supporting organisations with their Prevent policies, procedures and compliance, as well as delivering training.

How the standards work

It is critical for NHS organisations to demonstrate commitment to Prevent as a safeguarding priority. This is achieved through:

• visibility of risk and issues
• oversight of those at highest risk
• working with multi-agency partners to achieve effective outcomes

All commissioners and providers of NHS-funded healthcare are expected to have plans in place that demonstrate this commitment to Prevent.

The overarching standard, and core standards for commissioners and providers of NHS services below, provide a minimum benchmark for Prevent plans and should be followed to ensure effective Prevent delivery.

Overarching standard

Below is the overarching standard for commissioners and providers:

The organisation can clearly demonstrate visibility and oversight of delivery of the Prevent duty. Prevent is incorporated as business as usual within safeguarding processes and structures. 

The following sections, ‘Core standards for commissioners of NHS services’ and ‘Core standards for providers of NHS services’ set out the benchmarks that commissioners and providers should meet to ensure they’re meeting this overarching standard.

Core standards for commissioners of NHS services

In this document, ‘commissioners’ refers to integrated care boards (ICBs) in England.

Prevent leads

Commissioning boards will have a director level accountable Prevent lead who is responsible for providing assurance at board level.

Commissioning boards will have an operational Prevent lead responsible for delivery of the Prevent agenda.

The nominated Prevent lead will be integrated into the wider multi-agency Prevent leadership within their geographical area, connecting to:

• local Counter Terrorism Policing (CTP) leads
• local authority Prevent leads
• chairs of Channel panels (part of the Channel multi-agency support programme)
• Home Office leads
• other relevant strategic leadership forums, such as the NHS England regional Prevent forum

The Prevent lead will have a clear understanding of their leadership role across the geographical region.

The Prevent lead will identify a clear line of accountability to the commissioning board to enable notification of high-risk issues and escalation of concerns. They will also have a clear understanding of how this links to other safeguarding partnerships such as the children’s safeguarding partnership, adult safeguarding partnership, community safeguarding partnership and health and wellbeing boards, as needed.  

The Prevent lead will work with their healthcare providers across their geographical region to develop a community of practice for Prevent. They will support key partners to develop shared understanding of:

• roles and responsibilities
• accountability
• skills development
• required training
• threat management
• risk and issues oversight

The Prevent lead will be readily available to support providers from across the healthcare community in managing difficult and challenging issues. They will have up-to-date knowledge and skills to provide guidance and support to healthcare partners. They will also support the management of complex cases and conflict resolution, as needed.

Annual work programme

Commissioning boards will have an annual Prevent work programme.

The work programme will describe how the organisation will:

• undertake and maintain a training needs analysis to support the commissioning boards’ staff needs as well as support for wider providers across their area
• undertake a risk assessment to help inform decisions on the appropriate training requirements, as well as the broader management of risk both to and from people who may be susceptible to radicalisation into terrorism
• take account of changes to legislation, guidance and/or organisational, structural and staff changes
• identify how the organisation will engage with local Prevent delivery, including Channel, and contribute towards the local multi-agency Prevent partnership plan
• include measures to engage GPs and other primary care providers with Prevent

Prevent framework or policy

Commissioning boards will have an overarching framework or policy which sets out expectations of the organisation regarding Prevent.

The framework or policy will:

• have clearly linked policies, including, but not limited to, those related to human resources (HR) functions, estates and safeguarding
• have a process that takes account of changes affecting Prevent both organisationally and from a multi-agency perspective
• have clear Channel referral pathways for the commissioning board and for providers within their area
• include information sharing arrangements so that information flow is not obstructed within their area
• identify how specific Prevent concerns will be recorded
• have a clear process in place to identify escalation and/or referral of specific Prevent concerns
• set out how Prevent will be supported and monitored within provider contracts. This will include quality checks to ensure provider staff are appropriately trained and are accounting for Prevent alongside other safeguarding considerations

Reporting

The accountable Prevent lead will present a report on Prevent to the board and/or governing body on an annual basis (minimum).

The report will include information on all Prevent-related activity undertaken by the organisation. This includes any significant incidents and should confirm whether adequate resources are available for the organisation to meet the requirements of the core standards.

This report should be available to strategic leads - for example, the NHS England regional lead.

Lessons learned

Commissioning boards will work in multi-agency partnerships to develop a Prevent lessons learned group, supported by multi-agency partners.

The lessons learned group will:

• share anonymised Prevent cases so that learning is identified, creating a forum where learning is discussed and development across the partnership is agreed and implemented
• lead on how learning will be implemented to develop the wider healthcare system across their geographical area, potentially supporting regional and national learning as required
• have an expectation that a lessons learned case study should be undertaken around all referrals, to encourage shared learning with Prevent and safeguarding staff

Risk assessments and counter terrorism local profiles (CTLPs)

Commissioners will assess the risk around local impact and organisational Prevent compliance. This should include reflecting CTLP information in the work plan and should be reviewed annually (minimum).

Risk assessments will consider Prevent priority areas status, annual CTLP, CONTEST or Prevent delivery group issues and be linked with NHS emergency preparedness, resilience and response and NHS counter fraud authority agendas, where appropriate.

Information management

Commissioners will support multi-agency communication and information flow, ensuring this remains as efficient and effective as it can be.

Commissioners will work with partners to support the development of agreements, policies, procedures and/or processes to support timely risk management. 

Core standards for providers of NHS services

In this document, ‘providers’ refers to:

• NHS organisations
• organisations providing services for the NHS or NHS patients
• organisations working on behalf of the NHS

Prevent leads

Organisations will have a director level accountable Prevent lead who is responsible for providing assurance at board level.

Organisations will have an operational Prevent lead responsible for delivery of the Prevent agenda.

The Prevent lead will have a clear understanding of their leadership role within the organisation and to any locally managed contracts as needed.

The commissioner is kept informed at all times of the identity of the person holding the position.

The Prevent lead will work with their wider healthcare partners across their partnership area to support the development of a community of practice for Prevent. They will also support key partners to come together to develop shared understanding of roles and responsibilities, accountability, skills development, threat management and risk and issues oversight.

The Prevent lead will be responsive to Channel requests and work with multi-agency partners to respond to threats, risks and issues as required. They will ensure there are effective mechanisms in place for sharing information.

The Prevent lead will identify a clear line of accountability to the trust board to enable notification of high-risk issues and escalation of concerns.  

Annual work programme

Organisations will have an overarching framework or policy which sets out expectations of the organisation regarding Prevent.

The framework or policy will:

• have clearly linked policies, including, but not limited to, those related to HR functions, estates and safeguarding
• have a process that takes account of changes affecting Prevent both organisationally and from a multi-agency perspective
• include a Channel referral pathway
• include information sharing arrangements so that partners can be appropriately advised in a timely manner
• identify how specific Prevent concerns will be recorded
• have a clear process in place to identify escalation and/or referral of specific Prevent concerns
• ensure local contracts include quality checks, to ensure provider staff are appropriately trained and are considering Prevent alongside other safeguarding considerations

Reporting

The accountable Prevent lead will present a report on Prevent to the board and/or governing body on an annual basis (minimum).

The report will include information on all Prevent-related activity undertaken by the organisation. This includes any significant incidents and will confirm whether adequate resources are available for the organisation to meet the requirements of the core standards. This report will also be made available to the commissioning board. 

Lessons learned

Organisations are recommended to develop arrangements that include a case or referral review process to identify lessons learned and inform future arrangements.

Taking this approach, organisations would:

• share anonymised Prevent cases so that learning is identified. These can then be utilised within a wider learning group with the commissioning board
• have an expectation that a lessons learned case study should be undertaken around all referrals to encourage shared learning

Risk assessments and counter terrorism local profiles (CTLPs)

Organisations will assess the risk around local impact and organisational Prevent compliance. This will include reflecting CTLP information in the work plan and should be reviewed annually (minimum).

Risk assessments will consider Prevent priority areas status, annual CTLP, CONTEST or Prevent delivery group issues and be linked with NHS emergency preparedness, resilience and response and NHS counter fraud authority agendas where appropriate.

Information management

Organisations will be able to demonstate that there are clear guidelines and support for information management, information sharing and documentation. Prevent arrangements will include processes for requesting and sharing information where it is necessary to do so.

Organisations will have arrangements in place so that relevant timely information can be shared with partners when necessary. This should include clear guidance on how Prevent concerns are noted on patient records, and handed over when patients are transferred.

Organisations will have an information sharing protocol to share information about confirmed and potential Channel cases with relevant partners.

The protocol will include a process to:

• check for existing relevant records of the person who is under consideration for referral - for example, is the person known to the service or practice?
• inform staff as to what constitutes relevant information
• inform staff how to appropriately share information
• record the search made, the information shared or not shared and the rationale behind the supporting decision

Information governance policies will outline guidelines on areas of information management risk for the organisation such as:

• an IT policy that identifies inappropriate use by either patients or staff
• room hire by external organisations
• appropriate use of notice boards
• the distribution of inappropriate materials or leaflets

Prevent training programme

The Counter-Terrorism and Security Act 2015 places a duty on the organisations, or specified authorities, listed in schedule 6 of the act to prevent radicalisation. To do this, organisations should ensure all healthcare staff are trained to recognise where a person might be susceptible to becoming radicalised into terrorism. Ongoing monitoring of organisations’ Prevent data regarding training and referrals supports this. All healthcare staff should complete Prevent training in line with the expectations set out in the NHS Prevent training and competencies framework.

The healthcare sector must ensure that, where there are signs that someone has been or is being radicalised, NHS employees are trained to recognise those signs correctly. Training must include understanding the pathways for available support, including access to the Channel multi-agency support programme, where necessary. There are several supplementary Home Office Prevent duty training courses available.

The following guidance documents published by the Royal College of Nursing include Prevent information and identify competencies for all healthcare professionals against 6 levels:

• Safeguarding children and young people: roles and competencies for healthcare staff
• Adult safeguarding: roles and competencies for health care staff
• Looked after children: roles and competencies for healthcare staff

Prevent training is mandatory for all NHS trusts and foundation trusts. Training is also mandatory for NHS provider organisations, NHS commissioners and organisations providing services on behalf of the NHS, to meet contractual obligations in relation to safeguarding training. All healthcare professionals should receive annual updates and 3-yearly refresher training.

Training

Overarching standard for training

The workforce has received the appropriate level of training and understands their role in safeguarding vulnerable and susceptible people under the Prevent duty. This is set out in the NHS Prevent training and competencies framework.

How to meet the standard

The organisation will have effective arrangements in place to deliver basic Prevent awareness training, including approved e-learning packages. For more information, please see the NHS Prevent training and competencies framework.

The training will be in accordance with the organisational training needs analysis and aligned with the expectations of the NHS England Prevent training and competencies framework. 

The minimum compliance rate for training completion is 85%. The plan will demonstrate how the target of 85% trained staff has been or will be achieved.

The organisation will have a Prevent training delivery plan that describes how the organisation will:

• undertake and maintain a training needs analysis
• ensure all staff receive appropriate basic Prevent awareness training
• ensure there are sufficient trainers that meet the skillset requirements to access and deliver training using the Home Office Prevent duty awareness course materials according to the size of the organisation
• include refresher training delivery for all staff

The Prevent training needs analysis will be aligned to roles as specified in the NHS England Prevent training and competencies framework.

The organisation will be able to demonstrate how staff meet the criteria for basic Prevent awareness training, level 3 Prevent or face-to-face training.

Arrangements will include an ongoing training, support and development programme for the Prevent lead and safeguarding staff with a role in Prevent referrals.

The organisation will be able to demonstrate a training, engagement and development programme for Prevent lead staff.