New Zealand Broadcasting School (NZBS) Investigation

Ref

Recommendation

Actions Completed

1.1

The NZBS should introduce a professional development component for tutors which enables them to spend time in their respective industries on an annual basis. This is to ensure tutors stay abreast of the current workplace environments within the industry. From my perspective, this is in relation to prevailing practices concerning the culture of the main media organisations (including health and safety, and staff wellbeing). I am not recommending this in relation to tutor skill sets for the respective crafts. It is intended to address the often-reported refrain of “that is how it is in the industry”. Staff need to therefore keep fully abreast of the changes in the industry and all recent developments.

The NZBS Programme Manager and Head of Department are rolling out modified professional development plans for NZBS tutors. These plans will include time for tutors to spend in industry on an annual basis, with an emphasis on understanding current cultural and wellbeing practices.

1.2

Ara should ensure that the above recommendation is properly funded by Ara to allow this to occur and ensure that time is made available to each tutor to complete this on an annual basis. I am not making recommendations as to how this would be structured or how long it should take, as it is likely to be different for each tutor/area of specialisation.

Ara has a provision for professional development funds in collective agreements.
The revised NZBS Professional Development Plan has been incorporated into department work plans and is budgeted for 2023. This practice will be ongoing.

2.1

Staff should undertake compulsory training in relation to diversity and inclusion, in particular in relation to the LGBTTQIA+ community. I understand Ara offers diversity and inclusion training through external partners, but it appears to be optional whether or not staff complete it.

All kaimahi are now required to complete a diversity and inclusion online training module. This is a comprehensive module taking an all-inclusive, holistic approach to diversity, rather than a focus on a single aspect of inclusion. 

2.2

To the extent it is not already available, cultural mentoring should also be provided to staff to allow them to engage appropriately with Māori and other cultures. I understand significant steps have already been made in this area with Ara having, in the last six months, set up a dedicated team led by Ara’s Executive Director Treaty Partnerships. I am advised that this team is focused on building cultural capability across Ara and is available to support NZBS in developing the team’s capability.

Cultural mentoring is available to assist kaimahi to appropriately engage with and support Māori learners. Capability development is ongoing, together with the design and implementation of a Māori Achievement Plan (MAP).

2.3

Staff should be provided with training in relation to how to appropriately respond to a student who presents or approaches a staff member with mental health issues. This must include providing clear and direct information to the student on the Ara Support Services available to students as well as providing information on the support services available in the wider community.

Kaimahi can access ‘how to respond to psychological distress in ākonga’ training (provided by the Mental Health Education & Resource Centre). The training includes what may be triggering events for learners and how to respond. This has been embedded into training material.
Ara support services work with departments on an ongoing basis to ensure colleagues know how to provide information to learners. External support services are communicated to students through the different channels such as MyAra.

2.4

Staff training should include education in relation to identifying what may amount to a triggering event for some students from the proposed course content or lecture, including guest lectures (there was evidence of this concern, which I have not addressed above in the body of the report due to privacy and confidentiality issues).

Kaimahi can access ‘how to respond to psychological distress in ākonga’ training (provided by the Mental Health Education & Resource Centre). The training includes what may be triggering events for learners and how to respond. This has been embedded into training material.

3.1

I recommend that Ara continues to review and take steps to improve the mental health and wellbeing services offered by Ara. It is apparent from the many reports of being unable to access support and the demand for mental health support, that this continues to be an issue. In this regard I acknowledge that Ara may be constrained in its efforts to some degree by the current issues facing New Zealand in relation to the lack of access to mental health and wellbeing services generally.

A review of mental health services and demand has been completed.
Ara mental health services have been supplemented with a social worker, online counselling and psychological services, and after-hours evening counselling sessions.
Significant effort has gone into informing learners about support services, including enhancing and updating the website and MyAra. Updates include a directory of student support information and links to resources.
The MyAra application now includes a photograph and information about each of Ara's support people.

4.1

Guidelines for students should be developed with regard to expected student conduct and the consumption of alcohol at both formal and informal events associated with the NZBS, including, for example, at internship provider drinks and dinners (formal) or class drinks (informal). This should be made clear to students in the Learners Responsibilities and Rights Policy which currently provides that students are to “ensure you are not intoxicated or under the influence of drugs when at Ara or involved in Ara related activities, e.g., field trips”. This should be more clearly articulated and include a wider range of anticipated activities where this requirement is to be observed. The Students Rights and Responsibilities document on the MyAra App also requires this amendment. It should also be clearly articulated in the BBc Programme Handbook.

Guidelines for learners have been developed and are included in the learner orientation process.
The APP301 Learner Responsibilities and Rights Policy and handout have been updated and are now available via the MyAra App.
The 2023 BBC Programme Handbook has been updated.

4.2

The Code of Professional Practice Policy for staff does not expressly address expectations of staff conduct and the consumption of alcohol at both formal and informal events associated with Ara, like internship provider drinks and dinners (formal) or class drinks (informal). This should be made clear in guidelines to staff and in the Code of Professional Practice. That code refers to refraining from “conduct (such as the use of intoxicants, drugs or other substances) that might impair work performance or place people or property at risk”. The focus is on “work performance” and “risk to people or property”, not expected behaviours and conduct in social situations where professionalism is expected.

The CPP211 Code of Professional Practice for Staff has been updated to include guidelines for refraining from intoxication. The new policy has been consulted on, approved and published.

4.3

“Initiations” and “de-initiations” should be strongly and expressly discouraged generally by Ara and not permitted on Ara premises, in particular Ōtautahi House. “Substance misuse” as an example of unacceptable behaviours is only generally noted in the Learners Responsibilities and Rights Policy. In the Student Rights and Responsibilities document on the MyAra App, there is only general reference to “misuse of alcohol, drugs or other substances” as an unacceptable behaviour.

The Ōtautahi House Rules & Regulations and the wellbeing section of the Ōtautahi House Handbook have been updated to include appropriate behaviour expectations.
Rules have been tightened around the number of visitors to a flat.
Two Ōtautahi House Hono were run in 2022 focussing on healthy behaviours and relationships. These were interactive workshops where residents identified what is acceptable and unacceptable behaviour and how they could contribute to a healthy and responsible community at Ōtautahi House. These Hono will be repeated annually for new residents in Semester 1.
The APP301 Learner Responsibilities and Rights Policy and Handout have been updated, consulted on and are now published including improved explanations of unacceptable behaviour.

5.1

I recommend that the PP component of the course be reviewed by the NZBS.

The review has been completed.

5.2

This could include (if it is considered valuable to continue with peer assessment) removing the course weighting of the peer assessment.

The peer assessment course weighting has been removed from the Bachelor of Broadcasting Communications degree.

5.3

In addition, the questions in the peer assessment could be reviewed so as to not invite negativity where none may exist (for example, “I wish the student would stop doing…”).

The questions have been adjusted to match the recommendation.

5.4

Peer comments are already sensitively communicated to the recipient by the tutor in a filtered format. This could be extended to providing the comments in draft which allows the student to consider the remarks and meet with the tutors to discuss or rebut them (if appropriate) to finalise the assessment, and to enable constructive feedback.

The review has been completed and the changes are now in place.

6.1

I recommend that Ara implements a specific standalone anti-bullying policy in addition to an anti-harassment policy.

Ara has included separate bullying, harassment and discrimination sections in a new policy: CPP222 Addressing Bullying, Harassment and Discrimination. 
The policy has been through the consultation process, was approved and is now published.

6.2

The anti-bullying and anti-harassment policies should be made more accessible to staff and students. This should include making them available through the MyAra App and more readily accessible from Ara’s website.

Ara webpages, Waituhi and MyAra have been modified to include revised policies, support resources, contacts and examples for the anti-bullying and anti-harassment policies.
These have been, and continue to be, promoted to all colleagues and learners.

6.3

There should be dedicated easily accessible pages dealing with bullying and harassment on Ara’s website, on the MyAra App and in the BBc Programme Handbook (“Dedicated Bullying and Harassment Information”). These should paraphrase the anti-bullying and harassment policies and provide links to all relevant further information (including to the policies themselves, to the student advocate webpage, and to the other web/MyAra pages detailing how to access safety and wellbeing services when required).

Ara's website and the My Ara app now contain pages with advice about bullying and harassment, including process diagrams, escalation processes and links to support resources.

The Bachelor of Broadcasting Communications Programme handbook includes summarised bullying and harassment information including reporting and escalation processes.

6.4

The anti-bullying and anti-harassment policies should use direct and easily understood language.

Ara has implemented separate sections on bullying, harassment, and discrimination in a new-look policy CPP222 Addressing Bullying, Harassment and Discrimination. 
The policy has been through the consultation process, was approved and is now published.
Consultation feedback commended the ease of reading and the clarity of definitions in the policy.

6.5

The anti-bullying and anti-harassment policies should include examples of what behaviour constitutes bullying and harassment (including sexual harassment and racial harassment). Although the current Harassment Prevention Policy does provide good examples of these behaviours, I recommend that they be incorporated into the body of the document or in a hyperlinked appendix (as opposed to within the definition section).

The revised CPP222 Addressing Bullying, Harassment and Discrimination policy includes examples and improved definitions.

6.6

The definitions of “Bullying”, “Harassment”, “Racial Harassment” and “Sexual Harassment” currently within the Harassment Prevention Policy could all be improved. For good examples of these definitions, see the University of Canterbury Te Whare Wānanga o Waitaha’s “Prevention of Harassment and Bullying Policy” as published on the University’s website.

The revised CPP222 Addressing Bullying, Harassment and Discrimination policy includes examples and improved definitions.

6.7

The anti-bullying and anti-harassment policies should include examples of behaviours that are not usually considered to be harassment or bullying.

The revised CPP222 Addressing Bullying, Harassment and Discrimination policy includes examples and improved definitions.

6.8

The examples of what does, and does not, constitute bullying and harassment should be included on the webpages/resources containing the Dedicated Bullying and Harassment Information.

The revised CPP222 Addressing Bullying, Harassment and Discrimination Policy has been revised and published.
Webpages, Waituhi and MyAra have links to revised policies, support resources, contacts and examples.
These resources have been and continue to be promoted to all colleagues and learners. 

6.9

The anti-bullying and anti-harassment policies should clearly set out the level of behaviour that it expects from its staff and students. This should include reference (and hyperlinks) to both the Learners Responsibilities and Rights Policy and the Staff Code of Professional Conduct which provides for the expected standards of conduct of all students and staff.

The revised CPP222 Addressing Bullying, Harassment and Discrimination Policy has been updated with improved definitions, examples and links to other related policies.

6.10

The current Harassment Prevention Policy does not encourage bystanders/witnesses to report bullying, harassment or any other type of inappropriate behaviour. The anti-bullying and harassment policies should make express reference to bystander’s obligations and give guidance on how someone might raise an issue anonymously and how a bystander can participate in the process, whilst still complying with natural justice.

The revised CPP222 Addressing Bullying, Harassment and Discrimination Policy encourages bystanders to report observed bullying, harassment or discrimination. 
Bystander training modules have been rolled out to colleagues.
Bullying, Harassment and Discrimination modules for learners have been released.

NZBS has also rolled out the modules to their ākonga.

6.11

The current Harassment Prevention Policy does not clearly articulate what resolution processes are available, nor how to access them. The anti-bullying and harassment policies need to provide clear information as to what each resolution procedure entails (including both the informal and formal processes) who to contact, and why an individual would choose one procedure over another.

The revised CPP222 Addressing Bullying, Harassment and Discrimination Policy incorporates up-to-date resolution processes.

6.12

The anti-bullying and anti-harassment policies should contain specific templates dedicated to reporting harassment and bullying reports. These should be hyperlinked in the anti- bullying and anti-harassment policies and be accessible on the webpages/resources containing the Dedicated Bullying and Harassment Information.

The revised CPP222 Addressing Bullying, Harassment and Discrimination Policy incorporates processes for making formal and informal complaints and links to the templates for lodging them.

6.13

The Learners Responsibilities and Rights Policy should be combined with the attachment entitled “Learner Responsibilities and Rights”, together with the flowchart, into one easy to follow document. A hyperlink to the anti-bullying and harassment policies should be included in the Learners Responsibilities and Rights Policy.

The APP301 Learners Responsibilities and Rights Policy has been updated, has been through an academic review process, and has now been published.

6.14

The Learners Responsibilities and Rights Policy should be redrafted to incorporate the similar (but in my view better) content as contained on the MyAra App page entitled “Students Rights and Responsibilities”.

The APP301 Learners Responsibilities and Rights Policy has been updated, has been through an academic review process, and has now been published.

6.15

The dedicated MyAra App page (whether entitled Learners Responsibilities and Rights or Students Rights and Responsibilities) should refer to bullying under the unacceptable behaviours section (in addition to those already there) and have hyperlinks to the anti-bullying and anti-harassment policies and to the underlying Learners Responsibilities and Rights policy.

MyAra and website pages have been reviewed and refreshed to align with updated policies. Links have been included to the relevant documents, processes and policies.

6.16

The Learners Responsibilities and Rights policy is currently located under the General Academic Policies tab on the website, which is not the right location for it. It should be made more accessible for students on the website.

All policies are now available on new tabs in the MyAra application and on the Ara website.

6.17

The Code of Professional Conduct is in two parts. It should be combined into one, easily accessible document. It should also include hyperlinks to the anti-bullying and anti- harassment policies and the Learner Responsibilities and Rights Policy (which should include attachment AAP301a, which includes the important statement that staff have the responsibility to maintain a safe and effective learning environment and that they may ask a student to leave the class if a student is being unsafe, is a disturbance to others learning, or is putting others at risk).

The CPP211 Code of Professional Practice has been updated, consulted upon and published. It includes links to all related policies.

6.18

The Raising Problems or Complaints Policy should name the separate specific policies that cover complaints related to harassment and bullying and provide hyperlinks directly to those policies. This should be clearly articulated within the body of the policy document itself and not just by reference to the Harassment Prevention Policy in the “Related Ara Ltd Policies” box. Ara must then ensure that these separate policies and procedures are followed when dealing with complaints related to harassment and bullying.

The CPP117 Raising Problems or Complaints policy has been updated, consulted upon and is now published.

6.19

The purpose of the Raising Problems or Complaints Policy should be clearly articulated within the document itself, with reference to it being the primary policy under which all complaints are made and formally recorded.

The CPP117 Raising Problems or Complaints policy has been updated, consulted upon and is now published.

6.20

The Probation Policy should remove reference to the appeal process for those students who are suspended under the policy. Suspensions are dealt with under the separate Suspension and Refusal/Cancellation of Enrolment Policy.

The APP506 Learner Behaviour Management policy has been updated, consulted upon and is now published.

6.21

The Probation Policy and the Suspension and Refusal/Cancellation of Enrolment Policy should refer to and hyperlink the anti-bullying and harassment policies.

The APP506 Learner Behaviour Management policy and APP512 Suspension and Refusal/Cancellation of Enrolment policies have been updated, consulted upon and are now published.

6.22

The Learner Support at Ara Institute of Canterbury Ltd Procedure Document should be redrafted to make it clear what its purpose is, and ensure the information contained within it is consistent. It should also be referred to in the related Learners Rights and Responsibilities Policy (and hyperlinked).

This document has been re-drafted and is aligned to the revised policy.

6.23

All of the above-mentioned policies should be reviewed at least every three years.

Ongoing reviews of policies will continue until the responsibility for policy maintenance and review is subsumed by Te Pūkenga.

6.24

As part of this review, Ara should ensure that the policies refer to the most up to date related legislation, regulation, and good practice guidelines, and provide hyperlinks to each.

Ongoing reviews of policies will continue until the responsibility for policy maintenance and review is subsumed by Te Pūkenga.

6.25

The Quick Reference Guide as contained in the 2022 BBc Programme Handbook should include the name and contact details of the Complaints Co-Ordinator.

The quick reference guide in the 2023 BBC Programme Handbook includes links to or details of all key contacts for issues and feedback, and links to relevant policies. The Complaints Coordinator is not a student-facing role, but a link to their email address and a link to the complaints form is included in policies and on advice pages. The contact details, name and role of the Independent Student Advocate, Duncan Dunbar are widely distributed. 

6.26

The Quick Reference Guide should also be published on the MyAra App.

Links to or details of all key contacts for issues and feedback, and links to relevant policies are available through MyAra.

6.27

The MyAra App should contain a dedicated tab on the home page where all of the key policies in relation to harassment and bullying can be found.

The MyAra App includes a ‘Need Help’ tab that directs ākonga to the support options available. The ‘Health & Wellbeing’ tab provides a direct link to the Bullying and Harassment policies.

7.1

Ara should implement compulsory training for all current staff and students on identifying bullying and harassment. The training should include;
7.1.1 how staff should respond to a complaint by students;
7.1.2 how staff should respond to harassment or bullying if it is witnessed; and
7.1.3 what students should do if a victim of harassment or bullying, or witness to it.

Current & new Kaimahi are required to complete a Bullying and Harassment online training module, and to repeat that module annually.

Bullying & harassment content is progressively being integrated into all full-time programme orientation and induction sessions for ākonga, rather than being embedded into specific programme content. NZBS orientation and induction included bullying & harassment modules in 2023.

Bullying & Harassment and Bystander Training modules have also been made available to all ākonga via MyAra or the Ara web.

7.2

The training should also be compulsory for all new staff and new students to Ara.

Current & new Kaimahi are required to complete a Bullying and Harassment online training module, and to repeat that module annually.

Bullying & harassment content is progressively being integrated into all full-time programme orientation and induction sessions for ākonga, rather than being embedded into specific programme content. NZBS orientation and induction included bullying & harassment modules in 2023.

Bullying & Harassment and Bystander Training modules have also been made available to all ākonga via MyAra or the Ara web.

7.3

Ara should implement (if it has not already done so) a compulsory consent training module for all students to assist in reducing the incidences of sexual harassment between students.

All new NZBS learners and Ōtautahi House residents are required to attend consent (healthy relationship) workshops. These workshops are rolled out in term 1 of each semester. Professional counsellors attend these workshops.

All full-time learners are provided with details on how to access the prevention of sexual harm resources, and links to support services, during Department orientation and induction.

In addition, academic departments may identify specific programmes (e.g. groups who spend long hours together, undertake close contact activities, extended internships) to explore this content in more detail either during orientation, or when relevant to specific courses or learning components.

8.1

Ara/the NZBS should implement a specific “internship safety and well-being module”, to be completed towards the end of the second year of study. The purpose of the module being to:
8.1.1 educate students about what they can expect on an internship (from a safety and well-being perspective) including identifying what behaviour is and is not appropriate;
8.1.2 inform the students about who to contact at Ara/the NZBS should an issue arise affecting their safety and wellbeing while on their internship; and
8.1.3 inform students on how to make a complaint while on an internship and detail how it will be handled.

The Professional Placement Lead delivers pre-placement and internship safety and wellbeing training that incorporates how to raise an issue. This information is published on the dedicated placement Moodle page that NZBS ākonga can access when off campus.

Placement providers are made aware of these procedures.

8.2

The NZBS should create a succinct document to be provided to all interns before starting their internships which summarises what they should do if they experience bullying or harassment in the workplace.

There is a clear and simple flow chart supplied on Moodle for NZBS ākonga to reference.

8.3

That document should also be contained on the MyAra App, and easily accessible to interns via the Ara website. See, for example, Victoria University of Wellington Te Herenga Waka Faculty of Law’s document entitled “Clerkships, internships and employment while studying: What to do if you experience harassment”.

There is a clear and simple flow chart supplied on Moodle for NZBS ākonga to reference.

8.4

The NZBS should implement a process with internship providers so that the NZBS can satisfy itself that the providers rules, policies and procedures comply with all of the requirements of the HSWA and that they are adequately conveyed to the student by the internship provider.

This has been incorporated into the internship provider agreements between Ara and its placement providers.

8.5

The NZBS should implement a process with internship providers which ensures any problems that arise in relation to an intern’s health, safety and wellbeing are reported to NZBS. Any welfare related issues should immediately be notified to the NZBS so the appropriate steps can be taken by Ara/the NZBS to support the student.

This has been incorporated into the internship provider agreements between Ara and its placement providers.

8.6

Ara should appoint a dedicated contact within the NZBS whom students can contact for health and wellbeing support whilst on an internship. That person should be contacting students on at least a monthly basis to check on their wellbeing generally and to identify any problems that may have arisen in this regard.

A Professional Placement Lead has been appointed and their name and contact details have been communicated to ākonga. The Professional Placement Lead is in contact regularly in the form of phone check-ins, progress reports, assessments, video or in-person catch-ups and emails.

9.1

Ara should appoint a dedicated Bullying and Harassment Officer, being the first port of call for any student or employee wanting to raise an issue related to bullying and harassment.

As part of the revision of the CPP222 Addressing Bullying, Harassment and Discrimination Policy, Ara has set out comprehensive issue resolution options and multiple contacts for ākonga and kaimahi to access. These are also detailed in CP222A Guidelines to Assist with Addressing Bullying, Harassment and Discrimination. The range of student options includes access to academic, managerial, and pastoral kaimahi, student representatives and an independent student advocate.

Ara has also identified and publicised the contact details for 20 kaimahi as bullying and harassment First Responders. These First Responders are intended to support kaimahi and can also be directed to support ākonga where beneficial.

9.2

The contact details of the Bullying and Harassment Officer should be widely disseminated across Ara communication streams, including on the dedicated bullying and harassment web and MyAra pages (as referred to above) and in the Quick Reference Guide.

The revised CPP222 Addressing Bullying, Harassment and Discrimination Policy and options for resolution and contacts have been published on kaimahi and ākonga communication channels.

9.3

Ara’s webpages/resources containing the Dedicated Bullying and Harassment Information should address what individuals should do if they want to raise an issue related to bullying and harassment (including racial and sexual harassment). Specifically, with regard to complaint and resolution mechanisms this page should:
9.3.1 set out the different processes and options available where an individual wants to raise an issue or complaint in relation to bullying and harassment. Both informal and formal processes should be clearly outlined; and
9.3.2 clearly explain what resolution process or complaint process might be most appropriate in the circumstances.

MyAra and the website have been updated. The updates include policies and flow charts and references to the complaints raising and resolution processes.

9.4

Encourage students and staff who both experience and/or witness bullying or harassment to contact the Bullying and Harassment Officer (whose contact details should be provided).

Active Bystander training has been rolled out to staff. Active Bystander training modules are available through MyAra and the website for student use.

9.5

Also provide the contact details (together with hyperlinks where available) of any other individuals/organisations that students and staff can appropriately contact in the event they have an issue/complaint to raise in relation to bullying and harassment.

Contact details are included in all support resources.

9.6

Provide links to specific templates dedicated to reporting (both informally and formally) incidences of harassment and bullying (as recommended above).

Links have been updated and navigation aids implemented to make discoverability simpler.

9.7

The Quick Reference Guide should refer specifically to the process for raising issues or complaints in relation to bullying and harassment specifically (and provide a link to the webpage/My Ara page that contains the Dedicated Bullying and Harassment Information).

The Quick Reference Guide has been updated as part of the 2023 BBC Handbook refresh.

9.8

Ara (to the extent it has not already) should implement a system which records informal complaints raised in relation to bullying and harassment. This would give Ara the ability to identify whether certain patterns of behaviours exist (such as a culture of inter-student bullying) or whether a certain person is frequently the subject of complaints (prompting further investigation by Ara).

The revised CP117 Raising Problems or Complaints Policy sets out options for informal complaints to be reported and resolved. This includes expectations and options for kaimahi to follow to resolve the issue, including escalation where required, and the requirement to provide feedback to the complainant.  Ākonga are provided options for making a formal complaint where the informal process resolution is unsatisfactory.

Outside the complaints processes, ākonga are also provided the option to provide anonymous disclosures on InformUs, which is used to detect patterns of behaviour and to inform ongoing capability development.

9.9

Ara already has a system in place with regard to monitoring feedback from the Student Experience survey, it appears that a large number of students are not being followed up, despite their request to be contacted. Ara should continue to ensure all students who have raised concerns in the survey are followed up.

The student survey feedback process has been reviewed. All learners that ask to be contacted are contacted. Where some learners do not ask to be contacted, but do raise a specific problem, discretion is applied, and contact may be made to understand and resolve the issue. 

9.10

Ara needs to implement a system to ensure that all informal complaints are adequately investigated, reported on and followed up in order to create a culture where students (and staff) are encouraged to speak up against bullying and harassment.

The revised CP117 Raising Problems or Complaints Policy sets out options for informal complaints to be reported and resolved. This includes expectations and options for kaimahi to follow to resolve the issue, including escalation where required, and the requirement to provide feedback to the complainant.  Ākonga are provided options for making a formal complaint where the informal process resolution is unsatisfactory.

Outside the complaints processes, ākonga are also provided the option to provide anonymous disclosures on InformUs, which is used to detect patterns of behaviour and to inform ongoing capability development.