On 9 February, England¡¯s Office for Students (OfS) published?its draft Statement of Expectations to prevent and address harassment and sexual misconduct. This follows?its 2020 consultation on the same topic, cut short?by the pandemic in March last year.

While we welcome any call from the regulator to address issues of harassment and sexual misconduct on campus, we have concerns that there is a complete failure to acknowledge the role of online abuse in harassment.

We are mindful that this is a draft, which will be reviewed following consultation with ¡°student and sector representative bodies and other stakeholders¡±. Nonetheless, when one examines the statement of expectations in detail, we see no mention whatsoever of online abuse or the use of digital technology to harass.

This is perhaps not too much of a surprise, given that the original consultation seemed to consider online abuse to simply be one of the ways in which harassment or sexual misconduct can occur, rather than being a different form of abuse that needed to be addressed separately.

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Given the year we have just had, in which the majority of student education and the associated higher education experience has been moved online, we might expect some acknowledgment of the need to address student welfare in the online environment.

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This has been a year with plenty of high-profile media stories about different forms of online abuse, along with the failings of institutions to take them seriously.?

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Online abuse is different ¨C and that should be acknowledged. It can have a far wider geographical reach, it can be delivered across multiple platforms and devices and it can be delivered incessantly. It can facilitate ¡°pile ons¡± to a victim in a way physical harassment simply cannot.

Moreover, many abusers will dismiss online abuse as ¡°banter¡± and not recognise the severity of the harassment, or, due to anonymity, do not believe that they will get caught. We should also be mindful of the use of catfishing for harassment and the creation of pseudosexual images in order to harass.

We know from our work with the Revenge Porn Helpline that they are contacted by many students who have become victims of the non-consensual sharing of intimate images ? and the resultant harassment and abuse.

In a previous research project, funded by the OfS, we spent a lot of time exploring online abuse with students.?About 20 per cent of them disclosed that they had been subject to online sexual solicitation and being in receipt of unsolicited intimate images, and about 50 per cent disclosed that they had dealt with unwanted contact online.

These are, sadly, commonplace experiences, and institutions should have policy and practice in place to support the students, proportionate and transparent sanctions for abusers and the means to provide education and training around acceptable and unacceptable online discourse.

A simple quote from one student highlighted the impact of persistent digital harassment: ¡°It could be any time in the day, and I would get a message going: ¡®I like your purple shoes today¡¯.¡±

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The abuser in this case was making use of technology to be both hidden from sight and able to harass without fear of detection. And the comment, while fairly innocuous at face value, reveals itself to be an extremely sinister reminder that the abuser was close and could see what the victim was wearing.

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As a result of our work in statutory education, we know that in October 2012 senior leaders in schools all over England started to take online safeguarding issues seriously. Before this date, it was, at best, ad hoc.

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It is no coincidence that in September 2012, Ofsted ¨C England¡¯s Office for Standards in Education ¨C announced for the first time that online safeguarding would now form part of?its school inspections.?

This was reinforced in subsequent years, with the expectations for all schools in terms of online safeguarding defined through the statutory document Keeping Children Safe in Education ¨C schools now have a statutory duty to have practices in place to address online harms, to provide training for staff and education for students. And because it is statutory, they do it.

We can contrast this with our research in the universities sector, where we requested policies from HEIs where online abuse was addressed. We were deliberate in asking for these to be sent to us, rather than collected from institutional websites, because we wanted to see which policies the institution believed addressed online abuse. We received, in total, 266 policies across the sector, and 60 per cent of them had no mention whatsoever of online abuse or how the institution responds to it.

Universities UK released the guidance document in late 2019, which made some excellent recommendations for how the sector might improve its support for students in tackling online abuse ¨C there is much work that can be built upon, but it needs the buy-in of the regulator.

The OfS must take a lead in clearly defining online harassment and abuse and make clear statements on acceptability and the duty of care for institutions if we wish to see a change in approach across the sector. After all, if the regulator doesn¡¯t appear to take this seriously, who will?

Andy Phippen is professor of digital rights at Bournemouth University and Emma Bond is professor of socio-technical research at the University of Suffolk. Between them they have more than 30 years¡¯ experience researching online safeguarding.

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