Responsible event booking and venue hire policy and procedure

Local authority and community premises protocol

Forward

Blackpool is made up of communities that have shared values and principles embedded in their fabric. Modern day challenges associated with extremism threaten the positive influence of our diverse communities, which is why Blackpool Borough Council (BBC) is refreshing our approach to community cohesion and engagement with a renewed focus on strengthening the bond our communities share, celebrating diversity, and isolating those that wish to deny, distort or divide us.

As a vibrant multi-cultural borough, we have a responsibility to protect our communities from speakers who seek to spread hate using speech to incite violence or hatred and threaten community cohesion, health and public safety. It is vital that people are given the space to think and speak freely even when we disagree or are offended by what they have to say. People do have a right to offend us, so long as we also maintain our right not to be subject to that, which we find offensive.

However, the line between free speech and hate speech is not easily defined. The challenge for public authorities like Blackpool Borough Council is two-fold: Where is the line between a person's right to offend and what they say requiring action be taken; and then what does the public body do about it?

Whether it is racist groups or individuals who promote extremist ideas and sow seeds of division and hate in the borough, as a public body we need to ensure our buildings are safe and welcoming spaces for all, as well as seeking to use our influence to ensure other facilities in the borough are too.

Building stronger and resilient communities is at the heart of everything we do here in Blackpool. The approach to challenging hate speech and intolerance will require a multi-agency approach from other public and third sector organisations.

We hope that local, private and community venues will also refer to our framework for guidance, should they be presented with events featuring individuals or groups promoting hatred and intolerance. Thus, creating uniformity in approach and strengthening the status of this framework.

Neil Jack
Chief executive
Blackpool Borough Council

Executive summary

The responsible event booking and venue hire policy has been compiled to assist local authority and community premises in Blackpool with their hire procedures. Visitors to these venues have the right to enjoy services and facilities without fear of intimidation, harassment, extremist or threatening behaviour. This protocol provides guidance on mitigating the risk and the processes involved in ensuring that defendable and informed decisions are made when hiring out venues.

When hiring venues for events, consideration should be given to health and safety, responsibilities under various legislation, potential for reputational risk and impact on the community and visitors to the premises etc. Where a booking has been made which causes concern, it is expected that the booking be passed on to the relevant agencies for further checks.

The main legislation/guidance governing this issue is:

Statutory guidance issued under s29 of the Counter-Terrorism and Security Act 2015 makes explicit reference to the `Use of local authority resources’ and outlines expectations of partnership working and that `, local authorities should ensure that publicly-owned venues and resources do not provide a platform for extremists and are not used to disseminate extremist views’ through the establishment of a responsible booking policy for public venues.

As a responsible authority under the Crime and Disorder Act 1998, BBC also has a statutory duty to work in partnership with other agencies to reduce and prevent crime. Maintaining public order is a priority for the Local Authority and the Police, therefore when an event poses a risk to the general public, there are grounds to review and reconsider venue hire. Where the property is not under local authority control, they can provide advice to the property owners/occupiers.

The Human Rights Act 1998 sets out the fundamental rights and freedoms that everyone in the UK is entitled to. In some limited situations, certain freedoms are qualified meaning that public authorities may interfere with them. This is only possible where the authority can show that its action has a proper basis in law, and is necessary and ‘proportionate’ in order to protect Public safety, Public order, Health or morals, the rights and freedoms of other people.

The Equality Act 2010 requires public bodies to have due regard to the need to eliminate unlawful discrimination, harassment, victimisation and any other conduct prohibited by the Act as well as advance equality of opportunity and foster good relations between people who share a protected characteristic and people who do not. The latter relates to the need to tackle prejudice and promote understanding.

This policy provides practical assistance and support to venues in ensuring that local service users are not subjected to messages of hate or intolerance of any kind. The recommended steps for managing booking of venues are outlined in this document:

• Receive and identify booking requests
• Gather and assess the information and the level of risk posed by the event
• Communicating the process to the applicant and make a joint decision with partners on whether event should or should not run forward
• Review event and consider future booking requests

Detailed guidance on how to conduct information gathering, analyse the data, seek advice, raise a concern and respond is provided. The appendix also includes a one-page venues booking checklist, event/speaker of concern reporting form and an investigation recording form.

Introduction

What is the purpose of this document?

This responsible event booking and venue hire policy has been compiled to assist local authority and community premises with their hall hire procedures.

Visitors to these venues have the right to enjoy services and facilities without fear of intimidation, harassment, extremist or threatening behaviour. A robust policy would assist to reduce the risk of local venues being vulnerable to hosting events which are not conducive to promoting cohesion, equality, diversity or tolerance.

Local authorities have a responsibility to ensure their venues are not used by those with views that may draw people into terrorism, by ensuring that rigorous booking systems are in place and staff responsible for them are trained to know what to do if they have suspicions.

Whilst Blackpool Borough Council (BBC) recognises the need to support freedom of expression amongst the community, it cannot support events which are contrary to the borough’s values.

This protocol provides guidance on mitigating the risk and the processes involved in ensuring that defendable and informed decisions are made when hiring out community venues. Where a booking has been made which causes concern, it is expected that the booking be passed on to the relevant agencies for further checks.

Who is the guidance for?

This guidance provides practical assistance and support to venues in ensuring that local service users are not subjected to messages of hate or intolerance of any kind. The recommended steps for the booking process are outlined, and it is anticipated that the following users will be expected to refer to this document:

1. Venue booking staff/volunteers
2. Centre managers
3. Governing bodies/trustees
4. Caretakers

The types of venues covered by this policy include:

• Council owned and operated
• Business centres
• Libraries
• Community centres/community assets
• Leisure centres
• Children’s centres

Please note that this list is not exhaustive and any person concerned with the booking or hiring of council owned and operated property should consult this guidance.

Why is this policy important?

There are several important issues that must be considered when using community venues, some examples of these are listed below:

Regulatory enforcement framework

A range of regulations are relevant to events (e.g. licensing, environmental health, noise pollution) and early discussion should be had to look at whether an event conforms to the relevant regulations.

Reputational risk

Local authorities and venue owners will need to be made aware if there are concerns about speakers who have a history of expressing extremist views and/or views that aren’t consistent with British values using a private venue for an event in view of the potential reputational impact of an unsuitable booking. Consideration should be given to exposure from media coverage (this encompasses both journalistic reporting and online posts).

Charities

Those organisations registered as a charity should be aware that trustees have specific duties under charity law which are relevant to the protection of their institutions. The Charity Commission has a variety of guidance available for trustees, including Chapter 5 of the Compliance Toolkit ‘Protecting Charities from abuse for extremist purposes’. Amongst other information, this provides guidance on managing risks associated with speakers, events and publications.

Illegal activities

It is important that venues pay due regard to preventing illegal activities i.e. fundraising for unlawful purposes, criminal activities or discriminatory actions etc. This should also include actively limiting the effect of leafleting by extremist groups in or around their premises.

Legislation and due diligence informing policy framework

The Counter Terrorism and Security Act 2015²

The Counter-Terrorism and Security Act came into force on 1st July 2015. The Act imposes a duty upon specified authorities to have “due regard to the need to prevent people from being drawn into terrorism” and guidance anticipates that all local authorities will be partners in prevention efforts.

The legislation makes explicit reference to the `Use of local authority resources’ and that ` local authorities should ensure that publicly-owned venues and resources do not provide a platform for extremists and are not used to disseminate extremist views’ through the establishment of a responsible booking policy for public venues.

“In order to maintain our existing high levels of community cohesion, promote equality and maintain public order, Blackpool Borough Council will not tolerate messages of hate and intolerance in the borough”

Crime and Disorder Act 1998³

As a responsible authority under the Crime and Disorder Act 1998, BBC has a statutory duty to work in partnership with other agencies to reduce and prevent crime.

Maintaining public order is a priority for the local authority and the police, therefore when an event poses a risk to the general public, there are grounds to review and reconsider venue hire. Where the property is not under local authority control, they can provide vigorous advice to the property owners/occupiers.

Health and safety considerations

Some events can attract significant attendance with the potential for disorder outside a premise and health and safety implications for staff, visitors and residents. Local authorities may need to assess the risk, ensure appropriate measures are put in place or advise private venues accordingly.

Human Rights Act 1998

The Human Rights Act 1998 sets out the fundamental rights and freedoms that everyone in the UK is entitled to.

In practice, the Act incorporates the rights set out in the European Convention on Human Rights (ECHR) into domestic British law; ensuring that law will be interpreted to uphold The Human Rights Act, no national law should directly conflict with The Human Rights Act 1998⁴. In some limited situations, certain freedoms are qualified meaning that public authorities may interfere with them.

² The Counter Terrorism and Security Act 2015 (Specific guidance under Part 5 of the statute)
³ The Crime and Disorder Act 1998 (Specific guidance under Part 1 of the Statute)
⁴ Section 2(1) The Human Rights Act 1998

This is only possible where the authority can show that its action has a proper basis in law, and is necessary and ‘proportionate’ in order to protect:

1. Public safety
2. Public order
3. Health or morals
4. The rights and freedoms of other

Below are examples of Human Rights that a Public Authority may seek to withdraw from a group or individual.

Article 10: The Freedom of Expression⁵

 

People have the right to hold their own opinions and to express themselves freely without government interference. This includes the right to express views aloud or through:

1. Published articles, books or leaflets
2. Television or radio broadcasting
3. Works of art
4. Communication on the internet

Public authorities may restrict the right to freedom of expression if they can show that their action has a proper basis in law, and is necessary and ‘proportionate’ in order to:

• Protect national security, territorial integrity or public safety
• Prevent disorder or crime
• Protect health or morals
• Protect the rights and reputations of other people
• Prevent the disclosure of information received in confidence
• Maintain the authority and impartiality of the

It may be permissible to restrict a person’s freedom of expression if, for example, a person expresses views that encourages racial or religious hatred.

However, the public authority must show that the restriction is ‘proportionate’; the restriction must be no more than is necessary and appropriate and should not be excessive, in the circumstances.

Article 11: Freedom of Assembly and Association⁶

People have the right to protest by holding meetings and demonstrations with other people.

Nobody has the right to force anyone else to join a protest, trade union, political party or another association. On occasions, it can be acceptable for a public authority to restrict a person’s rights to freedom of assembly and association. This is the case only where the authority can show that its action has a proper basis in law, and is necessary and ‘proportionate’ in order to:

⁵ Article 10 The Human Rights Act 1998
⁶ Article 11 The Human Rights Act 1998

• Protect national security or public safety
• Prevent disorder or crime
• Protect health or morals
• Protect the rights and freedoms of other

A ‘proportionate’ response to a problem is one that is necessary; appropriate and not excessive in the circumstances.

Article 14: Prohibition of Discrimination⁷

The Human Rights Act prohibits discrimination on a wide range of grounds including ‘sex, race, colour, language, religion, political or other opinion, national or social origin, association with a national minority, property, birth or other status’.

Equality Act 2010: Public Sector Equality Duty⁸

The Equality Act 2010 requires public bodies to have due regard to the need to:

1. Eliminate unlawful discrimination, harassment, victimisation and any other conduct prohibited by the Act
2. Advance equality of opportunity between people who share a protected characteristic and people who do not share it; and
3. Foster good relations between people who share a protected characteristic and people who do not share it

The latter relates to the need to tackle prejudice and promote understanding. A ‘protected characteristic’ as defined in the Act includes age, disability, gender reassignment, pregnancy and maternity, race (including ethnic or national origins, colour or nationality), religion or belief, sex and sexual orientation⁹.

Gender segregation

Local authorities are required to ensure they are fully familiar with their legal obligations under equality law and how this relates to their policy on gender segregation at events and meetings held on their estate or in connection with their activities.

Forced gender segregation is not consistent with British values. Where it occurs on the public estate or in connection with the functions of local authorities as public bodies there is a risk this will be viewed as tolerance or even support for such practices.

It is important that the relevant staff are aware of:

• The legal obligations under equality law
• What is permissible and not permissible on a segregated basis
• Exceptions from equality law for religious practice and observance:

⁷ Article 14 The Human Rights Act 1998
⁸ Section 149 of The Equality Act 2010
⁹ Protected characteristics are discussed fully by Section 4 of The Equality Act 2010

Segregation by gender will constitute unlawful discrimination except for in a few specifically defined purposes falling within one of the exceptions under the Equality Act 2010. The general rule is that exceptions in the act must be interpreted narrowly as they are a departure from the fundamental principle of equal treatment.

Local authorities must not knowingly facilitate discrimination by others at the request of a speaker or an individual attending or wishing to attend an event. In order to comply with their duties under the act, local authorities and their contractors should request information about the purpose of the meeting and firm details of seating arrangements on any form used to book premises for events.

If there is reason to suspect a risk of unlawful segregation, local authorities should conduct further investigation and, if proportionate, decline any bookings for the individual or organisation concerned where this would be justified under either their equality or prevent duties.

Elections in England and Wales

Guidance has been produced by the Electoral Commission for candidates and agents¹⁰ in relation to campaigning during elections. This may be in the form of engaging with the public at meetings, promoting their views and responding to questions from the audience. Any individual candidate or party list candidate is entitled to use publicly funded rooms and schools for public meetings.

The electoral registration officer¹¹ keeps a list of the location and availability of meeting rooms in their area. They will make this list available for inspection by candidates and election agents (and persons authorised by them) from the day the notice of election is published. Candidates will be able to use public rooms up until the day before polling day.

Candidates must contact the owner of the premises to make a booking, giving reasonable notice to reduce the risk of the request being refused although any prior letting would take precedence.

The Equality & Human Rights Commission have published guidance ¹² for local authorities, candidates and political parties about how the legal framework for equality and human rights law operates in England, Scotland and Wales during local and national elections

Due diligence

This refers to the reasonable steps taken by the council to avoid committing an offence under either civil or criminal law. In relation to this policy, BBC will conduct checks on individuals and groups seeking to host an event in BBC owned and operated premises to ensure they are not espousing extremist views and are not associated with other extremism related activity.

Rigorous scrutiny will assist in ensuring compliance with section 149 of the Public Sector Equality Duty which includes having due regard to the need to advance equality of opportunity and foster good relations between people sharing different “protected characteristics”.

Those responsible for undertaking checks to ensure events are compliant and adhering to BBC values are reminded that conducting such checks should be managed sensitively and proportionately, in strict accordance with the legal requirements for information sharing amongst statutory partners and data protection principles.

¹⁰https://www.electoralcommission.org.uk/ data/assets/pdf_file/0011/141788/Part-4-The-campaign-LGEW.pdfhttps://www.electoralcommission.org.uk/ data/assets/pdf_file/0006/163527/EPE-Part-4-The-Campaign.pdf
¹¹www.yourvotematters.co.uk
¹²https://www.conwy.gov.uk/en/Council/Voting-and-Elections/Assets/documents/GeneralElections/Equality-and-Human-Rights-Law-  during-an-Election-Period.pdf

Managing booking of venues

The SARA process

BBC recommend undertaking the SARA process (Scan, Analyse, Respond and Assess) to safely administer and manage booking of venues.

• Scan - Receive and identify booking requests
• Analyse - Gather and assess the information and the level of risk posed by the event
• Respond - Communicating the process to the applicant and make a joint decision with partners on whether event should or should not run forward
• Assess - Review event and consider future booking requests

Information gathering process

When information is collected for the purposes of sensitive decision making, there must be a clear and thorough process that collates relevant information from a variety of sources.

It is anticipated that during this exercise, it will often be necessary to consult appropriate partner organisations for advice and guidance (i.e. when trying to interpret information or to better understand the context).

Once the type of venue has been confirmed, information about the event should be gathered considering the following points:

1. The hiring party should be requested to provide details of the event. This may involve an advance look at the materials which the speaker intends to present, an agenda for the meeting, names of speakers, seating arrangements etc. as well as copies of any promotion material or social media marketing.
2. An ‘open source search’¹³should be conducted for any information regarding the event/key speakers/organisation.
3. Any material found as a result of the search should be critically assessed in terms of:
   1. Its validity and reliability (this can be informed via the source of this information and the author or publisher details)
   2. Is there any evidence or information to suggest that the speaker has promoted messages of hate or intolerance towards any groups that are protected under the Equalities Act 2010
   3. Is there any evidence or information which suggests that the speaker has been banned or prohibited from speaking elsewhere nationally or internationally?
   4. Any indication to suggest potential public order issues as a result of this event?

4. Engage in dialogue with the hiring party and/or the

¹³ An open source search is a search conducted on the Internet for any information that is freely available to the general public. Any information that is restricted access and is not freely available to the public is not considered to be ‘open source’.

Open source information gathering

When conducting open-source internet searches, primary source material must be considered as the preferred data type. This is because data emitting from a secondary source may have been misinterpreted or misrepresented, thus hindering the overall validity and reliability of the information. For this reason, it is important to be wary of over relying on information contained within blog sites, or opinions/hearsay shared on social media (‘fake news’).

What is primary and secondary information?

Below is a table which outlines the differences between sources with some examples.

Details of data types

Primary source data	Secondary source data
Any data written by the original author, Primary data is original data straight from the person or group that you are interested in. Examples: A book/ journal written by the original person, the person’s own Facebook account, a clip of the person talking or the band playing	Any information which may make use of the original author’s work, Examples: Any newspaper article which discusses an author’s work but is written by someone else, any information which may talk about the group that you are interested in, but is not written directly by them.

Reflections for data gathering online

The following reflections have been outlined to assist the information gathering process. It is important that these are taken into account as they will affect the quality of the data gathered and in turn have a bearing on the decision-making process to allow an event to take place or not. It is important that a thorough assessment is completed in order to arrive at a well-informed decision.

How to analyse the information that you have collated

As per the council’s obligations under The Equalities Act 2010, using the following questions should help you analyse the information that you have gathered in order to arrive at a decision to allow the event or otherwise:

Use the information that you have found to answer the following – if you are struggling to provide a response, this may suggest a gap in the information that you have gathered.

• Does the event have the potential to advance equality and promote good relations?
• Has the information identified a predominantly negative or positive impact to the wider community?
• Does the event have a greater impact on one protected group from the community over others? Moreover, is this consistent with the overall aims of the event?
• If the event was to go ahead, would it deliver potential benefits for protected groups in the community?
• Have you found that some groups are less satisfied than others with the activity as it is currently described?
• Is there any part of the proposed activity that has the potential to discriminate unlawfully?
• Where negative impacts have been identified, have you discussed those? If so, who with? Are these discussions documented and what is the view of the other party?
• Are there any further changes that could be made in order to improve the responsiveness of the activity?

Seeking advice or guidance

If further clarification is required in relation to the information gathered or if there are any concerns identified, internal or external partners should be consulted for advice and guidance. These can include but should not be limited to:

• The senior management team/Prevent lead
• BBC Prevent team
• BBC community safety (communities coordinator/cohesion advisor)
• Community assets manager
• Lancashire Constabulary (Prevent team or hate crime and diversity unit)
• Where applicable, relevant community contacts from protected groups which may be affected by the event taking place (this could be the LGBT community for example or an ethnic minority group).

Who can raise a concern?

Concerns or queries can come from: Local residents, organisations, concerned groups or statutory partner agencies.

• Council is notified of a potential event of concern.

Council response

1. Decide what type of venue is affected and therefore what action the council can take
2. Gather information where possible on the concern and event

Note: The onus for making the final decision depends on the classification of the venue type.

Responding to events of concern

There are a number of relevant issues that must be considered when responding to speakers or groups promoting potential messages of hate and intolerance in venues within the borough.

BBC operated and owned premises

• BBC owns and manages venues such as the Winter Gardens and events run in parks and open spaces in the borough
• When responding to the threat of hate or intolerant speakers at events taking place in BBC operated and owned venues, the local authority are the final decision maker on whether an event will take place within a particular venue space
• Where an event is deemed unsuitable, the host will be notified and the rationale
• Where a host can agree to remove problem groups or speakers from an event and BBC is satisfied that the event will subsequently pose no threat to cohesion, equality or public order, the event may be allowed to proceed
• BBC reserve the right to make the final decision on all events planned in BBC owned and operated space

BBC owned premises managed or leased by community organisations

• BBC owns a number of properties within the borough that are leased to local community organisations to run and manage for the purposes and enjoyment of the Some of these spaces are available for hire by local residents and groups.
• When responding to the threat of hate or intolerant speakers at events taking place in community assets, BBC will support the managing organisation to assess the risk and provide advice to inform decision making

Premises managed by community organisations with a funding relationship with BBC

• A number of local voluntary, community and social enterprises who are funded by BBC manage spaces that are available for hire, i.e. rooms within a local community centre. It is recognise that venue hire is a source of revenue for these organisations
• BBC and partner organisations will advise and support the managing organisation when they are responding to events of concern in their venue

Private or external venue hire

• There are a number of private hire venues in BBC including music halls, pubs, hotels that hire their space for a number of diverse events
• If a concern of potential messages of hate and intolerance is brought to the attention of the council, and the event is to take place in a venue managed by an external organisation, the latter must take responsibility for decisions on the event
• The council cannot direct the decision of an external organisation. However, BBC does have a duty to notify them of concerns if it views the event to be in some way detrimental to equalities, community cohesion and public order.

See the below chart for guidance:

• BBC council owned and operated venues » Decision lies with director/chief executive for BBC
• Venues owned by the BBC but managed by Community organisations » BBC and relevant partners will advise and support the managing organisation as they will be responsible for making the final decision
• Communities, voluntary or third sector organisations with space for venue hire who have a funding arrangement with BBC » BBC and relevant partners will advise and support the managing organisation as they will be responsible for making the final decision
• Private or external venues and room hire i.e. Pub, music hall, hotel, education establishment etc. » BBC and relevant partners will advise and support the managing organisation as they will be responsible for making the final decision.

The decision-making process

In view of the responsibilities the local authority operates under; an equalities and public safety approach is considered to be an appropriate framework for BBC to assess speakers promoting messages of hate and intolerance in venues in the borough.

All decision making relating to potential messages of hate and intolerance must ensure that information gathered is assessed appropriately and the final decision balances equalities, cohesion, public order and human rights considerations.

The decision-making process will be instigated following a thorough information gathering exercise.

The decision-making flowchart

1. Consult and gather information for decision making »

1. 1. Engage with hiring party/organiser to obtain full details
   2. Conduct an open source search

2. Critically assess »

1. The validity and reliability of the information.
2. Equality, human rights, cohesion or public order considerations
3. Any evidence of concern?

3. If there are concerns »

1. Seek advice and guidance from relevant internal or external staff i.e. senior manager, BBC Prevent team, communities coordinator, Lancashire Police or community contact.
2. Liaise with hiring party/event manager

»No concerns

Continue with booking arrangements

4. Decision making & next steps »

1. What are the Legal considerations?
2. Communicate decision to hiring
3. Inform BBC and other interested
4. Communicate with wider community where relevant

Potential outcomes for venues that are owned and operated by BBC

Equalities, cohesion, CTSA 15, human rights and public order are not impacted:

• Event is acceptable to go ahead
• Necessary steps should be taken with partners to ensure plans are in place to manage events effectively and safely

A speaker/group within the event has been identified as not conducive to promoting cohesion and equality or is a risk to public order:

• Speak with the organiser/hiring party and request that the speaker or group is removed from the event
• Upon agreement, the event can go forward
• If there is no agreement, consultation should take place with a director/chief executive to approve/disapprove the decision to hire which should then be communicated to the hirer

The event has been identified as not conducive to promoting cohesion and equality or is a risk to public order:

• Discuss the assessment with director/chief executive and come to an agreement
• Notify the hirer/inform the host and explain the reasons for the decision
• Inform relevant internal and external stakeholders – consider impact or likelihood of the event being held elsewhere in the borough

Potential outcomes for external venues and community managed premises

An event at an external venue or community managed premises is identified as posing equalities, cohesion, extremism or public order concerns:

• The council cannot direct the organisation on the action to take. The local authority’s role is to be supportive and provide advice and guidance.
• Discuss the assessment with director/chief executive and come to an agreement re next steps
• Notify the host of the concerns and if appropriate signpost suitable support
• Consider the impact of the event going ahead and ensure necessary steps are taken with partners to manage the risk and threat

 

Frequently asked questions

Does this apply to a venue hired for a private function i.e. wedding, party etc.?

Any venue, which is booked for the purposes of functions such as a wedding or a party, must comply with existing private hire policy and procedures for the venue concerned.

Who can I contact to discuss any concerns?

The council’s community assets manager will support volunteers running BBC community venues to assess the risk of bookings and give advice to reach an informed decision.

If you have any concerns about the speaker or the organisation enquiring about the booking, you should raise them as soon as possible with the community safety manager by calling 01253 477477 or emailing dominic.blackburn@blackpool.gov.uk.

Staff within community safety can provide advice and guidance if you have any concerns or queries in relation to a speaker/group, event or venue booking. The community safety team can be contacted via 01253 477477 or communitysafety@blackpool.gov.uk

How long should the decision-making process take?

 

The process aims to be as efficient as possible, although liaison with other organisations and information analysis can take some time. Ideally, the decision-making process from the point it is referred to BBC should not take longer than 10 working days; however, this could be extended in extenuating circumstances.

Community or external venue decision making will be subject to their own timescales as set out in their processes.

Is there an appeal option available on the decision?

All decisions relating to BBC venues will be made after a robust and in depth enquiry including collation of information, critical evaluation of the data and consultation with key local partners. The hirer or event organizer will have an opportunity to respond to concerns prior to the director of adult services and Prevention making a final decision. In the absence of the director, it will be the chief executive who will make a decision. There will be no scope for appeal.

Community venues will have undertaken a similar approach and therefore there will be no recourse to appeal.

How should findings be reported/ logged?

The event/speaker of concern reporting form in Appendix 2 should be used to report concerns about an event or speaker. BBC will utilise the investigation recording form (Appendix 3) to document the information gathering and decision-making process.

These documents should be stored in accordance with GDPR and the Data Protection Act 2018.

Appendix 1

Venue booking checklist

Step 1: Event details

Obtain information on the event from the hiring party

• Details of the hiring party including name of organiser/group, address, company or charity registration
• Event information i.e. agenda, format, name of speakers, who will be invited, seating arrangements etc
• Copies of promotional literature/social media marketing (confirm booking only once received)

Step 2: Research

Conduct checks on individuals/groups hosting an event in BBC owned and operated premises.

• Check Online- using a variety of sources to find information on event/speaker or organisation
• Consider primary and secondary source data – is it valid, reliable?
• Local knowledge from council staff/councillors/local police etc.

Step 3: Assessment

Public buildings must ensure all activity is inclusive and equal for all members of the community. Any information found should be critically analysed with this in mind.

• Speak to the hiring party and obtain further details, if you do not have sufficient information to assess
• Is there evidence of the speaker/organiser previously promoting messages of hate or intolerance?
• Ensure the speakers/organiser have not been banned or prohibited from speaking elsewhere
• If you have any concerns or queries in relation to a speaker / group, event or venue booking, contact:
  • The community safety team on 01253 477477 or communitysafety@blackpool.gov.uk
  • Community safety manager on 01253 477477 dominic.blackburn@blackpool.gov.uk

Appendix 2

Event/speaker of concern – Reporting form

The purpose of this form is to record details of any planned events happening in Blackpool where concerns are raised about the content, speakers, group etc.

Please note: Where the venue in question is not BBC owned, the role of BBC is to assist and advise the managing organisation. BBC will not make the final decision in this situation.

Person reporting

Name/organisation:

Job title:

Address:

Contact details, telephone/email:

Event/speaker/group of concern

Venue to be hired/location of event including address:

Event details (Brief synopsis of event including date and time):

Speaker details
Name:

Address:

Contact details:

Group details (include name, address, contact details etc):

Concern summary

Details of your concern:

Appendix 3

Investigation recording form

If concerns relating to an event or speaker are highlighted to Blackpool Borough Council, this form should be utilised to record actions undertaken in the information gathering and decision making process.

• If the venue is owned and operated by BBC, the final decision will be made by the director/chief executive
• In all other circumstances, BBC will provide advice and guidance. The final decision as to if the event can continue or not will remain with the venue management

Please ensure all questions are completed fully.

Event/speaker/group of concern

Venue to be hired/location of event including address:

Event details (Brief synopsis of event including date and time):

Speaker details
Name:

Address:

Contact details:

Group details (include name, address, contact details etc):

Type of venue

BBC owned and operated
Community Asset (Venue owned by BBC but managed by community organisations)
Business centre
Library
Leisure centre
Children’s centre
Community, voluntary or third sector venue
Private or external venue

Activity

1. Have details of the event being requested from the hiring party? This should include any material, agenda, promotion or social media marketing, seating plans etc.

 

2. Has the information gathering process i.e. open-source search, being completed as outlined in the responsible event booking and venue hire policy?

 

3.Have partner organisations or relevant community contacts from protected groups been consulted for advice? If so, please document who was spoken to, dates and times and summary of main points.

 

4. Has the information gathered been critically assessed in terms of:

1. Validity and reliability
2. Evidence of previously promoting hate or intolerant speech
3. Evidence of being banned from speaking elsewhere

 

5. Are there any concerns in relation to potential public order issues?

 

6. What are the legal considerations?

 

7. What decisions have been made from the data?

1. Is further research necessary?
2. Is further liaison with partner organisations required?
3. Do we need to further engage in dialogue with the hiring party/speaker

Please state the final decision and rationale:

 

If BBC owned and operated venue, confirm how the decision will be communicated to the event organiser:

 

Please record any comments/feedback from the event organiser:

 

If other type of venue, specify details of the advice given, and to whom it was communicated and when:

 

Please record any comments/feedback from the venue management:

 

Appendix 4

Responsible event booking and venue Hire Policy and Procedures: Local Authority and Community Premises Protocol

Guide for volunteers managing BBC community facilities

This guidance is intended to support volunteers who manage BBC community facilities to understand their responsibility under the council’s responsible event booking and venue hire policy.

This relates to the hiring of facilities to groups/speakers that do not support fundamental British values and for events that do not promote community cohesion and tolerance, values that are very important in Blackpool.

Councils like Blackpool must be sure that their venues aren’t used by anyone who may try to draw people into terrorism or to encourage hatred and intolerance.

The policy is to help volunteers who run community venues to know what to do to gather necessary information about groups/individuals who want to hire venues, to be able to make an informed decision about accepting or refusing bookings.

It’s been written in line with government legislation, such as the Counter Terrorism & Security Act 2015, the Human Rights Act 1998, and the Equality Act 2010. (More information on this is available on pages 12-15 of the Responsible Event Booking & Venue Hire Policy.)

How to manage booking enquiries?

There are a number of steps to take when dealing with an enquiry about a booking for a community venue:

1. Gather information

Ask the individual/organisation that has enquired about the booking to provide details of the event: an agenda, names of speakers, materials the speakers will use, seating arrangements, promotional material etc.Carry out an internet search for additional information about the event, the speaker, and/or the individual/organisation enquiring about the booking – take care to use a variety of sources to avoid bias.

2. Analyse information

Consider all the information you have discovered to reach a decision about allowing the booking to go ahead or not – on pages 16 and 18 of the public buildings policy you will find some useful questions to ask yourself to help with this.

3. Ask for advice/ guidance

The council’s community safety manager will support volunteers running BBC community venues to assess the risk of bookings and give advice to reach an informed decision. If you have any concerns about the speaker or the organisation enquiring about the booking, you should raise them as soon as possible with the community assets manager by calling 01254 585590 or emailing dominic.blackburn@blackpool.gov.uk.You can also contact the council’s community safety team by calling 01253 477477 or emailing communitysafety@blackpool.gov.uk.

4. Making a decision

To help you make a decision on a booking, use the flowchart on page 18 of the public buildings policy. This guides you through the decision-making process and makes sure full consideration is given to all the information and advice you have gathered.

5. Respond to applicant

If a decision is made to refuse a booking on the grounds that it poses a threat to community cohesion, equality or public order, the individual / organisation enquiring must be informed as soon as possible.

• There’s a useful checklist on page 20 of the Responsible Event Booking & Venue Hire Policy (Appendix 1) which guides you through each step of the process to assess whether a booking is appropriate or not
• You will find a form to report your concerns about a booking enquiry on page 21 (Appendix 2)
• BBC will record their investigation and decision on the form on page 22 (Appendix 3)

Glossary

Extremism: The UK government defines extremism as vocal or active opposition to fundamental British values, including democracy, the rule of law, individual liberty and mutual respect and tolerance of different faiths and beliefs. Extremism also includes calls for death of members of the armed forces. (Revised Prevent Duty Guidance for England and Wales (originally issued on 12 March 2015 and revised on 16 July 2015, paragraph 7)

Radicalisation: Radicalisation refers to the process by which a person comes to support terrorism and extremist ideologies associated with terrorist groups. (Revised Prevent Duty Guidance for England and Wales, issued on 12 March 2015 and revised on 16 July 2015, definition)

Terrorism: Terrorism is defined as an action that endangers or causes serious violence to a person/people; causes serious damage to property; or seriously interferes with or disrupts an electronic system. The use or threat must be designed to influence the government or to intimidate the public and is made for the purpose of advancing political, religious or ideological cause (Section 1 of the Terrorism Act 2000)

Fundamental/British values: Democracy, the rule of law, individual liberty and mutual respect and tolerance of different faiths and beliefs (Revised Prevent Duty Guidance for England and Wales, issued on 12 March 2015 and revised on 16 July 2015, definition)