Everyone affected by Party activity, whether directly or indirectly, is entitled to be treated with dignity, courtesy and respect.
Bullying and harassment will not be tolerated within the SNP. Any complaints of this nature will be taken seriously.
Please note that anyone who has been the subject of behaviour that could constitute a crime is strongly encouraged to make a complaint to the Police.
This policy covers all those affected by Party activity, including members of the Party, elected members and volunteers. This policy should be read in conjunction with the SNP Safeguarding policy, and the Sexual Harassment Policy. Please note, separate guidance is available for Parliamentary staff.
All complaints should be directed to the SNP Complaints Officer by email on firstname.lastname@example.org or by telephone on 0131 525 8919.
Creating a Positive Culture
Our aim is to create a respectful and friendly environment across the Party, where bullying and harassment is not acceptable. We all have a role to play in developing a friendly and inclusive environment where members and volunteers respect one another.
Diversity is vital for us to grow as a country and an organisation and we should value one another’s differences as much as our similarities.
Definition of Bullying and Harassment
There are many different ways that bullying and harassment can manifest itself.
- Physical: Threatening or causing injury to a person or property
- Verbal: Teasing, insulting, ridiculing, humiliating or making sexist, racist or homophobic comments to someone
- Social: Excluding others from a group, spreading rumours about them, rejecting or isolating them, or making them feel inferior
- Online: Using digital media to purposefully harm someone, like spreading rumours and hurtful comments through the use of email, mobile phones, social media websites and text messaging.
Harassment means any unwanted behaviour that makes someone feel intimidated, degraded, humiliated or offended. It is not necessarily always obvious or apparent to others. Bullying or harassment can be between two individuals or it may involve groups of people. It may be persistent or an isolated incident. It can also occur in written communications, by phone , through email, or on social media, not just face-to-face. The SNP treat all forms of bullying and harassment in the same way.
Under the Equality Act 2010, harassment is unlawful. The Act also provides legal protection for certain characteristics. These include age, disability, gender reassignment, race, religion or belief, sex and sexual orientation.
The Act defines harassment using the example of two people, A and B. A harasses B if A engages in unwanted conduct related to a relevant protected characteristic, and the conduct has the purpose or effect of: (a) violating B’s dignity; or (b) creating an intimidating, hostile, degrading, humiliating or offensive environment for B.
To decide whether A’s conduct has that effect, there are certain things that must be taken into account: (a) the perception of B; (b) the other circumstances of the case; and (c) whether it is reasonable for the conduct to have that effect.
The perception of behaviour is very important to determining whether or not harassment has occurred.
Online Bullying and Harassment
Technology is often used to harass, threaten, embarrass or target another person. This type of bullying and harassment can take many different forms, some of which are harder to detect or less obviously associated with bullying than others. It can include:
- Threats and intimidation: via comments in websites, social networking sites or message boards, emails, electronic devices.
- Insults and remarks: sending inappropriate or hurtful text messages, emails, instant messages or posting personal information or videos designed to hurt or embarrass someone else.
- Public posts: include photos, messages or pages that don’t get taken down, even after the person has been asked to do so. This might include things that the target has posted themselves.
- Harassments or stalking: repeated and unwanted texting or messaging or online stalking which may be an extension of offline harassment
- Exclusion: Online exclusion can be harder to detect, but include things like, excluding members from facebook groups or deliberately changing campaign plans and not sharing the details.
- Identity thefts: Hacking into someone’s system to copy files, steal information, harass or humiliate. They may set up fake identities, delete information or impersonate someone.
- Manipulation: Putting pressure on someone to share private information or pushing for physical meetings.
In other words cyberbullying is anything that gets posted online and is deliberately intended to hurt.
Anytime, Anywhere and Anonymous
The impact of cyberbullying can be felt immediately and can be far reaching very fast. It can take place at any time and can intrude into places that might previously have been regarded as personal and safe. It’s therefore harder to walk away. Cyberbullying also offers anonymity for the bully.
“It’s just a joke!”
Some instances of cyberbullying can be unintentional. It can be the result of not thinking, for example something sent as a joke may be deeply upsetting or offensive to the recipient.
Making a Complaint
In terms of the communication channels for reporting concerns, the SNP is firm in its belief that allegations of bullying and harassment must be taken seriously and that anyone who considers that they have been subject to such behaviour must feel able to come forward.
Individuals can report any matter on a confidential basis to the Party. The point of contact at SNP Headquarters is the Complaints Officer, who may be contacted at email@example.com and direct dial 0131 525 8919.
If you choose to contact us, it will be treated as a formal complaint.
Where we believe a criminal offence may have taken place, we will advise you to report the incident to the police. If we have serious concerns about your safety or the safety of others, the SNP has a duty to contact the police, and will do our best to let you know before doing so. If your complaint is subject to an ongoing police enquiry, we will not investigate until the police investigation has run its course.
If we receive more than one complaint of a serious criminal nature; or where we are concerned that an allegation may form part of an ongoing pattern of behaviour that could put other party members or members of the public at risk; we reserve the right to report this matter to the appropriate authorities, including law enforcement. If we do need to do this, we will let you know.
- We will request a written statement from you, with as much detail as you remember. We would recommend that you try to keep a diary. It’s vital that there is evidence of such behaviour, and a note of each time, date, type of behaviour and how it made you feel could be useful.
- The respondent will be informed of the details of the complaint made against them, and asked to provide a statement.
- Both parties will be asked to provide relevant evidence and names of witnesses that support their statement to establish matters of fact from both sides.
- The statements from the complainant, respondent and any witnesses will then be provided to the Bullying and Harassment Panel. The panel will be appointed by the NEC, and will be supported by the Complaints Officer.
- All statements will be anonymised before being put in front of the panel, so they will not know the names of the individuals involved in the case.
- Should the panel decide if there is a case to answer, they will decide whether to take a formal or informal resolution route, depending on the wishes of the complainant.
- The Bullying and Harassment Panel reserves the right to request separate interviews with complainant and respondent.
- The Panel may offer their findings to the Member Conduct Committee following their investigations.
- Both the complainant and respondent will be informed of the decision of the Panel normally within 14 days of the evidence being seen by the Panel.
At no point in the process will the complainant be required to confront the respondent face to face. All details of the complaint will be dealt with in the strictest confidence. Reporting of complaints, or the outcome of the panel should not be commented on publicly (in either media outlets or on social channels) and any attempts to do so will be reported to the National Secretary for disciplinary action.
Support for Staff
In addition to the support available from the SNP centrally, staff (HQ, Holyrood and Westminster Group staff and constituency, and elected members have the additional support of Harassment Advisers.
These advisers are trained in how to deal with issues around bullying and harassment, in order to listen to staff and elected members who believe they are being bullied or harassed, to clarify the options open to them and to assist them in resolving the matter.
Where appropriate one of each of the advisers in both Parliaments should be an elected member, and the other a member of staff. All contact will be in the strictest confidence. Harassment Advisers are able to offer advice only, and have no formal role in reporting or disciplinary procedures.
Where a number of concerns have been raised with a Harassment Advisor regarding the same person, indicating a pattern of behaviour, the Advisor may report these to the Bullying and Harassment Panel for further investigation. Complainants will be advised before the report is made.
Complainants will be offered use of the SNP’s wellbeing service. The service is free of charge and anonymous.