1. Introduction
The Senedd Commission is committed to providing a safe, respectful and inclusive environment for everyone. This document sets out the standards of behaviour expected from members of the public when interacting with Senedd Commission staff.
We welcome engagement from members of the public and aim to treat everyone fairly, courteously and with respect. Accordingly, we ask that everyone who contacts or visits the Senedd behaves respectfully towards staff and others.. These expectations apply to all forms of engagement, including in person, by telephone, in writing, online, and via social media.
The Commission regards any incident of unacceptable behaviour directed against its staff as serious and will take action in accordance with this document.
This document should be read in conjunction with the Dignity and Respect Senedd internet pages and the Visitor Code of Conduct (applicable to those attending the Senedd estate).
2. What we expect
When contacting the Senedd (by phone, email, letter, online or in person), you are expected to:
- Treat staff and others with dignity and respect.
- Communicate politely, without abusive, aggressive or threatening language.
- Respect personal boundaries and follow reasonable instructions from staff.
- Allow reasonable time for responses and engage constructively.
- Use appropriate channels for enquiries and requests.
3. What we mean by unacceptable behaviour
Unacceptable behaviour means any behaviour that adversely affects the dignity of another person. It covers all unwanted behaviour – that is, behaviour which is not encouraged or reciprocated by the recipient, regardless of whether it was meant to cause offence, and whether it is repeated or an isolated incident.
This includes, but is not limited to:
- Abusive, aggressive or threatening language or behaviour.
- Discriminatory or harassing behaviour of any kind.
- Sexual, intimidating or sexually inappropriate comments or actions.
- Repeated, malicious or vexatious contact.
- Damage to property or threats of harm.
More information on what is meant by these is provided in the further information section below.
4. What happens if behaviour is unacceptable
If behaviour is unacceptable, we may:
- Ask that the behaviour stops.
- End a phone call or interaction.
- Restrict how or whether further contact takes place.
- Implement a managed communication plan / require communication to be made in writing only / temporarily cease communication.
- Refuse access to the Senedd estate or ask the individual to leave the Senedd estate.
- Prevent further access to the Senedd estate on a short, medium or longer term basis.
- Retain information related to the individual’s interactions with the Senedd.
- Undertaking an investigation into the facts of the situation.
- Take any further action as appropriate in the circumstances.
- In serious cases, we may involve security services or the police.
In undertaking their duties (and in line with their operational guidance), Security staff might be required to make unilateral ‘in the moment’ decisions to deal with live incidents or occurrences, potentially resulting in persons who are deemed to have acted, or are acting inappropriately being refused access or asked to leave the Senedd estate.
Any further action required beyond immediate ‘in the moment’ actions will be decided by Security, Legal Services and senior management, taking into consideration the nature of the incident, the particular circumstances in which it arises, the safety of other individuals and the democratic right to engage with the Senedd as the Parliament for Wales. Decisions on how to consider an incident will be taken on a case-by-case basis.
Any action taken will be proportionate and intended to protect staff, visitors and the integrity of the Senedd.
Further information
If you are unsure how best to contact the Senedd or need guidance on making an enquiry, please visit: www.senedd.wales/contact-us
You can view our privacy notice at https://senedd.wales/help/privacy/ and our Complaints policy at: Complaints Procedure
It is noted that whilst aggressive, abusive and inappropriate behaviour is not acceptable, the Commission has statutory obligations around certain kinds of requests for information, such as Freedom of Information, Environmental Information Regulations, and Subject Access (including a right to not reply under certain circumstances)
Further information on types of unacceptable behaviour
Discriminatory behaviour
Behaviour that adversely affects a person’s dignity may be based on that person’s age, sex, sexual orientation, gender identity, marital or civil partnership status (or lack of it), race, colour, nationality, ethnic origin, association with a minority, language, disability or medical condition, religion or belief or lack of it, trade union membership or lack of it, domestic circumstances, property, birth or other personal characteristic of the individual. Where it does so, that behaviour will be inappropriate and in breach of this policy.
In many cases, it will also constitute unlawful discrimination or harassment contrary to Equalities legislation (which gives legal protection in relation to many of the characteristics listed above).
A single act of inappropriate behaviour based on many of the characteristics listed can amount to unlawful discrimination. A single act can also be enough to constitute harassment contrary to Equalities legislation.
Sexual harassment / sexually inappropriate behaviour
A particular form of inappropriate behaviour occurs when a person engages in unwanted behaviour of a sexual nature towards another person. As well as being inappropriate behaviour contrary to the policy, it may constitute unlawful discrimination, sexual harassment contrary to Equalities legislation, or the criminal offences of common assault or sexual assault. Therefore it can have disciplinary consequences, and/or give rise to civil and criminal liabilities.
Behaviour ‘of a sexual nature’ can cover verbal, non-verbal or physical behaviour, including, for example, unwelcome sexual advances, standing too close, sexual jokes, displaying pornographic photographs or drawings, asking for sexual favours, making decisions on the basis of sexual favours being accepted or rejected, or sending emails with material of a sexual nature, as well as touching and sexually-motivated violence.
Violence and threats of violence
Unacceptable behaviour includes: hoaxes, damage to the Senedd estate or to property of the Senedd Commission; verbal abuse; violence or threats of violence, or aggression. Threats to do any of the things mentioned in the previous sentence also constitute unacceptable behaviour.
The Health and Safety Executive (HSE) defines violence at work as "any incident in which an employee is abused, threatened, or assaulted by a member of the public in circumstances arising out of the course of his or her employment".
Vexatious or malicious demands
Whilst there is no legal definition of the terms ‘malicious’ or ‘vexatious’ they are generally understood to include communications which are offensive in tone or language, persistent to the point of constituting a nuisance. Malicious or vexatious communications must be reported to line managers in the same manner as all other unacceptable behaviour. Any vexatious communication will be dealt with in line with the current legislation on such issues.
Members of the public may also make unreasonable demands such as seeking inordinate amounts of information, by having inappropriate expectations of the service they expect to receive or by the amount of contact they make with the Commission. Examples include demanding responses within an unreasonable timescale, continual telephone calls or written correspondence, repeatedly changing the substance of a complaint or raising unrelated concerns.
Data Protection and information management
In order to comply with the Data Protection legislation, any personal data in incident reports or any other personal data held by the Commission about people mentioned in those reports must be accurate, factual and non-emotive. Records are stored in line with the Security Retention Schedule and Security Incident Reporting Form Privacy Notice.
Security Incident Reporting Forms are stored securely on Commission servers. Incident reports are shared with only those members of staff who have a business reason to be aware of the information they contain.
For example, if a member of staff has experienced unacceptable behaviour from a member of the public, such as receiving threatening or abusive communications, it may be necessary for Security or the police to have access to personal data such as names or contact details of the member of public in order to prevent further contact.
If other staff are at risk of experiencing unacceptable behaviour from a member of the public, such as a known engagement activity is taking place, they may also be informed for their own safety.
However, other teams within the Commission who are unlikely to come into contact with the member of the public may not have access to the information in the incident report.