1. UKBA Compliance Visit Experience at UH Sue Grant Academic Registrar University of Hertfordshire

2. Prior to the visit 20 OctoberUKBA rang to say they wanted to visit; 1 NovemberA formal letter about the visit was received ; 2 November UKBA said they wanted to see 30 students from a particular cohort; 4 November A list of students was supplied to UKBA ; Visit took place 7 and 8 November

3. Information from UKBA about the visit “ This visit is in relation to your licence to sponsor migrants under the Points Based System. The purpose of the visit is to ensure that: You continue to have systems in place to enable you to meet the sponsorship duties; You have complied with the sponsorship duties and the specific requirements for the tier(s) you are licensed for; and You are compliant with the work permit arrangements and other immigration related legislation. “

4. Information from UKBA about the visit “…To minimise any inconvenience this visit may cause to you, please be aware that I will need access to your student and staff files. Additionally, I request that you prepare the following information for me to take away: Full staff list of all employees high-lighting all overseas nationals, and stating the names, nationalities, dates of birth and immigration status (including passport numbers, passport expiry dates, visa/residence permit numbers and visa/residence permit expiry date); Hierarchy chart showing lines of responsibility/supervision; Full list of all overseas students stating the names, nationalities, dates of birth and immigration status (including passport numbers, passport expiry dates, visa/residence permit numbers and visa/residence permit expiry date) and course details (including course titles, qualification being studied for, level of course, duration of course, expected end date and awarding body); Attendance registers for each class for the last three months Timetables for all classes Non attendance warning letter – all versions from initial to final warnings Student Handbook”. “…I may also need to undertake additional interviews and to make enquiries of any employee/student subject to Immigration Control, identified during the visit.”

5. Visit Day 1: Meetings with Students UKBA interviewed 30 students; Interviews took up most of the day; UH supported students by being present outside interview room.

6. Visit day 2: Meetings with Staff UKBA outlined: responsibilities of the visiting UKBA team - mixture of policy unit, entry clearance and compliance - more people than we expected were involved from UKBA; Noted this was a formal visit and a record would be taken. Questions will be asked – following a template format; Sponsor Licence holder was cautioned and asked to provide formal proof of identification and sign that he understood the process.

7. Visit The UKBA team outlined reason for visit, compliance, info provided would be assessed, it would include disclosure of information, could affect licence; UKBA reminded UH that information given in this session would be triangulated with evidence from the files, discussions with students and data in the SMS system; UH’s visit also covered staff (tier 2); UKBA Team split into 2; some carried out the interviews with staff, others visited our Student Centre to check out the records.

8. Areas covered by questions: Your Business What is the nature of your business? Can you confirm how long you have been in business, do you own any estate, could you provide evidence of deed, do you have a board, who is the chief executive, responsible officer, board of governors what is the size of the estate? Do you have any partners? subsidiary companies? other commercial activities? What is the main purpose of the business?

9. Areas covered by questions: Your Business Outline your academic calendar, length and dates of academic year, terms, semesters. Do you have any out of term activity pre-sessional courses, semester B entry? Can you outline your student numbers total then split home and overseas. Headcount and FTE? Can you give the same for staff numbers?

10. Areas covered by questions: Recruitment and Marketing Tell us about your marketing recruitment activity. What countries are you recruiting in? How do you decide which countries – can you provide a list? Do you use agents, how are these appointed, contracts, due diligence? Can you provide us with a list of these and the contracts? Do your staff actually visit these countries? Do you liaise with British Council, entry clearance officers?

11. Areas covered by questions: Recruitment and Marketing Do you give agents any staff development? Who makes offers, checks qualifications, take monies? Can you identify which students have been recruited by which agent? Do you pay royalties, against what criteria? Have you ever ceased a contract, if so why? Do you charge a deposit, what terms apply? Can we have a list of all the courses you market to overseas students?

12. Areas covered by questions: Pathway Providers/Partnerships Do you have any relationships with pathway providers? If so can you outline the relationship, who raises the CAS, does the recruitment, do they use the same/different agents. Is their entry criteria the same as yours? Do you know their no show, retention and completion rates?

13. Areas covered by questions: Pre-sessional Do you run any pre-sessional English courses, how do you raise the CASs? How long are the courses what is the minimum level of IELTS required?

14. Areas covered by questions: Admissions Procedures Please explain your application process from receiving the application through to issuing the CAS; What qualifications are required of overseas students, how do they compare for home students applying to the same courses? How do you check qualification, do you keep copies, who sees originals? What records do you keep of qualifications, passports etc?

15. Areas covered by questions: Admissions How many refusals have you had, what is your relation with entry clearance officers and the SMS system? How do you report no shows?

16. Areas covered by questions: Registration Outline your registration process; How do you keep up to date records, personal data – addresses etc. Do you re-register returning students. If so how? Do you have many students who finish early and get exit awards? What documents do you hold on every international student?

17. Areas covered by questions: Placements Do you have students on placements; Is this more than 50% of the course; How is attendance monitored at these placements?

18. Areas covered by questions: Attendance Monitoring How do you ensure that you comply with the UKBA monitoring requirements? How can you be sure this is the actual student?

19. Records checking UKBA visited Student Centre; Reviewed admissions and registration records of the students interviewed the day before including checking copies of documents held on file; Discussed with staff use of SMS system and reporting procedures.

20. Post visit UH received letter confirming HTS had been maintained (24 November 11) “I would stress that the UK Border Agency’s Visiting Officers continually monitor the behaviour and compliance of licensed sponsors. If you fail to comply with your sponsorship duties and/or rules about issuing or allocating certificates, the UK Border Agency may withdraw your licence, where criminal activity is found, issue a civil penalty or refer the case for prosecution.”