1. Consumer Protection Law (Application Stage)
James Bell and Liz Hough

2. What’s happening? The CMA guidance comprises three areas:
(a) Information provision
(b) Terms and conditions
(c) Complaint handling processes and practices
The Which Report

3. What’s changed?
Consumer Protection Law has become more important because:
a greater proportion of Universities’ funding is coming directly from students
AND
Students are in a weak consumer position because:
for most students deciding what and where to study will be a ‘one-off’ decision
Universities are ‘traders’ and students are ‘consumers’ for the purposes of the legislation

4. What does this mean for us?
We can’t ignore it: non-compliance could result in enforcement action by the CMA (reputational damage and future litigation)
The new Consumer Rights Act – came into force October 2015, which will make it easier for authorities to investigate and prosecute
CMA began conducting compliance checks in October 2015

5. Risk Analysis Fees for three years: 100 x 3 x £9,000 = £2,700,000
Living costs for 3 x 9 months: 100 x 3 x £10,000 = £3,000,000
Total = £5,700,000
(Excludes damages for lost time and impact on future career earnings.)

6. What does this mean to us?
We need to provide prospective students with all the relevant information that they need to help them make a decision of where to study and what that will entail.
This means ensuring all essential content is included such as additional costs and optional modules.
Information should be:
Accurate and honest (rooted in truth)
Timely
Consistent across channels

7. Information Provision
Student research and application stage
Offer stage
Acceptance stage
Student enrolment stage
ACCEPT
APPLY
OFFER
ENROL

8. External Events Answering questions Presentations
Refer to how things are at present
Study abroad
Presentations
Discussing when and how change takes place
Signposting

9. UG Prospectus Claims evidenced
We can demonstrate the reputation of our research through REF results
Bring copy to life by leading with examples of research breakthroughs.

10. UG Prospectus Pointing to web as most up-to-date source
New web page with full terms and conditions of why/when course details may change
Input from legal team

11. Study pages
Reviewing course pages and tabs updated to meet CMA requirements:
Where does information sit? eg:
Course information
Total course costs
Regulations and complaints

12. Student blogs
Updating current information from landing page to appear on all individual blogs and touch points.
Text will make clear that bloggers are paid.
T&Cs which bloggers agree to work to within updated to reference CMA requirements.

13. CRM
Centre s are generally department/course agnostic so no CMA concerns about course content. Rest of content will be checked for compliance before sending
Departmental s/newsletter content are all created and/or approved by department. CMA will be scanned for by CRM team but responsibility lies with department
All content is rooted in truth and evidenced

14. CRM
Reviewing how we can use to provide links to key areas (such as through the footer)
Link to consistent information that is maintained online
Need to balance retaining 5 years of CRM for CMA evidence with data protection regulations

15. Campus Events Checklist
Ensure all presentations are up to date
Ensure all collateral (course brochures) are up to date
Ensure Student Ambassadors are briefed

16. Student Ambassadors Encourage to speak from personal experience
‘This year I have had a choice of 10 optional modules…’
‘The way the course is structured at the moment is…’
Encourage them to caveat what they say
WWS Training and agreement