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

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

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

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

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.)

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

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

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

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.

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

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

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.

CRM email Centre emails are generally department/course agnostic so no CMA concerns about course content. Rest of content will be checked for compliance before sending Departmental emails/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

CRM email Reviewing how we can use email 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

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

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