1. Glasgow Caledonian University Glasgow School for Business and Society UKBA Compliance/Information Session 11/6/2012 Brian Fitzsimmons UKBA Compliance Officer Laura Wilson UKBA/SAAS Compliance Officer (GSBS)

2. page 2 Contents Points Based System (PBS) of Immigration Compliance Visits/Audits UKBA Sponsorship Management System (SMS) Consequences of Non Compliance Attendance Monitoring and Absence Reporting Early Completion of Programme Authorised Absences - Permission to Leave Dissertation/Final Write Up Period Student Withdrawals Resources

3. Points Based System (PBS) of Immigration page 3 Immigration into the UK is applied for using a Points Based System of Assessment (PBS) PBS consists of 5 separate Tiers Tier 1Highly skilled workers Tier 2Skilled workers with a Job Offer Tier 3 Low Skilled Workers Tier 4Students Tier 5 Temporary Workers

4. Points Based System (PBS) of Immigration The University has a licence to sponsor students/employees under Tier 2 Tier 4 Tier 5 Tier 2 is managed by the People’s Directorate Tier 4 is managed by GCU’s UKBA Compliance Officer Tier 5 is managed by GSBS page 4

5. Points Based System (PBS) of Immigration Tier 4 is the primary route available to students who reside outwith the EEA who want to study Full-Time in the UK They must be sponsored by an education provider that has the appropriate sponsor licence page 5

6. Points Based System (PBS) of Immigration Each sponsor license (Tier 2,4,5) is applied for every 4 years Tier 4 Highly Trusted Sponsor (HTS) status is applied for annually From April 2012 it is mandatory that in order to recruit non EEA students we hold both the sponsor licence (Tier 4) and HTS Status page 6

7. Compliance Visits/Audits UKBA Compliance Visit - 15 th May 2012 As a result of this visit our HTS Status was renewed for one year beginning September 2011. PWC Audit Conducting an internal Audit of GCU’s UKBA Compliance Should begin next month page 7

8. UKBA Sponsorship Management System (SMS) The Home Office developed system which interfaces with Institutional Systems (e.g. ISIS) All student interactions and reporting are carried out on this system and enable UKBA to draw up a comprehensive profile of the institution and its level of compliance page 8

9. UKBA Sponsorship Management System SMS SMS is a reporting tool implemented and administered by UKBA Sponsor license holders must nominate Key Personnel to access SMS Authorising Officer Key Contacts Level 1 & 2 Users The Authorising Officer is responsible for ensuring that all reporting via the SMS is carried out in a compliant manner page 9

10. page 10 Consequences of Non Compliance Ultimate sanction for student not complying is for them to be reported to UKBA and sent home Ultimate sanction for education provider not complying is to lose, suspend or downgrade sponsor licence Result in: Loss of Revenue Job Losses Reputational damage

11. Consequences of Non Compliance Examples of non compliance include Poor attendance monitoring and absence reporting Permitting students to complete programmes early without following due process Late notification to UKBA of student withdrawals page 11

12. Attendance Monitoring and Absence Reporting It is the responsibility of the University to monitor the progress and attendance of all sponsored students during the length of their programme of study at GCU and where necessary to report absence It is also the responsibility of the University to report to UKBA any failure on the student’s behalf in fulfilling their requirements page 12

13. Attendance Monitoring and Absence Reporting What processes are in place to ensure we are compliant? Recording (attendance registers) Monitoring (identify and communicate with students who have absences) Reporting of non-attenders Identify and record Authorised Absences page 13

14. Early Completion of Programme Permitting students to complete their course early must be the exception and not the rule The UKBA expect all students be in attendance at GCU for the full duration of their course. The duration of a course as defined by the UKBA is the start and end dates as they appear on the Confirmation of Acceptance for Studies (CAS) page 14

15. Authorised Absences – Permission to Leave Students must request permission to leave during Term Time prior to arranging travel as approval will only be given in exceptional circumstances. They should: Explain the reason for the leave Formulate a study plan Complete a Permission to Leave Form Provide copies of flight details and a dated passport stamp Discuss visa implications with ISSS page 15

16. Dissertation/Final Project Write Up Period ONLY IN EXCEPTIONAL CIRCUMSTANCES WILL PERMISSION BE GIVEN TO LEAVE THE UK TO COMPLETE THE DISSERTATION/ FINAL PROJECT School must approve/decline request; Approval of such requests must be the exception and not the rule Decision must be fully documented and auditable page 16

17. Student Withdrawals Current Process School decides when a student is withdrawn Student Records/Compliance Officer informed Compliance Officer withdraws student via SMS Once sponsorship has been withdrawn the University has 10 working days to inform, via SMS, UKBA of student’s new status page 17

18. Student Withdrawals There are delays with Schools identifying non attenders The current process is being reviewed as we are not reporting back to the UKBA within the prescribed timescales Late reporting of Tier 4 students via SMS is a serious issue and is seen by the UKBA as Non Compliance page 18

19. Resources Internal UKBA Compliance Information (Staff website) Tier 4 Briefing Document for Staff GCU Attendance Monitoring and Reporting Policy External UKBA guidance for sponsors (UKBA website) Contacts Laura Wilson UKBA/SAAS Compliance Officer (GSBS) Brian Fitzsimmons UKBA Compliance Officer page 19

20. Summary University must endeavor to be UKBA compliant at all times Non Compliance: Consequences are severe SMS is used by UKBA to draw up a profile of the institution and its level of compliance Data must be entered into SMS in a timely and compliant manner page 20

21. Summary Allowing a student to complete course early must always be the exception and not the rule Allowing a student to submit dissertation/final project from the home country must also be the exception and not the rule Vital to record Authorised Absences Vital that Tier 4 student withdrawal process is reviewed page 21