House of Commons - Home Affairs

Select Committee on Home Affairs Fifth Report

3 CONTROLS OVERSEAS

74. In our report we follow the path of an applicant through all the various stages of immigration control. The main steps would typically be to:

apply for a visa at a British post overseas
have documents checked by the airline before boarding, and then be questioned by Immigration Officers on arrival at the border
apply to the IND to extend the stay or to settle in the UK

The applicant might also:

appeal against a refusal decision, and
if unsuccessful, be detained and removed from the UK.

As we follow this path we shall look at the effectiveness of the immigration system both in allowing into the country those who are wanted here, and in rejecting or removing those who are not.

The entry clearance operation

75. The first stage of the UK's immigration control is the entry clearance operation overseas. We visited British visa sections in Nigeria, Ghana, Pakistan and India to see at first hand how it operates.

76. Entry clearance, normally in the form of a visa, is required for people of over 100 nationalities before they travel to the UK, whatever the purpose of their journey.[86] Some countries' citizens are required to have a visa even for airside transit in the UK.[87] In addition, people of all nationalities outside the EU who intend to enter for more than six months, or to settle or to marry, must also obtain entry clearance. The requirements they have to meet are contained in the Home Office Immigration Rules.

77. The entry clearance operation is managed by UKvisas, a joint unit of the Foreign and Commonwealth Office (FCO) and the Home Office.[88] A Foreign Office Minister (currently Lord Triesman) has ministerial responsibility for UKvisas but it also reports to Home Office ministers and has a joint management board of senior FCO and Home Office officials. In terms of structure, its headquarters is currently being restructured into five divisions, partly in order to bring quality control issues together. Six Directors of Visa Services are based overseas; Entry Clearance Managers (ECMs) at each post report to these Directors and themselves manage Entry Clearance Officers (ECOs) who take most of the decisions on the ground. A new network of Regional Operations Managers - intended to improve decision quality and consistency across specific regions - is in its infancy, and new Risk Assessment Units are being introduced for high-risk and high-volume overseas posts.[89]

78. UKvisas' aims, as published on its website, state that it aims to:

1. be the overseas arm of an integrated border control to help deliver the Government's Asylum and

5. maintain the highest possible professional standards.

79. Within UKvisas, half of the staff must be drawn from the FCO and the other half from the Home Office, and they therefore have different selection processes, pay and conditions. So, for instance, FCO staff are selected on the basis of paper applications, whereas Home Office staff have to have an interview which tests applicants against qualification requirements. This situation is entrenched by the Memorandum of Understanding which established UKvisas: this states that staff must be selected and employed in line with the procedures of their parent department.[90] When we visited entry clearance operations overseas, we were told that this causes difficulties for managers who have to apply two different sets of reporting requirements, and for staff who are being paid different amounts for the same work because they have a different 'parent' Department. Although some ECOs will stay in post for two or three years or more, there is a high turnover in some posts (Islamabad for example, for safety and security reasons) and a heavy reliance on temporary ECOs (a minibus-load was staying at our hotel in Lagos).

80. Because UKvisas is separate from the IND (which deals with the UK-based aspects of immigration control and with immigration policy), it has different guidance, fees, databases, management structures and targets, even though it applies the Home Office's Immigration Rules. We look critically at each of these topics later in the report. The Public Accounts Committee has also criticised the differences in opinion on standards for entry clearance between UKvisas and the IND, and ineffective communication between them.[91]UKvisas' current business plan assumes that it will continue to operate as a joint FCO/Home Office Directorate.[92]

81. We recommend that the Government should look again at the constitution of UKvisas with a view to unifying the terms and conditions of all of its staff. More fundamentally, it may also wish to consider whether it is in the best interests of an effective and comprehensive system of immigration control for the overseas operation to be separate from the IND.

82. UKvisas is meant to be self-financing, but we found it very hard to tell whether this is actually the case. In 2004-05 UKvisas' income from visa fees amounted to £130 million while its costs were £122 million, leaving a surplus of £8 million.[93] It therefore appears that it does indeed cover its costs. But UKvisas do not currently have a means of breaking down costs into individual activity costs (e.g. issuing visas, processing appeals), although an activity based costing system which would permit this is being developed.[94]

83. A particular problem raised by the overseas posts which we visited was that accommodation costs cannot be met from the resource budget as they are normally capital expenditure, and yet UKvisas does not have its own capital budget. This makes it very difficult for posts with rising numbers of applications and of staff to expand their accommodation accordingly. [95]

84. UKvisas' budgets should be much more transparent if it is to demonstrate clearly that the operation is self-financing. In the light of growing numbers of applications, there should be more flexibility over the accommodation budget.

85. In 2004/05 UKvisas handled 2.54 million entry clearance applications at 156 posts overseas. Overall, 79% of these applications were accepted. The busiest posts are handling around 1,000 applications a day and applications in 37 posts are rising at 30% or more a year.[96]

86. The number of visa applications has been rising steadily for several years, and this trend is projected to continue:

87. UKvisas is taking some steps to deal with the large volume of applications: two recent initiatives have been outsourced application centres (paragraph 90 to 97) and introducing the facility to apply online. However, its business plan suggests that it will make increasing use of temporary staff to deal with increased demand.[97]

88. We were told by UKvisas that the year-on-year rise in refusal rates since 2001 (it was then 10% globally, compared with 19% in 2005) shows that the increase in volume has not resulted in a decrease in scrutiny.[98] We are not convinced that this is a necessary conclusion: it may simply mean that ECOs under pressure are not giving applicants the benefit of the doubt.

89. The number of visa applications looks set to continue rising. UKvisas should not place a heavy reliance on the use of temporary staff to meet this demand. As we state throughout this report, the quality of initial decisions has an impact on the entire immigration system. Measures that lower the cost of front-line staff at the expense of quality are not likely to be cost-effective.

The application process: outsourcing

90. One of the ways in which UKvisas has sought to reduce delays and improve its customer service is through 'outsourcing': partnerships in overseas countries with companies such as VFS, FedEx, DHL, Abtran and others who provide some administrative aspects of the visa application process and cover their costs by levying an extra fee from applicants.[99] The company usually provides a network of application centres across the country, meaning that applicants do not have to travel long distances or send valuable documents by post. The actual service offered and the handling charges vary from country to country: for instance FedEx in Pakistan was originally little more than a courier service but now takes visa fees and gives some information to applicants, whereas VFS in India offers a more comprehensive service. None plays any part in the decision-making process, and none is allowed to give immigration advice to applicants.

91. Outsourcing is expected to be in place in "all posts that require support" by 2007. The new post of Regional Operations Manager (ROM) was created in late 2005 with a specific task of ensuring that all posts in their region adopt streamlining measures. ROMs are supported by a dedicated team in UKvisas who assist them in conducting efficiency reviews. Over the past year China, South Africa, Russia, Thailand, Turkey, Jordan, Indonesia and Nigeria have been added to the list of countries with outsourcing arrangements. As the number of countries covered by outsourcing arrangements grows, UKvisas should keep in mind that a record of success by a contractor in one country will not necessarily guarantee a high standard in another, in which the culture and work environment may be entirely different.

92. We visited outsourced visa application offices in Lagos, Accra, Islamabad and New Delhi, and on the whole were impressed with their operations. Queues were manageable, staff appeared professional and knowledgeable about applications and about the limits of their role, and in Nigeria applicants could even track the progress of their applications online through a helpful website.[100] Although applicants have to pay an extra fee for using the application centre, in addition to the visa application fee, we did not feel this was excessive. After initial difficulties in Islamabad, the first post to outsource, the operations now seems to be running smoothly: we got the impression that links with the visa sections were close and measures were in place to monitor quality and tackle any problems as they arose.

93. Outsourcing has allowed ECOs to concentrate on decision-making and this appears to have had a very beneficial impact on backlogs and waiting times. For instance in Lagos, where entry clearance applications more than doubled from 2003-04 to 2004-05 and are now arriving at the rate of about 1,000 a day, full outsourcing (along with a significant increase in staffing) has allowed queues to be much reduced and a temporary suspension of visa applications from young first-time visitors to be lifted.

94. Outsourcing the collection of visa applications seems to be of great benefit to both applicants and visa sections, and its expansion should be supported as long as close links can be maintained with visa sections.

95. In India we were told that 50% to 55% of applications are made through travel agents, and that an on-line system has been introduced for approved travel agents. There is also a business service where applicants can use couriers and do not have to attend in person. This may give rise to concerns about fraudulent applications, but in some countries with similar schemes the risks are reduced by requiring applicants to collect their passports in person.

96. The UK does not have a visa-issuing post in every country in the world, so there are already significant numbers of people whose applications are dealt with outside their home countries. For instance Accra (Ghana) also handles applications from Ivory Coast, Togo, Niger and Burkina Faso. Even in countries with a visa-issuing post, most decisions are made without seeing the applicant (paragraph 150), and despite what the Foreign Office Minister Lord Triesman told us,[101] any interviews were not, in our experience, generally conducted by the same ECO who had looked at the papers. UKvisas has said that it will explore the case for a pilot regional processing centre to handle applications that can be mainly processed on paper.[102]

97. A comprehensive network of application centres, approved travel agents and couriers should be put in place for collecting visa applications and providing information to applicants, with appropriate measures for preventing fraud and abuse such as requiring applicants to collect their passports in person. Once this is done, we can see no overriding reason why paper-based applications should not be dealt with by country-specific teams in regional processing centres or even in the UK. In principle this could reduce problems of high staff turnover and raise the quality of decision-making whilst reducing the cost of the operation, though interviewing would clearly still have to be done at posts. We recommend that UKvisas should conduct a full feasibility study of this proposal at the earliest possible opportunity.

Information and advice for applicants

98. The applications we saw in posts, both on paper and at interview, suggested that many applicants do not fully understand the evidence ECOs require to make their decisions. ECOs sometimes ask applicants to bring to an interview further documents such as bank statements or photographs confirming family relationships, but since there is simply not time to do this in every case many applications are quite rightly turned down for a lack of evidence. The applicant might be refused for "vagueness",[103] but then appeal and submit further evidence at that stage (causing problems that we look at in (paragraph 337 to 341 below), or re-apply. This is clearly less efficient than if they had submitted the required documents in the first place.

99. Guidance leaflets give some information but this tends to be non-specific. For instance, the guidance for students states:

What supporting documents should I include with my application?

You should include all the documents you can to show that you qualify for entry to the UK as a student. If you do not, we may refuse your application.

As a guide, you should include:

any relevant diplomas or educational certificates that you have
a letter from the university, college or school confirming that you have been accepted on a course of study in the UK, and a statement of charges for the course
evidence of government sponsorship (if appropriate)
bank statements, payslips or other evidence to show that you can pay for your stay and your course of studies in the UK, and
if you are being privately sponsored (for example, by a college in the UK) you should provide a letter from your sponsor giving details of how they will support you during your studies, and evidence that they can do so.

We will refuse your application if we find that any documents are forged.

104

100. The lack of clarity goes deeper than this, in that the Immigration Rules themselves are often vague and imprecise. To continue with the student example, the Rules say that the applicant must show he or she "intends to leave the United Kingdom at the end of his studies" and "is able to meet the costs of his course and accommodation and the maintenance of himself and any dependants without taking employment or engaging in business or having recourse to public funds".[105] This leaves considerable discretion to the decision-maker. Fiona Lindsley, who was Independent Monitor of entry clearance refusals without the right of appeal from December 2003 to November 2005, suggests that it allows them to make decisions which amount to saying "What you are doing is not something someone of your sort of background would do normally, therefore you must be up to no good".[106]

101. However, UKvisas guidance to ECOs on student applications is more specific on the documents which an ECO should look for. On students, it says for example that:

"A student should normally provide an up-to-date letter from a school, college or university containing the following information:

the type of course;

what qualification it will lead to;

the duration of the course;

the number of hours of organised daytime study per week, or confirmation that the course is a full-time degree course at a publicly-funded institution or a full-time course at an independent fee-paying school;

the cost of the course;

whether the fees have been paid in part or in full; and

the level or stage reached (if continuing a course)

107

102. Whilst this information is available on the UKvisas website, it is by no means clearly signposted.[108]

103. We were not impressed with the argument, raised several times by caseworkers we met on our visits, that providing detailed information on the type of evidence needed is undesirable because it makes fraudulent applications easier by providing greater clarity for bogus applicants too. Fiona Lindsley, former early clearance monitor, suggested to us that UKvisas might be reluctant to set out this kind of detailed information because in certain countries those documents will not be available, but this difficulty could be alleviated by having better sources of advice for applicants.[109]

104. ECOs have specific expectations of the documents needed to support an application. These are not set out in the Immigration Rules nor explained in guidance for applicants. Where there are specific requirements in practice, this should be made clear in the Immigration Rules and in guidance for applicants. Security might be improved by changing the list of required documents from time to time.

105. A well-informed application can be dealt with much more easily than a poor one. However, in addition to a lack of detailed written guidance, there appears to be very little good-quality advice for visa applicants. We asked to meet local immigration advisers on our trips overseas but there seemed to be very few professionals who met this description. The firm we met in Lagos which advertised themselves as immigration lawyers dealt with only a handful of cases each year, and suggested that many applicants are given poor advice by non-professionals. Keith Best of the Immigration Advisory Service told us that

110

106. In Islamabad we saw "experts" who had set up in the grounds of a Mosque across the road from the FedEx application centre and charge visa applicants for their advice; visa staff told us that they frequently encounter applicants who complain when this advice turns out to be incorrect. We could not assess the quality of their work but there must at least be a potential for abuse and exploitation. We were also told that in Lahore there are advertisements on big hoardings for agents who say they can get anyone student visas for the UK or Australia.

107. There are however some good examples of professional advice for overseas applicants. The Immigration Advisory Service (IAS), a UK-based charity which provides immigration advice as well as campaigning for changes in the law, has recently opened an office in Sylhet in Bangladesh to try to assist clients in getting their applications right first time rather than going to appeal, or (knowing the criteria applied by ECOs) advising them not to apply if they do not have a good chance of success. They feel the project has been very successful and have therefore opened another office in Lahore and have plans for a number of other small offices around the world.[111]

108. We also heard from a Chinese solicitor in the UK whose firm has recently set up a branch in China. The office is in the same building as the British Embassy: "every time the British Embassy has a problem, they send people up to us and we can explain to them in Chinese what is going on there."[112]

109. The former Independent Monitor for entry clearance refusals, Fiona Lindsley, strongly supported the provision of good advice to visa applicants in her 2004 report:

113

110. Providing a good advisory service would not necessarily get rid of poor advisers, though, as there are always likely to be people willing to charge less for what they would claim is the same service.

111. The Office of the Immigration Services Commissioner (OISC), which is responsible for regulating immigration advisers in the UK, is concerned that the proposals under the Points Based Scheme[114] for deciding more applications abroad will mean an increased reliance on unregulated local advisers at the expense of regulated UK-based advisers. It refers to the Australian scheme for registering immigration "agents" working abroad which was set up because local agents tended to be ill-informed, incompetent and even corrupt.[115] Entry clearance staff in Islamabad felt that an agent accreditation scheme would give people the choice over whether or not to use an approved one, but that it would still be difficult to stop corruption. British posts do already provide lists of local lawyers in some circumstances,[116] but they do not accredit them.

112. The OISC links the provision of immigration advice overseas with trafficking networks: "There are credible reports of human trafficking and general abuse of the UK's immigration system by overseas criminal networks. It is possible that the provision of deliberately false or improper immigration advice to applicants whilst abroad may actually result in a lucrative sideline for such networks."[117] It suggests that all those applying for permission to work in the UK should have the opportunity to have their applications checked by a "reputable" immigration adviser.

113. Measures that improve the quality of advice to applicants will improve the quality of initial decisions and reduce the demand on the appeals system. The Government is already considering whether or how to regulate overseas advisers.[118] This cannot simply be an extension of the scheme for regulating UK advisers. We recommend that it either encourages UK-based advisers to operate overseas, or establishes an agent accreditation scheme for local immigration advisers.

Decision-making

114. It is clearly beneficial to everyone to invest in getting decisions correct at the initial stage. Refusing applications which should have been allowed is not good customer service, can have significant consequences for applicants and their family and friends, and can lead to increased costs further down the system (from complaints, appeals or fresh applications). On the other hand, allowing applications which should have been refused weakens the control and public confidence in it, and may increase the risk of overstaying and other forms of illegal migration.

115. Poor quality decision-making at first instance is an issue that is often raised across the whole immigration and asylum system. Our predecessor Committee's report on asylum applications expressed concern over the poor quality of much initial decision-making by immigration officers and caseworkers.[119] Much of the evidence given to us criticised the quality of decision-making by ECOs. The IAS developed in some detail their claim that there is a 'culture of disbelief' within the entry clearance process. They argued that in some posts ECOs see themselves as a Thin Red Line rather than as modern service providers. They claim that background questions are "in truth designed to elicit reasons for refusal", and that decisions are based on a distorted idea of average human behaviour in which the worst motives are assumed, often based on racial and cultural stereotypes, and on expectations which are unrealistic given local conditions. IAS gives examples:

120

116. IAS claims that "an arms race or escalation situation develops, where unreasonable requirements become local practice at a Post, to which applicants then have to respond. When they do, the requirements are ratcheted up yet further on the basis that the earlier requirements were too lenient and accessible." They add that ECOs directly as well as indirectly trick applicants into providing reasons for refusal.[121]

117. We also heard about the difficulties that faced those seeking a visa in Zimbabwe. Crispen Kulinji told us that the average salary in Zimbabwe was 9 million Zimbabwe dollars: but an applicant for a visa was expected to show a bank statement with 100 million dollars in the account for three months. The visa fee, when agents' fees and other expenses were included, was over 39 million Zimbabwe dollars. Given that there was no certainty that a Zimbabwean with a visa would be granted entry on arrival in the UK, and given the presence of Zimbabwean police and security forces around the British High Commission (because of its proximity to Mugabe's office), it was not surprising, he argued that many Zimbabweans turned to irregular methods of entering the UK, such as using a forged passport from a neighbouring country.[122]

118. The Immigration Law Practitioners' Association (ILPA) comments that its members' experience is of "considerable variation in the substance and quality of decision-making between different posts abroad", and frequent poor-quality decisions by immigration officers, with obvious errors of law and errors arising from failures to consider documents provided. They recommend that consideration should be given to accreditation of ECOs under existing schemes set up for the accreditation of immigration lawyers.[123] We consider this proposal at paragraph 217 below.

119. The former independent monitor for entry clearance refusals, Fiona Lindsley, told us that although she felt UKvisas had made good progress in speeding up decision-making, the focus now needed to shift to quality of decisions.[124] While she found that ECOs are generally polite, well-motivated and hardworking,[125] she also had many criticisms of the decisions she had seen, alleging that decisions made on the basis of finance were of especially poor quality (even though this is one of the clearer requirements); that frequently no sensible criteria were given for decisions on intention to return (which she thought should be explored at interview rather than assumed); and that decisions based on socio-economic class were made by ECOs who had no understanding of the local culture.[126] In her report for 2004 Ms Lindsley repeatedly criticised ECOs for not applying the Immigration Rules or for imposing requirements which were not in the Rules:

"It is a nonsensical reason to refuse a visa for not knowing someone in the UK where this is patently irrelevant…it says nothing as to whether these applicants will comply with the Immigration Rules";
"It is not lawful to refuse a visa application on the basis that the applicant is associated with someone who has lawfully varied their leave";
"It is not a requirement of the Immigration Rules that such applicants should have any understanding of medical matters: it is the letters from the doctors which should explain the condition";
"ECOs are effectively adding a number of requirements under the auspices of the requirements to leave at the end of their studies and being able and intending to follow the course set out in the Immigration Rules".[127]

120. During our visits we were consistently impressed by the care and diligence with which entry clearance staff worked, despite often difficult conditions, rising numbers of applications and increasing levels of forgery and fraud. However, we felt that they were not always in a position to be able to make good decisions. A large part of the difficulty is, as we note above (paragraphs 100 to 104) that the Immigration Rules do not provide a clear, precise and comprehensive basis for decision-making. They have also been amended scores of times since their last consolidation in 1994. Colin Yeo of the IAS suggested that they "often present a list of issues to be addressed rather than a list of criteria which you might or might not meet".[128] They also include a number of what might be called "subjective" tests, including intention to leave the UK, intention to follow a course of study or intention to live together.[129] As a result, there are very few applications which can be decided by an entirely mechanistic application of the Rules. In the decisions we saw during out visits to posts, there was nearly always an element of judgment in deciding on the validity and sufficiency of evidence, even before considering the "subjective" elements of the Rules such as intention to study.

121. ECOs currently use published and unpublished guidance and their own experience to decide whether or not these conditions have been met. In our experience from the visits they rarely looked at the Rules themselves. Their refusal letters (often using pro forma templates) frequently give grounds which are not in the Immigration Rules, such as "the course is widely available in the applicant's home country," or "the course is inconsistent with the applicant's previous pattern of study". In cases like these (which we saw during our visits to the AIT) the ECO presumably felt that the application was not justified or realistic, but the reasons given are not in the Immigration Rules. Grounds for a refusal which are not themselves requirements of the Immigration Rules would be struck out if it went to appeal.

122. There are three issues here: the adequacy of the Rules as a basis for good decision-making; how to deal with situations not precisely covered by the Rules; and how to show that a decision has been made in accordance with the Rules.

123. The clearer and more specific the Immigration Rules, and the more closely they deal with realities presented by applicants, the easier it will be for caseworkers to make a correct decision which is unambiguously in accordance with those Rules and fair both to applicants and to the interests of the UK. At the moment it is very difficult for them to do so. The Immigration Rules should therefore be consolidated and redrafted to provide a clear, comprehensive and realistic framework for decisions.

124. It must also be recognised that there will always be questions of judgment over what weight to give pieces of evidence, as well as situations which are not precisely covered by the rules. ECOs must be supported with enough training, guidance and experience to exercise their judgment where this is required.

125. If ECOs' decisions are to withstand challenge, ECOs must be better trained on how to evaluate both oral and written evidence, and how to express the grounds for their decision in a defensible way. We develop the subject of training and guidance at paragraphs 129 to 143.

126. It has been suggested that, under the new Points Based System for entry clearance decisions on students and workers, the subjective element of decision-making will be removed. The July 2005 consultation document stated that the criteria will be completely "objective and verifiable".[130] We do not see how this can possibly be the case, and we are very concerned about the loss of control if there were no questioning of applicants. Entry clearance staff told us that if the system becomes wholly document-based there will be major abuses in countries such as India, Pakistan and Nigeria. Dhananjayan Sriskandarajah of the IPPR said "you can never make clear, objective, bureaucratic, technocratic decisions about the movement of people".[131]

127. Although we can see the advantage of the proposed Points Based System in allowing applicants to work out much more accurately their chances of success, it must be recognised that an element of individual judgment will always be required. This will also be true of the many decisions on categories not covered by the Points Based System. Therefore there will be a continued need for well-trained, experienced, well-supported ECOs with good local knowledge. We reiterate our concern that under-investment in frontline staff is unlikely to be cost-effective across the system as a whole.

128. One concern about using individual judgment in decisions is that casual assumptions or generalisations which could amount to racism or other kinds of discrimination might go unchecked. Both IND and UKvisas are subject to the general duty under the Race Relations Acts to promote good race relations, and although there is an Immigration Race Monitor she has only a very limited role which does not extend to checking this kind of behaviour.[132] The current role of the Independent Monitor is very limited, and yet both the IND and UKvisas are subject to a duty to promote good race relations. Race monitoring must cover all aspects of the immigration system if statutory duties are to be met. This is not the only area where monitoring is lacking. Below we look at oversight of the immigration system more generally (paragraphs 599 to 603).

Training and monitoring

129. As we have already noted (paragraph 119), decisions can only be well made if ECOs have a good knowledge and understanding of local culture, society and condition, are fully aware of the law, and are well-trained in analysing and judging evidence on paper or in person and in expressing their judgments soundly.

130. At the moment Foreign Office ECOs are given three weeks initial training in the UK, and Home Office IOs undertake an ECO conversion course.[133] We are told that training on decision-making has recently been enhanced. On our visits we were told that measures were in hand to improve the quality of refusal notices, in order to ensure that the evidence on which decisions were based are more clearly and consistently presented.

131. Decision-making is a serious business which includes identifying the relevant facts, identifying material inconsistencies, applying the law to the facts, and exercising discretion where it is required. An ability in these matters takes time to acquire, and needs training, mentoring, monitoring and regular review. The former Entry Clearance Monitor, Fiona Lindsley, is concerned current training is inadequate in showing ECOs what evidence is needed to back up their decisions and how to conduct an interview in ten minutes.[134] Christine Lee, a solicitor, considers that three weeks' training is not enough, especially compared with the time it takes to qualify as a solicitor.[135] When ECOs arrive in post, the training available varies, with only the larger posts offering in-house training programmes.[136]

132. Because most ECO training is done in London and not all posts offer training on arrival, there is little emphasis on training on local culture. However, there are some good examples: Keith Best of IAS told us of an initiative in Dhaka under which locally-engaged interpreters sat down once a month with the ECOs and talked about their own cultural background and the aspirations of people from that background;[137] and we felt that the ECO training offered in Accra (which was apparently more extensive than in many posts) was strong on local culture—for instance staff had compiled a useful handbook on Ghana. In Islamabad, where we were told ECOs need about two months to get fully up to speed, new arrivals are given training on aspects of Muslim culture.

133. We had the impression that ECOs gain their local knowledge from dealing repeatedly with applications and talking to colleagues, rather than through immersion in local life. We met very few staff who lived amongst local people (in some posts of course security concerns make this impossible).[138] The limited amount of time some ECOs spend in post also means that they are less likely to develop local knowledge.

134. We recommend that training for visa staff should be extended and improved. Training in the UK must pay more attention to evaluating evidence, questioning applicants at interview and writing reasoned refusal notices. Posts should follow the good examples set by Accra and Islamabad, particularly regarding training in local conditions and culture. We have proposed above that paper-based decisions could be made in regional centres or in the UK, but all staff would still need appropriate training and local knowledge. The use of temporary staff must be kept to a minimum.

135. ECOs are managed by Entry Clearance Managers (ECMs). UKvisas told us that ECMs set and monitor objectives and are responsible for operational performance and quality control; they sample a daily percentage of all visa issues; they review non-appealable visa refusals within 24 hours and all appealable refusals following receipt of an appeal; and are available to discuss decisions with ECOs before a final decision is made.[139] However, we got the impression in posts that ECMs did not have time to do all these tasks properly, in particular reviewing appeal decisions. As we conclude later (at paragraphs 336 to 347), the time saved by not conducting effective reviews generates considerable expense and personal distress at a later stage in the appeal system. UKvisas should ensure that the ratio of managers to ECOs is high enough to allow them effectively to carry out all the quality control checks and reviews required of them.

136. UKvisas has taken some steps centrally to improve quality control. Three UK-based teams have been brought together to improve the quality of decision-making (Control Quality, Systems Quality and Decision Quality).[140] A new post of Regional Operations Manager has been created with the aim of delivering decision quality and consistency to medium and smaller posts.[141] Risk Assessment Units in high-volume, high-risk posts help ECOs determine the categories of application with the highest risks and assess decision-making processes (see below paragraphs 163 to 165).[142] Home Office Presenting Officers have been travelling to overseas posts to discuss decision-making, evidence and reasons for refusal, and they also fill in some Quality Assurance feedback forms on ECOs' decisions.[143]We support the intention underlying the recent measures to improve the quality of decision-making overseas, but urgent consideration should be given to assessing whether quality is indeed improving as a result. The savings resulting from investment in good initial decision-making should also be assessed.

Internal reviews

137. A growing number of visa refusals are overturned when ECMs review them. In 2005-06, 2.3% of refusals were overturned by ECMs, compared with 1.8% in 2004-05 and 1.4% in 2003-04. They are described as an "administrative check on the quality of refusals."[144] We have not seen a set of rules and principles for when these internal reviews should be carried out or of what they should consist. They do not appear to amount to a transparent opportunity for unsuccessful applicants to rebut the reasons given for refusal, which means that applicants have to go to appeal instead.

138. The National Audit Office found in 2004 that in 34% of the successful appeals against entry clearance refusals in its sample, the decision was overturned because of additional evidence (see paragraph 336 below).[145] We feel that it would be better if such cases, which can effectively amount to a fresh application, were handled quickly and efficiently by posts.

139. Matthew Davies of the Immigration Law Practitioners' Association suggested to us that there should be a "minded to refuse" stage when an applicant is given a chance to rebut the reasons for potential refusal.[146]

140. All unsuccessful applicants should be given the opportunity for an internal review of the decision, to which they could submit any further evidence. There should be clear rules and procedures on how such reviews should be carried out, and reviews should be available for appealable as well as non-appealable refusals as they would reduce the likelihood of going to appeal. We believe that the Government should assess the feasibility of a "minded to refuse" stage for both overseas and in-country applications.

Entry clearance targets

141. The National Audit Office (NAO) raised serious concerns about UKvisas' targets in its 2004 report on the entry clearance operation, saying that their focus on speed meant that staff "did not always have sufficient time to consider more thoroughly applications that raised doubts….in many of the posts that we visited, entry clearance staff considered that the daily processing targets took precedence over control issues".[147] Migration Watch UK is concerned that the very rapid increase in visa applications to the UK from throughout the developing world has led to an emphasis on speed of processing rather than "effective immigration control" at entry clearance posts.[148]

142. UKvisas' current PSA targets are almost entirely focused on speed:

PSA 1: 90% of straightforward non-settlement applications resolved within 24 hours

PSA 2: 90% of non-settlement applications requiring further enquiries or interview decided within 15 working days

PSA 3: 90% of settlement applicants to be interviewed within 12 weeks (except in four busy settlement Posts (New Delhi, Bombay, Dhaka and Islamabad), where maximum waiting times for a settlement interview are set by Ministers)

PSA 4: 60% of visa applications to be processed by posts with Risk Assessment Units or visa assessment teams in 2005/06, rising to 70% in 2006/07 and 75% in 2007/08.

143. The NAO compared the turnaround time offered by UKvisas with those of some its major counterparts: Australia, Canada, Germany and the United States. Only Canada had similar targets to those of the UK.[149] On our visits overseas we discovered that the US requirement to interview every applicant means that in many countries they have to wait for months. The UK has a much tighter target for speed of visa decisions than most other countries. Turnaround times for applications to Australia and Germany, for example, are seven or fourteen days, whereas those who want to go to the United States often have to wait for months. The degree of contrast between the UK and other countries surprised us. Whilst it is right to take pride in the speed of decision-making, there is evidence that this is happening at the expense of quality.

144. UKvisas is aware of the need to ensure quality as well as speed of decision-making, and is hoping to introduce a new set of targets next year which will give more emphasis to control issues:

"Our current targets focus mainly (PSA targets 1-3) on speed of customer service. The control element is reflected in PSA target 4, but more needs to be done…we are introducing a balanced scorecard throughout UKvisas' business, focused on outcomes in five areas: Controls, Customers, Costs, Confidence, Capabilities. We aim to agree new PSA targets taken from balanced scorecard measures, in time for the new public spending triennium 2007-08, focusing on Controls and Customers.

150

145. All the ECOs we met felt that current targets meant they were not always able to make the checks they would like, and that this probably led to some people being allowed into the UK who should not have been, as well as some wrongful refusals. Staff in Islamabad told us that there is an inverse relationship between quality of decision-making and tightness of targets.

146. Lack of checks can also work against an applicant and result in wasted time and costs all round. Matthew Davies of ILPA voiced his concern that "the investigation and the inquiry is not thorough enough for those that they are deciding to refuse, and that decision to refuse can have major implications for an individual". Mr Davies gave us the example of an application for a spouse's visa where a quick check would have avoided a mistaken refusal and an appeal. The ECO had doubted that a marriage was genuine because he did not think the Islamic marriage certificate looked genuine. When the refusal was appealed, the imam at the mosque gave evidence to say that it was a genuine certificate. By the time of the appeal, the ECO had apparently accepted that it was in fact genuine.[151] Another example of an appeal which was successful because the ECO had not made sufficient checks was provided by Christine Lee of Christine Lee & Co, Solicitors, who says her firm wins 90% of the appeals it brings against entry clearance refusals.[152]

147. ECOs in some posts have only a few minutes to decide applications on the papers. The UKvisas guide Best Practice Entry Clearance Work gives a target of ten minutes for the more straightforward applications,[153] but the reality in Lagos was an average of 7 minutes per application and in Accra it was 12 minutes.[154] This scarcely gives ECOs time to read the application form and the documents submitted, let alone undertake any further checks. ECOs in Islamabad told us that it was hit-and-miss whether or not they spotted forged documents because the targets did not give them enough time. Average times per application are far shorter than for in-country applications handled by IND caseworkers, who get on average 1 hour 24 minutes for postal applications and 1 hour 42 minutes for applications made in person.[155] It is not clear to us how overseas decisions can be made so much more quickly than in-country decisions.

148. Time constraints also make it hard to write a robust set of reasons for decisions. Fiona Lindsley, the former Entry Clearance Monitor, told us that often when she reviewed a file she found that the decision was made badly because the information she would want to make the decision was not there: she could not tell whether it was the right or wrong decision. For instance, she suggested that three-quarters of refusals on forgery grounds are not supported with evidence, when even a note on the file setting out the reasons for considering the document a forgery or the name of the person in a bank who confirmed it was a forgery would suffice.[156] This is clearly unsatisfactory, and causes problems if the refusal goes to appeal. ( see paragraphs 342 to 346 below).

149. Targets must allow more time to make decisions and to justify them robustly. Seven minutes is not enough, in our view, even for apparently straightforward applications.

150. In both Lagos and Accra, as few as 10% of applicants are interviewed, although the British High Commissioner in Nigeria told us that roughly 40% of their 1,000 applications a day were 'doubtful' cases which needed investigation. The former Entry Clearance Monitor, Fiona Lindsley, was sceptical about how ECOs can assess matters such as intention to leave the UK at the end of a visit without interviewing the applicant,[157] and Keith Best of the IAS suggested that an appeal might be the only time that the applicant has questions put to them which the have an opportunity to answer.[158] There should be greater recognition of the circumstances in which interviews are appropriate, and targets should allow for more interviewing than currently takes place.

151. The NAO reported in 2004 that UKvisas' targets do not encourage posts to manage their operation in the most cost-effective manner.[159] The Entry Clearance Monitor's June 2004 report comments on the effect of considerable peaks and troughs in demand over the year: "There is…a notable correlation of the seasonal increase in refusals with the seasonal decrease in applications, posing another explanation that refusal rates rise at times of lesser stress on decision-making entry clearance officers."[160] Migration Watch UK suggested that this meant that "standards have to be lowered in peak periods to get through the numbers involved… If they lead to additions to the illegal population in the UK they don't show up in the system whereas visa delays do."[161]

152. It was also clear to us from our visits that different posts operate under hugely varying pressures. For instance we were told before visiting Pakistan that it was currently exempt from the PSA target because of the difficult circumstances there (though, surprisingly, staff at the post when we visited seemed unaware of the exemption and were still trying to reach those targets).

153. Current global targets for speed of processing visas are inappropriate, unhelpful, unrealistic and uncompetitive. We recommend that UKvisas sets more generous maximum targets and then works with individual posts to determine local targets that are appropriate to the local situation and security risks and the demands of good customer service. Posts should be given adequate resources to meet realistic yet challenging targets.

Access to information

154. One of the consequences of having an immigration system run by a number of different authorities is that it is impossible to track applicants through the system and therefore ECOs cannot tell whether or not they are subsequently deemed to have made a good decision. UKvisas, the IND and the AIT use a multiplicity of databases,[162] give people different reference numbers[163] and do not routinely share information. Unless an entry is made on the Home Office Warnings Index (the secure database against which all applications are checked) and the person makes a subsequent visa application, ECOs will never know whether the person was actually allowed into the UK or complied with the terms of his leave. Individual ECOs are rarely involved in appeals against their decision or informed of the outcome,[164] though appeals determinations are apparently sent to posts; and they have little confidence in appeals outcomes, a point we develop at paragraphs 332 to 335 below.

155. The Constitutional Affairs Committee has for some time been calling for the adoption of a single reference number for each applicant in asylum and immigration cases to track cases from initial application (both in-country and out of country) to final determination. The Committee felt that this would substantially improve the system by ensuring that the entry clearance operation, the Home Office and the Tribunal all knew who was in possession of the case.[165] The Government's response was that key reference numbers from the different stages are now searchable throughout the process, but that a longer-term solution towards the development of a single reference number is likely to be an expensive and complex exercise.[166] We were told that "there is no recent assessment of the costs and practicalities of introducing a unique reference number".[167] However, this may be changing because more recently the Home Secretary has identified the lack of a unique identifier across the immigration and criminal justice systems as one of the problems relating to foreign national prisoners.[168]

156. One step which must be taken to enable individuals to be tracked through the system is to introduce a single reference number for each individual which is used to identify them in visa applications, in-country applications, appeals and enforcement. Once this is in place, the Government should investigate the possibility of ensuring that it can be transferred into other databases including those for the police, the prison and probation systems and the Department for Work and Pensions.

157. Although each application is checked against the Home Office Warnings Index by a dedicated team before going to the ECO, the computer system used by ECOs, called 'Proviso', does not run any automatic checks on applications even within the UKvisas Central Reference System, let alone against other databases. Yet this would clearly help to identify abuses. When an ECO we met in Accra recognised a familiar-looking sponsor's telephone number and ran a manual check, 23 applications were discovered which used that same number with different names and addresses, and checks on those names and addresses revealed 25 further applications. We were told in Islamabad that it is not possible to check applications by passport number, meaning that individuals who change name and apply for a passport under their new name effectively wipe out their immigration history. These problems may stem from the fact that the database was developed as a tool for keeping records rather than for purposes of analysis and investigation.

158. Even where ECOs have been instructed to carry out manual checks, it appears that they are not always doing so. This was the case in Islamabad; yet when we happened to ask an ECO to run a check against the sponsor's details in an application that was about to be granted, it revealed an address in Luton which had been used for about 130 other applications, over 30 of which had been successful.

159. The next version of the UKvisas caseworking system should run automatic checks against all fields in an application which would alert ECOs to possible fraud. Meanwhile staff should be given enough time to carry out systematically those checks which are possible with the current database, and ECMs should monitor this carefully.

160. We are told that from 2008 UKvisas will have access to an expanded system of watch-list checks (from UKvisas themselves, IND, police and HM Revenue and Customs), and that it will also have a new caseworking system intended to enable closer integration with IND.[169] UKvisas is also in discussion with the Serious and Organised Crime Agency (SOCA) about a possible Partnership Agreement on sharing information which they hope to sign by the end of the summer. At the moment it cannot run checks on applicants against police databases, though some information from the police is on the Home Office Warnings Index. We encourage UKvisas to continue efforts to work more closely with other authorities, including the police, so that the best possible information on visa applicants is available to them when making a decision.

Tackling forgery and fraud

161. Forgery and fraud are now the biggest problems in immigration applications. They are particularly acute at the entry clearance stage in countries where corruption is rife. Mandice Campbell, then Head of UKvisas, told us that "in the overseas environment forged supporting documents [are] a big problem. Obviously in a lot of countries it is difficult to get the authentication of documents and we find there are high levels of fraud with financial documents."[170]

162. In Nigeria, for example, we were told even by the Nigerian lawyers we visited that it was normal for people to rely on forged documents. We saw forged documents at all the posts we visited: British electricity statements which can be bought in the local markets and used to try to meet the "maintenance and accommodation" requirement of the Immigration Rules; numerous forged bank documents, some of which corrupt bank officials had authenticated when questioned; and even a forged letter from a British Member of Parliament on headed notepaper which apparently confirmed an appointment in the House of Commons.

163. Posts are developing their own expertise on the kinds of forgery and fraud common in their areas, for instance in the Forgery Unit at the British High Commission in Islamabad which we visited. They are clearly in the best position to do this. Risk Assessment Units (RAUs), which have a particular focus on forgery and fraud, are now in place in major posts around the world, and the network is expanding.[171] Their job is to identify applications that present a potentially higher risk and subject these to extra checks, and to examine the effectiveness of decision-making processes. In doing so they work with the IND Intelligence Service.[172] The aim is to ensure that the riskiest applications are thoroughly checked, and allow applications identified as less risky to be dealt with more quickly. RAUs take a variety of approaches: for instance we saw that the risk assessment process in Islamabad is at arm's length, assessing patterns and trends of abuse and placing warnings on the computer system, whereas in New Delhi risk assessment staff are more involved in individual applications. Although in the past there had been no way for Risk Assessment Units to record their findings, they now issue practical guidance and in some cases Document Verification Reports.

164. It was not yet clear whether the work of RAUs had had a significant impact on reducing successful fraudulent applications. They do identify areas of particular risk, but what is less clear to us is how resources are re-deployed to tackle those risks effectively, and how the effectiveness of any re-deployment is measured.

165. We consider risk assessment work to be a potentially valuable approach which could help ensure resources are targeted at those applications where forgery or fraud are most likely. The Government must ensure that Risk Assessment Units' findings are clearly and comprehensively recorded and disseminated, and used to re-deploy staff to areas of greatest risk. The effectiveness of these measures in discovering forgery and fraud must be monitored.

166. Of course it takes time to carry out checks against forgery and fraud. We were told in New Delhi, for instance, that ECOs do not have time to contact universities to find out if the offer letter submitted with a student application is genuine, even though such a check could be concluded within a day or two. This reinforces the concern we express above (paragraphs 141 to 153) about lack of time for making proper checks. Even when applications are turned down on the basis of forgery or fraud, applicants may well simply try again as there is no reason for them not to. A new approach is needed, and the one being followed in Ghana seems to provide a good model. It was described to us by Mandie Campbell, then Head of UKvisas:

173

167. We were told that the prison in Accra to which offenders may be sent is hardly of British standards, but that many offenders are apparently fined rather than imprisoned. We understand that it is the organised criminals who are reported, rather than individuals who may be simply naïve or badly-advised. Other countries' visa sections in Accra are looking at following the British example.

168. In every country where there is sufficient confidence in the criminal justice system, fraud and forgery in visa applications must be reported to the local police.

169. In response to high numbers of apparently abusive applications, UKvisas sometimes suspends visa services for a whole category of applicants in a particular country. For instance, visa services in respect of Working Holidaymaker applications were suspended in Malaysia, Sri Lanka, Namibia and Botswana in March 2005 and had still not been resumed in June 2006.[174]In Nigeria an unprecedented level of demand led to a temporary suspension of all applications from first-time visitors aged 18 to 30, a group which took a large amount of time to process because around 80% were refused; the notable increase in the number of student applications during this time was, staff feared, the knock-on effect of the suspension.[175] There have also been allegations of fraud regarding the UK ancestry visa route for Zimbabweans, which led to a suspension of applications in this category and then increased scrutiny for Zimbabweans over other nationals.[176]

170. Suspension of visa applications produces inconvenience and frustration for genuine applicants, possibly results in some applicants trying another route instead, and leads to backlogs when the category is re-opened. This is not acceptable. Where high levels of forgery or fraud are detected in a particular category such as the Working Holidaymakers scheme, UKvisas and the Home Office must consider whether such provisions should be modified or removed. Where this is not appropriate, applications should be handled by a specialist team whilst investigations are carried out.

Fingerprinting visa applicants

171. In a major initiative aimed at tackling fraud, the Government is gradually introducing biometric visas across its visa issuing posts.[177] All entry clearance applications in Sri Lanka, Djibouti, Ethiopia, Eritrea, Tanzania, Uganda, Kenya, Rwanda, Democratic Republic of Congo, the Netherlands and Vietnam must now be accompanied by a record of the applicant's fingerprints. By 2008 the Government hopes to be collecting fingerprints electronically from all visa applicants, including visitors, in posts throughout the world and checking this against immigration and asylum fingerprint databases.

172. UKvisas told us that information collected in the initial pilots "is proving effective in revealing applicants who seek to conceal an adverse immigration history from the entry clearance officer by using a false identity".[178] They add that it is difficult to project what the effect of routine fingerprinting will be on refusal rates, since they cannot tell how many potential applicants were deterred from applying because of the much greater risk of discovery of previous immigration abuse. But they anticipate that the global introduction of fingerprinting will have a lasting deterrent effect.[179]

173. Applications submitted at those posts which require fingerprints accounted for 3.44% of the total number of visa applications in November 2005. From July 2005 until December 2005 there were 8,049 matches against the Immigration Fingerprint Bureau database, from a total of 40,151 applications in these posts (20%). The majority of these (7,596) were matches against previous visa applicants rather than asylum applicants,[180] but a match does not necessarily mean that the current application is fraudulent. In these nine posts, 321 applicants have so far been refused as the result of a biometric match (0.7% of applications).[181]

174. However, fingerprints are not being used as fully as they should be. They are checked at the border to compare them with the prints given with the visa application. We are told that the Biometrics programme in UKvisas is not even part of the e-Borders programme which is intended to introduce comprehensive electronic management of the whole immigration system by keeping records of who travels into and out of the UK[182] (paragraph 445). Nor are fingerprints automatically checked against police databases of fingerprints.[183]

175. A request to the Government for the latest cost-benefit analysis of biometric visas and electronic entry/exit control was not satisfactorily answered. We were told only that there has been some preliminary cost-benefit analysis on the introduction of a complete electronic entry control system, and that "savings in the region of £130 million (discounted) over 25 years could be achieved if the vast majority of EU/EEA nationals with biometric travel documents utilised an electronic entry control system".[184] We were given a cost of £70 million for introducing fingerprinting worldwide,[185] but this is only the estimated capital cost.[186] The running costs following full rollout are estimated at £10 million per year, including IT service charges, technical support and maintenance and the anticipated impact on staff time.[187]

176. In its report on Identity Cards, our predecessor Committee in the last Parliament stated that it was essential that the biometrics involved should be subject to exhaustive testing of their reliability and security, and that the results of those tests should be made available to expert independent scrutiny.[188] The Committee was also concerned about the costings of the ID card system.[189] The Government's response to our questions on fingerprinting visa applicants suggests that there are grounds for similar concerns about the extensive use of biometrics in visas.

177. The fingerprinting of visa applicants has the potential to play an important role in an effective immigration control. However, we are concerned about the way the biometric visas programme is being implemented, given that it is an expensive project without a specific cost-benefit analysis and it is not fully integrated into other IT developments such as e-Borders. Its impact must be properly assessed to ensure that the expenditure is commensurate with the benefits it brings.

178. If fingerprinting visa applicants is to be truly effective, in the future applicants' fingerprints must be checked against police fingerprint databases before a visa is issued, and fingerprints should also taken on arrival and departure and checked against the immigration record.

Previous recommendations

179. Many of our observations echo those of a National Audit Office report on the entry clearance operation published in June 2004.[190] It concluded that UKvisas has taken a number of important steps to respond to the considerable challenges of providing an efficient, high-quality service to applicants. Its international comparisons showed that the service provided by UKvisas compares favourably with other countries. But it considered that UKvisas should continue to evaluate whether posts are striking the right balance between service delivery and control; and to enhance its ability to evaluate trends and outputs for the better management of its business. The NAO's recommendations to UKvisas included:

a detailed evaluation of the impact of streamlining initiatives
adapting targets to give more emphasis to control issues
improving the range of performance information, particularly on the quality of decision-making
making better use of available information on breaches of immigration rules to inform their approach to risk analysis
disseminating to posts all relevant United Kingdom-based information, such as immigration and forgery intelligence
more explicit consideration of the implications of increasing demand and possible development in immigration policy
developing further its approach to handling appeals
better training and efforts to retain skilled staff in entry clearance work.

180. The subsequent report from the Public Accounts Committee (PAC) showed that it was impossible to track improvements in the service due to a lack of information on the subsequent actions of visa holders after entry to the United Kingdom. Further problems included differences in opinion on standards for entry clearance between the IND and UKvisas; ineffective communication; and a lack of monitoring. Quality control and consistency of decisions was another area that was criticised. The PAC's recommendations included improving quality of decisions, allowing for more time to check visa applications, increased use of risk assessments and use of complete, up-to-date and searchable databases for monitoring and intelligence purposes.[191]

181. We have not seen a comprehensive update on progress with implementing these recommendations, though we were told that a number of improvements are being made by UKvisas as a result of them[192] and that UKvisas' new mission statement is intended to reflect this:

193

There has been a study of the impact of streamlining initiatives;[194] targets are being changed; and there is some evidence of improved training. However, on the evidence provided to us we are less convinced of progress against the other recommendations.

182. We endorse the recommendations of the National Audit Office and Public Accounts Committee on the entry clearance operation and are encouraged by the steps already taken to implement some of them, but have been unable to chart progress on them all.

86 The list of nationalities, which is amended from time to time, is set out in Appendix 1 to the Immigration Rules (HC 395 of 1993-94, as amended) Back

87 http://www.ukvisas.gov.uk/servlet/Front?pagename=OpenMarket/Xcelerate/ShowPage&c=Page&cid=1020786334922#datvnationals Back

88 This unit was originally called the Joint Entry Clearance Unit (JECU), and was established in June 2000. Back

89 Ev 48, para 37, HC 775-III Back

90 Ev 50, paras 48-9, HC 775-III Back

91 Public Accounts Committee , Foreign and Commonwealth Office: Visa entry to the United Kingdom: the entry clearance operation (HC 312), 2004-05, pp .3-5. Back

92 UKvisas Business Plan 2005-06 para. 2.2 Back

93 Foreign and Commonwealth Office: Resource Accounts 2004-05, HC 776, 19 December 2005, p29 Back

94 Ev 377, HC 775-III Back

95 See Report by the Comptroller And Auditor General, Visa Entry to the United Kingdom: The Entry Clearance Operation, HC 367 Session 2003-2004, 17 June 2004 paras 1.19-1.20 Back

96 UKvisas Annual Report 2005 p. 14 Back

97 UKvisas Business Plan 2005/06 para 3.4 Back