2. Memorandum submitted by
Professor Geoffrey Alderman
1. I have been asked to make a submission
to the Home Affairs Committee with respect to the role of "bogus"
higher-educational institutions [HEIs] in facilitating the entry
into the United Kingdom of persons who might otherwise not be
considered positively for such admission.
2. I am by background a teacher and researcher
in the broad fields of modern British history and politics, and
latterly a senior university administrator with experience both
in the UK and the USA. I have also researched and published extensively
in fields allied to the maintenance of quality in higher-education.
My full CV and bibliography are available on my website: www.geoffreyalderman.com.
I have researched into and written about the problem of "bogus"
HEIs in the UK.
3. For the purposes of this submission I distinguish
two types of institution:
(a) institutions which exist only on paper, and
sell so-called "qualifications"; such institutions may
maintain a presence in the UK—for instance through post-office
boxes—but have no physical presence in this country;
(b) institutions which do have physical presence
in this country, and which may well carry out teaching activities
defined in the broadest terms, but which are completely unregulated
or are regulated by accrediting agencies of doubtful worth.
4. In this submission I shall deal only
with the second type of institution, since I believe this type
poses a far greater challenge to the immigration system. In so
doing, however, I realise that the acquisition of bogus qualifications
by whatever means must of itself be a source of concern both in
terms of sensible immigration regulation and of the maintenance
of the UK's deservedly high reputation for academic quality.
5. That said, I have for some time become increasingly
concerned at the growth, pre-eminently in London and the south
of England, of higher-education institutions that appear bona
fide, but which on closer inspection must be regarded, by
any sensible and academically-grounded yardstick, as fake. To
be sure, these institutions exist—they have a physical presence,
they employ teachers, and they offer a range of awards—most
usually in the business, management, and information-technology
areas. But the teaching is likely to be poor, the attendance requirements
to be risible, the standards of assessment to be phoney, and the
awards to be of a standard considerably below that which the academy
would consider worthy of the titles by which these awards are
known—be they (allegedly) university foundation courses,
Bachelor's, Master's or even Doctoral "degrees."
6. On closer inspection it invariably turns out
that such institutions are either not accredited at all [I am
regularly importuned by some such institutions begging to be accredited
by my own], or they are accredited by bodies which in spite of
their illustrious titles are themselves of questionable status.
Occasionally such institutions actually claim a genuine accreditation—for
instance by a well-known UK university—but it turns out
that this claim is totally false. I can give the Home Affairs
Committee examples if it wishes.
7. My interest in such institutions derives primarily
from my work experience. Both at Middlesex University as head
of quality and Pro Vice-Chancellor (Quality and Standards) and
at my present University I have had to deal with cases in which
non-EU students present themselves for admission and demand the
transfer-in of academic credit awarded by such institutions. I
have had to tell such students that the credit certificates they
offer are more or less worthless. In a few cases I have no doubt
that the student is genuine, but has been cruelly duped by an
appealing website viewed at a distance of several thousand miles.
In most cases I am equally convinced that the sole purpose of
the attempted enrolment has been to stay in this country: for
instance, some such students have told me that they do not mind
what degree I enrol them for, so long as they get a letter from
me attesting to their student status, on the basis of a "foundation
diploma" offered by institution "x".
8. I have for some years been urging the government
to crack down on such institutions, initially by the rigorous
application of existing legislation (primarily the Trade Descriptions
and Business Names Acts) but also through a system of inspection
that would weed out the few genuine such institutions from the
many bogus ones. When, in 2004, the Department for Education and
Skills announced that it was minded to establish a Register of
Education and Training Providers I thought that the problem was
at last going to be tackled in an efficient and effective manner.
9. My hope was soon crushed. As soon as I saw
the draft proposals I knew that a clever entrepreneur could get
his institution onto the register with comparative ease, and I
said so in an article I published in the Guardian in October
2004.[1]
In that article I explained that it was hardly fair to expect
British consular officials to know the difference between a genuine
UK-based HEI and a bogus one, and that for that reason alone I
welcomed the idea of a register. But I went on to point out that
while the HE sector as a whole wanted a full-blown quality-assured
scheme, the government had (a) opted for a voluntary register
and (b) had so designed the voluntary register that anyone with
Internet cut-and-paste skills could easily put together the necessary
documentation that would guarantee them a place on the register.
Incredibly, this paperwork did not include even the names of individual
teachers at the establishment it was proposed to set up and register.
I concluded that "a real opportunity to crack down on bogus
institutions has been well and truly missed."
10. My prediction, that bogus institutions would
survive to fight another day, has unfortunately proved only too
true. In a follow-up article early in 2005 I reiterated my concerns
now that the Register had gone "live".[2]
Anecdotal evidence began to reach me that bogus institutions were
easily able to obtain registration. On 9 September 2005 I myself
received a letter from a self-styled college of computing in London
applying for "affiliation" to my university and offering
what was in fact a copy of a genuine letter from the DfES (dated
7 February 2005) giving the good news that the college had secured
a place on the Register of Education and Training Providers. But
I knew—and an email to the DfES confirmed this—that
this selfsame institution was on a DfES list of bogus institutions!
The government's left-hand clearly did not know what its right-hand
was doing. I am able to provide the Home Affairs Committee with
the documentation in this case if it so wishes.
11. There are those who believe that the task
of identifying bona fide educational institutions can be
left to bodies such as the British Council, the Association of
British Language Schools, and the British Accreditation Council.
It is true that these bodies enjoy the patronage of the Home Office's
Immigration and Nationality Directorate. But none of them is itself
subject to specialist inspection or regulation insofar as its
academic "accreditation" activities are concerned.
12. The BAC boasts that it is "the national
accrediting body for independent further and higher education".
It is, in fact, a charity that has apparently arrogated to itself
the task of quality assuring everything from colleges teaching
soft furnishing design to purveyors of theology diplomas. I have
had to deal with several cases of students who wish to transfer
from an institution which, though BAC-accredited, is not accredited
by any recognised university anywhere. The role of the BAC as
a catch-all accreditation entity "of last resort" [as
it were] is in my view very unhelpful (to put it mildly). The
BAC is part of the problem, not part of the solution.
13. What is to be done? As I said in the Guardian,
it is unfair to expect consular officials to be able to distinguish
between bogus institutions and legitimate ones. But the DfES Register
is quite unreliable. What is needed is a register the contents
of which have been thoroughly researched and verified by experts.
This expertise exists, but needs to be properly organised and
harnessed. The aim would be to produce a continuously updated
register of bona fide providers of education and training
in the UK, who in turn may be relied upon to enforce rigorous
attendance policies within a robust accreditation framework.
14. I make this submission exclusively in a personal
and private capacity.
Professor Geoffrey Alderman
MA DPhil (Oxon), FRHistS, FRSA, FICPD, MIQA, MCMI
Senior Vice-President, American InterContinental
University—London
26 January 2006
1 "Paper Tiger", Education Guardian,
12 October 2004: http://education.guardian.co.uk/higher/columnist/story/0,,1325495,00.html Back
2
"Visa Express", Education Guardian, 8 February
2005: http://education.guardian.co.uk/higher/columnist/story/0,,1407671,00.html Back
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