Student Visas - Home Affairs Committee Contents

Written evidence submitted by Tilsley College, Motherwell (SV10)


1.  Tilsley College is a small (total annual intake of 15-18 students) but long-established private provider of further/higher education which is accredited through EEAA and BAC offering Certificate level (NQF 4/5) education in the niche market of the Christian services sector on an international scene. We are in the process of seeking HTS approval and have already incurred serious costs in the pursuit of this goal. We are essentially service-driven and are not commercially driven in our overall ethos and reason for existence, especially as regards receiving international students for training.

2.  A key role for Tilsley College is to make provision of training for between one and three international non-EU students per annum as a service to the wider churches network they support. Legislation restricting our welcome of these students will hamper our service provision not our budget.

3.  Having been registered on the previously existing register of Education Providers with the Ministry of Education, though not yet having received a sponsors' licence under UKBA, we are keen to establish the fact that colleges like ours are not "bogus" and our present lack of HTS status is through no lack of effort on our part. We want to affirm our bona fide status and full commitment to meeting legislative requirements.

4.  The main concerns raised by Tilsley College focus on:

  • (i)  The fact that a restriction of the Tier 4 route to degree level courses only would effectively prevent Tilsley College from fulfilling part of its purpose in providing international and cross-cultural training experience for key leaders within a recognised international network of churches, in which academic degrees are not the primary measure of professional excellence.
  • (ii)  The proposed changes to legislation would have a negative impact on our own reputation as "a highly regarded college" and an education service provider and training facility for an international organisation (GLO) potentially ruining almost 40 years reputation within our own networks.
  • (iii)  The implications of new legislation that appears to assume "guilty" until proven innocent in the case of "sub-degree level" and "private" colleges when they are branded automatically along with bogus colleges as housing "the least compliant students".
  • (iv)  The importance of maintaining opportunity for NQF 3, 4 and 5 provision to be made through small private bona fide colleges like Tilsley College within the required legislative process while at the same time not making the provision unduly difficult and, relative to student body size, very expensive for small institutions.

A.  Our historical credibility and education provision

1.  Tilsley College has grown up as the training wing of the work of Gospel Literature Outreach (GLO) in Europe (Scottish registered charity No SC007355). GLO itself is an international movement with bases in such countries as Australia, Korea, Malaysia, New Zealand, Peru, UK and Zambia. It aims to play a significant part in establishing, equipping and enabling the church of Jesus Christ throughout the world. GLO was launched in Australia in 1965 through the vision of Colin Tilsley and the base for GLO Europe was established in Motherwell, Scotland in 1974. It has developed into an international ministry and now has around 230 people in more than 20 countries worldwide engaged in various Christian ministries. GLO Europe currently has over 90 people working full time.

2.  Tilsley College has grown steadily in the work of training since 1974. With close to 40 years experience as a small private college for higher education we have seen many students, national and international, equipped and sent out into Christian service. In the period 1975-2010 Tilsley College has seen 390 students graduate, 167 of whom entered Christian service. Presently 129 alumni continue their service in Christian ministry, 59 within GLO and 70 with other agencies spread over 24 different countries. The college is well known within its own networks and is highly regarded as an appropriate training ground for Christian workers and missionaries.

3.  Tilsley College offers an accredited Certificate in Biblical Studies and Christian Mission on completion of our one year residential programme at our campus in Motherwell, Scotland. The course is rated at NQF 4 and includes both academic and vocational aspects of training. Vocational elements of the course are closely supervised by the college staff and lecturers who are all qualified in their fields of expertise (many to post graduate or PhD levels). Tilsley College also offers a second year internship programme which is certified by the college and an evening class programme for church leaders across central Scotland. We currently have 14 students on the full-time certificate course, three on the second year internship programme and 51 registered for evening classes. These courses are highly regarded on the international scene of which we are a part as well as enjoying recognition within the theological education sector here in UK.

4.  Tilsley College is a bona fide college which is currently accredited through EEAA[4] and BAC.[5] We work within a niche market making provision of theological education and vocational training for persons expecting to be involved in Christian service. Tilsley College has been on the Register of Education Providers and has been actively seeking UKBA approval over the past three years. We have subjected ourselves to rigorous academic analysis and evaluation with a view to maintaining our previous high standards and in proving these to the necessary bodies in order to secure the award of Highly Trusted Sponsor with UKBA. Further reference to this ongoing process follows below, however it is worth highlighting that in all the years of training with a consistent number of international students being regularly part of the annual cohort there has never been any case of a student absconding or not meeting the immigration requirements in place at the time.

B.  Our commitment to government legislation

Tilsley College is fully committed to meeting the requirements of government legislation. This has been clearly demonstrated by our willingness to pursue the necessary agreements and awards which will allow us to operate within our field of training expertise as we have in the past without the constraints of having international students dis-barred from our courses through immigration law. We have over recent years invested considerable time and resources into meeting the requirements of the Points Based System previously introduced by seeking to attain appropriate recognition with UKBA.

Tilsley College works within a sector where the moral obligation to keep the law is extremely high. As a Christian organisation our ethos and training is firmly focused upon doing what is right. The international network which we serve within GLO is similarly committed to these standards. All the students, including international students which the College would receive at Tilsley, are vetted and screened by personnel within the organisation who have selected the proposed candidates for the very purpose of equipping them for a career in Christian vocational ministries. The moral fibre of these candidates is key to their acceptance for training and offers Tilsley College great confidence that international students will willingly uphold the law of the land in all aspects, including immigration.

Several concerns arise for Tilsley College in regard to the present proposals for amendment to current legislation:

1.  Restriction of international students

The College would wish to reiterate the view of the Chair of the Committee in his comment "that any arbitrary decision to restrict the number of international students will be of grave danger to the UK economy and reputation". Furthermore, accepting that Tilsley College international student cohort's absence would make little impact on the UK economy, nevertheless Tilsley would be keen to maintain their reputation on the international scene of GLO with the constituent church networks in which we currently operate.

2.  Bogus colleges

The college would want to strongly affirm the government in the rooting out of bogus colleges. However, Tilsley is NOT a bogus college. We are deeply concerned that legislation be suitably tailored to deal with the problem and not have a detrimental effect on small genuine colleges like Tilsley College which are seeking to make education provision for our own sector of the market. We recall the words of the Chair again and strongly concur: "we hope to ensure that any restrictions proposed by the Government do not disadvantage a vibrant and successful industry". The prospect of Tilsley College no longer having international students would seriously hamper our current training programme and gravely undermine the work of our organisation on the international scene. Our exhortation would remain again with the Chair when he says: "...efforts would be far better directed towards tackling bogus colleges and those who overstay their visas in order to seek employment, than penalising legitimate students".

3.  Being overlooked in the big picture of national government policy

Tilsley College is concerned that our current status as a genuine bona fide college will be seriously undermined as a result of the broad brush approach to immigration currently being proposed. Paragraph 11, of the Bogus Colleges paper (pg 4-5) makes the case in point for Tilsley College and the Minister for State and Immigration's warning is accurate in our case. As a small college we have already invested some £12,000 in the pursuit of accreditations from EEAA and BAC with a view to securing the Tier 4 approval from UKBA. Our annual turnover from fees will be around £50,000. The impending proposals for changes to the legislation would leave Tilsley shocked and in serious financial loss if the broad application of granting visas to international students only on degree level programmes was to be applied. Tilsley College reiterates its readiness and willingness to attempt to meet the criteria for Highly Trusted Sponsor but we remain concerned that in the pursuit of that goal the door may be closed to us. As a small college, Tilsley is well placed to closely supervise and monitor ALL the students we train (typically 15-20 per year), whether international or not, and to ensure that all legal requirements are maintained.

C.  Our contribution to the present Tier 4 dialogue

Finally, Tilsley College would like to lodge the following points as engagement with the present dialogue. These points are drawn from the proposals of UKBA in their Tier 4 consultation documentation.

1.  Sub-degree level study

Tilsley College would want to lodge an objection to the implication that because a college enrols "sub-degree level" students they are automatically grouped with "the least compliant students". Clearly, non-compliant students will be found even in graduate and post-graduate programmes. Tilsley College is also a private college and similar implications are being made that this in some way makes us suspect. The bogus college phenomenon has largely been created by spurious English Language training facilities and we object to being gathered up with them.

2.  Some courses below degree level merit inclusion within Tier 4

Tilsley College would want to be included in this category. Our call for caution is so that the intention to restrict only HTS institutions to offering courses of study below degree level (i.e. NQF 3, 4 and 5) should not disqualify colleges like us who are presently in the process of seeking that award. Any new legislation should be so delineated as to allow small private colleges like us to continue to seek HTS status. Tilsley College would strongly object to the concept of only current HTSs being granted approval to offer below degree level courses if the requirements imposed for HTS status are effectively eliminating small private colleges such as us. As noted above Tilsley has already invested considerable resources of personnel, time and money into progressing the application to UKBA for approval - we call for that channel to remain open to us.

3.  UKBA "consultation"

Tilsley College would like to make the following representation as a response to the consultation questions offered by UKBA survey. We note however that the questions are worded in such a way as to closely shepherd and direct responses to what appears to be the "thrust of new policy" rather than a "consultation" as to how immigration problems may be resolved in the context of student immigration.

(a)  Question 1, answer: We do not think that raising the minimum level of study offered under Tier 4 to degree level will be an effective way of reducing abuse of Tier 4 route. It is certainly a way of "increasing selectivity" and perhaps "simplifying the current rules" but it is strongly discriminatory against small private colleges like Tilsley who are offering a bona fide service in a niche market to an international clientele. Furthermore, as highlighted above, restricting to degree level and above is no guarantee of eliminating abuse since moral duty does not always go hand in hand with higher education among students.

(b)  Question 2, answer: Yes, we do accept that only HTSs should be permitted to offer study below degree level at NQF 3, 4 and 5 in the Tier 4 route provided that colleges currently pursuing such status are not dis-barred from continuing to do so in the foreseeable future. HTS award should continue to be made available to bona fide colleges, like Tilsley College, with appropriate measures put in place to monitor their international student cohort.

(c)  Question 3, answer: Yes, we think these changes should be phased in over a period not less than two years. At Tilsley we have experienced many hurdles and obstacles on the way to seeking HTS award, not least the massive financial implications for a small college like ours, and the lack of clarity around the process and its implementation have been an ongoing frustration for us. Time is essential to make the transition effectively—immediate changes would be hugely restrictive to our education provision.

(d)  Question 5, answer: Appropriate English language testing should be required but we feel that decisions as to levels and types of test should be left within the education sector and not become an immigration requirement. The course that Tilsley College offers to international students does require a high degree of English language proficiency however owing to the nature of our college we are able to put appropriate provision in place for those who are needing to improve their English - indeed sometimes this is part of the learning experience for our students. We agree that appropriate standards of English should be maintained, but we disagree that they should be an immigration requirement, rather an educational discretion when appropriate.

(e)  Question 7, Question 8: answer: Genuine students who come to the UK for education within the broader education sector and having graduated from their programme should not be required to go home if applying for another course of study; neither should they be required to show evidence of "progression". In our situation we have had students who, having completed a Science degree for example, wish to seek a short course in theological study before returning to their home country. We would like to be able to assist them in offering such opportunity.

(f)  Question 12, answer: We have no objection to imposing limitations on students in working. We believe that international students come to study and we should encourage them to focus on that as a priority.

(g)  Question 13, answer: Owing to the nature of the Christian service training we provide it is to our advantage to have the provision for immediate family members being allowed to accompany a student. Mostly this proves to be two students (husband and wife) and occasionally with siblings. We have the accommodation for such requests and would normally encourage the family to come for study together.

January 2011

4   European Evangelical Accrediting Association,  Back

5   British Accreditation Council,  Back

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Prepared 25 March 2011