Written evidence submitted by Tilsley
College, Motherwell (SV10)
EXECUTIVE SUMMARY
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, www.eeaa.org
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5
British Accreditation Council, www.the-bac.org
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