Written evidence submitted by London School
of Commerce (SV44)
I am pleased to be able to provide this written evidence
to your enquiry in both my role as a central London MP and as
Deputy Chair of the Advisory Board of the London School of Commerce
(LSC) on which I have served in a non-executive role since 2005.
We all recognise the importance of the government's urgent need
to ensure eradication of abuse and the difficulty of maintaining
a careful balance between the UK's security, immigration, economic,
education and research interests However my colleagues at the
LSC and I are very much concerned that some of the measures currently
under consideration would make the UK a far less attractive destination
for legitimate international students and would undermine the
UK's global success In this major export industry.
By way of an introduction to our institution, LSC
is a wholly owned UK institution, it offers UK degrees validated
by a selection of UK universities and is an Associate College
of UWIC. We are successful in that we have about 5,000 students
enrolled on our London Bridge campus over half following MBA programmes.
We also have two functioning overseas campuses and a further three
likely to open this year. All only offer UK degree programmes
and all our programmes must meet in full the requirements of the
UK's QAA. We have already submitted our case for securing our
own Degree Awarding Powers and we understand that this is now
with the Privy Council. We believe we represent the new innovative
approach to higher education promoting access amongst the less
affluent both in the UK and from overseas so strongly proposed
by the Rt Hon David Willetts MP. Indeed we have met with him and
been encouraged by his enthusiasm and commitment.
I have set out below those main areas that I wish
to submit as Information and evidence and would be very willing
to provide oral evidence if deemed to be useful In summary the
main points we wish to submit are:
- There is a need to ensure that the measures to
reduce abuse do not undermine one of the UK's most important and
successful exports; the result would only benefit our competitors
in a key global professional services sector.
- It would be appropriate to categorise international
students as "temporary residents" rather than longer
term migrants, just as is done by our main competitor countries.
- UK private sector providers have proved to be
very successful at winning business for the UK and it is vital
not to consider all private colleges as offenders when it comes
to visa abuse.
- It is extremely important to allow international
students to access employment, both during studies and immediately
post-study, to consolidate learning and build business networks.
If any restrictions are to be applied we suggest that work should
be limited to twelve hours per week during term time and, for
post-study employment, to restrict to postgraduates In both cases
this should only be for institutions with "Highly Trusted
- It is both Impractical and inappropriate to require
students to return home to apply for visa extensions. We recommend
that as a guideline extensions might be limited to two occasions
per student. thereby facilitating a transition from foundation
to undergraduate then to postgraduate.
Several studies have clearly demonstrated that international
students are of tremendous benefit to the UK, both in direct and
indirect terms. Currently their presence is independently estimated
as being worth between £8 billion and £10 billion per
annum to the UK economy. The indirect benefit is even greater
and in many different ways international students are potential
lifelong ambassadors for the UK, enhancing our longer-term trade
and commerce. our diplomatic and political relationships and our
wider cultural, scientific and educational interests. Additionally
providing education and research opportunities for international
students is a very high value added activity; it is vital for
enhancing the UK's innovative and research capabilities and helps
grow our knowledge economy.
The UK and Australia are generally recognised as
world leaders in the market for internationally mobile students.
Many of our competitors want to win market-share at our expense;
they are adopting our approaches and are investing heavily at
national and institutional levels to do just this. Most other
countries consider international students to be "temporary
residents" and thus not included in their main immigration
For the last 10 years or so both the government and
UK education institutions have invested strongly to grow the UK's
international market position. This has been successful as is
reflected in the large growth of student enrolments in the UK,
including in relation to our competitors. National programmes
such as the Prime Minister's Initiative (PMI) on International
education and the Education@UK Brand (owned by the Secretary of
State) have served to raise the profile of the UK globally and
in ways that our competitors are now seeking to emulate.
While the government has invested considerably, UK
institutions, both public and private, have Invested even more.
The private sector depends entirely on student fees, as these
are their only revenue source. We are only too aware of this latter
al the LSC and have a carefully constructed approach to marketing
and communications. This helps to ensure that we generate sufficient
income for our survival but also, and importantly, that all our
students are sufficiently qualified for UK degree programmes and
meet fully all requirements of the UKBA. The proof is that we
have extremely high pass and attendance rates and at levels at
which most state universities are in envy.
We have a major concern m that much of the discussion
concerning private education provision mentioned in Home Office
documents and presentations only serves 10 suggest that all private
providers lack appropriate controls Private sector providers are
perceived as a class to be frequent offenders, in terms of visa
abuse, whereas state providers are considered compliant. We would
suggest that Home Office statistics and recent reports have on
occasions been partial and sometimes misleading in this regard
as they draw conclusions about the private sector by comparing
a relatively small number of private colleges (and under close
scrutiny) with Universities with Highly Trusted Status this does
not. I believe, provide a sound evidence base on which to make
some of the wide-ranging changes proposed.
Additionally the data and studies would seem mainly
to predate the major rule changes introduced last year, when the
system was significantly tightened.
In our case, LSC has been at the forefront m the
introduction of strict controls to ensure full compliance with
UKBA requirements; we have "Highly Trusted Status",
have established biometric monitoring procedures and have also
volunteered our college (successfully I should add) as a pilot
centre of UKBA from the very beginning of the new approaches.
At LSC we are proud that we have encouraged so many
young people to come to study in London and we consider this has
been of highly mutually beneficial. Ultimately, and unlike slate
providers, we are entirely dependent on fee revenue Any significant
changes to student visa procedures, and the associated negative
international publicity, will very directly and adversely effect
our operation - and the UK economy.
Returning home to re-apply for a visa extension is
both very impractical and further suggests to students that the
UK is not a welcoming destination for them It is important to
the UK to encourage those students that are sufficiently able
to transfer through our system right from foundation programmes
through undergraduate, Master's and to doctorates, as appropriate.
The proposal is also highly impractical, as it would
force students to close their UK bank accounts, leave their accommodation
and settle prematurely any other personal matters. Additionally
they would then be required to again join the visa queue to their
home country, with a good chance that they would miss the deadline
for commencing their next programme in the UK. Ultimately it would
merely result in both a large loss of business for the UK and
put avoidable pressure on the UKBA staff overseas to process
many new requests in a crowded summer period.
The ability to access employment while in the UK
by international students both part-time, during studies, and
full-time for some period on completion of their studies is very
much to the UK's advantage. It also provides students with a wider
perspective on Britain, helps to reinforce their learning experiences
and additionally encourages the growth of business links that
they will ultimately take home with them.
The suggestion to restrict part-time work for the
students to campus employment and only hours during the weekend
would be both confusing to employers (for example both "campus"
and "weekends" are difficult to define) while in no
way reflecting the study patterns and needs of students and institutions.
Some students need to study for long concentrated periods, for
example to research and write-up projects and dissertations, and
the weekend might be best for this. While we consider it preferable
to retain the current rules of 20 hours per week we suggest if
there are any restrictions to be applied then this amount might
be reduced to twelve and only for those providers deemed to have
Highly Trusted Status.
The suggested abolition of the post-study work programme
is of concern. It is our experience that It is beneficial both
to the student and to the UK to encourage international students
to build on the value of their UK degrees through some form of
employment. We note that the Migration Advisory Committee had
previously observed that they had found "no evidence of Job
displacement" of UK graduates.
If some form of amendment is necessary then we would
suggest that post-study work might be restricted to those with
postgraduate qualifications and from those provided with HTS.
My colleagues at LSC and fellow members of the LSC Advisory Board
trust that you will find these observations and suggestions helpful
and constructive in your deliberations. Naturally we should be
delighted. If you feel it appropriate, to appear before your committee
to provide evidence We wish you success in your endeavours.