Student Visas - Home Affairs Committee Contents

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 Status".
  • 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 data.


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.

January 2011

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