1. Right Here; Right Now:
Providing the Information your Students
Need and your Regulator Requires
Marieke Guy, Data Analyst
Institutional Web Management Workshop
23rd June 2016

2. The Quality Assurance Agency for
higher education (QAA)
Our mission is to safeguard standards
and improve the quality of UK higher
education wherever it is delivered
around the world.

3. Our main work
• Higher Education Review (HER) of HEIs, FECs and
Alternative Providers
• Maintaining UK Quality Code for Higher Education
• Investigating concerns about academic quality
and standards
• Involving students in quality assurance work
• Working internationally with other QA agencies
• Supporting the assigning of degree awarding powers
• Regulating the Access to Higher Education Diploma

4. Students as
Consumers?

5. A changing HE landscape
• Greater share of HE provider funding coming directly
from students
• Students have clearer expectations regarding the
offering from their provider
• Different providers have different offerings at different
costs – an increase in marketisation
• The sector is expanding with more HE provision
available – FECs, alternative providers
• Complaints by students are generally on the rise
• However HE is not a conventional market…

6. “For most students, decisions on
what and where to study will be a
‘one-off’ involving the investment of a
significant amount of time and money.
Therefore that decision needs to be
properly informed and right for them.”
Gordon Ashworth, CMA

7. Regulation

8. Student
protection
Students
protected by:
Consumer
Rights Act
2015
Consumer
Protection
from Unfair
Trading
Regulations
2008 (CPRs)
Consumer
Contracts
Regulations
2013 (CCRs)
Unfair Terms
Regulations
(UTCCRs)
Office for
Independent
Adjudicator
(OIA)
Competition
and Markets
Authority
(CMA)

9. Consumer Rights Act
• Came into force in October 2015
– pulled together pieces of previous legislation
• Protection covers pre-enrolment and
post-enrolment
• Requirement to provide sufficient information
including: programme structure and content,
contact time, accommodation options and
breakdown of fees
• Information should be accurate, complete and clear
and made available in a variety of ways

10. CMA guidance
• March 2015 - Competition and Markets Authority
(CMA) publish advice to support the sector in
complying with obligations under pending law
• Majority of students (75%) use the university
website or prospectus to make their first and
insurance choices (Which? 2015)
• http://bit.ly/HEadvice

11. CMA guidance covers:
• Information provision – clear, timely, accurate and
comprehensive in advance of choices
– Stage 1: Research and application stage
– Stage 2: Offer stage
– Stage 3: Acceptance stage
– Stage 4: Enrolment stage
• Terms and conditions – covers all contracts, rules
and regulations documents that students are bound
by – should be easily located, in plain language
• Complaint handling processes and practices –
should be easily located, fair and accessible

12. What information?
• Entry requirements
• Core modules
• Contact hours
• Expected workload
• Teaching qualification
of staff
• Assessment
• Course award, location,
length, accreditation
• Fees, extra costs

13. Course changes
• An admission offer is an offer of a contract
• University must obtain applicants agreement to
change anything stated at stage 1 – what does this
mean in reality?
• Will result in longer planning schedules for
curriculum design (up to 5 years for UG)
• Clearer deadlines for changes
• Need for good internal and external communication
• Decrease in dynamic, innovative courses?

15. “There is significant risk to
organisations which are found to be
non-compliant with consumer
protection law. These range from the
relevant contracts being deemed to be
unenforceable, through to fines and
significant reputational damage.”
UEA CMA action plan

16. Do students get the
information they need?

17. • Which? compared websites of 50
unis offering psychology courses
• 38 did not give all the details
required under consumer law

18. 2015 Which? report found failings..
• Looked at 12 areas including entry requirements,
contact hours, assessment, course award and location
• Nearly two-thirds failed to provide updated information
about tuition fees on their website
• Three providers failing to provide approximately 30%
of the material information required
• Main issue areas:
– Missing information on course fees or extra costs
– Lack of context for KIS widgets
– Missing information on indicators of quality for course
e.g. contact hours

19. QAA review findings
• Higher education Review 2014-15 – 100% HEIs
expectations were met with regard to information
• However still significant number of recommendations e.g.
– adopt a coordinated approach to the provision of information on
fees and additional course costs at programme level
– publish the current Admissions Policy on the website
– make information regarding its collaborative partnerships publicly
available for potential students
– ensure that all students have appropriate and timely access to
information on procedures for complaints and appeals

20. “Information, particularly on price and
quality, is critical if the higher education
market is to perform properly. Without
it, providers cannot fully and accurately
advertise their offerings, and students
cannot make informed decisions.”
Success as a Knowledge Economy,
BIS White paper May 2016

21. Challenges for
the Web

22. Web governance
• Corporate responsibility for what is said about a
university’s education offering
• Central group need to insure information is accurate,
timely, clear, easily available etc.
• Change needs to be managed – clear deadlines,
understanding of what is reasonable to change…
• SLAs
• Clarity around roles of different marketing channels
(prospectus, course database, web pages, social media)
• Old information to be removed promptly

23. On the website…
• Is all your information available? T&Cs, regulations,
disciplinary procedures, complaints etc.
• Is all your information clear e.g. total cost of course
– does it include additional cost associated with a
course?
• Are you informing students of changes to courses?
Wider discussion around when this is necessary
and curriculum development cycle
• What are you doing with your KIS widgets? Are they
contextualised, are they at the top of the page?
Is there a break in content before the widget?

24. How can QAA help?

25. UK Quality Code part C
Information about Higher
Education Provision
• Chapter C requires that
providers produce
‘appropriate information,
focused on their
intended audiences,
about the higher
education learning
opportunities they offer’.

26. Quality Code principles #1
• Principle 1: Information should be timely, current,
transparent, and focused on the needs of the intended
audiences.
• Principle 2: Providers are responsible and
accountable for the information they produce but have
autonomy regarding the mechanisms and media they
choose to communicate this information.

27. Quality Code principles #2
• Principle 3: Information should be available and
retrievable where intended audiences and information
users can reasonably expect to find it. The format and
delivery of information should take account of the
access requirements of a diverse audience.
• Principle 4: Information produced by higher education
providers should offer fair and accurate reflection of
the higher education learning opportunities they offer.

28. Guidance documents
On explaining:
• staff teaching qualifications
• class size
• Workload (covers academic support, approaches to
learning and teaching, assessment,
contact time etc…)
• Responding to feedback from students

29. Universities are responsible for
ensuring that they comply with
consumer protection legislation.
Failure to comply could result in fines,
complaints and loss of reputation.

30. Other resources

31. Other Resources
• Higher Education Providers: Consumer Law
– 60 second summary (CMA)
• Guidance work on explaining staff size, workload,
responding to feedback from students (QAA)
• Impact Study of the Guidance Documents (QAA)
• UK Quality Code: Part C: Information about Higher
Education Provision (QAA)
• Audit of providers’ website information provision (Which?)
• Consumer Protection Law assessment
(Durham University) – works through scenarios used by
David Palfreyman

32. qaa.ac.uk
enquiries@qaa.ac.uk
+44 (0) 1452 557000
© The Quality Assurance Agency for Higher Education 2015
Registered charity numbers 1062746 and SC037786
Images
• Images on slide 4 and 12 copyright QAA
• Images on slide 14 copyright CMA – available via Flickr
(https://www.flickr.com/photos/cma-gov-uk/)
• Other images CC0 from Pixabay (https://pixabay.com/)