Developed and agreed at a UCL staff-student open meeting 5th June 2018, and finalised on 13th June. We have now launched our campaign, UCL: Stop Policing International Students.
As staff and students at UCL, we recognise that international students lie at the heart of our institution. International students make an invaluable contribution to UCL’s dynamic intellectual climate and the important diversity of our university community. These are priorities which are consistent with UCL’s Global Engagement Strategy, including its commitment to cultivating international outlooks and sharing academic expertise for solving global problems through extending the reach of our teaching, research, and academic partnerships.
Since 2012, universities have been increasingly involved in monitoring the compliance of international students on Tier 4 visas. Staff across the university sector have raised concerns that such processes harm staff-student relationships and turns staff into proxy border guards for the Home Office. While current legal duties are in place, UCL cannot but conform to Home Office requirements. We also, however, have a moral duty to ensure that in doing this we do not foster a climate of suspicion and discrimination against international students.
Unfortunately, recent changes to UCL regulations for staff monitoring and reporting of international students’ compliance with Tier 4 visa requirements are having precisely such pernicious effects. The ‘comprehensive’ monitoring and requirements for increasingly regular, on site, face to face checks put a clearly discriminatory burden on international students that exceeds the UK Visa and Immigration (UKVI) Tier 4 guidance requirements. As the UK Council for International Student Affairs’ document Tier 4 Compliance: A Practical Guide states, it is inappropriate to put in place monitoring processes that are not directly linked to academic activities or that place additional burdens on either staff or students (p. 28).
In addition, as colleagues noted in a May 24th letter to the Provost, the current UCL processes: put additional pressure on students at a time when we have increasing evidence about risks to student wellbeing and mental health; take up time of both professional and academic staff in bureaucracy that is irrelevant to and in conflict with the task of supporting learning and research; and build a culture of mistrust, putting at risk what should be a relationship of mutual respect between students and the university.
While UCL is required to carry out Tier 4 monitoring duties, it is crucial that does so in line with the following principles:
- Principle of minimalism: UCL should be doing the minimum necessary to meet the UKVI compliance requirements in order to keep its sponsorship status, not enlarging or exceeding the scope of what is legally required.
- Principle of non-discrimination: All students should be treated equally in relation to attendance and supervision requirements regardless of their immigration status. International students should not be subject to differential treatment or expectations than home students.
- Principle of academic integrity: The requirement of UKVI is that universities should be able to demonstrate students are engaged with their programmes of study, as these have been designed based on academic principles; academic programmes should not have to be re-designed to fit non-academic, immigration policy requirement.
- Principle of transparency: Policy changes should be developed and communicated in a way that ensures transparency and consistency: the justification for changes should be clear and based on appropriate consultation with legal advisors and with UCL staff and students; there should be clarity as to how UCL is interpreting UKVI requirements; and students and staff in different faculties/departments should receive consistent guidance.
- Principle of digital education: UCL has embraced the goal of being a world leader in digital education. Students and staff should be able to engage with one another, and with programmes of study, digitally: physical presence on campus and pen and ink documents should not be given preference over digital engagement and documentation, except where these are motivated by core academic goals and principles.
- Principle of ethical and critical engagement: UCL must put the principles of ethical and critical engagement into practice in relation to requirements for HEI immigration monitoring and directly challenge the Home Office when guiding principles of equity, respect and academic values come into conflict with the minutiae of bureaucratic requirements.
Therefore, we call on Professor Michael Arthur and the UCL Senior Management Team to act immediately to:
- Ensure that there is no discrimination or inequality in how engagement is supported and monitored for UK, EU and international students. Staff should not be asked to treat students differently because of their different citizenship or residency status; and international students should not have any extra engagement burdens placed on them.
- Ensure that no academic programme is compelled to change its core academic practices solely to comply with immigration policy, and instead work to fit engagement monitoring around academic programmes as these currently operate.
- Share with all members of the UCL community the information the university has gathered that shows that UCL currently does less than other UK universities for monitoring the engagement of Tier 4 students.
- Share with all members of the UCL community the advice that the university has received from Eversheds and UKVI regarding Tier 4 engagement monitoring.
- Carry out an equality impact assessment of the recent changes in Tier 4 engagement monitoring practices at UCL.
- Instruct departments and faculties not to issue warnings or threats to staff and students surrounding Tier 4 engagement monitoring policy until the above five steps have been taken.
- Use the status and authority of UCL as a leading UK University to publicly challenge UKVI policy which has led to an incursion of borders and a ‘hostile environment’ into academic intuitions.