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Statement on compliance with Competition and Markets Authority guidance

In 2015 the Competition and Markets Authority published advice for universities on consumer protection law. This was further supplemented in 2023. The CMA’s advice sets out the minimum requirements for compliance with consumer protection law. However, it is not a substitute for the law itself. It is a condition of our registration with the Office for Students (OfS) (our principal regulator) that we comply.

To read the guidance, visit: CMA Consumer law advice for higher education providers

The CMA guidance covers four key areas:

  • an overview of legislation
  • information provision for applicants and students
  • terms and conditions
  • complaints.

Although the focus of the CMA’s guidance is on undergraduate, the OfS has made it clear that consumer law applies equally to postgraduate courses (taught and research).

This Statement provides information on how the University seeks to comply with the CMA’s expectations.

Information provision

The CMA requires universities to provide prospective and current students with information that is clear, accurate and up to date. The University must make available to prospective students a minimum level of information (“Material Information”) at the research and application stages, offer and enrolment stages and have this available during the period of study. The level of information is designed to ensure that applicants and current students are able to make an informed decision about their choice of university and course.
Material Information is defined as:

Course Information including:

  1. course title
  2. entry requirements (academic and non-academic, plus standard offer criteria)
  3. core modules and an indication of likely optional modules
  4. the composition of the course, how it will be delivered, and balance between the elements, e.g:
    1. the number and type of contact hours that students can expect (e.g. lectures, seminars, work placements, feedback on assignments)
    2. whether these will be in person, online or a mix of blended learning
    3. the expected workload of students (e.g. the expected self-study time)
    4. the general level of experience or status of the staff involved in delivering the different elements of the course.
  5. the overall method(s) and balance of assessment for the course (e.g. exams, coursework, practical assessments, etc)
  6. the award to be received on successful completion
  7. location of study, including any work placements where known
  8. length of the course
  9. whether the course is regulated and by whom (OfS in England)
  10. whether the course is accredited by a professional, statutory or regulatory body (PSRB), and by whom; an
  11. any particular terms that students may find surprising (e.g. where the awarding body is different to the HE provider delivering the course, or variation terms regarding course content, delivery or withdrawal).

Total course costs, including:

  1. tuition fees – including whether fees in future years will increase and by how much
  2. any extra costs students are likely to incur (e.g. for field trips, equipment, materials, bench fees, studio hire), and how much these extra costs are or are likely to be.

Material Information regarding a course is collected when a new course is approved and updated when changes are made. This is published on the University’s website under the Course Information pages.

The CMA expects us to provide information to applicants/students in a “durable medium”. We do this by signposting to the relevant course information page as part of the offer and again before enrolment. We are able to produce a copy of a course page at any time during the cycle in order to provide the information that was live on a given date. An archive of all course pages is held over a six year period.

Course changes

Should it become necessary to make reasonable changes to a Course or to related educational and other services and facilities to enable us to deliver a better quality of educational experience to students enrolled on the Course or in relation to specific modules then we will be entitled to do so. In so doing we will ensure that changes are kept to a minimum and where the change is in relation to the Material Information noted above we will notify and consult with affected students in advance of the changes being made. We will notify offer holders affected by a change to Material Information.

Timing is key in meeting CMA expectations which is why we have specific deadlines for the approval of course changes. We should not make changes to the Material Information about a course after December in any year.

Communications

All communications – verbal or written - to prospective or current students must comply with CMA expectations and must be accurate and not misleading. Anyone involved in producing or communicating information about the student experience, has a responsibility to follow CMA guidelines.

Either deliberately or inadvertently providing misleading information would be a breach of consumer protection legislation.
This would include:

  • giving a misleading impression at an Open Day that a particular module would be available to all students when this is not the case
  • giving a misleading impression about the location of a course
  • suggesting a course provides a particular qualification by a professional body when in fact further study (and possibly cost) would be required to obtain the award.

Terms and conditions

The basis on which students take up an offer is set out in the University’s Terms and Conditions. The CMA has set its expectations for making terms and conditions fair and transparent:

  • Documentation should be accessible in relation to format and location.
  • The University cannot seek to limit its liability if for instance there is industrial action or a public health emergency.
  • Fees should be clear and there should be no hidden costs.
  • Rights to intellectual property should be clear.
  • Rules and regulations should be accessible.
  • Students should be alerted to anything that they may find surprising in the way the University works or a course is delivered.