Dr. Jim Murray:

There are three distinct elements that, collectively, will bring it all together. The first is the due diligence aspect. A provider cannot get the IEM unless it goes through the due diligence, and that will look at all the features Mr. Moynes was talking about, namely, everything from corporate governance to how the school deals with agents, whether it is financially sustainable and whether the people running the institution are reputable. If there is not a clean bill of health in that regard, the school will not get the IEM, but that is only the beginning. Thereafter, the school will be assessed against the code of practice, which is a very extensive document and of which Ms Grennan outlined all the different elements. Again, each provider will have to secure a clean bill of health and there will be two elements to the process in that regard. Each provider will have to demonstrate, through its IEM application statement, how it meets every criterion in the code of practice and, similarly, how it complies with the quality assurance guidelines we have established under statute. It must demonstrate compliance and, again, if there is widespread failure in that regard, it will not be authorised to get the IEM.

Another element is that the provider will have to contribute to the learner protection fund, which is a further signal of its bona fides in being concerned about its learners, in order that in worst-case scenarios, where a provider ceases to operate or a programme ceases to be offered, we will be able to use the fund either to ensure those learners are transferred to other programmes to finish their studies or to refund their tuition fees for the year in which the programme ceases to be offered.

If the provider comes through all that, which is a very robust set of examinations that includes site visits, inspections and observations of teaching, of how the school in general operates and so forth, and is authorised to use the IEM, we will authorise it either with or without conditions. Authorisation with conditions is significant because we will have a follow-up process to make sure every condition we set is met and there will be absolute timelines or deadlines associated with that. Depending on what it is, it could be a six-, eight-, 12- or 18-month deadline. Once we have carried out the initial set of reviews, we will set those conditions.

I would be confident that poor or nefarious operators would not get through that system but in the low likelihood they do, if anything else comes to light subsequent to a review in our follow-up activities, there will be an 18-month quality report and a triennial review thereafter. We will have intelligence from other sources and we will continue to liaise with our colleagues in the Department of Justice in the context of immigration and so on, and there will be other ways and means by which information will come our way, as it always does to a quality agency. If we need to, we can take action and, at any time, call for a review of compliance with the IEM if we are made aware, or if it comes to our attention, that there is a failure. The ultimate sanction is that we can withdraw the IEM. That is provided for in the legislation and it is in our policy on authorisation. There is a process to go through. Withdrawal from the IEM means the provider cannot then recruit non-EU or non-EEA learners. The process is staged and stepped, therefore, but it does escalate along the way and it is a very robust system.