NPC/07/07/A - National Postgraduate Committee response to the QAA Code of Practice Section 5 Consultation

The National Postgraduate Committee of the United Kingdom welcomes the opportunity to respond to the QAA Code of Practice Section 5: Academic appeals and student complaints on academic matters consultation. The National Postgraduate Committee of the United Kingdom is the principal representative body of postgraduate students in the UK. As a registered charity (no. SC033368), our aim is to promote, in the public interest, postgraduate education in the UK. We share best practice through publications and meetings, respond to consultations, address conferences and take on casework. In the furtherance of our aims, we co-operate with other like-minded democratic student bodies, professional associations and trades unions.

The NPC welcomes the revision to the Code of Practice to take note of changing mechanisms in complaints and appeals procedures such as the creation of the Office of the Independent Adjudicator. We note the title of the revised Code of Practice Section 5 and feel that the title is too narrow. We note that complaints and appeals on other matters affected the academic environment and in some institutions, plagiarism, for example, was dealt with under disciplinary complaints procedures and not complaints or appeals procedures.

On the specific precepts we would like to make the following comments:

1 Institutions have fair, effective and timely procedures for handling

students' complaints and academic appeals.

We feel that the importance of the precept should be the students completion of the course is not affected by procedures. A typical timeline of a complaint would benefit students making complaints or appeals and allow an institution to monitor its success in undertaking processes in a timely manner. The NPC also feel that there should be consideration to Second order complaints if the complaint is taking too long to ensure the student is not disadvantaged when returning to a programme.

2 Institutions' complaints and appeals procedures are approved and

overseen at the highest level.

We feel that while the precept implies student input there should be an explicit statement that student representation should exist at the highest level.

3 Institutions ensure that those studying at all levels have the opportunity to raise matters of concern to them without risk of disadvantage.

The nature of PhD student relationships with an institution are particularly pertinent to the ability to raise matters of concern fairly. We feel that a stronger link to section One of the Code of Practice encouraging institutions to avoid one sole supervisor would further strengthen this precept.

The National Postgraduate Committee also feels that the accompanying text should refer to graduates, not recent graduates, to enable those who were unable to raise complaints during their programme of study to do so. We recognise the danger of malicious complainants and would suggest institutions are reminded they can have processes to deal with malicious complaints to stop complaints over long periods of time being raised over small matters.

4 Institutions make publicly available easily comprehensible information on their complaints and appeals procedures.

The NPC feels that while websites are often used to great effect in providing comprehensible information on procedures there is a concern on the version that is provided if regulations are changed. We feel that they need to be easily found with the onus on student unions and associations to inform students about procedures. We also feel that procedures should always be informed to students at the the point of likely need when a complaint or appeal might arise. The NPC also recognises the value of ensuring induction processes and roles and responsibilities consideration makes note of such procedures to ensure that staff and students are aware of the relevant regulations of their institution.

The NPC also feels that a strong reminder on the need for information to be accessible for those with disability needs.

5 The clear design of institutions' complaints and appeals procedures enable them to be conducted in a timely, fair and reasonable manner, and having regard to any applicable law.

6 Institutions ensure that appropriate action is taken following a complaint or an appeal.

We feel that information must highlight routes outside of institutional complaints for example the OIA. Information should also be provided for complainants and institutions in circumstances after a complaint, particularly if the complaint is successful. This would be crucical for research students as this would impact on relationships with supervisors.

We also feel that a strong encouragement should be made to ensuring the findings of complaints and appeals are clear on what departments and the institution must do in response to judgements.

7 Institutions satisfy themselves that appropriate guidance and support is available for persons making a complaint or an appeal, including those taking advantage of learning opportunities provided away from institutions and/or through flexible and distributed learning.

The NPC is concerned that it is more important than to solely provide information and that it was not the sole responsibility of student representatives. We feel that there could and should be support and guidance from the institution such as tutors.

8 Institutions make provision in their procedures for those making a complaint or an appeal to be accompanied at any stage, including formal hearings.

The NPC is concerned that there is a strong difference between being accompanied and represented. We would be concerned that there would be a cost implication and disadvantage to those who could not afford lawyers. The NPC is concerned that the precept is titled too weakly and could be used ambiguously by institutions.

9 Institutions have effective arrangements to monitor, evaluate and improve the effectiveness of their complaints and appeals procedures and to reflect on their outcomes for enhancement purposes.

The National Postgraduate Committee note good practice such as anonymised student complaints and appeals information supplied to student representative bodies. We acknowledge that this needed to be balanced for those in smaller institutions where complainants might be easily recognised.

10 Institutions ensure that suitable briefing and support is provided for all staff and students involved in handling or supporting complaints and appeals.