1 Introduction
1.1 Institutions holding a UKVI Student Sponsor Licence are required to have a working procedure in place to ensure it can effectively monitor the attendance and engagement of the international students it sponsors. Student Sponsor obligations are set out in the following document:
Student Sponsor Guidance - Doc 2: Sponsorship duties
1.2 At Cardiff Metropolitan University, Global Engagement's Immigration Compliance Team is responsible for the international student engagement monitoring procedure; the analysis of the attendance/engagement data; advising staff and students on the UKVI engagement monitoring requirements and reporting poor attendance and engagement to UKVI.
1.3 The academic schools are responsible for capturing the attendance data for international students throughout their periods of enrolment, for ALL timetabled sessions and non-standard elements of the programmes.
1.4 At the start of every term, the Immigration Compliance Team will communicate the university's engagement monitoring process to all international students, confirming consistent and active engagement is a requirement to comply with the conditions of their student visas.
1.5 The University is required to monitor and review international students' academic engagement according to the requirements set out below:
1.5.1
Band 1 - Study at a higher education provider at RQF level 5 (SCQF 8 and equivalents) and below (Applicable to Cardiff Met students studying HND level, International Foundation Certificate and Pre-sessional English).
Each student in this band is required to attend a minimum of 15 hours of daytime (08:00 to 18:00, Monday to Friday) classroom-based study per week. Where the student has not reached 85% attendance of their classroom-based study in any given month, the university must review the reason for the student's absence. The student's record must then be annotated with the reason for the non-attendance and the steps being taken to improve the student's attendance. Where a student's attendance falls below 70% for three consecutive months, the University must withdraw sponsorship due to lack of academic engagement unless there are exceptional and evidenced reasons for the non-attendance (e.g. illness).
1.5.2
Band 2 - Study at a higher education provider at RQF 6 (SCQF 9/10 and equivalents), RQF 7 (Taught and Research) (SCQF 11 and equivalents), and RQF8 (SCQF 12 and equivalents)
Applicable to ALL Cardiff Met degree seeking students (UG, PG ) Sponsors are required to have a single academic engagement policy in place that applies consistently to international students across the institution. (This can be the same policy that applies to home students, although there is no requirement or expectation that home students are to be included). The policy may differentiate between levels of study (for instance, doctoral and masters by research students may have their engagement recorded in a different way to undergraduates).
1.5.3 Where the structure of a programme/elements of a course do not require regular attendance at timetabled sessions, provisions must be in place to monitor engagement. For example, where students are:
- on work placements/research programmes/field research trips
- on study-abroad programmes (outward from the UK)
- writing dissertations and have no taught elements during this period
- undertaking official roles as Student Union sabbatical officers
1.5.4 Academic engagement monitoring is not required during university vacations or the post-study period (usually the final 2-4 months of the visa validity after completion of study).
1.5.5 Students will be withdrawn from their course following 10 consecutive missed contact points.
2 Engagement Monitoring Process – Band 1
2.1 At Cardiff Met, currently Band 1 students all study at the English Language Training Centre (ELTC). The in-person attendance is monitored daily by the ELTC staff and students are encouraged to maintain consistent attendance to ensure successful course completion and to meet the requirements of their visas.
2.2 Registers are completed at the start of each class and each opportunity for attendance is marked. For example, on a Monday there may be a maximum of three possible attendances.
2.3 This data is used to calculate overall attendance for the week for each student. If a student is frequently away from class, they are asked to provide evidence for their absence e.g. medical certificate. If there are compassionate or diplomatic reasons (e.g. a meeting with their embassy) academic staff are permitted to authorise a discretionary, short period of absence. The ELTC provides a monthly report to the Immigration Compliance Team which confirms the attendance for all the students. For study below degree level, the UKVI requires students to have over 85% attendance and where this falls to 70% or less for 3 consecutive months, students will be withdrawn from the course.
2.4 The Immigration Compliance Team will make contact with the students via email to determine the reason for non-engagement and offer support to re-engage with their studies. If the student does not re-engage a second email is sent explaining the importance of engaging with their studies and consequences of doing so and the impact on their student visa. A phone call is also made, to check on their welfare and emphasise the importance of attendance. Where a student does not respond and/or re-engage and the student has an attendance percentage below 75% for three consecutive months with no known mitigating circumstances, the student is withdrawn, change of enrolment status reported to the UKVI and the student is sent an email to confirm that action has been taken along with advice about returning overseas.
3 Engagement Monitoring Process – Band 2
3.1 Cardiff Metropolitan University utilises its own purpose-built system to track and monitor the attendance and engagement of its international students. The collection of data is facilitated by each academic school.
3.2 For standard taught courses, the lecturer will generate a four-letter code at the beginning of each lecture/seminar and display a QR code linked to the attendance monitoring system.
3.3 The students scan the QR code via their phone and enter the four-letter code to record their attendance at the session. The registrations in smaller session can be entered manually by the lecturer so no code will be generated.
3.4 On a weekly basis, the Immigration Compliance Team will extract attendance data directly from the online Attendance Monitoring System and contact international students whose attendance is of concern, in accordance with the Student Communication Plan (see below).
3.5 One contact point equates to attendance at one timetabled class per week. An absence is recorded if the student misses every expected contact point in a week.
3.6 Where a student does not respond and/or re-engage, further attempts are made to contact the student at trigger points (shown in the table below).
3.7 Where a student fails to re-engage and they are recorded as absent for 10 consecutive contact points, with no known mitigating circumstances, the student is withdrawn, the change of enrolment status reported to the UKVI and the student is sent an email to confirm that action has been taken along with advice about returning overseas.
4 Attendance and Engagement monitoring for untimetabled/non-standard elements of study
4.1 As some programmes/elements of programmes do not require student attendance at timetabled seminars or lectures, alternative means of collecting data are required. It is essential that international student attendance and engagement data is captured throughout the period of enrolment (excluding official vacations). Details of how data must be captured for each untimetabled period can be found below.
4.1.1
Work Placements
Students on work placements are required to complete and return a weekly, signed timesheet to the School administration office, to confirm they have been present at the work placement. The designated school administrator will record the information on a work placement attendance spreadsheet, located on the MS Teams site International Student Engagement Monitoring. The data will be accessed and analysed by the Immigration Compliance Team weekly.
4.1.2
Dissertation/Project
For students undertaking a dissertation/ project, attendance will be monitored via the supervisory meetings. Students must attend a supervisory meeting or have engaged with their supervisor online or via email at least one time per month during this phase of their studies. Once the meeting has been completed/contact made between supervisor and student, the supervisor will confirm this to the School Administration Office and the School Administrator will record the data on the Dissertation Attendance Spreadsheet on the dedicated Team site.
4.1.3
PhD Students
PhD student attendance is recorded on the Doctoral Research Manager system. Supervisors are required to update the DRM system to confirm the student's engagement and progress. The Immigration Compliance Team will access the records monthly. Where there are concerns about a student's engagement, The Immigration Compliance Team will contact a member of the School Research Team for further details and communicate with the student where necessary.
4.1.4
Student Union Sabbatical Officers
When International students take on a position as sabbatical officer, this change of circumstance must be reported to UKVI. During their time as Sabbatical Officer the Chief Executive of the Cardiff Met SU, must inform GE Immigration Compliance Team, of any unauthorised absence or changes to their engagement/position.
5 Student Communication Plan
|
Stage of Communication Plan |
Immigration Compliance Team Actions |
| 2nd week of teaching | Email sent to all international students to confirm attendance monitoring process, obligations, and consequences of poor attendance. |
Student misses 2 consecutive contact points | Targeted emails sent to poor attendees to check on wellbeing and support offered to encourage re-engagement. A response deadline is set one week from the date of the email. All updates and actions taken are recorded.
|
|
Student does not respond and misses 5 consecutive contact points | Email sent to students requesting response within 1 week.
Reasons provided for non-engagement will be addressed and support/advice/referral offered where necessary. Reminder of immigration conditions and consequences of continued poor attendance issued.
Where welfare concerns are raised, a referral will be made to the Welfare Team to make contact with the student. |
|
Student does not respond and misses 7 consecutive contact points | Phone call / MS Teams meeting arranged and conversation documented.
Reasons provided for non-engagement will be addressed and support/advice/referral offered where necessary. Reminder of immigration conditions and consequences of continued poor attendance issued.
Where welfare concerns are raised, a referral will be made to the Welfare Team to make contact with the student. |
|
Student does not respond or re-engage and misses 8 consecutive contact points | Email sent to student with a warning – high risk of withdrawal. |
|
Student does not respond or re-engage and misses 9 consecutive contact points | Email sent to student with final warning to confirm withdrawal from course and report to UKVI. |
|
Student misses 10 consecutive contact points | School advised of withdrawal.
Withdrawal reported to UKVI.
Email sent to student confirming withdrawal and advised on visa curtailment and next steps. |
5.1 Where a new student fails to attend or engage with any taught sessions from the point of enrolment and fails to engage with the Immigration Compliance Team and/or re-engage following email warnings, it will be assumed that the student does not have a genuine intention to study. In these circumstances, the student will be withdrawn at 7 missed contact points and sponsorship withdrawn.
5.2 Where a student disputes their attendance record after having been withdrawn and reported to UKVI or provided evidence of mitigating circumstances, all evidence should be forwarded to the Immigration Compliance team for review. The circumstances will be discussed with the Programme Director to determine whether it is feasible for the student to continue with their studies and the UKVI report withdrawn.
6 Attendance Monitoring of Students who become pregnant during their studies
6.1 This policy should be read in conjunction with the University's
Student Maternity, Parental Support and Adoption Policy.
6.2 The Student Maternity, Parental Support and Adoption Policy is applicable to all students studying at Cardiff Metropolitan University, however additional points relating to international students and their immigration obligations must also be considered.
The Immigration Compliance Team should be informed of any sick leave that is approved by the Programme Team as a result of absences following a miscarriage or a termination, in order to prevent any unnecessary communication with the student regarding attendance monitoring obligations.
Due to complex immigration regulations for international students, any decisions about interruptions to study, extensions to course length and plans to return to study should be made in consultation with the GE Welfare Team. This applies to maternity and paternity leave.
Those international students who are not entitled to any maternity benefits in the UK may prefer to return home for the duration of their pregnancy.
7 Attendance Spot Checks
7.1 Ad hoc attendance and engagement checks are carried out by the Immigration Compliance Team at various points in the academic year. A member of the team will attend a class and check the number of international students who have self-registered at the lecture/ seminar and take a manual register of the international students to ensure the numbers match. If there is a discrepancy in the numbers, the online register can be manually amended by the lecturer to reflect the correct number of students present.
