Transparency data

SLC Customer Compliance Statement of Intent

Published 2 September 2020

1. Objectives

Student Loans Company Limited (SLC) plays a central role in supporting the higher education (HE) and further education (FE) sectors. We do this by making timely and accurate payments of Maintenance Loans and Grants directly to learners and Tuition Fee Loans to HE and FE providers on behalf of learners. We work with the Department for Education (DfE), and the devolved administrations in Scotland, Northern Ireland and Wales. We also work with the Student Awards Agency for Scotland (SAAS), the Education Authority for Northern Ireland (EANI), HE and FE providers and other delivery partners. We also work in partnership with HMRC to collect repayments through the PAYE and self-assessment systems while directly collecting from borrowers outside the UK tax system or those nearing the end of their repayment term.

In all our contact with our customers, we aim to provide an outstanding customer experience by:

• Delivering easy to use, seamless and transparent services;
• Collecting information once and using it then to provide the best possible customer experience over the whole student life-cycle;
• Ensuring that clear and accessible information and application / payment (and repayment) systems are available, allowing customers to interact with us and self-serve in a fully informed way; and
• Making it easy for customers to contact us through their channel of choice and to have any query resolved by experts with full access to all required information.

SLC also has a duty to ensure, in carrying out its delegated functions and helping customers to understand the various eligibility rules, that these rules are complied with and public funds are appropriately administered and protected. We have a responsibility to pay the right amount of support to the right people at the right time, and to ensure the accurate repayment of loan balances. SLC is committed to the detection and prevention of errors and fraud in the student finance system.

2. What we do

SLC has a Customer Compliance function, which carries out investigations following internal and third-party referrals where fraud and/or error is suspected in connection with our customers in England or Wales. For customers studying in Scotland and Northern Ireland, SLC works in conjunction with SAAS or EANI respectively to take appropriate action to detect and prevent fraud in the student finance system. In addition, we conduct analysis and verification of information to ensure eligibility for funding, and to ensure that our assessment process continues to operate accurately and efficiently. This includes sampling activities to identify organisational risk, targeted campaigns to proactively identify fraudulent activity, and auditing of applications in areas known to be susceptible to fraud and error. Each of these are core components of our compliance and risk management strategies, approved by the SLC Board, DfE and the Devolved Administrations. Our Customer Compliance function is assessed annually against the Government’s Counter Fraud Functional Standards.

SLC also has a Repayments function tasked with ensuring that all customers make loan repayments when due, and that those repayments are made timely and accurately whether through the UK tax system, or by direct repayment.

3. Customer commitment by SLC

The experience of applying for student funding should be as straight-forward and clear as possible. We continue to improve our application services to ensure that the application journey has an intuitive online capability for customers and real time data that either enables self-service or enables staff to provide a truly effective and ‘right first time’ service to customers. Our customers are encouraged to contact our experienced advisors if they require assistance at any stage of the process.

We recognise that, on occasion, incorrect information may be entered as part of the application process which will trigger a need for us to investigate for error. When this occurs, we carry out a proportionate investigation including, where appropriate, interviews with customers. Evidence of customer identity, residency and/or eligibility may also be collated from relevant third parties (including other Government Departments) and publicly available sources of information, including social media, in accordance with our Social Media Acceptable Use Policy. A customer’s application will be deemed fraudulent only where there is sufficient evidence to make such a determination.

We may also rely upon evidence from relevant third parties (including other Government Departments), and publicly available sources of information, as part of any repayment evasion investigation. All data gathered as part of any investigation will be processed in line with our Privacy Notice.

In conducting its analysis or investigations, we rely upon customers to engage with us to verify information relating to their eligibility or entitlement to student finance, or eligibility to repay. If a customer who is a current student persistently fails or refuses to provide information requested by us, their funding may be suspended, until the requested information is provided. If a customer in repayment fails or refuses to provide information requested by us, a higher rate of interest may be applied to their account. It is a customer’s obligation to ensure that their contact information is always up to date, and to respond promptly to requests for information, in accordance with their loan contract and the relevant regulations. In exceptional circumstances, funding may be suspended during a fraud investigation, e.g. if there is suspected organised crime.

4. Sanctions

Where an application for student funding is believed to be fraudulent (in part or in full), sanctions may be applied. Accordingly, the identification of fraudulent activity may have a significant impact on a customer’s academic future and personal aspirations.

The range of sanctions which may be applied include:

• a warning that future similar conduct may result in the removal of funding;
• immediate recovery of any payments which have already been made;
• termination of eligibility to receive some elements of funding (which may be backdated to the start of the academic year, and/or previous academic years, resulting in all funding paid since the date from which the student is not eligible being treated as an overpayment and immediately repayable);
• passing the customer’s details to the UK’s national fraud database, which may have a detrimental impact on future ability to obtain credit, and full removal of all student funding going forward, for the duration of the period the customer remains on the UK’s national fraud database in respect of SLC’s referral (normally a maximum of 6 years); and/or
• referral to law enforcement and prosecuting authorities.

5. Integrity of applied sanctions

A wide range of factors will be considered in determining an appropriate sanction in each individual case, having regard to the extent and severity of the fraud. We are committed to ensuring that there is consistency in the decision-making process and that fair and appropriate outcomes are achieved.

6. Legal basis for sanctions

We work within the parameters of our delegated functions pursuant to the Teaching and Higher Education Act 1998 (“the Act”), together with all regulations made pursuant to the Act, which provide SLC with the legal basis to impose sanctions in relation to entitlement to student finance if fraud is identified.

7. Appeals or Complaints

SFE customers who disagree with a decision taken by SLC to apply a sanction have a right of appeal under SFE’s Appeals Process. SFW customers who disagree with a decision taken by SLC to apply a sanction have a right of appeal under SFW’s Appeals Process.

Customers in Scotland and Northern Ireland who wish to appeal a sanction must refer to the appeals processes of SAAS and Student Finance NI respectively.

Any customer wishing to make a complaint regarding how SLC has conducted an investigation into suspected fraudulent activity or repayment evasion may do so using our Customer Complaints Procedure.