Transparency data

SLC Economic Crime Unit Statement of Intent (“SoI”)

Published 6 August 2024

1. Objectives

Student Loans Company Limited (“SLC”, “our”, “us” and “we”) 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 will also pay Third Parties in relation to some grant payments which may be administered via a third-party supplier. We work with the Department for Education (“DfE”), and the devolved administrations in Scotland, Northern Ireland and Wales, together 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 His Majesty’s Revenue & Customs (“HMRC”) to collect repayments through the Pay As You Earn (“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 of our contact with our customers and third parties, we aim to provide an outstanding customer experience by:

• delivering easy to use, seamless and transparent services.
• collecting information once and using it to provide the best possible customer experience over the whole customer life cycle.
• ensuring that clear and accessible information and application / (re)payment systems are available, allowing customers and third parties to interact with us and self-serve in a fully informed way; and
• making it easy for customers and third parties 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 our delegated functions and helping customers and third parties 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 ensure that the correct payments are made at the right time and to ensure the accurate repayment of loan balances. SLC is committed to the detection and prevention of errors and economic crime in the student finance system.

2.  What We Do

SLC has an Economic Crime Unit (“ECU”), which carries out investigations following internal and third-party referrals where fraud and/or error is suspected within the student finance system in England or Wales. For customers studying in Scotland and Northern Ireland, SLC may also work 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 economic crime.

If a customer’s SLC account has been compromised by a phishing incident, ECU will carry out a thorough investigation into the incident. Please note that we may be unable to reimburse any funds that are lost as a result of any phishing incident.

Each of these are core components of our economic crime risk management strategies, approved by the SLC Board, DfE and the Devolved Administrations. Our ECU 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 timeously and accurately whether through the UK tax system, or by direct repayment.

3. SLC Commitment to Protecting Public Funds

The experience of applying for student finance should be as straightforward 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 us to provide a truly effective and ‘right first time’ service to customers and third parties. Our customers are encouraged to contact SLC 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 and third parties. Evidence of customer identity, residency, eligibility and/or grant claims may also be collated from relevant third parties (including, but not limited to, other Government Departments) and publicly available sources of information, including social media, in accordance with our Social Media Acceptable Use Policy. 

We may also rely upon evidence from relevant third parties (including, but not limited to, 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 our analysis or investigations, we rely on customers and third parties to engage with us to verify information relating to their eligibility or entitlement to student finance (including grant claims), 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. If a third party refuses or fails to provide information requested by us, payments may be suspended, until the requested information is provided. It is a customer’s and third parties’ 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, the relevant regulations or their third-party terms and conditions. In exceptional circumstances, funding may be suspended during a fraud investigation, e.g. if there is suspected organised crime. 

A customer’s application or a third-party account will be deemed fraudulent only where there is sufficient evidence to make such a determination on the balance of probabilities.

4. Sanctions

Where an application for student finance is believed to be in any way fraudulent, sanctions may be applied to the student. Accordingly, the identification of fraudulent activity may have a significant impact on a student’s application and consequently their academic future and personal aspirations.  Sanctions may also be applied to third parties in relation to claims relating to student finance.

The range of sanctions which may be applied to students include:

• a warning that future similar conduct may result in the removal of student finance.
• immediate recovery of any payments which have already been made.
• termination of eligibility to receive some or all elements of student finance, (which may be backdated to the start of the academic year, and/or previous academic years, resulting in all student finance paid since the date from which the customer became ineligible being treated as an overpayment and immediately repayable);
• passing the customer’s details to the UK’s national fraud database, the Credit Industry Fraud Avoidance System (“Cifas”). This may have a detrimental impact on future ability to obtain credit, and will result in the customer being ineligible for student finance for the duration of the period the customer remains on Cifas in respect of SLC’s referral (normally a maximum of 6 years); and/or
• referral to law enforcement and prosecuting authorities.

The range of sanctions which may be applied to third parties include:

• a warning that future similar conduct may result in the removal of access to relevant payment systems (eg. the Childcare Grant Payment Service (“CCGPS”).
• immediate recovery of any payments which have already been made to the third party which were not due.
• removal of access to relevant payment systems (eg. CCGPS) and a block on the third party from re-registering for such systems.
• passing the third party’s details to Cifas; 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 fraudulent activity. 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 fraudulent activity is identified.

In the case of third-party childcare providers (“CCPs”), SLC may additionally place reliance on the declarations which require to be made by CCPs when registering with the CCGPS.  This declaration clearly states that SLC may investigate suspected fraud in the CCGPS and sets out the sanctions which may be applied to CCPs where fraud is established to SLC’s satisfaction.

7.  Appeals or Complaints

Student Finance England (“SFE”) customers who disagree with a decision taken by SLC to apply a sanction (see section 4. above) have a right of appeal under SFE’s Appeals Process. Student Finance Wales (“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 SFNI 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.

Where a third-party disagrees with a decision taken by SLC to apply a sanction (see section 4 above) or wishes to raise a complaint, they may escalate the matter to the Governance Team within SLC’s ECU, who will conduct an independent review of the case. This can be done by contacting the Governance Team at ECU_Governance@slc.co.uk .