Protecting UK higher education from foreign interference
Guidance for higher education providers to recognise, prevent and report foreign interference and protect people, research and academic freedom.
This guidance supports higher education (HE) providers to:
- understand foreign interference
- recognise the risks
- know how to report concerns
It also points to resources that support academic freedom and research security.
This guidance is for:
- UK HE providers
- senior leaders, academics and staff involved in international collaborations
- researchers and research offices
- staff and students concerned about foreign interference
This guidance has been prepared in partnership with the National Protective Security Authority (NPSA).
Overview of foreign interference
UK universities and HE providers have a world-class reputation, and education is one of the UK’s most powerful tools for global engagement.
The UK HE sector has a crucial role in:
- educating students from across the world
- fostering international collaborations in a range of fields
- producing cutting-edge scientific research
- influencing global debates on issues from human right to regulatory approaches to international challenges
However, this can make UK HE an attractive target for foreign states who wish to promote, shape or censor activity, or otherwise seek to exploit the reputation and connections a university, academics or students can offer.
This can lead to attempts of ‘foreign interference’.
Foreign interference
Foreign interference in HE involves attempts by a foreign state to interfere in decision making or other activities at UK providers in ways that are deceptive, corrupt, or coercive.
This is importantly different from legitimate influence, where foreign states try to shape decisions on issues of importance to them in an open and transparent manner. This is a normal aspect of international relations.
Why you may be a target of foreign interference
State actors may target people working in HE providers because you or your institution:
- can influence decisions on international collaborations, investment or appointments to decision-making positions
- are in a position of influence or authority on subjects of interest to foreign states, from foreign affairs to technology governance
- could promote a positive narrative, or dampen criticism, about another state through research, activism, statements or collaborations
- have access to someone of interest, including policy makers or political figures, and may therefore be used to gather information about or reach them
- may host students and staff that a foreign state wishes to control, monitor, censor or punish
An example of foreign interference includes, but is not limited to, attempts to use covert, corrupt or coercive means to influence:
- academic publications
- the appointment staff
- student admission criteria
- the hosting of events or the entering of arrangements, for example collaborations with international organisations or foreign states
State actors may also target individual academic staff and students. This is called ‘transnational repression’.
What you should look out for
Most international engagement with HE providers is legitimate and makes a significant positive contribution to the sector, economy and society.
Foreign interference is different. It may feel intimidating or include threats of negative consequences if you do not meet the request. Other engagements may look legitimate but are deceptive, corrupt or coercive in nature. What might begin as an apparently genuine interaction can transition into something more malign.
It’s important you remain alert and trust your instincts. If something doesn’t feel right, report it to your provider’s security function.
Available guidance and resources
This section provides guidance on 3 main areas:
- how to respond to transnational repression
- how to manage risks to individuals
- how to protect HE from cyber threats
Transnational repression
In the UK, some crimes directed by foreign states against individuals are called transnational repression (TNR). These crimes can happen in person or online and can take many forms. A foreign state must direct the activity for it to be considered TNR.
TNR in the UK is targeted and specific. Some foreign states have targeted people they see as a threat or want to control, including those who speak out against them.
While TNR does not affect large numbers of people across the UK, its impact can be severe. What to do if you think you are the victim of transnational repression includes further information and resources on how to safeguard yourself if you are concerned about TNR or believe yourself to be a victim.
Managing risks to individuals
High-risk individuals are those who may be exposed to threats to their personal safety and security due to:
- their access to sensitive information
- the specific work they are involved in
- their public stance on contentious issues
The vast majority of those working or studying at UK HE institutions will not experience personal safety risks due to their work or studies. However, there may be exceptional cases where it is relevant.
The National Cyber Security Centre (NCSC) and NPSA have designed advice pages for high-risk individuals. This includes guidance for organisations to support their ability to identify, assess and manage risk to their people.
Further guidance is available for individuals, including steps you can take to protect yourself and what to do if you are concerned about suspicious behaviour or activity. NCSC has published guidance for high-risk individuals on protecting your accounts and devices, and there is guidance on high-risk individuals from NPSA.
Cyber security
Cyber security for Higher Education Institutions, from NCSC, includes advice and practical resources to help HE providers improve their cyber security.
Regulatory advice and guidance
England
The Office for Students (OfS) regulates the HE sector in England and has specific duties to promote freedom of speech. Regulatory advice 24 from the OfS provides guidance for universities and colleges in England on meeting their free speech duties in the context of international arrangements.
Where there are events that may relate to a provider’s compliance with its conditions of registration, they may need to submit a reportable event to the OfS, outlining the situation and the steps the institution intends to take. Individuals, such as students and staff, can also raise concerns directly with the OfS by submitting a notification.
Where a student’s complaint about freedom of speech or other issues cannot be resolved to the student’s satisfaction through the institution’s complaints process, you can submit a complaint to the Office of the Independent Adjudicator for Higher Education, which was set up to review student complaints about HE providers in England and Wales.
Northern Ireland
Higher education in Northern Ireland is overseen by the Department for the Economy Northern Ireland. Contact details for the HE branch are available online.
Students can raise individual complaints through their institution’s complaints process. If you remain dissatisfied after completing the college or university’s complaints procedure, you can contact the Northern Ireland Public Services Ombudsman.
Scotland
The Scottish government expects universities in Scotland to comply with relevant legal requirements and carefully consider existing Equality and Human Rights Commission guidance on freedom of expression for HE providers in Scotland.
The Further and Higher Education (Scotland) Act 2005 (as amended by the Higher Education Governance (Scotland) Act 2016 requires universities to:
- aim to uphold the academic freedom of persons engaged in teaching, or the provision of learning or research at the university
- ensure that appointments held or sought, and entitlements or privileges enjoyed, are not adversely affected by engaging in these activities
Scottish universities are required to comply with:
- the terms of the Scottish Funding Council’s (SFC) Financial Memorandum as a condition of grant funding
- the Scottish Code of Good Higher Education Governance
This includes the requirement of universities to inform SFC without delay of any circumstance that is having, or is likely to have, a significant adverse effect on the ability of the institution to deliver its education programmes, research and other related activity. This can be done by contacting SFC
Individuals who are concerned about the extent to which a Scottish university is meeting its legal requirements can consider raising a complaint through the institution’s formal complaints process. If you are dissatisfied with the outcome of your complaint, you can raise your concerns with the Scottish Public Services Ombudsman.
Wales
Medr is responsible for regulating the tertiary education and research sector in Wales.
For advice on regulatory issues, you can contact Medr via regulationadvice@medr.cymru, or you can raise a complaint with Medr about any regulatory concerns.
Where a student complaint about freedom of speech or other issues cannot be resolved through the institution’s own complaints process, you can submit a complaint to the Office of the Independent Adjudicator for Higher Education.
Foreign Influence Registration Scheme
The Foreign Influence Registration Scheme (FIRS) is a 2-tier registration scheme that strengthens the resilience of the UK political system against covert foreign influence and provides greater assurance around the activities of certain foreign powers or entities where there is a national security risk.
How the scheme works
Organisations acting on behalf of certain foreign powers must register their political influence activities. This requirement applies whether they are acting directly or through intermediaries.
The scheme operates on 2 tiers:
- political influence tier: covers political influence activities by foreign entities generally
- enhanced tier: specifically targets activities carried out by Russia or Iran - under this scheme, any such activities must be registered
By requiring registration, the scheme prevents foreign powers from hiding behind proxies. Anyone who attempts to obscure their involvement in influencing UK political processes must now declare their connection.
The Home Office has published an introduction to FIRS and guidance for the HE sector on how to comply with FIRS.
Research security
Research security is led by the Department of Science, Innovation and Technology.
The Research Collaboration Advice Team (RCAT) is your first point of contact for official advice on national security risks linked to international research.
Within research institutions, communication with RCAT should be through your institution’s nominated point of contact. If you do not know who this is, contact your research office.
Trusted research
Trusted Research is advice and guidance published jointly by NPSA and NCSC. Designed in partnership with the HE sector, it:
- supports the integrity of the system of international research collaboration
- provides guidance to researchers, university staff and funding organisations to help keep sensitive research and intellectual property secure from theft, misuse and exploitation