This Plan should be read along with the KLC Refunds & Compensation Policy and the Terms and Conditions, which are available on our website. Where we have used a defined term in in this Plan, if you don’t see a definition here then you will be able to find the definition in the Terms and Conditions. For example, you will see the School being referred to in this document, which is defined in the Terms and Conditions as meaning KLC School of Design.
Introduction: What this Student Protection Plan is for
This Student Protection Plan sets out what measures KLC School of Design has in place to protect you as our student in the event that a risk to the continuation of your studies should arise. The Higher Education & Research Act 2017 requires Higher Education Institutes to maintain a Student Protection Plan (“Plan”) to protect students’ interests in the case of material change (eg programme changes, course cancellation or institutional closure).
This plan is currently under assessment by our regulator, the Office for Students (“OfS”), to ensure it addresses our specific circumstances and is available to all current and potential students here. The measures contained in this plan are in addition to the protection you have under consumer protection law, and do not impinge on your consumer rights.
What type of events will prompt this Student Protection Plan?
The type of event or changes, which might cause such a risk, could be situations such as (but not limited to):
A. School makes a significant alteration to the Course content or delivery, regulations and policies
B. School has to cancel or discontinue a Course
C. School is unable to run a Course at its studios in Chelsea Harbour
D. School loses its UKVI Tier 4 Sponsor licence
E. School loses its validation from the University of Brighton
F. School loses its registration with the Office for Students
G. School has to close for financial or other reasons
Inclusion of a scenario should not be assumed to mean that we consider it likely to occur.
Our commitments to you as a student
We commit to:
1. Being open and transparent with students should any risk to the continuity of your studies arise, and inform you as early as possible with clear information and options (this will be initially communicated through Course Leaders)
2. Taking reasonable steps to protect your studies and minimise the resultant disruption should we discontinue a Course, have to change location or close the School altogether, for example, by:
a) Teaching out existing student cohorts, where it is possible to do so;
b) Offering affected students the chance to move to another course (eg transferring from Level 5 Foundation Degree Interior Design to Level 5 Diploma HE Interior Design) or an alternative method of delivery (eg transferring from Full Time Foundation Degree Interior Design to Online Foundation Degree Interior Design);
c) Providing assistance to affected students to switch to a different provider (we have identified potential alternative providers and keep an up to date list of comparable courses); and/or
d) Making reasonable adjustments for students.
3. Considering students’ views, their needs and the possible impact on them of any proposed changes before deciding to implement any substantial changes to or discontinue a Course , change its location or close the School altogether.
4. Informing the OfS of any changes that may necessitate a review of the Plan or any of the measures contained within it.
We will regularly seek students’ views on this Plan as part of our student feedback processes (this is done through student representatives, student focus groups organised by the Admissions Team and giving all students the opportunity to feedback through the Online Student Support Services). Student feedback for this version of the Plan was sought in May 2018. However, if you have any immediate views, concerns or feedback in relation to this Plan, please contact our Senior Registrar on 020 7376 3377 or at firstname.lastname@example.org.
Student Protection Measures
In the following paragraphs, a number of risks and scenarios are identified, along with the measures that the School will take in order to protect your continuity of study.
We are confident that all these measures are viable and will take into consideration the needs of all our students, including those with mobility considerations or special educational requirements. Measures contained in the Plan may be triggered at any time, if, for example, doing so would reduce the impact or likelihood of any interruption to students’ studies.
A. Changes to course content or delivery, regulations and policies
Generally, improvements to Course delivery are planned well in advance and the School has not previously made any significant changes to Course content or to delivery of a Course whilst students are studying on it. The School undertakes to take reasonable steps to avoid doing so in the future including by only making necessary changes up to 8 weeks before a student joins a Course (or up to 4 weeks before a student joins a Course that is two weeks or less in duration). It is simpler for the School to enable change outside of actual Course delivery than some other providers, due to the duration of some of our Courses being shorter.
Nevertheless, should a Course change beyond recognition of the one originally offered, then please refer to the KLC Refunds & Compensation Policy. Should the School make significant changes to the course up to 8 weeks before the start of the Course (or up to 4 weeks before a student joins a Course that is 10 weeks or less in duration), then KLC will notify and consult with enrolled students as appropriate to ensure that the offer is still acceptable. If the offer is no longer acceptable, then please refer to the KLC Refunds & Compensation Policy.
However, KLC reserves the right to make minor adjustments and improvements to Course programme and module content year on year, and these will not trigger this Plan. Please refer to our Terms and Conditions, in particular to clause 15.10 for further details.
Where minor updates to Course content are made, these will normally be proposed though the School’s Academic Board, which includes student representatives, before being approved by the University of Brighton.
Where a lecture or workshop has had to be cancelled or replaced at short notice due to staff absence through illness or other unforeseen events such as IT infrastructure failure, this does not in itself constitute significant adjustment to the Course. The School undertakes to ensure that either the lecture or workshop is repeated or students are brought up to date with the Course syllabus through other means, for instance a flipped classroom 1*. KLC has a core in-house team of tutors that operate across different Courses and an in-house IT team who are able to swiftly resolve technical issues arising. Lecture or workshop cancellations, therefore, happen rarely.
KLC’s ongoing commitment to quality assurance and enhancement means that from time to time regulations and policies will also be updated. These changes may be prompted by law or by the University of Brighton and the Office for Students and will be considered by the School’s Academic Board before being approved. Significant changes to regulations and policies will only be brought in at the start of a new academic year, whilst minor updates may be incorporated more quickly. However, students will be notified of all changes through the student portal of the Online Student Support Services and Student Handbooks and Course Handbooks will be updated accordingly.
1* “Flipped classroom” refers to when students read or watch study materials before coming in to attend a/participate in a class or workshop in which they can discuss what they have studied or put what they have learnt into practice. This stands in contrast to the more traditional approach of students attending a class or lecture and then going home to undertake individual study.
B. School has to cancel or discontinue a Course
KLC may need to make a strategic decision to cancel or discontinue a Course where there are (i) insufficient student Enrolments to make running the Course viable from an academic, student experience or resourcing perspective or (ii) insufficient academic staff available to teach the Course.
i) Cancelling a Course before a student starts their studies
Should the School have to take this decision before a student commences their studies, then the School undertakes to provide at least 8 weeks’ notice to enrolled students (except for Courses that are 10 weeks or less in duration when up to 4 weeks’ notice will be given), as well as prospective students going through the application process.
Our first step will normally be to look at an alternative Course or study method for affected students. This way a student can achieve the same level qualification through a different Course or by an alternative study method, as the majority of our Courses have both an on-site and online option. We would try to discuss the best approach with each individual student to see if this would be a workable solution. Should that not be a viable option, the School would put forward other suitable training providers offering the same qualifications in the same subjects.
KLC would also take into account the cancellation of a Course that a current student was intending to progress onto. For instance, if a Foundation Degree Interior Design Student had made plans to continue their studies with the BA (Hons) Interior Design, the first option would be to identify an alternative method of study, but if this was not available then the School would help affected students to find an alternative provider.
Please see the KLC Refunds & Compensation Policy for further details.
ii) Cancelling a Course during a student’s studies
The School’s policy is to always teach out a Course on which students are currently enrolled and the School has never had to cancel a Course during a student’s studies. The School’s business planning is structured so that income received is spread over the duration of a student’s studies to ensure that the School can cover related costs. The School’s academic team is structured so that there is flexibility across departments to cover any short term gaps in resourcing. The School also has an in-house IT team who manage systems that are fully PCI DSS compliant, with regular security audits and which use an off-site ‘failover’ back-up, so that any disruption to the School’s Online Courses or access to the Website including Online Student Support Services is rare and normally for a very brief period.
However, in the event that a Course had to be cancelled, the School is a small institution providing highly specialised training for the interior and garden design industries and, as such, our Course structures are unique to the School. In the event of one of our Courses being discontinued, our first step would be to look at an alternative Course or study method for affected students. This way a student can achieve the same level qualification through a different Course or by an alternative study method, as the majority of our Courses have both an on-site and online option. We would try to discuss the best approach with each individual student to see if this would be a workable solution. Should that not be a viable option, there are other courses in interior and garden design available and the School would work towards transferring affected students to a stage as similar as possible in their studies in order to help them achieve the same qualification. The School has undertaken a dialogue with our validating partner, the University of Brighton, to establish how this transition could be affected smoothly and efficiently. The School would also try to provide assistance to affected students to help them switch to a different provider. We have identified potential alternative providers and keep an up to date list of comparable courses. Please see the KLC Refunds & Compensation Policy for further details.
C. School is unable to run the Course at its studios in Chelsea Harbour
The School has one location with its studios at Chelsea Harbour and a secure lease of a sufficient length to cover all students enrolling in the academic year 2018/2019, for the duration of their studies. Whilst regular refurbishments are undertaken of the studios, these are always scheduled in such a way as to cause minimum disruption to students or, where possible, to be completed outside of study time.
Therefore, the main risk to students’ study at Chelsea Harbour is as a result of extreme disruption through some unanticipated event and a change in location would only be undertaken if it was in the students’ best interests for health and safety reasons, for instance if there had been a fire on the premises.
The School would endeavour to contact all students as soon as possible (there is an emergency contact protocol in place) and explain the situation. Temporary alternative appropriate premises would be located, certainly within Greater London and as close to Chelsea Harbour as is possible. The School’s insurance policy allows for hiring alternative premises in these circumstances and potential venues have been identified in case they are required. Generally in such circumstances, students would not be offered another Course option, but the School would take into account any special individual circumstances and work with individuals to find the best solution. For instance, where an alternative location did not have appropriate disabled facilities, the School would look at alternative study methods. If no alternative study methods were appropriate, please refer to the KLC Refunds & Compensation Policy for further details.
Where appropriate, the School would also look at financially compensating students in the event that they have suffered demonstrable, material financial loss directly because of the change of location for their studies. Please see the KLC Refunds & Compensation Policy.
Should the School be unable to find suitable alternative premises for a short period of time (1-2 weeks), the School would look to continue students’ studies through online study or flipped classrooms. If the School could not find appropriate premises for a longer period than 2 weeks, then the School would offer students the option to switch to an alternative study method (ie online). If this was not suitable, then please see the KLC Refunds & Compensation Policy for further details.
D. School loses its UKVI Tier 4 Licence
The School has been licensed by UK Visas and Immigration to enrol international students under Tier 4 of the Points Based Systems since 2008 (“Tier 4 Sponsor Licence”) and has policies and robust systems in place to manage our handling of student visas. The volume of students that the School sponsors is a reasonably small number and therefore the School considers that it is at limited risk of losing its Tier 4 Sponsor Licence.
However, if the School failed to achieve the required rating in our external oversight inspection, the School would be made a Legacy Sponsor. This means that we would not be allowed to sponsor any new students, but we would be able to continue to sponsor students who are already studying with us until their visa expires.
If the School became a Legacy Sponsor, we would take all reasonable steps to minimise the resultant disruption to affected students including:-
- Continuing to renew the School’s Legacy Sponsor Licence to ensure that all current sponsored students can complete their studies in full.
- Allowing students already in receipt of a visa and who have travelled to the UK based upon sponsorship from the school to enrol and commence their studies.
- Offering prospective international students who have made an application to study, the opportunity to postpone their application or have all fees paid refunded (please see the KLC Refunds & Compensation Policy and the Terms and Conditions).
- Taking steps to restore its full licence as soon as possible, depending on the circumstances.
However, if the School fails the annual Basic Compliance Assessment, the School’s Tier 4 Sponsor Licence could be suspended or revoked. Whether or not the School can continue to teach existing or current students (and for how long) would depend on a number of factors, including the reasons why the licence was revoked.
Where the School is unable to continue its sponsorship of an international student due to its Tier 4 Sponsor Licence being suspended or revoked, the School will contact all affected students within 2 working days and provide support and advice about alternative course providers and how to apply for a new study visa. Where appropriate, the School will liaise with UCAS with a view to allowing the applicant a substitute choice in their application.
Please see the KLC Refunds & Compensation Policy for what would happen in the event of the School's inability to continue to sponsor a student due to UKVI suspending or revoking KLC’s Tier 4 Sponsor Licence.
E. School loses its validation from the University of Brighton
The School is proud to be associated with the University of Brighton (the “University”) and has had a formal partnership agreement with the University since 2010.
The School and the University mitigate against the failure of the partnership agreement by keeping close operational links and strong approval processes, including forward-planning and financial review.
Under the agreement, the School and the University are contractually required to:
1. Provide at least 1 year’s notice in the event that either the School or the University would like to end the partnership agreement;
2. If the agreement is terminated for any reason, ensure a period of transition to enable students to complete their studies. Students may also be offered the opportunity to transfer to equivalent courses within the University subject to a review of course learning outcomes, content delivered to date and student progress, and appropriate operational considerations in terms of the impact on resources and student intake size;
3. More generally, if the agreement is suspended or terminated, commit to ensuring that the obligations and commitments to students made under the terms of the agreement are fulfilled.
The risk to students is therefore reduced and current KLC students registered with the University will normally be permitted to complete their studies at the School, subject to the above.
Where the above is not possible for some exceptional reason, the School would consider obtaining validation from an alternative University partner or achieve its own degree awarding powers. Failing that, the School would try to help students transfer to appropriate programmes at other providers and look at financially compensating students where they have suffered demonstrable, material financial loss directly because of this scenario. Please see the KLC Refunds & Compensation Policy for further information. The School would do its best to ensure that reasonable steps are taken to minimise the resultant disruption to affected students and that, as far as possible, changes are made in a transitional manner.
F. School loses its registration with the Office for Students
Where the School’s registration with the Office for Students is withdrawn, suspended or is not successfully renewed, and depending on the circumstances of de-designation, the School will appeal the decision and / or make a new application for designation with a view to the restoration of its registration for the next academic year.
Where appropriate, the School will also apply for “teach out designation”, allowing eligible existing students to continue to access student tuition and maintenance loans, including those students making new loan applications, for the remainder of their studies while on their current Course at the School.
It is anticipated that the loss of registration, in itself, is unlikely to have a material effect upon current students eligible for student loans, while other students may also be unaffected if they are not already eligible or do not wish to apply for student loans.
In the event of “teach out designation” not being granted, the School will endeavour to transfer existing eligible students, in receipt of or seeking loans, to an approved and designated alternate provider, should they so wish. Please see the KLC Refunds & Compensation Policy for further information. Students should note that loss of registration with Office for Students may also relate to, or lead to, the closure of the School and students should refer to provisions made below for this eventuality.
G. School has to close for financial or other reasons
As with all providers, an extreme set of events may lead to the prospect of the School being closed or a decision being taken to exit the market. This may be triggered by events such as the School becoming insolvent or through falling student demand, withdrawal of external oversight or a major event rendering the School’s mission non-viable.
Although the higher education market is challenging, the risk of this arising is reasonably low. The School has been established for 35 years and has a track record of audited financial statements. The School has a strong liquid balance sheet and a consistently healthy cash balance. Robust controls are in place to monitor expenditure and manage cash flow on a monthly basis. In addition, the School currently has no overdraft, loans or debts.
The School’s Directors have invested in the long term security of the company through the creation of a more diverse product portfolio, technological enhancements to course delivery, studio refurbishments and marketing efforts required to achieve student recruitment aims. The shareholders have indicated their willingness to provide additional capital to the company should this prove necessary.
Where the School has no option other than to close, it may consider measures such as those below to protect students:
1. It would remain the School’s policy to teach out Courses and therefore where possible, would try to close in a gradual way, over a period that would allow current enrolled students to complete their studies at the School.
2. Where the above is not possible, the School would support students to transfer to appropriate programmes at other providers and look at financially compensating students where they have suffered demonstrable, material financial loss directly because of the School closing (please see the KLC Refunds & Compensation Policy for further information).
3. Merging with another institution to maintain all or part of the current provision of Courses.
Notification, advice and support
We commit to notifying you of any changes which may affect your studies as soon as possible. Should the Plan need to be triggered, you will be notified by our Senior Registrar within two School working days.
Advice and support will be offered in the first instance by our Senior Registrar and Course Leaders. Additional, independent advice and support is available from the Deputy Head of the School of Architecture & Design at the University of Brighton.
We undertake to update our Website and presence on UCAS within 5 School working days of a decision or notification of significant change, including taking the steps set out in the scenarios outlined above, refusing to accept new applications where a Course has e.g. been discontinued or putting the School into a “continuity period”, as required.
We will publicise our student protection plan to current and future students by having it easily accessible on both the KLC website and VLE. It will also be included in Student Handbooks.
The Student Protection Plan was approved by the Executive Board on 16 May 2018. We will ensure that all staff are aware of the implications of our Student Protection Plan through e-mail communication, internal team meetings and notification at a termly Staff Meeting.
We will review our Student Protection Plan on an annual basis. Students will be encouraged to participate in this review formally through Student Representatives and our Alumni Advisory Board and more informally through feedback passed on the Marketing and Finance Teams from any enquirers or students.
What can I do if I have a complaint?
If you are not content with the proposed outcomes, students wishing to provide feedback can follow KLC’s Complaints Procedure outlined in the Student Handbook. Issues can ultimately be raised with the Office of the Independent Adjudicator, at http://www.oiahe.org.uk/.
Duration of Student Protection Plan
The Student Protection Plan remains in place for the duration of a student’s contract with the School.
However, student transfers due to mitigating circumstances may need us to re-evaluate our Student Protection Plan. As some students may leave their course of study due to mitigating circumstances and re-join a cohort sometime in the future, it is reasonable that some changes may have occurred which might affect the course, its location or its external oversight. This will not in itself trigger the Student Protection Plan, but the School will do its utmost to make any reasonable adjustments required for a particular student to adapt to the changes made.
Approval Date: 23 May 2018
Review Date: 23 May 2019
Contact point for enquiries about this Student Protection Plan:
Maria Josef, Senior Registrar
020 7376 3377