Higher education is a highly regulated sector. To be able to recruit and teach students who have access to loans from the Student Loans Company, universities need to register with and respond to the requirements of the Office for Students (OfS) which, since its launch in 2018, sets the standards for the quality of teaching (via the Teaching Excellence and Student Outcomes Framework/TEF), fair access, participation and success of a diverse student population (via Access and Participation Plans), student information, data and feedback (via the National Student Survey), student wellbeing, skills and employability and funding.
The OfS works with a range of partner organisations to support and inform their work to shape the sector, and to ensure that students are at ‘the heart of the system’ (as promised by the Higher Education White Paper 2011 that introduced the regulatory framework that now exists with the OfS.)
All of the above is probably familiar, but it is useful to start with the big picture and the driver for the policy context in UK universities. The broad remit of the OfS means that almost all aspects of the student journey and student life is included, from recruitment and retention to wellness and employability.
Universities need to ensure that their practice is guided by standards that meet the requirements of the OfS as well as other external legislation and professional bodies. This is demonstrated by the portfolio of policies that exist in any university. As well as meeting this external requirement, these policies need to be accessible to their internal audience and represent the culture of the specific study and work community of the university in which they sit. Policies need to perform for all sorts of reasons.
Policies are ‘marmite’ for university staff – but love them or hate them, they are needed to demonstrate compliance with regulatory and legal requirements, to attempt to standardise services and regulate the shape of the academic year, and to protect the needs of students and staff. As such, they are a useful backstop for queries and complaints, a post for staff to safely lean on when unfamiliar with how things are done in their workplace and a reassuring guide for students on how they will be supported once registered. This is the ideal, but the reality of the internal policy and procedure landscape is often different and more organic.
Halpin is often in a privileged position when conducting reviews. We can take the time that busy internal staff do not have to review a specific area of policy and how it impacts students and staff across the university. We see a variety of documents that have been updated at different times, often in isolation and a range of practices that have evolved through well-intentioned pragmatism.
We have found a ‘Policy on Policies’ which sounds like the product of the utmost pedant but is actually a very good way of providing a standard definition and format for documents and an easy-to-work-with method of maintaining relevance and responsibility via ownership and committee review.
Even with this governance guidance, there is inevitably variety in the way that practices are enacted in reality. This is especially important when policies guide what is done to/with people when something goes wrong, such as a complaint or a serious breach of behaviour and/or a criminal act.
One of the OfS partners is Universities UK which has been working on the issue of sexual violence for a number of years following the work of the NUS, and cumulating in the ‘Changing the Culture’ report in 2016. In 2021, the OfS published their expectations for universities on addressing and preventing all forms of harassment. Whilst not (yet?) part of institutional registration with OfS, the expectations prompted thoughts about how current and compliant policies in this area were.
Halpin has worked with a number of universities to support the assessment of this. One important expectation was that a ‘whole university’ approach would be achieved so when undertaking a review, we ensure that we speak to staff from operational areas, through to staff in academic schools, members of governing bodies and importantly students.
As could be expected given the range of opinions and experiences that will be met with this variety of people, there is not always agreement on what policies are for and what they should achieve. With our overview and brief to advise on what is best for the university, we make recommendations for consideration which may be followed up or may prompt further discussion. Where needed, we consult with our legal advisors and include this for additional reassurance. Whilst recommendations are report and institution-specific, a few general observations have emerged that will apply to all:
- Policies almost always have a specified internal review date but are not always up to date; policy owners need to observe internal deadlines as well as the external regulatory/legislative environment so that policies maintain currency.
- Students do not read policies at registration so those that directly guide their experience and are relevant to their welfare should be accessible and communicated to them in a way that is meaningful and resonant to them.
- Include students in the review and approval of changes to policies.
- Members of council/governing bodies need information on the performance of policies and what activity sits underneath them to give oversight to policy areas, so reports for them need a narrative as well as data for them to understand the full context.
- Policy creep exists: Local practices evolve and continue even when central teams have made changes. It is important to have firm and collaborative links between schools/faculties and central professional services teams.
- An aligned policy approach to staff and students is useful so that complaints/cases/events can be managed similarly by the policies and procedures that exist.
- Policies do not exist in isolation: a change to one may have an impact on another.
- Policies need to include very clear advice and allow for fair and proportionate decisions to be made.
- It is useful to include principles within policies so that the intention of actions is clear.
- Provision for collective decision making removes the vulnerability/pressure on individual named members of staff.
Good policies make good practice clear to a range of audiences. An external audience will be looking for compliance with legislative and regulatory frameworks. Perhaps more importantly, an internal audience needs to know what their university will do for them when something has gone wrong.
If the policy context is accessible and clear, they will know what is expected, where to go and what to do, and how much effort and resource their university has allocated to help. If it is hidden and presented as a list of dry documents, all this will remain unseen and unknown when perhaps the harm has been done and it is a little too late.
Halpin can conduct policy reviews across all areas of higher education. Get in touch to find out more.