The University operates a three lines of defence model to ensure compliance with the ongoing conditions of registration, including notification of reportable events to the OfS and ensuring that all returns are submitted.
A specified individual is responsible for compliance with each condition of ongoing registration. These individuals manage the teams which deal with the day-to-day running of the relevant functions.
The conditions of ongoing registration table identifies these responsibilities: the table is available on the University website and is maintained throughout the year. In addition, the annual report to Council includes a copy of the table.
Where appropriate, reports are made directly to Council on specific conditions (e.g. the submission of the Access and Participation Plan).
Reportable events: Key employees are aware, and at least annually reminded, of the need to provide details of any potentially reportable event that they become aware of to the Director of Planning and Council Secretariat (or their nominee). These employees are the individuals who, between them, will become aware of all potentially reportable events that occur: the Director of Legal Services, the Academic Registrar and the Finance Director.
Returns: The Data Assurance Group, which has appropriate data capability, oversees the submission of quality checked data returns to OfS and HESA.
The Council Secretariat has responsibility for monitoring compliance by the responsible individual and ensuring that there are no gaps. This is done by way of ongoing review and updating throughout the year, combined with a full annual review. The annual review includes obtaining confirmation from the responsible individuals that the University remains compliant in respect of the conditions that they are responsible for. The website is updated on an ongoing basis and following the annual review.
Reportable events: Following initial review by the Council Secretariat, the event details are passed on to the Registrar who, in consultation with the Vice-Chancellor, makes a final decision on whether the event must be reported to the OfS. Any required event report is made by the Council Secretariat, keeping the Registrar informed as to the response from the OfS.
Returns: The Data Assurance Group reports to the Planning and Resource Allocation Committee (PRAC) and PRAC reports on to Council.
The results of the annual review are included in the annual report to Council, which highlights any gaps identified. The annual report also provides details of all reports made and responses received and confirmation that all returns have been submitted on time (or details of and reasons for any delays). Where necessary, any concerns are reported to the Audit and Scrutiny Committee.
‘Compliance’ is one of the core topics within the Internal Audit rolling programme, and this includes OfS compliance. There was an audit on this topic in 2019 and a follow up is due 2020/21. The next audit will be programmed depending on the outcome of the 2020/21 audit results.
The audit provides independent and objective assurance of the University’s compliance with the ongoing conditions of registration.
The results of the internal audit are reported to the Audit and Scrutiny Committee and on to Council as required.