UK Quality Code for Higher Education – Chapter B5 Student Engagement: UCL
response to consultation.
General Comments
UCL welcomes the opportunity to comment on this consultation. We have answered the
more detailed questions in the prescribed format as set out below. However, there are a
number of general comments which we would wish to make.
(1) The two main dimensions of the term ‘student engagement’ covered by the consultation
are given in the Chapter’s introduction as:


improving the motivation of students to engage in deep learning and to learn
independently;
the provision of feedback by students and their participation in quality assurance and
quality enhancement processes, resulting in the improvement of their learning
environment.
The consultation proposes to deal only with the latter. However, the Expectation, Indicators
and their accompanying text as set out, seem, rather confusingly, to conflate these two
dimensions. For example, the Expectation refers to students and HE providers as partners in
the students’ learning experience but the Indicators seem to focus on a wider and more
general notion of student experience. This can be problematic, particularly when dealing with
notions such as that of equality of access to information. For example, HEIs usually provide,
as far as possible, information to students which is fully transparent and relevant to the
enhancement of their learning experience. However, the Chapter gives no notion that there
might necessarily be limitations to this where information might be of a commercially or
strategically sensitive nature. While acknowledging that the broader environment will
influence a student’s experiences, there is an implicit understanding that student
engagement takes place within the context of a student’s learning and teaching. It would be
helpful if the Expectation and Indicators could focus more clearly on this.
(2) The word ‘engagement’ seems here to be being used as a catch-all, and within the
document it is capable of a number of nuanced interpretations, from ‘participation’ to ‘active
representation’. In some HE contexts, ‘engagement’ can also mean UKBA monitoring of
student attendance. We feel that, given its ambiguity, a replacement (or replacements)
should be sought.
(3) The Chapter makes no mention of the important role in student feedback played by
external surveys, such as the International Student Barometer.
(4) Despite noting in its introduction (paragraph 4, first bullet) that student involvement in
admissions can have an influence on its delivery and/or development, none of the Indicators
or their accompanying text make any further reference to admissions.
Finally, we would like to note that the views expressed in this response are subject to the
publication of those as yet unwritten Chapters which will make up the new Quality Code;
particularly those with clear links to this Chapter, such as Chapter B3: Learning and
Teaching. We may wish to revisit our response in light of the publication of these subsequent
Chapters.
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Consultation Questions
Chapter B5: Student Engagement – Overview
5. Does the title of this chapter adequately reflect the content?
Please see our comment at (2) above regarding the use of the word ‘engagement’.
6. Is the remit of the Chapter appropriate and clearly stated?
Yes.
7. Is the Chapter sensitive to the diversity of higher education providers and higher
education students?
Yes. There are a number of constituencies for whom it would be less meaningful, such as
part-time and short-course students but we accept that the Chapter is deliberately pitched at
a high and therefore very general level.
8. Would this Chapter as written be useful to you? If not, what other changes might be
needed?
Yes, as a threshold-setting document, the Chapter is useful, although it should be noted that
HE institutions are not responsible for ensuring student engagement, but, rather, for offering
students the opportunity to engage. The Chapter in its present form does not sufficiently
acknowledge the important role played by Students’ Unions in facilitating student
engagement and we feel that, particularly now that they are classified as independent
bodies, the Indicators and their accompanying text could be re-purposed to make them more
helpful to Students’ Unions.
This Chapter sets out the following Expectation about student engagement which
higher education institutions are required to meet: Higher Education providers take
deliberate steps to engage students, individually and collectively, as partners to
enhance their learning experience.
9. Do you agree with the wording of the Expectation for this Chapter?
As noted in our general comments at (1) above, the Expectation seems to confuse the
notion of student learning with that of student feedback. We would suggest that it read:
‘Higher Education providers take deliberate steps to engage students, individually and
collectively, as partners to enhance their experience’.
The Chapter sets out seven Indicators of sound practice as follows. Please answer
the questions for each Indicator. Indicator 1: Higher education providers, in
partnership with their student body, define what student engagement means in the
context of their quality systems.
10. Do you agree with the wording of this Indicator?
We feel that the phrase ‘quality systems’ is too narrow to describe the structures and
processes HEIs usually have in place to ensure enhancement of the student experience. We
suggest that a replacement (or replacements) be sought.
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11. We would like to expand the explanatory text accompanying this Indicator. This
could include adding signposts to further information (see Indicator 7 for examples).
Do you have any suggestions for additional explanatory text or signposts to further
information?
No.
Indicator 2: Higher education providers ensure that opportunities for individual and
collective student engagement in their quality systems are reflected across their
provision.
12. Do you agree with the wording of this Indicator?
No, in part because of the objections already stated at (10) above to the phrase ‘quality
systems’. We would suggest the alternative below:
‘Higher education providers ensure that opportunities for students to participate individually
and collectively are reflected across their provision.’
We would also like to note that, in the explanatory text accompanying this Indicator, the
phrase ‘Quality systems can operate at many different points across provision’ (our italics), is
ambiguous and therefore unhelpful. We would suggest that the sentence read
‘… can operate across all aspects of the student experience’
13. We would like to expand the explanatory text accompanying this Indicator. This
could include adding signposts to further information (see Indicator 7 for examples).
Do you have any suggestions for additional explanatory text or signposts to further
information?
No.
Indicator 3: Higher education providers, working in partnership with their student
body, create an environment that is conducive to all students engaging in their
learning and in quality systems, irrespective of their programme or mode of study or
previous educational background.
14. Do you agree with the wording of this Indicator?
We would suggest that the expression ‘student body’ might be replaced by ‘students’. This
Indicator has also conflated the notion of student learning and student feedback as we
mention in our general comments at (1) above.
Otherwise, the wording of the Indicator seems broadly appropriate. However, we would
query the penultimate paragraph of the accompanying text which notes ‘Students usually
appreciate feedback systems that are timed such that they themselves experience the
benefits of their own suggestions’ We feel that it might be more appropriate to encourage the
altruism which sees successive cohorts of graduating students complete the National
Student Survey.
15. We would like to expand the explanatory text accompanying this Indicator. This
could include adding signposts to further information (see Indicator 7 for examples).
Do you have any suggestions for additional explanatory text or signposts to further
information?
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No.
Indicator 4: Higher education providers, in partnership with their student body, create
effective arrangements for the representation of the individual and collective student
voice in their quality systems.
16. Do you agree with the wording of this Indicator?
We feel that this Indicator expresses broadly the same idea as Indicator 2. It is therefore
otiose and might more usefully be merged with Indicator 2.
17. We would like to expand the explanatory text accompanying this Indicator. This
could include adding signposts to further information (see Indicator 7 for examples).
Do you have any suggestions for additional explanatory text or signposts to further
information?
See response to 16 above.
Indicator 5: Higher education providers, in partnership with their student body, ensure
through appropriate induction and on-going support, that students and staff are
equipped to fulfil their roles in student engagement in quality systems effectively.
18. Do you agree with the wording of this Indicator?
Broadly, but with the reservations expressed about the word ‘engagement’ and the phrase
‘quality systems’ already noted above. However, the accompanying text (first paragraph, line
three) notes that ‘clearly identified resources might assist students and staff to fulfil their
respective roles’ (our italics). We feel that ‘resources’ might usefully be further defined as
‘guidance’ or ‘briefing material’.
19. We would like to expand the explanatory text accompanying this Indicator. This
could include adding signposts to further information (see Indicator 7 for examples).
Do you have any suggestions for additional explanatory text or signposts to further
information?
No.
Indicator 6: Higher education providers, in partnership with their student body, share
information so that students and staff involved in quality systems have an equally
informed voice.
20. Do you agree with the wording of this Indicator?
In addition to the reservations already expressed about the phrase ‘quality systems’ we
would wish to emphasise that ensuring equality of access to information is not necessarily
the same thing as ensuring that all participants are equally informed. We would suggest
therefore, that this Indicator should read:
‘Higher education providers, in partnership with their student body, ensure that students and
staff involved in quality systems have equality of access to relevant information.’
21. We would like to expand the explanatory text accompanying this Indicator. This
could include adding signposts to further information (see Indicator 7 for examples).
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Do you have any suggestions for additional explanatory text or signposts to further
information?
No.
Indicator 7: Higher education providers, in partnership with their student body,
monitor and review the effectiveness of student engagement in their quality systems.
22. Do you agree with the wording of this Indicator?
With the exception of the phrase ‘student body’, which could be replaced by the word
‘students’, we broadly agree with the wording of this Indicator.
23. We would like to expand the explanatory text accompanying this Indicator. This
could include adding signposts to further information (see Indicator 7 for examples).
Do you have any suggestions for additional explanatory text or signposts to further
information?
No.
24. Do the Indicators of sound practice in this Chapter adequately set out what a
provider might do to meet the Chapter Expectation?
Yes.
25. Should we include any additional Indicators in this Chapter?
No.
26. Please use this space for any further comments on the Chapter. There is NO word
limit for this question.
Please see our General Comments at the beginning of this response.
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