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Comments on the collection method of the data

Comments in support of the proposals noted the greater usability of the resultant data, highlighting the benefits that subject-level data and improved definitions for types of TNE provision would bring. It was also noted that this would need to be consistent with data on non-TNE students in order to be of value.

A number of concerns were raised by respondents:

  • More detail is needed on the data specifications, the justification for the data, and the intended onward use of the data
  • That the current level of change across data returns more generally means that expanding the AOR presents an additional burden to submitting providers, Statutory Customers, and Jisc. It would be better to delay the implementation of new requirements until the changes to systems and business processes under Data Futures have been embedded across the sector
  • The burden of changes to systems and processes is significant, including where aggregate data is compiled by manual processes. Extending the time allowed for the sector to implement the changes would give providers and software suppliers more room to develop and test solutions and therefore reduce burden

One respondent noted their dependence on their software supplier to provision a solution that could meet the requirements. Another reiterated their opposition to requiring individualised data on TNE students, emphasising the associated burden and their concerns that the benefits would not be proportionate.

The sector body which responded to the consultation was broadly supportive of the proposals to enhance the existing Aggregate Offshore record, arguing that the same approach should be taken across the UK. They gave the view that an aggregate record could be used to monitor the quality of transnational education, while retaining a UK-wide approach and ensuring familiarity on the part of the overseas organisations expected to submit much of the data. They noted their concern that requirements for individualised data run the risk of straining and potentially creating barriers to international partnerships.

Several respondents requested that the data requirements be finalised and communicated to the sector – and software suppliers – with as much notice as possible.