People trafficking: how ELT centres and schools can protect students
9 December 2019

People trafficking: how ELT centres and schools can protect students

Could your ELT centre or school be used for people trafficking? Recent news stories about Vietnamese students disappearing after enrolling at private schools have raised concerns.

Pat Saini, head of immigration at English UK corporate member Penningtons Manches Cooper LLP, was involved in some of the cases and says member centres need to be diligent about safeguarding in order to protect their students.

"All education providers, whether or not they are Tier 4 sponsors, need to make sure they have robust systems in place that can spot issues quickly. It is important to remember that such instances are small and often isolated incidents," says Pat.

How education providers can protect students from people trafficking

Pat says there are several steps schools and ELT centres can take to ensure they are enrolling genuine students. Here's her advice:

Recruiting from new jurisdictions?

ELT centres should do due diligence before recruiting international students from countries which are new to them:

  • Is the country on the high-risk register?
  • What is the marketing strategy for recruitment?

When recruiting from new jurisdictions, it is a good idea to start with smaller numbers.

Monitor recruitment patterns

Use your data on the average number of students recruited from each country annually: if you see a spike in numbers without having run a recruitment campaign, investigate why before making offers to students.

Look at agent behaviour

Agents are an important and trusted part of student recruitment but it's worth investigating if:

  • A new agent approaches your centre;
  • An existing agent puts forward students who do not fit the usual profile from them or their country
  • An existing agent puts forward an unusually high number of student applications
  • An agent guarantees a specific number of students each year.

Review visa refusals

Whether or not your centre has a Tier 4 sponsor licence, visa refusals should be kept under review. These can help you pick up issues and patterns which can often be quickly addressed. For example, that you should be providing students with more information on the course they will be studying.

Look out for high visa refusal rates for students recruited via new agents or new jurisdictions.


Centres and schools which teach under-18s will need safeguarding procedures, including:

  • Permission from the child's parent or guardian to study in the UK
  • Ensuring that adequate travel, reception and accommodation arrangements have been made for the child whilst they are studying.
  • Having a process to notify the local authority of private foster care arrangements and when those arrangements change.

Tier 4 sponsors have specific requirements.

Review student drop-outs

Students drop out of their courses for different reasons, including homesickness, and Tier 4 sponsors need to report these. But all providers should review drop-outs for any patterns, for example that a particular agent or country is involved.

Be vigilant

As well as making sure that they comply with all your regulatory duties, it's important to:

  • Remain vigilant for unusual spikes in visa refusals, new student applications and/or drop outs;
  • Carry out due diligence on new agents and new jurisdictions
  • Follow all safeguarding procedures

The education team at Penningtons Manches Cooper LLP has a wealth of experience in advising English UK members on all aspects of regulatory, safeguarding and immigration matters. If you require advice please contact Pat Saini


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