Dear Student Loans Company Limited,
The Compelling Personal Reasons (CPR) process allows those who feel they may have reasons beyond their control for failing to complete their course of study to claim back previous years of study. I am struggling to find information which guides CPR claimants applying through Student Finance Wales through the processs, that is reasonably accesible in the public domain. In particular, the specific categories or types of reasons which are accepted and which are rejected for applicants applying through Student Finance Wales. I am also struggling to find any information provided on the appeals process. Applicants are also unable to communicated directlt with the assesors who evaluate their claim, or recieve any guidance from them, and amd struggling to find an explanation for this anywhere in the public domain.
On this basis, I wish to request access to the follwing information, through the Freedom of Information Act. Specifically, I am requesting information regarding the Student Loans Company's process when assesing CPR claims through Student Finance Wales for the academic year 2017-2018, and if available policies which will be followed in 2018-2019. I have included a breakdown of the particular information which I would most like to see if possible. I am happy to recieve this information in print or digital format. I would also appreciate being directed to any of this information if it is reasonably available in the public domain.
Please may the Student Loans company provide me with:
- Any and all available documents which list rules, guidelines, process outlines, or general policy which assesors are expected or enouraged to follow when assesing CPR claims and appeals made by applicants through Student Finance Wales.
- Any and all available documents which explain the difference between CPR claims made through Student Finance England and Student Finance Wales in terms of legislation or Studendt loans company internal policy.
- Any and all available documents which provide the reasononing for claimants being unable to contact, or recieve correspondence and feedback directly from the assesors working on their claim. Including, if available, the methods used to ensure applicants can recieve accurate and specific information about their claim in order to have a fair chance of appealing a rejected CPR claim and how this system is justified in terms of existing legislation.
- Any or all relevant policy documents regarding the appeals proccess, in particular general reasons or guidance on why rejected claims may be approved on appeal if possible.
- Any and all available documents which explain quotas, targets or metrics which are used internally by the Student Loans company to asses the CPR claims and Appeals process.
- Any and all available policy documents which explain situations or reasons for a CPR appeal to be rejected. In particular those which would cause them to be rejected regardless of the type or amount of evidence provided.
- Any or all policy documents which provide guidance for how CPR claims may be accepted for more than one year of study. Specifically how legislation is interpreted for chronic health conditions which have affected multiple years' of study.
- Any or all available documents which provide the working definition of the term "failure to complete a course of study" used bybthe Student Loans Company.
- Any exemplar versions of claims which would be accepted or rejected, which are provided to assesors for the purpose of training or guidance.
- Details of any and all legislation which the Student Loans Company are required to follow when assesing Compelling Personal Reasons Claims for applicants applying through Student Finance Wales from either the Welsh Assembly Government, or UK government as appropriate. Where possible, any documents which are provided to assesors for the purpose of training or guidance would be very helpful.
- Any and all data on total number of CPR claims and appeals which were approved, and the total number which were rejected for the most recent avaible year.
- Any available documents which explain how the CPR claim and appeals process is audited or assessed, both internally or by public bodies. Specifically, I would appreciate documents which explain the metric(s) used to assess how well the process is currently working and how they are applied.
-The most recent available annual data on the most common reasons, or categories of reason CPR claims and appeals are rejected.
- Any and all documents detailing the rules, guidelines or policies customer service staff are expected to follow when discussing CPR claims with applicants. In particular, the explanations given of these guidlines and rules.
- Any documents which give data on the number of complaints recieved regarding the Compelling Personal Reasons process over the most recent available year. If possible, including details of how many were resolved and at what stage of the complaints process.
- Any and all relevant documents or correspondence which contain guidance given to the Student Loans Company by public officials or bodies regarding CPR claims made by Student Finance Wales for the most recent available academic year.
- Any and all relevant documents which explain the financial auditing process the Student Loans Company follows for CPR claims and appeals in broad terms. Internal auditing or those conducted by the relevant public body or bodies if applicable. In particular, a complete list of information which the Student Loans Company is required to include for Compelling Personal Reasons Claims and appeals which have been accepted/approved.
-The most recent available policy documents for Customer support staff which explain how they should talk about Compelling Personal Reasons Claims to applicants and any documents which explain the reasons for this policy.
Thank you for your help.
Gareth Anthony Lloyd Nicholas
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Dear Mr Nicholas
Thank you for your email dated 10/11/2017.
Your request is being considered under the terms of the Freedom of
Information Act 2000 (“FOIA”).
Your request has been allocated reference 223-17.
We will respond to you under the terms of the FOIA and within 20 working
We will contact you further for clarification of your request if this is
Louise Chapman | Legal Executive
Student Loans Company
100 Bothwell Street, Glasgow G2 7JD
e: 32080 t: 0141 306 2080
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Dear Mr Nicholas
I refer to your recent email dated 10/11/2017 requesting information
relating to Compelling Personal Reasons (“CPR”), specifically in relation
to Student Finance Wales (“SFW”), under the Freedom of Information Act
The full text of your request is included at Appendix A below.
Having reviewed your request, and in consultation with the appropriate
departments within Student Loans Company Limited (“SLC”), I have concluded
that taken as a whole, the information that is held by SLC and which falls
with the scope of your request cannot be released as the cost of complying
with your request would exceed the appropriate limit set out in the
Freedom of Information and Data Protection (Appropriate Limit and Fees)
Regulations 2004 (“the Fees Regulations”). The limit applying to us is
£450 or 2.5 days (calculated to be 18 hours of staff time at £25 per
The information is therefore exempt under section 12(1) of the FOIA and in
accordance with section 17(1) of the FOIA this letter constitutes a
Refusal Notice in respect of your request.
By way of explanation, your request is considered extremely wide-ranging,
particularly due to your reference to “any and all” which effectively
means “all”, and requires the input of several different departments
Within the appropriate costs limit, and through our searches, some
information has been identified as falling within scope, and we are happy
to disclose this within this response instead of advising you what can be
provided within the appropriate costs limit, and ask you to submit a
narrowed request for this information.
Please note that the information referred to below relates to academic
Covering as many of your specific requirements as possible, please find
our response below.
The current legislation applicable to SFW applications is the Education
(Student Support) (Wales) Regulations 2017, which can be found at
relating to CPR can be found in regulations 6(9), 6(13)(e) and 6(13)(f).
Documents which list rules, guidelines, policies for the assessment of CPR
claims and appeals through Student Finance Wales
Please find attached relevant extracts of the SFW Lexicon 2017/18
(Appendix B), which is an internal document used by assessing staff. The
Lexicon is written in a language for internal use only, not for the public
and care should be taken when reading this document to avoid potentially
misinterpreting its content without background knowledge of the student
finance rules. It should also be noted that there is no exhaustive list
of types of personal reasons that may be considered as constituting CPR.
There is however, a CPR scenario index which lists some of the possible
CPR reasons – this is included towards the end of Appendix B.
Please note that the names of staff have been redacted under section 40(2)
of the FOIA. The employee names are considered to constitute their
personal data and we have therefore considered whether the disclosure of
this personal information is subject to the exemption under section 40(2)
of the FOIA (by virtue of section 40(3)(a)(i). If the disclosure of the
personal data would contravene any of the eight data protection principles
contained within the Data Protection Act 1998 the exemption under section
40(2) of the FOIA will apply. It is unlikely that it would be within the
expectations of the individuals concerned that their names would be put
into the public domain. It is considered unfair to the named individuals
to release information which could be used to identify them. Therefore
disclosure would be in contravention of the first Data Protection
Principle, which requires personal data to be processed “fairly and
lawfully”. Accordingly, we are of the view that the exemption under
section 40(2) of the FOIA is engaged.
The SFW Assessing Eligibility Guidance Chapter 2017/18 also includes
policy guidance on CPR. The SFW Guidance Chapters are publicly available
therefore exempt from disclosure under section 21(1) of the FOIA as this
information is considered reasonably accessible to you by other means.
The direct link to the Assessing Eligibility Guidance Chapter is:
There is a CPR section starting on page 42. There are also are various
references to CPR throughout this document, therefore the easiest way to
search is by searching the document (e.g. Control F) for “compelling”.
The SFW Assessing Eligibility Guidance Chapter will also cover your
requirement for explaining why a CPR appeal may be requested and how CPR
claims may be accepted for more than one year of study.
There is publicly available information on CPR on the SFW website at:
CPR is also referenced in a number of leaflets and guidance documents,
which can be found at:
Documents which explain the difference between CPR claims made through
Student Finance England (“SFE”) and SFW
There is no document held which explains the differences between CPR
claims made through SFE and SFW. CPR claims are handled by experienced
members of staff in line with the relevant regulations and guidance
provided by the relevant administration – Department for Education for SFE
and the Welsh Government for SFW.
The CPR guidance for SFW can be found in the SFW Assessing Eligibility
Guidance Chapter which is referred to above.
Any differences between how CPR claims are handled will be established
through reading the CPR section of the SFE Assessing Eligibility Guidance
Chapter 2017/18 which can be found at:
Guidance on failing to complete a previous course
Please refer to the attached email chain which includes reference to a
policy steers from the Department for Education and Skills, Wales in 2015
and 2016 (Appendix C). This steer is still applicable in academic year
Please note that the names of staff and direct contact details have been
redacted under section 40(2) of the FOIA for the same reasons as outlined
above in relation to the SFW Lexicon extracts.
Number of CPR claims
SLC does not have a CPR indicator on our systems, therefore to provide the
number of CPR claims would require a manual check of 2017/18 SFW
applications. When an application is assessed and awarded student finance
on the basis on CPR this is noted in the customer’s account notes and is
not recorded centrally.
For academic year 2017/18, so far there has been only one appeal for CPR
for a Welsh student and that was successful.
The appeals data is not broken down into categories of reasons – the
reasons must be deemed to be of a compelling and personal nature, and each
case is assessed on its own merits.
Appeals for both SFE and SFW are handled by SLC’s Regulatory Support Team.
The appeals work instruction is attached.
Complaints data does not record CPR as a specific category. CPR
complaints will recorded under “previous study”. Please find below a
table of the “previous study” complaints for SFW over the last full
financial year, and the current financial year to date.
Number of Number of
complaints complaints -
Primary Primary Sub Primary Root - Financial Financial year
Business Area Area Cause year 2017-18 to date
2016-17 (April to October
Core Previous Study
Core Assessment discrepancy 18 11
Core Previous Study
Core Assessment ELQ 1 0
GFD GFD Assessment Previous Study 1 1
GFD Assessment Previous Study
GFD Error ELQ 0 0
Pre-Assessment Data Entry Previous Study 0 0
Customer service advice on CPR
Please find attached the CPR Advisor Guide which is used by contact centre
staff when advising customers on CPR (Appendix D).
Names of staff have been redacted under section 40(2) of the FOIA, for the
same reasons as outlined above in relation to the SFW Lexicon extracts.
Academic year 2018/19
There is currently limited information available for academic year
2018/19. Having searched our records, there is reference to CPR in the
SFW Information Notice (SFWIN04/2017) which is available at
The specific reference to CPR relates to proposed changes to the policy
relating to part-time study intensity – see page 7.
Once you have reviewed the attached information and the information
available online, if there is anything more specific you wish to receive,
we would be more than happy to consider as a new request for information.
If you decide to submit a new request for information please bear in mind
that when a public authority is estimating whether the appropriate limit
is likely to be exceeded, it can include the costs of complying with two
or more requests if the conditions laid out in regulation 5 of the Fees
Regulations can be satisfied. Those conditions require the requests to be:
* made by one person, or by different persons who appear to the public
authority to be acting in concert or in pursuance of a campaign;
* made for the same or similar information; and
* received by the public authority within any period of 60 consecutive
Internal review process
If you are dissatisfied with the handling of your request, you have the
right to ask for an internal review.
Internal review requests should be submitted within two months of the date
of receipt of the response to your original request and should be
addressed to the Freedom of Information Office, Student Loans Company
Limited, 100 Bothwell Street, Glasgow, G2 7JD, Email:
[SLC request email]. Please remember to quote the reference number
above in any future communications.
If you are not content with the outcome of the internal review, you have
the right to apply directly to the Information Commissioner for a
decision. The Information Commissioner can be contacted at:
Information Commissioner's Office
Louise Chapman | Legal Executive
Student Loans Company
100 Bothwell Street, Glasgow G2 7JD
e: 32080 t: 0141 306 2080
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