Multiple FOI requests regarding valid information notices

Thomas Coward made this Freedom of Information request to Student Loans Company Limited

This request has been closed to new correspondence from the public body. Contact us if you think it ought be re-opened.

The request was partially successful.

Dear Student Loans Company Limited,

Please note this is to be treated as four separate FOI requests.

FOI request:
- Please provide the current template for the information notice you serve on customers(debtors) as defined by The Education (Student Loans) (Repayment) Regulations 2009, Regulation 23. This would ideally be in pdf, doc or docx format. More information on what a valid information notice can request can be found here: https://www.legislation.gov.uk/uksi/2009...

FOI request:
- Please provide the total number of valid information notices that you have served on customers (debtors) from 2013 to 2018, this should be provided as a broken down yearly figure .

FOI request:
- Please provided the total number of valid information notices that have been successfully & correctly completed and returned to you by customers (debtors) of your company from 2013 to 2018, this should be provided as a broken down yearly figure.

FOI request:
- Do you class the Confirmation of Customer Details Form as a valid information notice as defined by The Education (Student Loans) (Repayment) Regulations 2009, Regulation 23?

In closing please make sure to provide valid data regarding information notices, not the Confirmation of Customer Details Form which is a not an information notice.

Yours faithfully,
Thomas Coward

SLC FOI Requests - Do Not Reply, Student Loans Company Limited

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FOI Requests, Student Loans Company Limited

Dear Mr Coward

Thank you for your email dated 12/07/2018.

Your request is being considered under the terms of the Freedom of
Information Act 2000 (“FOIA”).

Your request has been allocated reference 156-18.

We will respond to you under the terms of the FOIA and within 20 working
days.

We will contact you further for clarification of your request if this is
considered necessary.  

Yours sincerely

Louise Chapman | Legal Executive
Student Loans Company
100 Bothwell Street, Glasgow G2 7JD
e: 32080  t: 0141 306 2080

[1]www.slc.co.uk
Follow us at [2]Twitter/SLCcomms for the latest corporate news and updates

From:        Thomas Coward <[FOI #497131 email]>
To:        FOI requests at SLC <[SLC request email]>
Date:        12/07/2018 15:12
Subject:        Freedom of Information request - Multiple FOI requests
regarding valid information notices

--------------------------------------------------------------------------

Dear Student Loans Company Limited,

Please note this is to be treated as four separate FOI requests.

FOI request:
- Please provide the current template for the information notice you serve
on customers(debtors) as defined by The Education (Student Loans)
(Repayment) Regulations 2009, Regulation 23. This would ideally be in pdf,
doc or docx format. More information on what a valid information notice
can request can be found here:
[3]https://www.legislation.gov.uk/uksi/2009...

FOI request:
- Please provide the total number of valid information notices that you
have served on customers (debtors) from 2013 to 2018, this should be
provided as a broken down yearly figure .

FOI request:
- Please provided the total number of valid information notices that have
been successfully & correctly completed and returned to you by customers
(debtors) of your company from 2013 to 2018, this should be provided as a
broken down yearly figure.

FOI request:
- Do you class the Confirmation of Customer Details Form as a valid
information notice as defined by The Education (Student Loans) (Repayment)
Regulations 2009, Regulation 23?

In closing please make sure to provide valid data regarding information
notices, not the Confirmation of Customer Details Form which is a not an
information notice.

Yours faithfully,
Thomas Coward

-------------------------------------------------------------------

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show quoted sections

FOI Requests, Student Loans Company Limited

1 Attachment

Dear Mr Coward

I refer to your recent email dated 12/07/2018 requesting the following
information under the Freedom of Information Act 2000 (“FOIA”):

“FOI request:
- Please provide the current template for the information notice you serve
on customers(debtors) as defined by The Education (Student Loans)
(Repayment) Regulations 2009, Regulation 23. This would ideally be in pdf,
doc or docx format. More information on what a valid information notice
can request can be found here:
[1]https://www.legislation.gov.uk/uksi/2009...

FOI request:
- Please provide the total number of valid information notices that you
have served on customers (debtors) from 2013 to 2018, this should be
provided as a broken down yearly figure .

FOI request:
- Please provided the total number of valid information notices that have
been successfully & correctly completed and returned to you by customers
(debtors) of your company from 2013 to 2018, this should be provided as a
broken down yearly figure.

FOI request:
- Do you class the Confirmation of Customer Details Form as a valid
information notice as defined by The Education (Student Loans) (Repayment)
Regulations 2009, Regulation 23?

In closing please make sure to provide valid data regarding information
notices, not the Confirmation of Customer Details Form which is a not an
information notice.”

Although you have intimated that you wish your questions to be treated as
four separate requests, we are responding on the basis that these are one
request relating to the same subject.  We are fully aware of the decision
in case of Ian Fitzsimmons v ICO & Department for Culture, Media and Sport
(EA/2007/0124, 17 June 2008) and there are no issues with the appropriate
costs limit for dealing with any of these questions.  

We do not consider your fourth question to constitute a request for
information under the FOIA – you are asking for our opinion as opposed to
requesting recorded information.  Your fourth question is also considered
to be a loaded question as you have concluded your email by stating that
the Confirmation of Customer Details Form is not an information notice.
 We consider both COCD and Overseas Income Assessment (“OVFA”) Forms to
constitute information notices under regulation 23 of the Education
(Student Loans) (Repayment) Regulations 2009, as amended, as well as
regulation 18 of the Education (Student Loans) (Repayment) Regulations
(Northern Ireland) 2009, as amended.  Reference in this response to any
regulations is therefore widened to a collective “Repayment Regulations”.
 On the basis that you do not consider the COCD to be an information
notice, then this would result in an “information not held” response to
your questions.  The response that follows covers both COCD and OVFA
forms.  

Response

Question1

As stated above, we consider both COCD and OVFA forms to constitute an
information notice under the Repayment Regulations.  

The COCD form is for student loan borrowers who are resident in the United
Kingdom.  Please find attached the current template that is issued to
borrowers.

The OVFA form is for student loan borrowers who are resident overseas.
 The current template for the OVFA is held by SLC, however exempt from
disclosure under section 21(1) of the FOIA on the basis that this is
reasonably accessible to you by other means.  The OVFA is available on our
repayment website ([2]www.studentloanrepayment.co.uk) at
[3]http://www.studentloanrepayment.co.uk/pl....

Questions 2 and 3

Please refer to the table below for the number of COCD and OVFA forms
issued in the years

Year of Issue Number of Forms Issued Number of Forms Returned
Complete
2013                                                          
                    445,585                        179,886
2014                                                          
                    512,249                        227,705
2015                                                          
                    740,714                        317,793
2016                                                          
                    656,041                        282,504
2017                                                          
                    817,027                        374,692
2018 (to date)                                                          
                    357,276                        196,280
Totals                                                          
                3,528,892                    1,578,860

Please note the following in relation to the above figures:
·        the effective date of the data is 18/07/2018;
·        multiple forms may have been issued to borrowers, therefore the
“number of forms issued” is not a unique count of borrowers, rather a
count of the number of forms issued;
·        any forms which have been returned incomplete have not been
included within the figures; and
·        borrowers could be counted more than once if there has been a
requirement to re-assess.

Question 4

We have already answered this question despite it not being considered to
constitute a request for information under the FOIA.  In light of your
comments about the COCD form not being an information notice, if you were
willing to provide your reasons as to why you do not consider the COCD
form to constitute a valid information notice, then we would be happy to
respond outside the scope of the FOIA.  

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
Wycliffe House  
Water Lane  
Wilmslow  
Cheshire  
SK9 5AF

Yours sincerely

Louise Chapman | Legal Executive
Student Loans Company
100 Bothwell Street, Glasgow G2 7JD
e: 32080  t: 0141 306 2080

[4]www.slc.co.uk
Follow us at [5]Twitter/SLCcomms for the latest corporate news and updates

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References

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1. https://www.legislation.gov.uk/uksi/2009...
2. http://www.studentloanrepayment.co.uk/
3. http://www.studentloanrepayment.co.uk/pl...
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