Process steps to mitigate risk
- Where payment is taken by credit or debit card, any refunds should only be made to the same card on which the payment was made.
- Where payment of tuition fees or any other charges has been split between more than one payee, any refund due will be made in proportion to the original split.
- In cases where a bank account has been closed, it may be possible to make direct payment to an alternative UK bank account in the payer’s name provided the original fee payment came from a UK bank account and was also in the payer’s name.
- Refunds will not be made in cash. In cases where the original fee was paid in cash, the refund will be made to a valid UK bank account in the name of the payer or in certain circumstances by cheque payable to the payer with the exception of one-off refunds of up to £20 for prepaid library cards (and irrespective of how the cards have been originally charged/topped up) which may, at our discretion be made in cash.
‘Know your customer’
It is important that steps are taken by the College to verify the identity of students, customers and third parties. This may include conducting appropriate due diligence and screening against applicable financial sanctions target lists prior to entering into agreements with a third party including checking whether such third party is on the HM Treasury consolidated sanctions list (https://www.gov.uk/government/collections/financial-sanctions-regime-specific-consolidated-lists-and-releases ) and/or on the Office of Foreign Assets Control List (https://sdnsearch.ofac.treas.gov ). Satisfactory evidence of identity must be obtained, such as:
- Passport and/or Visa
- Birth Certificate
- Correspondence with student at their home address
- Letters or documents proving name, address and relationship with student
- If an organisation (for example, a sponsor) is not known to the College:
- Check for letterhead documents
- Check that invoices show a registered office and VAT number
- Check with Companies House
- Meet or contact key sponsors
For third parties Due diligence records (including identity evidence) must be retained for a period of five years from the end of the transaction or business relationship with the relevant student, customer or third party.
Students must make arrangements to cover their living expenses prior to arrival including setting up their bank accounts. If a donor or third party sends money in excess of requested tuition fees, the excess can either be repaid to the donor using the same bank details or, with the permission in writing of the donor, be used to fund College accommodation due. The excess cannot be transferred to the student or to any other third party.