Alternative Collection Locations - Is Your School Ready for a Tier 4 Audit?

Registering as an ACL means that the school and its Tier 4 pupils do not need to visit a local Post Office to collect the BRPs. This also helps schools with their Tier 4 record keeping duties and ensures that students' BRPs have arrived and are in order.

UKVI plan to start conducting audits of schools which are registered as ACLs to ensure that the ACL Guidance is being complied with. It seems that UKVI are also concerned that the security of BRPs - which are important identity documents - is not being treated seriously enough in all cases.

UKVI's "ACL Audit Team" have written to all ACLs asking them to confirm in writing certain details regarding their ACL operations with a view to ensuring all ACLs are compliant by August 2019.

Preparing for an Audit

If your school is an ACL, the issues which UKVI and the ACL Audit Team are likely to be interested in are as follows:

• Do you store your BRPs in safe meeting the Eurograde EN1143-1 standard, or equivalent, which provides insurance cover for cash to the amount of £10,000?
  
  
• Do you ensure that staff who access the safe where BRPs are stored are ACL accredited by the Home Office?
  
  
• Do you ensure that the key or combination to the safe is secured and only known or accessible to ACL accredited staff?
  
  
• Do you ever have to transport BRPs to other sites away from your main ACL and, if so:
  
  - are they transported in a locked container which is appropriate to the volume of BRPs being transported?
  
  - do they remain within the sight and under the control of an approved member of staff?
  
  - are they only transported by ACL approved staff members directly to the place where they will be issued?
  
  - are they only transported in a private vehicle, private taxi or hire vehicle remaining in the possession of the ACL member of staff at all times, with the driver going directly to the issuing site without taking unnecessary or unauthorised detours?

• Do you ensure that only ACL accredited staff only handle and distribute BRPs?
  
  
• Do you have a clear audit trail of the BRPs you receive and distribute?
  
  

Schools with Tier 4 sponsor licences will hopefully already be well versed in ensuring compliance with their sponsor duties. Those which have already registered as ACLs should also be fully compliant with the requirements of the ACL guidance, but the news that UKVI plan audits looking at this specific issue suggests they are concerned that some ACLs may not be fully compliant.

If your school is also registered as ACL, we strongly advise that you review your ACL facilities and processes against the ACL guidance, and ensure that you respond to the ACL Audit Team's request for information by the deadline given.

If you have any queries or concerns about your activities as an ACL, or any other aspect of Tier 4 compliance, please contact Tom Brett Young in our Immigration Law team on 0121 227 3759 or complete the below form.