Tier 4 UCL HR Tier 4 Student Visa

Tier 4 UCL HR Tier 4 Student Visa Timesheet Sessions: 3 July 2017 11 July 2017 25 July 2017 Sarah Danzie Head of Employment Policy Emma Beauchamp Senior HR Policy Advisor

Purpose • In response to feedback received from DAs, the HR Policy team have developed a tool to help departments manage their T 4 student workers to avoid visa breaches. • To ensure the timesheets are fit for purpose as an interim measure, they have been piloted with a number of departments. The feedback has been used to improve the design and process. Tier 4 (Student Visas) • Undergraduate: a max. of 20 hours paid or unpaid work per week during term time and full time during vacations. • Taught Masters students and Postgraduate Research students: required to be in continuous attendance – therefore they will continue to be restricted to 20 hours work per week throughout the year. • A “week” in this regard is considered Monday to Sunday. Guidance on Immigration and Visas website

A recent case which points to the seriousness of any breaches to UKVI rules.

Volunteering and unpaid employment There is a difference between unpaid employment (voluntary work) and volunteering • Tier 4 students should always check with the organisation which offers a volunteering opportunity whether it can be regarded as unpaid employment - unpaid employment counts towards the maximum number of hours of work a week. • The Tier 4 policy guidance confirms that Tier 4 students can volunteer and explains how the Home Office differentiates between 'voluntary work' and 'volunteering'. If you are a Tier 4 (General) student you can do voluntary work if you are permitted to work, but this work and any other (e. g. paid) work that you do must not exceed the number of hours you are permitted to work during term time. For example, if you can work for 20 hours during term time and have paid work of 15 hours a week during term time, you cannot do more than 5 hours voluntary work per week. If you are not permitted to work you cannot do voluntary work. Tier 4 (Child) students aged 16 and over can undertake voluntary work. Factors that may be taken into account when considering whether it is voluntary work or volunteering are: • Voluntary workers will usually have contractual obligations to perform the work (e. g. to attend at particular times and carry out specific tasks) with the employer being contractually required to provide the work – the contract does not have to be written. The worker is usually remunerated in kind. • Students who are volunteering do not have a contract, they must not be a substitute for an employee and they must not be doing unpaid work – i. e. receiving payment in kind (although they are sometimes reimbursed for reasonable travel and subsistence expenses). Volunteers usually help a charity or voluntary or public sector organisation.

Procedure for the Student worker 1. Student workers should submit their timesheet daily to their Supervisor/Line Manager. Your Supervisor/Line Manager must review your timesheet to ensure any work commenced with them will not cause you to work in excess of the 20 hour limit. 2. Once you have completed your work, complete the number of hours worked in the timesheet for your Supervisor’s/Line Manager’s authorisation. 3. If you also work outside UCL or in other UCL departments then you must record all hours that have been worked for each employer and department on the timesheet. 4. You and your supervisor will need to sign to confirm that the 20 hour limit has not been exceeded in the working week, which is now defined as from Monday to Sunday. 5. Timesheets should be submitted to your Departmental Administrator (or delegated authority) by the timesheet deadline as agreed by the department date each month. 6. If you work for more than one department then you will need to submit your timesheet to each relevant department administrator.

T 4 Timesheet Electronic version Box Information required Student The name of the student worker Name Employee The student’s employee number as number listed on their payslip Department The department the student works for Email The student’s email address UCL student The student worker’s student number as identified on their UCL ID card Supervisor The person who mainly supervises the student’s work Student The student’s status, e. g. type Undergraduate, Postgraduate (Taught), Postgraduate (Research).

T 4 Timesheet Electronic version Week The date of the Monday at the start (Monday to of the week the work was Sunday) completed Commencing UCL The name of the UCL department that Department the student worked in that day Work Completed For Hours The number of hours the student worked for worked on a given day for the UCL department Hours The number of hours the student worked for an external employer on a external given day employer

T 4 Timesheet Electronic version Student declaration

Notes • • Print and electronic version available Electronic version comes complete with drop downs lists and formulas You may submit your timesheet to your Supervisor/Line Manager by email if a wet signature is not practicable. The onus is on you to provide the relevant email authorisation in absence of a signature when presenting your timesheet to all Supervisors/Line managers*.

Procedure for Supervisors/Line Managers 1. Supervisors/Line Managers must review hours worked on the timesheet by the student worker before the student commences work with them. • Supervisors / Line Managers must not schedule or allow work for Tier 4 student workers without full visibility of their timesheet. • This is to ensure the student worker is not permitted work that will cause them to exceed the 20 hour limit. 2. Student workers will submit their timesheet after completing work, the timesheet must then be authorised daily. 3. The timesheet should be handed back to the student worker for submission to their department administrator for payment. 4. Report breaches of visa conditions by contacting hr. eca@ucl. ac. uk

Notes • • The timesheet supports student workers who have more than one supervisor/Line Manager If there is more than one Supervisor/Line Manager, each will be required to confirm the hours worked by the student in their department. Supervisors may authorise timesheets by email if a wet signature is not practicable The onus is on the Student worker to provide the relevant email authorisation in absence of a signature when presenting their timesheet to their Supervisor/Line manager*.

Procedure for DAs 1. Upon receipt of the fully authorised timesheet, the Departmental Administrator (DA) in the department must review the form to verify that the student has not worked more than 20 hours in any given week. • Any breaches must be reported to ECA 2. Submit the Form 6 payment request on SIP, confirming the worker has not exceeded the 20 hour limit 3. Submit the Form 7 payment request on SIP, uploading the relevant right to work documents for the student worker confirming that the worker has not exceeded the 20 hour limit. 4. The student workers T 4 timesheet should then be stored locally. – – – If there are visa breaches in your department, you may be asked by the ECA team to demonstrate how your department were being compliant. Therefore we suggest DA’s keep copies (online and print) for 12 months. Timesheets should be held securely - only accessible by those who need the data.

T 4 Timesheet Print version • Review the total weekly hours worked • Electronic version will highlight in red weekly hours worked above 20

Notes • Reject timesheets that have not been fully authorised • If the student worker works for more than one department, the supervisor for each department will authorise the date for which the student worked • DAs must have sighted, copied and retained a copy of right to work documentation (including any visas) before any work is carried out

Next Steps… Plan Expectations • Roll out across UCL from 31 July 2017 • Monitor and review feedback by December 2017 • ECA team will perform spot checks periodically • Ensure use of the timesheets by T 4 student workers • Colleagues should familiarise themselves with timesheets and process • Ensure all line managers / supervisors review timesheets prior to allocating hours

Additional Resources • Tier 4 Timesheet and Guidance • Immigration & Visas

Email template • Helpful email template to communicate the Launch to your student workers and their supervisors Dear all As you may be aware students studying in the UK on Tier 4 visas are allowed to undertake both paid and unpaid work for a maximum of 20 hours in total per week. A week is defined by the Home Office as a period of 7 days beginning with Monday. While the onus to ensure visa compliance lies primarily with the student worker, UCL as an employer is also responsible for monitoring how much work is that being undertaken when allocating work to student workers on Tier 4 visas. It is vital that both our Tier 4 student workers and UCL can demonstrate compliance with the visa regulations set by UKVI. The consequences for anyone found in breach of the working hours restrictions are severe (fines for the Department of up to £ 20, 000 levied by UKVI and possible revocation of visa for the student worker). To mitigate the risk of any student being allocated or working more than their allowed hours, UCL as an interim solution has developed timesheets to help increase its ability to monitor student worker compliance. Student workers will need to complete a weekly timesheet detailing hours worked. This will be signed-off by the supervisors who allocated the work (i. e. [xxxxx] in most cases) to confirm the hours and will need to be submitted to the Departmental Manager (or delegated authority) for payment. Kind Regards

Implementation plan Training & Comms Monitoring and Review

Training & Communication strategy for implementation 1. Initial comms will be heads up to introduction of the T 4 timesheet – Relevant networks SHARE, Week@, DEOLOs network, UCL Immigration web pages – Maybe necessary to identify the appropriate networks to target students 2. Email to all T 4 student workers, DAs and faculty managers identified by reporting team advising of timesheet launch and expectations. 3. HR Policy/ECA team to put on a number of briefing sessions* for Student workers, DAs, DAMs, Module convenors (other relevant groups). 4. Timesheet and supporting guidance documents available from HR website with users given opportunity for feedback (submit comments) 5. Further targeted comms to Student workers, DA/Ms and Supervisors/Managers etc around the launch of timesheets

Monitoring and Review of process • Following launch and training we would expect full compliance across UCL. • ECA/Policy will carry out spot checks across the University. • Feedback from users will be used to continuously improve the process and feed into requirements for a permanent online solution.