Internationalisation and social responsibility: policy and regulatory implications

In 2009, consideration of internationalisation and social responsibility must take account of the 2009 World Conference on Higher Education and the responsibilities it places before education systems. Oversight of the issue should reflect the principle that the relevant policy question is how the stated public objective is translated into responsibilities that can be applied, supervised and reviewed. Review should cover the complete affected scope and preserve material differences between locations, programmes, delivery modes and learner groups. The conclusion remains incomplete unless central requirements are reconciled with evidence of local practice.

Failure in relation to the policy matter may arise even where the stated policy is reasonable. Material concerns include management assurance accepted without testing, governing bodies receiving activity data instead of outcome evidence, corrective action closed without verification, and authority assigned without accountability. Materiality depends on the consequence and extent of an exception, not only on how often it appears in sampled records.

Scope of this analysis

Implementation of internationalisation and social responsibility should be organised around a decision that can be tested. In reviewing the issue, oversight should test whether formal commitments are reflected in decisions, resource allocation, provider conduct and accessible routes for review. Resources and activity should be reconciled with the operating evidence and result for which the responsible function is accountable.

The stated reference—the 2009 World Conference on Higher Education—establishes the contemporaneous context. Assurance concerning the issue should state the scope examined, evidence relied upon and any condition preventing a complete conclusion. Unsupported elements should remain open. Verified fact, policy expectation and discretionary institutional choice should remain distinct in the record. The basis of the distinction should be traceable through reporting and subsequent review.

A focused examination of the implementation question requires a clear analytical discipline. For the implementation question, cross-jurisdiction interpretation should distinguish international commitment, regional instrument, national law, regulatory direction and provider policy. Each has a different source of authority and may apply to a different object or person. The decision question, affected scope and measure should align; otherwise the conclusion may be unsupported despite substantial documentation.

• Escalate material exceptions and retain evidence sufficient for independent review.
• Preserve a traceable decision record, with responsibility, scope and timing recorded.
• Define information required for oversight, identifying the accountable function and affected scope.
• Test management assurance and retain evidence sufficient for independent review.
• Verify corrective action independently and retain evidence sufficient for independent review.

The substantive quality question

Care is required in drawing conclusions about internationalisation and social responsibility. Oversight of the affected arrangements should reflect the principle that governance structures do not provide assurance merely because committees exist. Membership, information quality, challenge, decisions and follow-through determine whether oversight is effective. A decision concerning the affected arrangements should recognise that a policy direction should not be presented as a uniform legal obligation where national implementation differs. Providers remain responsible for identifying the requirements that apply to their own activities. A finding should not be separated from limitations capable of changing how it is understood or applied.

The evidential record for the policy matter should permit a reviewer to trace the matter from decision to outcome. This may require conflict declarations and controls, independent review records, governing-body papers and decisions, and defined delegations and reserved decisions, supported by public reports reconciled with controlled records and risk and assurance plans. The sample should be extended when records conflict, a material group is missing or earlier corrective action may not have been sustained.

The assurance record for the relevant measure should retain the date of the evidence, the source responsible for it, the scope examined and the version of any instrument or definition applied. The retained record should show whether later movement reflects changed conditions or a change in the information reported. The evidential history should preserve conclusions that were operative when a material decision was made.

Testing implementation and effect

A proportionate method is available for internationalisation and social responsibility. The method for the policy matter is to prepare a jurisdictional register identifying the service, learner location, provider location, responsible authority, applicable instrument and conflict rule. Obtain competent interpretation where the legal position is uncertain and do not resolve uncertainty through promotional wording. Adverse cases and unresolved contradictions should be retained because they may reveal limitations concealed by an average result.

The implementation record for the relevant measure should identify the instrument being applied, its status, the competent authority, the affected jurisdiction and the action expected of each responsible body. Legal obligation, policy position and institutional response should each retain their proper status. A staged implementation record should set out transition dates, interim safeguards and the readiness review point.

• Who has enforcement authority?
• What is the status of the relevant instrument?
• Do partner arrangements change responsibility?
• How will conflicting requirements be managed?
• Which jurisdiction governs the activity?

Jurisdictional and evidential limits

The quality significance of internationalisation and social responsibility follows from a basic distinction between availability and effective provision. In reviewing the implementation question, governing bodies should receive sufficient, reliable and timely information to oversee education quality, learner protection and material institutional risk. Assurance should follow the learner journey and test more than a single access point or aggregate result.

Public reporting on the implementation question should distinguish established fact, analytical judgement and planned action. The record should preserve every revision capable of affecting a prior decision. Changes to definitions or evidence should be recorded separately from changes in educational performance.

The measure of progress on the implementation question is not the amount of policy or documentation produced. The relevant measure is demonstrated public benefit, including detection and correction of material variation.