Precedents database
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2.7 Complaints and appeals – UKÄ – Partial compliance (2021) No formal complaints procedure; Advisory role of appeals commitee
UKÄ
Application Initial Review Full, coordinated by ENQA Decision of 18/03/2021 Standard 2.7 Complaints and appeals Keywords No formal complaints procedure; Advisory role of appeals commitee Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “UKÄ has no formal complaints procedure in place (p. 34), even though the panel was confident that any issues stakeholders have, related to the work of the agency, are taken up by UKÄ. The report further discussed the advisory role of the appeals committee and the panel was concerned that this approach, paired with the fact that the committee cannot make recommendations how to correct potential errors, could undermine the authority of the appeals committee.”
Full decision: see agency register entry
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2.7 Complaints and appeals – QQI – Compliance (2019) Scope of the appeals system
QQI
Application Renewal Review Full, coordinated by ENQA Decision of 05/11/2019 Standard 2.7 Complaints and appeals Keywords Scope of the appeals system Panel conclusion Full compliance Clarification request(s) – RC decision Compliance “The Register Committee noted the panel's remark that the outcomes of cyclical institutional reviews can currently not be appealed, while noting thata provider “may still wish to challenge the findings in a way that would be better suited to an appeals process rather than a complaints process” (p. 33).The Register Committee has generally understood the standard to require that all results of external quality assurance processes be open to appeal, hence including reports that do not include “categorical decisions”.The Committee therefore underlined that QQI should consider widening the scope of its appeal system in monitoring the fitness for purpose of the current arrangements, per the panel's remarks. ”
Full decision: see agency register entry
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2.7 Complaints and appeals – evalag – Compliance (2019) Independence of the appeals committee
evalag
Application Renewal Review Full, coordinated by ENQA Decision of 05/11/2019 Standard 2.7 Complaints and appeals Keywords Independence of the appeals committee Panel conclusion Substantial compliance Clarification request(s) – RC decision Compliance “In the previous decision to renew evalag’s registration the Register Committee flagged for attention how evalag has followed up the recommendation to separate the bodies in charge of appeals from the bodies deciding on accreditation, and to rule out parallel memberships.The review panel confirmed the independence of the appeals committee from the evalag decision-making body for accreditation. The panel further reported that parallel memberships are now ruled out. The Register Committee therefore concluded that the flag has been addressed.”
Full decision: see agency register entry
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2.7 Complaints and appeals – AHPGS – Compliance (2020) brief procedure for complaints and appeals
AHPGS
Application Renewal Review Full, coordinated by ENQA Decision of 16/03/2020 Standard 2.7 Complaints and appeals Keywords brief procedure for complaints and appeals Panel conclusion Substantial compliance Clarification request(s) – RC decision Compliance “33. […] there was only a brief procedure for complaints and appeals, and that the process was not fully known by the universities concerned; the Appeals Committee was not yet appointed, neither another body that deals with complaints and appeals.
34. [...] a statutory change, introducing the legal basis of the Appeals Committee, had entered into force and that the Appeals Committee had subsequently been appointed.
35. Having considered the additional information, the Register Committee concurred with the review panel's conclusion that AHPGS complies with the standard.”
Full decision: see agency register entry
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2.7 Complaints and appeals – NOKUT – Partial compliance (2018) Absence of a formal complaints procedure
NOKUT
Application Renewal Review Full, coordinated by ENQA Decision of 06/12/2018 Standard 2.7 Complaints and appeals Keywords Absence of a formal complaints procedure Panel conclusion Full compliance Clarification request(s) – RC decision Partial compliance “The Register Committee noted the panel's analysis that the complaints procedure “is less clearly defined”. While the Committee acknowledged that the prevailing culture of dialogue meant that institutions were aware of their opportunities to voice complaints, it considered that the possibility to complain and the related procedures should be explicitly spelled out, e.g. in the relevant guides for institutions, as required by the standard.”
Full decision: see agency register entry
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2.7 Complaints and appeals – ANECA – Compliance (2018) Availabily of appeals for monitoring procedures
ANECA
Application Renewal Review Full, coordinated by ENQA Decision of 11/09/2018 Standard 2.7 Complaints and appeals Keywords Availabily of appeals for monitoring procedures Panel conclusion Full compliance Clarification request(s) Panel (09/06/2018)
RC decision Compliance “The Register Committee also noted that appeals are not made available in case of MONITOR procedure […]. The review panel stated as the activity has a supportive /developmental nature and that no decisions are taken on its basis no appeals can be issues. The panel noted that it had discussed the complaints (and appeals) procedures with key stakeholders, who expressed their satisfaction with the functioning of the processes and confirmed that the agency considered all appeals and complaints according to its policy and within a reasonable time-frame.”
Full decision: see agency register entry
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2.7 Complaints and appeals – SKVC – Partial compliance (2017) Absence of a complaints procedure
SKVC
Application Renewal Review Full, coordinated by ENQA Decision of 16/11/2017 Standard 2.7 Complaints and appeals Keywords Absence of a complaints procedure Panel conclusion Substantial compliance Clarification request(s) – RC decision Partial compliance “While the Register Committee noted that appeals’ procedures are well defined, accessible and handled adequately, the Register Committee noted that SKVC’s methodologies and principles do not cover complaints.The panel did not find how higher education institutions can raise issues of concerns or how they are handled by SKVC in a professional and consistent manner.The Committee underlined the recommendation of the panel for the development of a specific complaints procedure that should be made easily accessible to higher education institutions.”
Full decision: see agency register entry
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2.7 Complaints and appeals – ASHE – Partial compliance (2017) Absence of appeals procedure for initial accreditation and inadequate body to address the appeal.
ASHE
Application Renewal Review Full, coordinated by ENQA Decision of 20/06/2017 Standard 2.7 Complaints and appeals Keywords Absence of appeals procedure for initial accreditation and inadequate body to address the appeal. Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “The panel considered that the body deciding on appeals should not be identical to the body that made the decision being appealed, but identified an overlap in the case of ASHE. It further noted that there is no appeals procedure (internal to ASHE) for initial accreditation, but only a possibility to appeal decisions in a court.”
Full decision: see agency register entry
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2.7 Complaints and appeals – IAAR – Partial compliance (2017) Conflict of interest: same members in the Appeals Commission and Accreditation Council
IAAR
Application Initial Review Full, coordinated by ENQA Decision of 20/06/2017 Standard 2.7 Complaints and appeals Keywords Conflict of interest: same members in the Appeals Commission and Accreditation Council Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “The panel noted that IAAR established a commission to handle appeals and complaints in late 2015 that consists of a number of members representing national representatives of employer bodies. The review panel formed the view that the membership of the Commission was not well aligned with its role and purpose, having the focus almost exclusively on employer representatives. The panel further added the potential conflict of interest considering the overlapping membership of the Appeals Commission that of the Accreditation Council. The panel recommended the broadening of the Commission’s membership and a separation from the members of the Accreditation Council”
Full decision: see agency register entry
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2.7 Complaints and appeals – ASIIN – Compliance (2017) No possibility to appeal in cases where the review does not end in a judgment
ASIIN
Application Renewal Review Full, coordinated by GAC Decision of 20/06/2017 Standard 2.7 Complaints and appeals Keywords No possibility to appeal in cases where the review does not end in a judgment Panel conclusion Partial compliance Clarification request(s) – RC decision Compliance “The Committee noted that for the accreditation procedures the appeals procedure is regulated in the statute and in the board of complaints’ rules of procedure but that there is no clearly defined appeals procedure for evaluations and other external QA procedures not resulting in a formal decisionIn the additional representation, ASIIN explained that it had clarified that its regular complaints procedures, applicable to accreditation procedures so far, is also applied to certification procedures and in type-1 evaluation procedures. The Register Committee confirmed that this is indeed clarified in public documents.”
Full decision: see agency register entry
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2.7 Complaints and appeals – AAQ – Partial compliance (2016) Limited scope of complaints
AAQ
Application Renewal Review Full, coordinated by GAC Decision of 03/12/2016 Standard 2.7 Complaints and appeals Keywords Limited scope of complaints Panel conclusion Substantial compliance Clarification request(s) – RC decision Partial compliance “The Register Committee noted that AAQ and SAR provide a formalised complaints process for higher education institutions. The external review panel was, however, “more critical of the limited subject scope of the complaints procedure because, (…), higher education institutions can currently only complain about SAR’s decisions and not about possible errors in the implementation of the procedure” (p. 41).”
Full decision: see agency register entry
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2.7 Complaints and appeals – evalag – Compliance (2024) Definition of terms; Complaints; Appeals
evalag
Application Renewal Review Targeted, coordinated by ENQA Decision of 02/07/2024 Standard 2.7 Complaints and appeals Keywords Definition of terms; Complaints; Appeals Panel conclusion Compliance Clarification request(s) – RC decision Compliance “15. The Register Committee noted that the Complaints and Appeals Policy is detailed, covering the potential causes for a complaint or an appeal and it is easily accessible on the agency’s website. However, the Committee noted the panel’s concerns on the need to clarify the terms ‘complaints’ and ‘appeals’.
16. The Committee, therefore, followed the panel’s conclusion that the agency continues to comply with the standard. The Committee, however, shared the panel’s view that the agency should clarify what is meant by the terms ‘complaints’ and ‘appeals’ in all its documents, including the name of the ‘Complaints Commission’.”
Full decision: see agency register entry
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2.7 Complaints and appeals – NOKUT – Partial compliance (2023) Lack of formal complaints procedure
NOKUT
Application Renewal Review Targeted, coordinated by ENQA Decision of 30/06/2023 Standard 2.7 Complaints and appeals Keywords Lack of formal complaints procedure Panel conclusion Compliance Clarification request(s) – RC decision Partial compliance “Partially compliant with the standard due to the lack of formal complaints’ procedure– the higher education institutions could express their dissatisfaction with the process only informally throughout the review process. The agency is yet to establish a clear
complaints procedure that is known by higher education institutions”
Full decision: see agency register entry
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2.7 Complaints and appeals – Unibasq – Compliance (2024) procedure for handling complaints
Unibasq
Application Renewal Review Targeted, coordinated by ENQA Decision of 04/04/2024 Standard 2.7 Complaints and appeals Keywords procedure for handling complaints Panel conclusion Compliance Clarification request(s) – RC decision Compliance “12. In its previous decision for renewal of registration on EQAR (of 11-05-2019), Unibasq was found to be partially compliant with the standard due to the unclear procedure for handling complaints. From the report, the Committee learned that Unibasq now has a well established complaints procedure noted in the agency’s regulations of the Ethics and Guarantees Committee and the Code of Ethics.
13. Following the changes made by the agency, the Committee was able to follow the panel’s conclusion that the agency complies with the standard.”
Full decision: see agency register entry
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2.7 Complaints and appeals – AKAST – Compliance (2021) Lack of an independent appeals committee and limited coverage of appeals
AKAST
Application Initial Review Focused, coordinated by GAC Decision of 12/12/2021 Standard 2.7 Complaints and appeals Keywords Lack of an independent appeals committee and limited coverage of appeals Panel conclusion Substantial compliance Clarification request(s) Agency (07/12/2021)
RC decision Compliance “In its decision of rejection (of June 2020), the Register Committee noted that AKAST’s appeals and complaints procedure did not cover the peer institutional evaluation procedures and that the appeals were only considered by the same committee that also took the appealed decision. While AKAST agreed to revise its procedure and to establish a complaints committee consisting of independent members, the Register Committee remained unable to follow the panel’s judgment of compliance since the procedure was not yet in operation and the committee handling appeals has not been elected. 8. The panel notes that AKAST has now a revised complaints and appeals regulation and has elected a Complaints Committee at the AKAST General Meeting on 28/01/2021. In the description of the provisions for complaints (AKAST Complaints and Appeals Regulations as amended on 28/01/2021), the agency noted that the Complaints Committee’s statement is to be taken into account in the final decision of the Executive Board or the Accreditation Committee and that further details shall be regulated in the rules of procedure issued by the Complaints Committee and approved by the Executive Board.”
Full decision: see agency register entry
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2.7 Complaints and appeals – HCERES – Compliance (2022) Board member in appeals committee, independence of decisions on appeals
HCERES
Application Renewal Review Full, coordinated by ENQA Decision of 28/06/2022 Standard 2.7 Complaints and appeals Keywords Board member in appeals committee, independence of decisions on appeals Panel conclusion Full compliance Clarification request(s) Panel (14/06/2022)
RC decision Compliance “28. In the last renewal of registration, HCERES was found to be only partially compliant with the standard since its appeals and complaints processes were only just set up and not yet reviewed by an external panel; a specific concern was whether the decision-making on appeals was fully independent from those in charge of the appealed report/decision.
29. The panel considered that HCERES' appeals and complaints processes were clearly defined and communicated. The panel noted that HCERES had not received appeals or complaints since 2016.
30. The panel clarified that it considered the appeals committee's composition suitable. While HCERES Board members indeed serve on the appeals committee, the Board does adopt neither evaluation reports nor accreditation decisions. In addition, one external expert is part of the committee.
31. The Register Committee agreed that the appeals committee was sufficiently independent given that the HCERES Board does not adopt the reports or decisions that are being appealed. The Committee therefore concurred with the panel's conclusion that HCERES complies with ESG 2.7.”
Full decision: see agency register entry
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2.7 Complaints and appeals – ASIIN – Partial compliance (2021) handling of appeals and complaints
ASIIN
Application Renewal Review Full, coordinated by ASHE Decision of 15/10/2021 Standard 2.7 Complaints and appeals Keywords handling of appeals and complaints Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “The Register Committee considered the panel’s findings that show that ASIIN’s appeals and complaints processes are not well differentiated and as a result not consistently used, i.e. the institutional accreditation handbook discuss complaints procedure although what is described is the means to appeal a decision, whereas the handbooks for the programme accreditation and certification processes mention appeals procedure, the name of the Appeals/Complaints Committee appear to have four different permutation. The panel further comments on the agency’s lack of understanding of the two different concepts. In its response to the review report (19/07/2021) ASIIN’s stated that it has revised its documents and website, employing the right terminology. While the Register Committee welcomed ASIIN’s corrections, the Committee found the panel’s concerns have not been fully address, as the lack of understanding of the two concepts may affect the agency’s ability to effectively handle both appeals and complains for all its activities.”
Full decision: see agency register entry
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2.7 Complaints and appeals – FIBAA – Partial compliance (2022) Rudimentary nature of appeals procedure
FIBAA
Application Renewal Review Full, coordinated by ENQA Decision of 07/02/2022 Standard 2.7 Complaints and appeals Keywords Rudimentary nature of appeals procedure Panel conclusion Substantial compliance Clarification request(s) – RC decision Partial compliance “16. In its last decision, the Register Committee underlined the panel’s observation that there is no clear indication on whether higher education institutions can issue a complaint regarding the course of the procedure. The Committee also remarked at that the appeals procedure is documented only rudimentarily, with little or no explanation on the issues that could be raised under the appeal, no provision on the expected timeline to process a complaint, publication policy etc.
17. In its review report, the panel stated that higher education institutions may submit complaints about the conduct of the process writing an email to FIBAA and that FIBAA has established a procedure for appeals.
18. The Register Committee learned that FIBAA’s appeals procedure only applies to the procedures where the agency is awarding its seal and it does not cover the reviews where GAC is the decision-making body. Since higher education institutions may have concerns related to the application of the criteria and the judgments also in the reports prepared for the GAC, these should equally be subject to appeal in line with the standard.
19. The Register Committee further noted that FIBAA’s appeals procedure date back to December 2016, and has not been updated since the agency’s last review. The Committee found it surprising that the review panel has not addressed any of the issues the Committee raised in its last decision regarding the rudimentary nature of FIBAA’s appeals procedure and only commented on the wording of the process for complaints and appeals (that should be clarified).
20. In light of the above observations the Register Committee cannot follow the panel’s judgement of (substantially) compliant, but find that FIBAA complies only partially with the standard.”
Full decision: see agency register entry
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2.7 Complaints and appeals – ZEvA – Partial compliance (2022) requirement that appeals can be made against any report
ZEvA
Application Renewal Review Full, coordinated by ENQA Decision of 14/03/2022 Standard 2.7 Complaints and appeals Keywords requirement that appeals can be made against any report Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “25. The Committee underlined that any report is a formal outcome and thus needs to be open to appeal, even if it does not result in a yes/no decision.
26. In its additional representation, ZEvA clarified matters for evaluation reports. At the same time, it remained unclear whether and how institutions can appeal accreditation reports before submitting those to GAC. Even though GAC offers an appeals possibility, presumably GAC's process cannot fully investigate matters that are rooted in the report produced outside of GAC's direct control. Moreover, it would be unreasonable that institutions are forced to first submit to GAC a report against which they have strong objections before they can appeal against that report.”
Full decision: see agency register entry
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2.7 Complaints and appeals – AKAST – Partial compliance (2020) Impartiality in handling appeals (independence of the Appeals Committee). Coverage of all EQA activities by the appeals procedure
AKAST
Application Initial Review Full, coordinated by GAC Decision of 22/06/2020 Standard 2.7 Complaints and appeals Keywords Impartiality in handling appeals (independence of the Appeals Committee). Coverage of all EQA activities by the appeals procedure Panel conclusion Full compliance Clarification request(s) Agency (23/11/2024)
RC decision Partial compliance “The Register Committee underlined that the current arrangements does not ensure an impartial process in AKAST’s approach of handling appeals, since the appeals are considered by the same committee that also takes the accreditation decisions and nominates the review panel members for the review. The Register Committee further noted that the appeals and complaints procedure only cover issues concerning two of AKAST’s activities and it does not address the agency’s peer institutional evaluation procedures. While AKAST has not yet carried out any such evaluation, the Register Committee underlines that, since the activity is on offer, the agency is expected to ensure that all corresponding procedures will be adequately updated, including the agency’s appeals and complaints procedure.”
Full decision: see agency register entry