These queries have been in the context of UCAS Track, which communicates your offer to the applicant in the first instance, ensuring they can view their offers in one central portal.
The Competition and Markets Authority (CMA) has confirmed that earlier advice provided to Supporting Professionalism in Admissions (SPA) still applies.
In theory, a link to a PDF document should meet the requirement of ‘providing in a durable medium’, provided the following safeguards are in place.
- The information should be protected, so it cannot be altered (you may want to consider version control and date stamping).
- The information should be in a format which can be stored and printed by the applicant.
- The applicant should be able to easily identify the information they were given, i.e. it must be easy to find and be a permanent record of what they were given access to – so must not be changed.
- The information has to be easily available for the applicant to access for a sufficient period, including after they have completed the course.
The CMA has provided further clarification on how you can meet the requirement that the PCI be accessible to the applicant for a sufficient period post-completion of the course. It should not only be available to applicants in Track, but also supplemented by a further communication.
The best solution would be for providers to provide the [PCI in a ‘durable medium’] directly to students at the time required (within a reasonable time after acceptance of the offer) on a once and for all basis, for example by sending an email to prospective students who have accepted offers, with a link to the online PDF.
If you have any questions, please contact your internal legal advisers and, if you have any further questions, your Relationship Manager.