5We decide whether to use the Large Group Complaints process, but we would not make that decision without discussing it with the provider and the students involved. That discussion may take place before we receive any complaints, because the provider, student representative body or some students have approached us, or it may take place when it becomes apparent that large numbers of students are filling in our Complaint Form. It is important to establish early on how many students want to bring a complaint to us, so that we can decide if the number of similar complaints is such that it may be appropriate to review the complaints under the Large Group Complaints process.
6We encourage providers and student representative bodies to contact us informally and at an early stage if it appears that a large group of students may want to complain to the OIA. In some circumstances, where the provider and students agree that this could be beneficial, we may try to help them to reach an agreement about the complaint before the provider’s internal processes have come to an end. Early discussion may also help us to provide appropriate signposting, for example, if students contact us before raising any of their concerns with the provider or if a student representative body is in a position to offer support. Although we encourage providers to discuss group complaints with us at an early stage, it is not a requirement of our Rules to do so.
7Even if we talk to a provider and/or students and their representatives about a potential Large Group Complaint before any student formally brings their complaint to us by submitting a Complaint Form, we will not formally consider a complaint under our Rules and additional Rules until a student has made their complaint to us. We may make a customised Complaint Form available for students in a large group. This helps us to ask targeted questions about the complaint and remedy that students are seeking and also makes our administration more efficient. But if a student uses our standard Complaint Form to make their complaint, we will still consider whether it is a complaint that should be considered as part of the Large Group.
8After we have decided to use the Large Group Complaint process, if fewer students than anticipated choose to bring their complaint to the OIA we may decide to review the group complaint under our usual Rules. We would explain our decision to the students who have complained to us and to the higher education provider.
9Students in a Large Group may choose someone to represent them in their complaint to us. This may be someone who represented them as a group in the provider’s internal procedures, or it may be someone different. There is guidance about what makes a good representative on our website. We strongly encourage students to seek advice and support from their student representative body where this is available, even if that body is unable to represent them directly.
10Even where a group of students is represented by one or more individuals, each student who would like to complain to us will need to “opt in” as an individual. We will not review complaints from students within the Large Group Complaints process solely on the basis that the student was part of the group that complained to the provider.