The Request (dated 13 February 2018)

Dear Sir,
 
We, on behalf of parents whose children are studying in various Private Schools in Pakistan would like bng to your attention the exploitation by Private schools in registering students with British Council;
 
1.     Difference in examination registration fee by British Council that is charged to student of a School and Private candidate, this is discriminatory. 
2.     British Council discount offered to Schools is not being passed on to their students/candidate appearing in examination, instead pocketed by Private Schools as profit.
3.     Schools are overcharging examination registration fee from what is published on British Council website. Parents are told by Private schools that this fee is charged by British Council in a non-transparent manner. 
 
Parents of school / college students are extremely concerned at the un-regulated and unbridled increase in examination registration fee charged by the British Council to school/ college children in Pakistan. On behalf of Parents, we are requesting your office to furnish the following information, under Freedom of Information Act;
 
1.     Details of discounts offered by British Council to Private Schools in Pakistan in O & A level examination registration.
 
We are interested in following information.
 
a) Year wise examination enrolment number by Private Schools from 2012 to 2018.
b)  Year wise % age discount offered to candidates enrolled by Private Schools from 2012 to 2018.
c) Year wise Amount of discount offered to candidates enrolled by Private Schools from 2012 to 2018.
d) Year wise Amount of discount offered to top 50 Private Schools from 2012 to 2018.
 
In Pakistan's context, various Private Schools affiliated with CIE have been over charging fee from their students for their enrolment in O & A levels examination. The varying fee level charged (over and above British Council specified fee) by different Private schools for standard O & A levels examination is creating confusion among parents who often ask ' What exactly are the dues required by British Council/ CIE'. 
 
It’s a worldwide accepted principle that availability of information to all relevant stakeholders (Parents' in the instant case) shall lead to transparency as well as satisfaction of stakeholders. Therefore, publicising of provision of examination fee structure, discount % age and disclosure of transfer of discount to students by Private Schools requires oversight by both British Council & CIE to ensure transparency. 
 
2.     Efforts and systems put in place by British Council to safe guard the public interest of Society in general to ensure only registered schools are allowed for registering their students for examination with British Council.
 
As per governing laws in Pakistan, it is mandatory for all Private Schools (including Educational Institutes offering lower and higher secondary education) to get themselves REGISTERED with their respective regulatory & registering authorities before applying for their affiliation/ enrolment/ accreditation of their students with any Domestic/ International examining & degree awarding institute like CIE. In addition to this, as per governing laws, both International & domestic examining & degree awarding institute are bound to adhere due/ valid registration of their clients (Private Schools) before awarding affiliation/ enrolment/ accreditation of their students. 
 
3.     Efforts and systems put in place by British Council to safe guard the interest of Parents & Students in particular to STOP Private schools from overcharging in registering their students for examination with British Council.
 
Due to no ownership ( by British Council) of Parent's complaints on this issue, we are also taking this issue to the office of Fair Trading and National Audit Office in U.K.  and also exploring the option of putting a petition in Court if we fail to avail any relief from British Council & Cambridge. We strongly believe that due to non-existent oversight, check or regulation by Cambridge and British Council, Private Schools in Pakistan are facilitated in working against the public interest and well-being of Pakistani society and getting a free hand in overcharging parents. Public feedback on overcharging by Private Schools may be viewed on below social media links;
 
 
Please note that for a large majority of working class parents in Pakistan; education related expenses are the family’s biggest monthly burden. Despite second jobs, no holidays and living on a tight budget; many families are simply unable to afford to keep their children in the private school system and appear in private testing institutions conducted tests, like British Council.  Today's challenging economic climate has left thousands of middle-class parents struggling to pay for their children's education and parents are finding it hard to accept they can no longer afford fees to educate their children.  This situation also affects morale of the children in a negative way.
 
Pakistani Parents have to deal with another challenge,  all leading Private Schools have challenged the legislations regulating Private Schools in Courts, stopping its implementation and are in forefront in abusing child rights, especially UN’s Sustainable Development Goal number 4. They harass parents and students and subjected them to discriminatory attitude who question their illegal activities and in some instances they have gone to an extent that they have cancelled admission and stopped students from taking classes. We assisted such effected parents and gotir admission resumed through engaging high courts. Due to such act of Private schools, Parents are hesitant in registering their complaints against illegal activities of Private Schools in Pakistan. 
 
We would appreciate if you could take cognizance of the matter and take necessary measures that ensure transparency and reflects Cambridge & British Council positive role in helping Pakistani community and students’ by working closely with regulatory authorities of Private Schools like PEIRA, IBCC and Parents body Pakistan Parents Alliance, rather promoting vested business interests of few Private Schools at the cost of public interest in Pakistan. 
 
Looking forward to your urgent attention on this important issue.
 
Sincerely;

 

Our Response (dated 26 March 2018)

Dear 

Thank you for your request for information dated 13 February 2018, which you later clarified on 24 February 2018, concerning examinations fees for private schools in Pakistan. Your request has been handled under the terms of the Freedom of Information Act (FOIA) 2000 and has been passed to me for reply.

For your ease of reference I have restated your request below in bold and have provided our response beneath each point.

1.Details of discounts offered by British Council to Private Schools in Pakistan in O & A level examination registration

a)Year wise examination enrolment number by Private Schools from 2012 to 2018
b)Year wise % age discount offered to candidates enrolled by Private Schools from 2012 to 2018.
c)Year wise Amount of discount offered to candidates enrolled by Private Schools from 2012 to 2018.
d)Year wise Amount of discount offered to top 50 Private Schools from 2012 to 2018.
 

We are withholding this information as the exemption under section 43 (Commercial interests) sub-section (2) applies. 

Section 43 (2) allows a public authority to withhold information where it would, or would be likely to, prejudice the commercial interests of any person, including the public authority holding it.

Sharing this data would provide accurate information about the size of our market both to local and international competition. This data can be used by competitors to justify investing in the market and taking an aggressive market development approach. 

The exemption for commercial interests is subject to the public interest test as stipulated by the Act, which means that the exemption can only be upheld if the public interest in doing so outweighs the public interest in disclosure. 

Whilst we acknowledge that there is a public interest in understanding British Council’s operations and disclosure would facilitate transparency within our organisation in this case the damage that would be caused from disclosing this information to our commercial interests and our partners, Cambridge International, commercial interests outweighs the public interest in disclosure.

2.Efforts and systems put in place by British Council to safe guard the public interest of Society in general to ensure only registered schools are allowed for registering their students for examination with British Council

As per governing laws in Pakistan, it is mandatory for all Private Schools (including Educational Institutes offering lower and higher secondary education) to get themselves REGISTERED with their respective regulatory & registering authorities before applying for their affiliation/ enrolment/ accreditation of their students with any Domestic/ International examining & degree awarding institute like CIE. In addition to this, as per governing laws, both International & domestic examining & degree awarding institute are bound to adhere due/ valid registration of their clients (Private Schools) before awarding affiliation/ enrolment/ accreditation of their students.

Since the inception of regulatory authorities in Pakistan, the British Council ensures that each new School holds the required No Objection Certificate (NOC) before registering for curriculum delivery with the relevant UK Examinations Board; those currently delivering these Examinations through the British Council in Pakistan

3.Efforts and systems put in place by British Council to safe guard the interest of Parents & Students in particular to STOP Private schools from overcharging in registering their students for examination with British Council

There are three parts to the School exam registration fee. 1) The Board fee levied by the UK Board for each subject, 2) The British Council fee for administering the exam and 3) The School admin fee; this is levied by the School on the candidate.

The British Council only controls its own fee for administering the exam; in Pakistan specifically this is set with external conditions in mind and the prevailing security situation in a fragile environment.

I hope the information provided has been useful. 

If you are dissatisfied with the handling of your request, you have the right to ask for an internal review. Internal review requests should be submitted within two months of the date of receipt of the response to your original letter and should be addressed to: 

Information Governance Advisor (Disclosures)
Information Governance and Risk Management 
British Council
Bridgewater House
58 Whitworth Street
Manchester
M1 6BB 
 

If you are not content with the outcome of the internal review, you have a right to appeal to the Information Commissioner for a decision at: 

The Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
 
Phone: 0303 123 1113 

Website: www.ico.org.uk

Yours sincerely