Under 18 policy

Introduction

Malvern HE Partnerships (MHEP) is committed to protecting the safety, wellbeing, and dignity of all students. This includes students under the age of 18, who are legally defined as children in the UK. MHEP takes reasonable and proportionate steps to ensure that all students can study in a safe, supportive, and respectful environment. This includes protecting students from harm, abuse, neglect, and exploitation, as well as risks such as radicalisation.

This document has been developed as an operational guide for students under the age of 18 and their parents or guardians. It outlines the practical arrangements, expectations, and support mechanisms in place to help younger students successfully transition into higher education and student life at MHEP. It should be read in conjunction with the Group Safeguarding Policy, which sets out the institution’s overarching safeguarding responsibilities, procedures, and reporting framework.

University life is typically an adult environment where students are expected to behave independently and take responsibility for managing their daily lives, wellbeing, accommodation, finances, attendance, and personal conduct. Offers are therefore made on the basis that students can adjust to living away from home and show the maturity needed to manage everyday tasks.

All students, including those under 18, are treated as independent individuals. However, we understand that younger students may require additional support and guidance, which is why we offer a dedicated Under 18s Support Package tailored to their needs.

IMPORTANT: Procedures relating to students under the age of 18 may vary between Malvern Centres and their respective university partners. The relevant university’s Under 18 policy can be provided upon request.

This policy will be reviewed and updated annually as a minimum to ensure it remains current, effective, and compliant with relevant legislation and safeguarding requirements. It may also be reviewed and amended earlier where necessary, including in response to significant incidents, changes in legislation or guidance, operational developments, or changes to key roles and responsibilities within the organisation.

Key Principles

Students under the age of 18 are treated as individuals who are developing independence, but they remain children in law and are entitled to additional safeguarding protections. All decisions made by MHEP are guided by the principle that the safety and wellbeing of the student must come first. Safeguarding is a shared responsibility, and all staff are required to remain vigilant and report concerns promptly to the Designated Safeguarding Lead (DSL).

It is important to understand that Malvern International does not take on the role of a parent and does not act in place of parents or guardians. Parents or legal guardians retain full legal responsibility for the student at all times

Parental Responsibility

Parents or legal guardians remain responsible for the student throughout their time in the UK while the student is under 18. Before enrolment can be completed, a Parental Consent Form (Appendix A) must be signed and returned. This confirms that the parent or guardian understands and agrees to the arrangements for the student’s study, accommodation, and welfare.

Parents or guardians must provide accurate and up-to-date emergency contact details, and wherever possible more than one contact number should be supplied. They must also ensure that any relevant medical information, including existing conditions, allergies, or additional support needs, is shared with MHEP in advance.

Once a student reaches the age of 18, they become legally responsible for themselves and the parental consent arrangements no longer apply.

Pre-arrival Arrangements

 Before any student under the age of 18 travels to the UK, appropriate accommodation, care, and support arrangements must be fully confirmed. These arrangements must comply with UK Visas and Immigration (UKVI) requirements where applicable. The organisation must be satisfied that each student will reside in a safe, suitable environment with robust welfare support in place.

All arrangements are subject to review and approval prior to the issuance of a Confirmation of Acceptance for Studies (CAS). The Designated Safeguarding Lead (DSL), or a nominated delegate, must confirm that the arrangements are appropriate to the student’s age, needs, and circumstances. Records must be retained for compliance, safeguarding, and audit purposes.

Accommodation and Care Requirements

Students under 18 must have confirmed accommodation in the UK that aligns with permitted UKVI living arrangement categories. Where applicable, supporting evidence of accommodation must be obtained and verified before CAS issuance.

Guardianship Arrangements

Every student under 18 must have a responsible adult based in the UK. Where a parent or legal guardian is not resident in the UK, a guardian must be formally appointed.

The appointed guardian is responsible for the student’s welfare outside teaching hours and must:

• be an immediate family member(s) or legal guardian, over the age of 21 
• be a mature and positive role models 
• be able to communicate well in English 
• live in the UK and be based in a location that is reasonably close to the study centre, ideally residing in the same town or city of the study centre (proof of UK address required, e.g. utility bill, bank statement, or council tax bill, dated within the last 3 months)
• be able to make important decisions, and provide appropriate guidance to the student 
• have a UK phone number, able to contact in case of an emergency 
• not be a registered student or member of staff at Malvern International PLC or pathway centre (unless they’re a sibling or a parent) 
• be available 24 hours a day for emergencies
• provide support during illness, holidays, and unforeseen circumstances
• act as a key point of contact for welfare, academic, and disciplinary matters

Guardianship arrangements must be formally documented (e.g. through a letter of undertaking or guardianship agreement) and clearly outline responsibilities and contingency plans.

This requirement is typically fulfilled through an approved third-party guardianship provider arranged or endorsed by the organisation.

Approved Guardianship Provision

For students enrolled at our centres, we recommend that guardianship is provided by Sable International, an organisation accredited by AEGIS (Association for the Education and Guardianship of International Students).

Through this partnership:

• Each student is assigned a dedicated guardian on a one-to-one basis
• Guardians meet students at least twice per term
• Guardians are available by phone 24 hours a day during term time
• Ongoing support includes academic guidance, emotional wellbeing, and assistance during emergencies (e.g. illness or hospitalisation)
• Guardians maintain regular communication with students, parents, and centre staff

This collaborative approach ensures a consistent and reliable support network for all under 18 students.

Admissions Requirements Prior to CAS Issuance

Before issuing a CAS, Admissions must obtain, verify, and record the following:

• Details of the student’s intended UK accommodation (aligned with UKVI categories)
• Full information regarding the individual(s) responsible for the student’s care in the UK (guardianship details)
• Written consent from a parent or legal guardian confirming arrangements for travel, reception, accommodation, and care
• Supporting documentation evidencing accommodation and guardianship arrangements

Once all required documentation has been received, the Head of Admissions will review the submitted materials to ensure that all safeguarding and welfare arrangements for the under-18 student are appropriate and satisfactory. Following this review, the arrangements must be formally approved by both the Group Safeguarding & Prevent Coordinator and the Centre Director of the relevant centre. In the absence of either of these individuals, approval will instead be granted by the Chief Operating Officer (COO) in conjunction with the Centre Director at UEL, ensuring that all safeguarding responsibilities are consistently upheld.

Parent or Guardian Contact Protocol

Named Contact
A parent, legal guardian, or responsible adult must be identified at enrolment. Their contact details must be recorded and kept up to date.

Notification Requirements
The named contact must be informed promptly in the event of:

• Unexplained absence
• Welfare concerns
• Safeguarding referrals
• Medical incidents

Contact Procedure

• Contact must be attempted within 24 hours of any concern arising
• All attempts and outcomes must be documented
• If contact cannot be established within this timeframe, the DSL must be informed immediately

Monitoring and Compliance

All accommodation, guardianship, and welfare arrangements must be reviewed prior to CAS issuance and monitored throughout the student’s enrolment. The organisation retains responsibility for ensuring that safeguarding standards are maintained and that all documentation remains accurate and up to date.

Completion and Purpose of the Consent Form

We request that parents or guardians complete the Parental Consent Form (Appendix A) after reviewing the information provided above. This allows us to ensure that appropriate support and safeguarding measures are in place for students under 18, who may be more vulnerable or have different rights compared to older students. By signing the form, the parent or guardian agrees to the arrangements outlined and acknowledges the shared responsibilities of the student, the parent or guardian, and the University.

Emergency Contact

Provision of emergency contact details is a mandatory requirement for all students under the age of 18. Students and/or their parents or legal guardians must supply this information prior to registration. Failure to provide the required emergency contact details will result in the student being unable to enrol on their programme.

In line with KCSIE 2025 (para 101), the organisation will, where reasonably possible, hold more than one emergency contact number for each student. This is particularly important for students under 18 and provides additional options to contact a responsible adult where a student is absent and a welfare or safeguarding concern arises.

Airport pick-up

Students under the age of 18 must have suitable travel arrangements in place when arriving in the UK. Parents or guardians are responsible for ensuring that the student is met at the airport by an appropriate adult. Full details of the arrival arrangements must be provided in advance. Details include the flight number, flight arrival time at the UK airport, the name of the person collecting the student and their expected arrival day and time at the relevant University.

Accommodation

Responsibility for arranging suitable accommodation rests with the parent or guardian. MHEP strongly recommends accommodation arranged through the University, as this provides an additional level of assurance regarding safety and welfare standards.

Where accommodation is arranged independently, full details must be provided before enrolment. This includes the address of the accommodation and the identity of the adult responsible for the student at that address. The responsible adult must be over the age of 21 and appropriate identification and proof of address must be provided. Acceptable proof of address includes: utility bill dated within the last 3 months; bank statement; council tax letter; tenancy agreement; UK driving licence.

MHEP reserves the right to inspect the accommodation if there are concerns about suitability.

Post-Arrival Requirements and Information

Safeguarding and Welfare

MHEP operates a structured safeguarding system led by Designated Safeguarding Leads at each Centre. All staff are trained to recognise signs of harm or welfare concerns and are required to report these immediately. Safeguarding records are maintained securely and separately from general student records, in accordance with legal requirements.

Student welfare is monitored throughout the programme. This may include observation of attendance, engagement in class, behaviour, and general wellbeing. Where concerns arise, these are assessed by the DSL, who will decide on the appropriate response and whether further action is required.

Age-Specific Safeguarding Measures

All students under 18 receive safeguarding protection, but additional measures are applied depending on age and level of independence.

Students aged 16 are subject to enhanced safeguarding arrangements. Parental or guardian consent is required not only for enrolment but also for changes to accommodation and participation in overnight or extended activities. A named parent, guardian, or responsible adult must always be contactable, and MHEP will inform this contact within 24 hours if there is an absence, welfare concern, safeguarding issue, or medical incident. Regular welfare checks are carried out, and where a student is in long-term homestay accommodation, local authority notification requirements will be followed where applicable.

Students aged 17 are still legally children but are generally allowed a greater degree of independence. Standard safeguarding arrangements apply, and the Designated Safeguarding Lead will use professional judgement when deciding whether to involve parents in specific situations. However, where there is any doubt or risk, the priority will always be to protect the student, and parents may be contacted.

In all cases, if there is uncertainty about whether a parent or guardian should be informed, the decision will be made in favour of safeguarding and student welfare.

Attendance and Absence

Attendance is closely monitored for all students, as absence may indicate a welfare concern. If a student under 18 fails to attend without explanation, efforts will be made to contact them directly. If contact cannot be established, further steps will be taken, including contacting accommodation providers or guardians where appropriate.

For students aged 16, any unexplained absence is treated immediately as a safeguarding concern. It must be reported to the Designated Safeguarding Lead on the same day, and parents or guardians must be contacted within 24 hours. If the student’s location cannot be confirmed, the situation may be escalated to external authorities where necessary.

Medical Emergency

In the event of a medical emergency, there may be situations where immediate decisions are required before parents can be contacted. By signing the Parental Consent Form, parents or guardians give permission for MHEP to act on medical advice in the best interests of the student where necessary.

Parents or guardians remain responsible for ensuring that all relevant medical information is shared in advance. MHEP will always aim to inform parents as soon as possible following any serious incident.

Malvern International will only give consent for medical treatment if a student under the age of 18 is unable to do so themselves (for example, if they are unconscious).

Behaviour and Legal Restrictions

Students under the age of 18 must follow UK laws at all times. This includes restrictions on the purchase and use of alcohol, tobacco, and vaping products. Access to certain venues, such as nightclubs, is also restricted by law.

Any breach of these legal requirements may result in disciplinary action under the relevant student code of conduct and misconduct policies. While MHEP takes reasonable steps to promote compliance, students are expected to take personal responsibility for their behaviour, and parents or guardians should ensure that students understand these rules before arrival.

An up-to-date list of age restricted products can be found on the PASS website (passscheme.org.uk)

Activities and Excursions

Students may have the opportunity to take part in educational trips or social activities during their programme. These activities are subject to standard health and safety procedures, including risk assessments and appropriate supervision.

Although MHEP ensures that activities are managed safely, parents or guardians remain responsible for their child, and participation in such activities is understood to be part of the normal student experience.

Communication and Data Protection

MHEP’s standard approach is to communicate directly with students rather than parents, including those under 18. This reflects the student’s developing independence and their rights under data protection law.

Information about a student will not normally be shared with parents or guardians without the student’s consent unless there is a legal or safeguarding reason to do so. In situations involving risk or harm, safeguarding responsibilities will take priority over confidentiality.

Contracts and Financial Responsibility

Students aged 16 or 17 may enter into agreements related to their education and accommodation. However, they are not legally able to take full responsibility for all types of contracts.

For this reason, parents or guardians are required to accept responsibility for any contractual obligations entered into by the student before they reach the age of 18. It is important that both the student and their parent or guardian understand the terms of any agreements before they are accepted.

Safeguarding and Child Protection

MHEP complies fully with UK safeguarding legislation and guidance, including Keeping Children Safe in Education (KCSIE 2025). Any concern about the safety or wellbeing of a student under 18 will be taken seriously and may be referred to external agencies such as social services or the police where appropriate.

All staff are trained to respond to safeguarding concerns. They are required to report concerns promptly, record information accurately, and must not attempt to investigate matters themselves.

Full details can be found on the Group Safeguarding Policy.

Final Statement

Safeguarding is a fundamental responsibility shared by the Group, its staff, students, and parents or guardians. MHEP is committed to maintaining a safe and supportive environment in which all students, including those under 18, can live and study with confidence.

Where concerns arise, they will always be handled with care, professionalism, and a clear focus on the safety and wellbeing of the student.

Appendix A

Consent form for applicants under the age of 18

Malvern HE Partnerships (MHEP) is committed to safeguarding and promoting the welfare of all students. In accordance with UK legislation, which recognises anyone under the age of 18 as a child, the Group takes reasonable and proportionate measures to protect students’ safety, wellbeing, and dignity. The Group takes reasonable and proportionate steps to ensure that all students can study in a safe, supportive, and respectful environment. This includes protecting students from harm, abuse, neglect, and exploitation, as well as risks such as radicalisation.

We require the parents of all under 18 students to complete this Consent Form, to confirm that they consent to their child living independently in UK and have made suitable accommodation and care arrangements in the UK. The completed form and guardian details must be retained for compliance, safeguarding, and audit purpose.

Please note this form is mandatory and must be completed for all applicants who will be under 18 years of age on arrival. All information must be obtained, reviewed, and approved before the issuance of the CAS.

All sections of this form must be completed digitally and handwritten signatures required on the Declaration form.

Applicant (Student) Details

Your Student Application ID* (as shown on your offer letter)

First Name*                                                                  Last Name*

Applicant email address*                                           Which pathway centre did you apply for? *

A named UK-based responsible adult must be identified for all students under the age of 18. If the student is from overseas and the parents (or legal guardians) remains outside the UK, the student must arrange a guardian based in the UK until they turn 18. Guardianship services are widely available in the UK and can be arranged by parents for a fee.

If you do not have a contact in the UK who can act as a guardian, you may appoint and arrange one through a trusted, accredited provider. Please refer to the Association for the Education and Guardianship of International Students website a list of AEGIS Accredited Guardianship Organisations.

Please complete the Under 18 Guardianship Details and Guardianship arrangements form and provide all relevant supporting documentation.

Under 18 Guardianship Information

Every student under 18 must have a responsible adult based in the UK. Where a parent or legal guardian is not resident in the UK, a guardian must be formally appointed. The appointed guardian is responsible for the student’s welfare and must:

• be an immediate family member(s) or legal guardian, over the age of 21
• be a mature and positive role models
• be able to communicate well in English
• live in the UK and be based in a location that is reasonably close to the study centre, ideally residing in the same town or city of the study centre (proof of UK address required, e.g. utility bill, bank statement, or council tax bill, dated within the last 3 months)
• be able to make important decisions, and provide appropriate guidance to the student
• has a UK phone number, able to contact in case of an emergency
• notbe a registered student or member of staff at Malvern International PLC or pathway centre (unless they’re a sibling or a parent)
• be available 24 hours a day for emergencies
• provide support during illness, holidays, and unforeseen circumstances
• act as a key point of contact for welfare, academic, and disciplinary matters

Guardianship Arrangements:

Guardianship arrangements must be formally documented (e.g. through a letter of undertaking or guardianship agreement) and clearly outline responsibilities and contingency plans.

This requirement is typically fulfilled through an approved third-party guardianship provider arranged or endorsed by the organisation.

Please confirm the student’s guardianship arrangement

If you do not yet have a guardian, there are guardianship services widely available in the UK and can be arranged by parents for a fee.

Parental Consent Guardian Declaration Form

Parent/Guardian Details

According to your Passport, what nationality do you hold?

Name (parent/guardian)

First Name *                                                                 Last Name*

Date of Birth*                                                               Relationship to applicant*

Email address*                                                           

Telephone/Contact number of the nominated guardian in the UK* (UK number only)       

Your UK Address (Full address required)

Street address*                                                          Address Line 2

City*                                                                            County/State

Country*                                                                     Postcode*

Please provide documentation to confirm the identity of the UK based nominated guardian of the applicant and UK address e.g. passport or utility bill dated within the last 3 months.

Will you be living outside of the UK while the applicant is in the UK? * 

☐ Yes                         ☐ No

If you live outside of the UK and the applicant is less than 18 years of age, you will need to provide the contact details of a nominated guardian based in the UK. The applicant will need to have a nominated guardian in the UK from the point at which they commence their studies at the University to their 18th birthday.