The Internationalisation of
A submission to the
Department of Education
on behalf of
This Department of Education and Science initiative to develop Ireland as a provider
of quality education for international students is most welcome. To date, Ireland has
been extremely successful in attracting multinational investment in Irish industry and
internationally traded services particularly in the fields of pharmaceuticals and
software. Key to this national success has been the integration of policy and close
cooperation between the government agencies concerned. By adopting equally
appropriate structures and practices at national level, Ireland’s education sector could
be transformed to become a highly successful internationally traded sector, based on
sustainable long term high value earnings.
Griffith College is delighted to be given this opportunity to make a submission to the
Department in respect of the further development of this international education
sector. Given the college’s extensive experience in attracting and teaching
international students, it is keen to present the many opportunities involved and
suggest how they might be best exploited nationally. These opportunities are
balanced by the identification of a number of real current and potential challenges that
must be comprehensively addressed so that they do not serve as impediments to the
further growth of the sector.
Finally, the submission is intended as a contribution to the Department’s
consideration of the international education sector. We would greatly welcome the
opportunity to discuss the points raised with the Department or indeed other related
agencies sharing a common interest in the growth of this prestigious and valued
sector. Given the highly competitive nature of the international education sector, we
would respectfully request that the submission would not be circulated to other
Table of Contents
1. Ireland as a Centre of Educational Page 4
Excellence for International Students
Strengths, Weaknesses, Opportunities, Threats
2. The Promotion of a Quality Mark Page 5
3. Structural Issues to be Addressed. Page 8
4. Griffith College Dublin Page 13
Appendix 1: Issues in Respect of Visa Administration Page 15
Ireland Inc. is well positioned to develop a long-term sustainable profitable market for
quality education to International students. However, like other countries that have
already had varying degrees of success and failure in this maturing and increasingly
competitive market, Ireland’s success will depend on how well it addresses a number
of key factors, not only in the short-term, but also most importantly on a sustained
basis into the future.
Currently, Ireland’s potential strengths could be viewed as follows:
Ireland is English speaking with English being used effectively as a first
Ireland has a highly advanced educational infrastructure
Irish people value education highly, evidenced by already high and increasing
participation rates at all levels
Irelands is likely to have spare capacity in terms of resources (both physical
/human) in the short / medium term as the student population declines.
The Irish economy can provide international students with an opportunity to
undertake part-time employment to supplement their fees
Ireland is economically prosperous and politically stable
A number of weaknesses can also be identified as follows:
Ireland is distant from many Asian markets (e.g. shortage of direct air routes:
Ireland’s nearest competitor (UK) can be reached more directly is one stop.)
Ireland lacks an integrated Government supported approach similar to that
operated by UK administration
Ireland’s weather is less attractive than US / Australia for many students
Ireland has become relatively expensive, with costs higher than EU average,
particularly in relation to accommodation.
In developing the international education market, Ireland could also exploit related
opportunities, for example:
Combining English language tuition with education in other disciplines at
Combining education with leisure: (e.g. Personal Development programmes
for corporate clients incorporating Golf, Orienteering, etc.)
Providing programmes in European Business for those seeking to understand
the workings of the EU and its market
Providing programmes in Software Development leveraging the success of the
IT sector internationally
Securing international accreditation and mutual recognition of awards through
the Bologna declaration (e.g. Leonardo, Erasmus, etc.) to support students
wishing to complete a component of their third level studies in Ireland
By establishing a recognised National Brand / Quality Mark for Excellence in
A number of potential threats can also be identified, relating both to the quality of
education provision and to the wider environment in which the sector operates. These
threats are as follows:
Product / Course Related:
That Ireland would continue to deliver a most uneven quality mix
(from excellent to very poor)
That insufficient control standards would be applied to providers
That providers and other agencies would underestimate the educational
challenge involved in addressing the needs of international students.
That the absence of an overall shared vision for enabling Govt. and
Public Structures would continue
That Ireland would pursue an unplanned / uncoordinated “dash for
cash” in respect of the sector and fail to build a sustainable long term
market based on quality provision
That Ireland would fail to manage issues relating to cultural integration
by failing to “sell” the benefits of the sector to the public
That Ireland would experience worsening national economic / political
factors conditions (e.g. by pricing itself out of the market, or by
becoming unwelcoming, etc.)
2. The Promotion of a Quality Mark
Discussion on the development of a Quality Mark is most welcome. However, it is
important to realise that huge challenges must be faced if the aspiration of providing
consistent quality education on a national scale is to be realised in practice. In
particular, if Ireland Inc. is to succeed as a quality provider of international
education, the following matters must be attended to:
Getting the Product Right
Teaching in the medium of English to international students is not simple. For
customers to really learn, they must be taught in small groups at a level that matches
their particular understanding and ability. Quality providers typically provide a
minimum of eight distinct levels. For real advancement, student groups must also be
multinational in composition rather than being drawn exclusively, or even
predominantly from a single nationality or race. While learning requires commitment
from students, it is essential that motivated and where possible inspirational teachers
are employed. At a minimum, there must be controls in place to review student
progress and feedback in respect of the teaching provided and to resolve issues
relating to delivery quality, supporting and replacing teachers where necessary.
The points can be summarised as follows:
Students’ needs matched to appropriate / specific level
Small group teaching (e.g. max 12)
Mix of nationalities in each group
Motivated / Inspirational teaching
Up to date teaching methods / training support / renewal for teachers
Focused on learning outcomes (e.g. proficiency, confidence, oral, written, etc.
customising programmes to meet the requirements of particular students /
Getting the Student Right
Ireland Inc. will gain no long-term strategic benefit by simply seeking to attract as
many students as possible regardless of their ability, motivation and interests A
quality selection and monitoring process must be established and maintained as a
matter of priority if only to protect the country’s existing reputation in other
Issues involved here include:
Identifying motivated candidates from the outset (e.g. through a network of
international offices, agencies)
Eliminating the risks of bogus applicants (e.g. through financial and other
Scheduling / Matching students optimally to levels / groups to best advance
their learning / assimilation
Monitoring attendance / performance / controlling variance
Structuring programmes so as not to support students wishing to unduly
extend the duration in which they achieve the learning outcomes. (e.g.
maintain focus on intensive / accelerated learning)
Managing the Learning Process
Students have different learning style preferences. They also come with hugely
varying prior educational experiences. It is important that providers understand that
unlike the production process for the model T Ford, one product simply does not fit
all. To address / manage the sensitivities / requirements involved in a professional
manner, programme delivery must be adapted in the light of the following:
Factors relating to gender, age, religion, dress, class composition, etc.
Student Learning Style Preferences (e.g. activists, theorists, reflectors, etc.)
Cultural norms, expectations, taboos (e.g. respect, authority, etc.)
Predominant focus of prior teaching experience (e.g. rote learning, Socratic,
The Central role of Assessment
Some providers may be content once their students comment that they have enjoyed
the programme and have learnt a lot in the process. However, to build a worthwhile
brand, such general expressions of satisfaction are of little benefit. Ireland Inc. must
build a proven track record of continued excellent performance by students in
internationally recognised measurement tests. This can only be achieved through the
constant monitoring of student input profiles and the effect of particular teaching /
learning methods used on terminal scores.
To maintain a national branded quality mark, it would be essential that external
verifiers, examiners, auditors would be appointed to oversee the quality of all
approved providers. Students and their sponsors would benefit hugely from the
presence of a recognised quality mark, serving to increase the motivation,
commitment and performance of the students.
Getting the Right Providers
It is essential that standards would be set in respect of providers. These could extend
considerably beyond those currently in operation to cover a wider range of aspects
Physical Resources (e.g. on-site accommodation, teaching rooms, layout,
teaching facilities, conducive to learning: bright, welcoming, etc.)
Teaching Programmes and Resources (e.g. English for academic purposes,
appropriate bridging courses to facilitate the students’ integration into longer
Teaching Resources: (e.g. library, videos, teaching aids, computer
laboratories, courseware, etc.)
Related support facilities: (e.g. accommodation, welfare, counsellor, catering,
computing (e-mail contact home), medical insurance, etc.)
Teaching Programme Focus: (e.g. suitability for purpose, evidence of
achieving learning outcomes, academic / professional accreditation, )
Quality Audits: (e.g. internal monitoring of student satisfaction ratings,
meeting with students, coupled with appropriate action and external controls
by HETAC, NQAI, HEA, QAA, international overseas universities, an Irish
Quality Provider: (evidenced by student performance, prize winners and
adherence to international best practice benchmarks)
It is important that the eligibility criteria for the Quality Mark are demanding. It is
equally important that they facilitate the inclusion of all institutions equally solely the
light of their proven ability to deliver on their aspirations of providing excellent
tuition for students and meeting the agreed criteria. Furthermore efforts should be
made to avoid the extensive paperwork often associated with industry quality marks.
The quality system should ensure that institutions focus their efforts on achieving
quality rather than on producing records to facilitate quality audit.
3. Structural Issues to be Addressed
If Ireland is to succeed as a quality provider of international education the wider
political, legal, social, economic and technological environment must be managed. In
particular, it is necessary that all parties and agencies involved work together within
an integrated and cohesive structure in order to achieve agreed common goals and
objectives for the sector.
To date, there has been insufficient cooperation and integration of policy between
relevant government departments in the promotion of Irish education internationally.
This lack of cohesion, where international students can readily recognise a wide
divergence between national marketing image and reality has served to significantly
undermine promotional efforts to date.
For fear that promoting Irish education abroad without dealing with the domestic
impediments to its growth might be counter-productive the college respectfully
suggests that "the range of issues which arise from the intention to promote and
expand the internationalisation of education services" must be addressed as a
precondition to success of a promotional strategy.
The Case for a Cohesive Immigration Policy: Why the current situation is not
It is imperative that proper planning is undertaken in respect of visa and immigration
related issues in order to facilitate and support Ireland’s role in international
education. In particular, the return of students to their country following their period
of education in Ireland must be controlled. Without this Ireland will be more likely to
attract foreign students seeking employment under the guise of education and the
labour supply will quickly reach saturation point with resulting unemployment and
likely racial tension.
Some figures might help to illustrate the scale of the potential problem. New
Zealand's foreign student population as a percentage of total population is 2%.
Applying this figure to Ireland would suggest a foreign student population of 80,000
approximately. Assuming an average length of stay of three years this would imply a
maximum foreign student intake of 26,667 annually. If student migration were at this
level and the foreign students were to overstay in Ireland for three years the total
numbers of foreign students working in Ireland would reach 160,000. This would
represent approximately 8% of the working population. Recent statistics relating to
visas issued compared to numbers of foreign students known to be enrolled in
education would suggest that substantial numbers of foreign students have overstayed
beyond their period of education. The number is thought to be in tens of thousands
already though visa statistics do not permit a precise measure. The problem, as visa
officers will readily admit, is that there is little or no control at the outward end to
secure the return to their countries of foreign students as they complete their period of
education in Ireland.
It is important that foreign students coming to Ireland have the opportunity to work a
limited number of hours (maximum 20 hours a week) as they do in United Kingdom
and in most other countries. This not only meets labour shortages but enables Ireland
to compete in the international marketplace for bright young students from less
developed countries whose parents can afford to pay fees but not accommodation and
subsistence. However the jobs available will be limited. They simply will not be
available if taken up by those coming to Ireland for employment under the guise of
education and by those who remain in Irish employment after their period of
education. There have also been complaints from the United Kingdom immigration
authorities about leakage of foreign immigration into the United Kingdom through the
use of Irish educational visas.
In our opinion the absence of effective controls on students once in the country has
led the Department of Justice Equality and Law Reform to focus exclusively on its
principal point of control, the issuance of the visa. This has led in our opinion to a
significant disallowance of visas in respect of genuine and suitable applicants. In
addition the required increase in the staffing of the visa function to meet the
substantial increase in the volume of educational visa applications was far too
delayed. This has resulted in undoing much of the good work done over the last two
years by Enterprise Ireland and IEBI (International Education Board Ireland)
particularly in China and India.
It is imperative that the overstay issue and United Kingdom immigration leakage
problems be addressed by the proper implementation of immigration controls
operated within the country to ensure that educational visas are not abused. If this is
not done the promotion of Irish education abroad would add to domestic problems
and recourse will be had again to the only effective tap to turn off the problems - the
Specific issues are outlined in Appendix 1, which we believe served to undermine the
development of Ireland’s international education sector. These are offered for
clarification purposes rather than as mere criticisms of past practices. In particular,
the college would like to mention that progress has been made on a number of fronts
in respect to the administration of education visas. It further suggests that it would be
helpful to extend to other major markets such as India the initiative established in
China whereby the Department of Justice Equality and Law Reform delegates to its
staff in Beijing authority to grant visas. Consideration should be given to extending
the functions of these local bureaux to becoming one-stop offices for overseas
students. Such offices should for instance have the authority to hold English language
exams (in cooperation with ACELS).
General issues to be resolved
In moving to a more appropriate structure the following general points are worth
The need for government and programme providers to recognise,
communicate, promote and consistently “sell” the economic benefit of the
activity to all those involved in controlling / facilitating its operation so that a
common orientation can be sustained. (e.g. Enterprise and Employment,
Education, Foreign Affairs, Justice, etc.)
The need to “sell” the benefit of the activity to the general public, in order to
sustain a welcoming and supportive environment for students and to combat
racism through positive and well managed educational programmes.
The need for all to work to highly competitive timeframes in relation to
decision-making (e.g. visa approvals). This is particularly important since the
UK’s move to issuing student visa approvals often within 24 hours.
The need for exacting operating standards in line with best international
practice that are continuously monitored and rigorously enforced.
The need to facilitate and regulate the size of the sector through appropriate
legislation (e.g. supporting part-time work, requiring attendance thresholds,
setting maximum duration periods for certain programme outputs)
The need to regulate the quality of the service provided (e.g. validations,
designations, regular assessment audits, etc.)
The need for a co-ordinated approach to the development of the sector (e.g.
from public / private promotion initiatives, to admission controls, to quality
educational provision, to programme management, to final qualification and
The need for technological investment by providers and government alike in
order to communicate information in relation to the industry effectively (e.g.
visa applications, approvals, attendance monitoring, absences, progression
Immigration Controls Issues
In building Ireland’s reputation as an excellent educational provider, it is important
that access to educational visas are limited in so far as possible to genuine students
and not provided generally to candidates seeking to move to Ireland for economic /
employment purposes. In particular:
educational institutions need to agree through their welfare officers to keep
track of their foreign students so that they can inform the immigration
authorities of the whereabouts of students particularly where visa abuse is
educational institutions should maintain a record of attendance of foreign
students and inform the immigration authorities of the names and addresses of
students who have failed to attend courses.
an electronic database of foreign students needs to be established to enable the
immigration authorities to track students from date of grant of visa to date of
departure from Ireland at the end of their course. This database should contain
a copy of the student's passport and all passport particulars. On many
occasions members of the GNIB have asked colleges for copies of students'
passports to assist in cases of mistaken or fraudulent identity. They need
particulars of students in order to be able to track them. A protocol needs to
be agreed whereby educational institutions will feed into this database
information such as attendance records, students change of address etc.
consideration could be given to allowing educational institutions (or a central
national agency) to hold the passports of foreign students with their
agreement. This would prevent Ireland being used as a backdoor to the United
Kingdom in the event of visa fraud and would therefore reduce the substantial
number of visa refusals made only because there is a United Kingdom visa
refusal on record or because the applicant is from a country from which the
United Kingdom visa authorities are not accepting applications. (It would be
intended that the student would continue to have full freedom to move from
institution to institution.
the Garda Síochána need to be given unequivocal powers of deportation,
subject to proper appeals procedures, to deal with abuse of educational visas.
Other Significant Challenges Ahead
If Ireland Inc. is to achieve success in the provision of international education, it must
address a number of other key challenges. These can be categorised under a number
of headings as follows:
The Need for a Competitive National Marketplace in Education
Research indicates that the firms best prepared to compete and succeed
internationally are typically those which have experienced intense competition
within their own national market. While this applies in many traded sectors, it
should be appreciated that the funding policy of the Department of Education
and Science has had the effect of sheltering the public sector from private sector
competition and thus has done little to prepare Irish State run educational
institutions to compete in the international marketplace. Indeed public sector
costs when compared to private sector costs per graduate on similar State
approved programmes for the IT Skills Initiative (where a direct comparison can
be made) indicate a ratio of 5 to 1 public sector to private sector costs. Such a
cost differential could not be sustained in an openly traded market.
As both private and state owned institutions will be in direct competition in the
same marketplace, this will create an imperative under European law for the
State to support all institutions equally on the basis of a level playing field.
The Lack of an Incentive Structure
Ireland’s international success in the development of its software and
pharmaceutical industries has been considerably advanced by attractive
incentive packages encouraging the necessary investment in buildings,
machinery and research. The corresponding investment in third level
institutions would be in lecturer, library and administration buildings, sports
facilities and restaurant and leisure facilities. At present none of these
expenditures qualify for tax relief by way of capital allowances.
In much the same way as manufacturing companies are given capital allowances
on factory buildings in addition to their 10% (later 12.5%) rate of corporation
tax, the depreciation of buildings is just as much a cost to a third level
institution as to a manufacturer. In regard to the growth of institutions from
retained profits, it should be appreciated that private third level institutions are
treated as service companies and subject to a service income surcharge which
increases their corporation tax rate. In effect they are not treated as major
international businesses but rather as professional practices which should not
have the benefit of the corporation tax rate.
With a proper incentive package similar to that afforded by the Industrial
Development Authority to foreign companies setting up in Ireland it should be
possible to generate private sector education industry employment in
underdeveloped areas of Ireland.
In addition to the absence of private sector incentives there is an absence of
incentive in the public sector in that the Department of Education and Science
follows the practice of clawing back the funding of public sector institutions
generating international income.
The Absence of Resource Planning based on International Demand
To date Irish educational investment planning has tended to have a national
rather than an international focus. What is needed is a projection of the surplus
places available in Irish higher education on a discipline by discipline basis for
comparison against the corresponding demand for places in the discipline
internationally. In this way, additional places resulting from national
demographic decline could be anticipated and marketed internationally in order
to retain and indeed develop programmes that might otherwise be abandoned.
This approach is particularly appealing given the expectation of increasing
student populations nationally from 2011 onwards.
The Need for Greater State Investment in Marketing
Despite the considerable economic benefit to the State resulting from the
international education sector, to date the State support for international
marketing by educational institutions has been limited. Further investment by
the State is needed particularly if institutions are to avoid undue reliance on
particular markets or countries, which in turn serves to limit the attractiveness of
the programme’s educational experience for the candidates involved.
Given the scope of the sector to enhance the foreign earnings of indigenous Irish
institutions resulting in national economic benefits, the sector should be
supported in much the same way as the State has supported the successful
development of multinational companies across a range of internationally traded
products and services. However, in the case of education, it is considerably less
likely that such institutions, once successful would transfer their activities
Possibility of a Single Agency for Promotion
In order to coordinate overseas activities, there may well be a case for establishing a
single agency for promotion. This could promote Ireland as a centre of educational
excellence and could be structured possibly along the lines of the British Council. By
making its contribution locally in each target market, it would provide a better
investment would result from Irish based administrative/marketing staff. Such local
offices could carry out local promotions, organise English language tests and
interviews (to support visa applications) foster links with local institutions and deal
with student queries. It would make sense for it to share accommodation with the
local office representing the Department of Justice Equality and Law Reform with
responsibility to issue visas.
For activities conducted in Ireland, much could be improved without an additional
agency, simply by the adoption and more effective coordination of appropriate
procedures and practices.
4. Griffith College Dublin: International Experience
Griffith College Dublin wishes to contribute to developing Ireland as a significant
provider of quality education to International students. In making this contribution,
the college wishes to draw on its experience to date, which includes:
An international student population of over 700 students per annum, spread
across a wide range of programmes from Foundation to M.Sc. / MBA level.
Experience of teaching and supporting students from over 60 countries to
International Student Support Structures that have evolved over 10 years (e.g.
admissions, accommodation, attendance monitoring, health and welfare,
International teaching, management and administrative staff specifically
dedicated to addressing the needs of international students.
Growing experience of operating internationally from our campus in Karachi,
Pakistan, from Moscow, Russia and in association with an increasing number
of European and Asian universities and educational institutes.
Providing a full range of language teaching and support levels in English.
Successfully meeting externally controlled academic and professional
standards in respect of its teaching, for example in the case of its ACCA
Premier Status Plus designation for professional accountancy training.
Successfully adapting the teaching, learning and assessment strategies of
educational programmes to suit the learning needs and preference styles of
Providing specialised voice production / presentation classes through the
college’s Speech and Drama Department
Providing for the social and personal needs of international students (e.g.
social events, national celebrations, prayer facilities, catering needs, religious
Integrating international students through customised induction programmes
Managing highly successful Anti-Racism weeks of shared participation and
Continuing to celebrate and successfully manage the increasing diversity of
our student and staff body.
Extensive experience of applying technology to support student administration
and learning (e.g. courseware, e-learning, administration, web based
communication, processing, etc.)
Proven track record over thirty years of successfully preparing students for
external professional examinations (e.g. professional accountancy) and third
level academic programmes across a range of disciplines and levels to
exacting national and international audited standards (e.g. HETAC, NQAI,
NTU, QAA, etc.)
Appendix 1: Recent Issues Arising in Respect of Visa Administration
The following problems in administration of the visa function by the Department of
Justice and Law Reform have given rise to delays and inconsistencies in the issuance
of visas which have significantly damaged efforts to promote Irish education in both
China, India and Pakistan:
(1) excessive staff turnover due to pressures of work and pressures of visa inquiries.
(2) low staff morale due to the above
(3) the lack of availability of skilled staff due to staff turnover
(4) restrictions on increase in staff numbers when required
(5) excessive delays in visa processing (in China up to 14 months while United
Kingdom of visas were cleared in 14 days)
(6) inconsistencies in the application of visa rules between embassies and the
Department of Justice Equality and Law Reform
(7) applying changed regulations to visa applications made before the date of
(8) embassy staff acting beyond authority limits in introducing new visa requirements
(e.g. new IELS test requirement introduced by an embassy official in India
without consultation with the Department of Justice Equality and Law Reform)
(9) refusal of visas to applicants from countries from which the United Kingdom
will not entertain visa applications (e.g. Bangladesh)
(10) The non-recognition of special case visa applicants (e.g. students who have
already completed the initial stages of the Irish institution’s programme on an
outreach basis in an associated foreign campus / institution.)
Some progress has been made in respect of a number of the above items, particularly
in relation to the first eight issues raised. The points are nonetheless presented in their
entirety to indicate the need for the issues involved to be continuously addressed.