The company owned by the government and responsible for administering loans and grants to studiers makes significant use of autonomous tools, including to come to independent conclusions, PublicTechnology can reveal
The Student Loans Company has shed light on the use of algorithms to process hundreds of thousands of applications – and make entirely automated decisions about whether or not to provide financial support.
The company – which is owned by government, and operates as a non-departmental body, overseen by the Department for Education – has this year published two algorithmic transparency records on the government’s dedicated hub.
The first of these documents relates to an algorithm used by those applying for funding contributions to support postgraduate learning programmes, while the second concerns applications for Advanced Learner Loans.
In each case, the tools are designed to “perform an automatic assessment of applications from applicants wishing to obtain” financial support for their studies.
The records, which reveal that the Student Loans Company (SLC) has made use of algorithms for about a decade, add that the systems “make automated decisions considering the information provided” by applicants, as well as data from government and higher education institutions.
In each case, the records state: “The typical application… is fully automated, adhering to the business rules developed from government policy. Only when there is missing information (paper-based applications only), missing evidence or evidence that fails to meet requirements (online and paper-based), will the rules result in fallback to manual intervention. These exceptions are manually processed by staff trained to deal with these circumstances.”
They add: “Applications that do not meet the eligibility criteria… will be automatically assessed as ineligible.”
As well as processing applications and determining outcomes, the technology “also orchestrates automated correspondence to students, including chasers, and instructs SLC’s downstream processes to set up payments” – both to students and education providers, as and where applicable.
Applicants who disagree with decisions made by the system can make an appeal – which will then be reviewed by human appeals officers “with no automated processing”. This process takes about 40 days, the records indicate.
“Submitted appeals will be rejected where it is not a genuine appeal, such as disagreeing with policy, or requiring more information regarding their application,” the documents add.
Between them, the two automated tools process – and rule on – a cumulative tally of 180,000 applications a year. This largely encompasses online applications but, where an applicant fills in a paper form, this information is then entered into the algorithm by SLC staff.
This represents 12% of the overall total of 1.5 million applications made to SLC each year – the biggest chunk which concerns loans for undergraduate students.
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While there is, as yet, no transparency record indicating if and how automated decision-making is used across these millions of loan applications, the company’s formal privacy notice, published on GOV.UK in April, now features a dedicated section explaining that “your application may be subject to automated decision making if you are: new student applying for a non-means tested student loan; a new student applying for a means tested student loan…; [or] a returning student, who has previously applied and was awarded a non-means tested student loan”.
SLC loans a total of £21bn each year.
In response to enquiries from PublicTechnology, the Student Loans Company indicated that many organisations with similar operations used automated processing and decision-making tools. SLC also reinforced the claims made in the transparency document that, given the volumes of applications made each year, the use of automated technology is a necessity.
“The Student Loan Company receives a large volume of applications each year, with varying policy rules applied based on the cohort, domicile, product and academic year,” the records say. “The volumes received across the business cannot be manually processed in a timely, consistent, or cost effective manner. The automated processing of applications supports the large volumes of applications and results in the rules for each application being applied in a consistent manner.”
The SLC also indicated to PublicTechnology that the tools are subject to regular sample checks and quality assurance procedures. The organisation reiterated that applicants are informed of the use of automated decision making via the formal privacy policy. When asked whether students are explicitly pointed towards this document during the application, the SLC indicated that it users of its live chat service are directed to the policy – and that the rules are also made available for examination at points during the application process.
A spokesperson for the company said: “SLC uses industry standard business rules engine technology because it allows an efficient process when assessing advanced learner loan (ALL) or post graduate (PG) applications. SLC uses rules engine on an ALL or PG application to determine eligibility and entitlement, as set out in the student finance regulations. Where there is unusual, more complex circumstances, or missing or incomplete information, the application assessment is then completed by a SLC team member.”
