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I wonder whether it is strictly correct for BPP to claim that it is now a university (¡°And BPP makes two: coalition confers university title on second for-profit¡±, News, 8 August). The decision to allow a company to use in its title a?word classified by law as ¡°sensitive¡± is taken in the case of ¡°university¡± by ¡°the Registrar of Companies on behalf of the Secretary of State, not by BIS as the specified body¡±. Companies House merely requires confirmation from the Department for Business, Innovation and Skills that it has no objection.

I corresponded with BIS about this process late in 2011. The letter I received said that ¡°there are no formal criteria for dealing with such applications¡±. A Freedom of Information request yielded the missive BIS had written in the case of Coventry University College. It seems to have applied only one criterion, that ¡°the title is clear, unambiguous and not otherwise misleading¡±. It accordingly wrote to Companies House that it did not object.

However, the technical consultation published by BIS in August 2011 does identify ¡°formal criteria¡± and states that they are the same as those governing applications from higher education bodies that have taught degree-awarding powers. In that case, ¡°the Privy Council Office forwards the submission to the Secretary of State for advice as the relevant Privy Councillor¡±, who in turn seeks advice from the Higher Education Funding Council for England ¡°on which to assess whether the applicant meets the criteria of student numbers and good governance¡±.

It continues: ¡°Organisations not eligible to apply for university title via this process can apply to Companies House to use the sensitive word ¡®university¡¯ in their title. They will first need to seek the approval of BIS, as?the specified body for the sensitive word ¡®university¡¯, which applies the same criteria as above in assessing the application.¡±

It cannot be true both that there are ¡°no formal criteria¡± and that the criteria are ¡°the same¡± as those required by the Privy Council route. If there are going to be more BPP-type applications (and next time making sure that temporary degree-awarding powers have been renewed first), the consistent application of the criteria is going to be important ¨C or it could become easy for title to be confused with substance.

G.?R. Evans
Oxford