The 2023 death of 16-year-old international student Luna Wong has exposed critical regulatory gaps in the UK’s multi-million-pound education guardianship and summer programme industry. Safeguarding experts have warned that statutory oversight for the sector remains absent, even as recommendations from a 2024 safeguarding review await government action.
Luna, a student from Hong Kong who attended Wrekin College in Shropshire, died by suicide in London in July 2023. At the time, she was attending a private two-week residential course titled the ‘Young Psychologist Summer Experience’, operated by the firm InvestIN.
The tragedy has focused national attention on the lack of formal regulation for the private organisations that look after thousands of international students during their time in the UK. While schools and colleges are subject to rigorous Ofsted or Independent Schools Inspectorate (ISI) regimes, residential summer programmes and guardianship agencies currently operate under a system of voluntary accreditation.
Findings of the 2024 Safeguarding Review
A council-commissioned safeguarding practice review, published in 2024 following an inquest into the death, identified that guardianship and residential summer programmes remain unregulated by statute. The review highlighted that while staff are required to undergo Disclosure and Barring Service (DBS) checks, there are no statutory minimum standards or specific inspection regimes for these types of private residential courses.
A retrospective report on the case has now identified that the recommendations made in 2024 have yet to be fully enacted by the government. Experts note that this leaves a significant “safeguarding gap” in a sector that is a major contributor to the UK economy.
The financial scale of the industry is substantial. The ‘Young Psychologist Summer Experience’ attended by Luna cost £6,740 for a two-week London residential. Beyond summer courses, basic education guardianship fees for international students typically start at £2,700, but can exceed £4,000 per year when including “top-ups” for students with additional needs.
The 2024 review also revealed that the education guardian involved in the case was paid a commission by InvestIN for referring Luna to the course—a payment that was not disclosed to her parents.
Industry Policy Changes
In the absence of new legislation, some private bodies have tightened their own internal rules. InvestIN has updated its medication policies, now requiring that students’ medication be stored in locked cabinets and administered directly by staff.
However, because the sector remains unregulated by statute, parents are still advised to ask specifically if any commission-based referrals are being made between guardians and course providers.
The Parental Perspective
Luna’s parents, Thomas and Hilda Wong, have spoken out about the code of care they feel their daughter received despite the high fees paid for her education and supervision. “They accepted the money but didn’t take care of my child,” they stated following the conclusion of the safeguarding review.
The case has also clarified the distinction between venue providers and course operators. While the summer course took place at University of London facilities, the university acted only as an accommodation provider. The programme itself was entirely designed and operated by the private firm InvestIN.
As the industry continues to grow, the Department for Education has yet to confirm whether it will move towards a statutory regulation model that would bring private guardians and summer residential providers under the same level of legal scrutiny as traditional boarding schools.
