King's College London

Updated List of Tier 1 (Graduate Entrepreneur) Authorised Endorsing Bodies – June 2017

In June 2017, the list of authorised institutions for Tier 1 (Graduate Entrepreneur) visa applications was updated by the Home Office.

The Tier 1 (Graduate Entrepreneur) route is for graduates who have an outstanding business idea that they wish to put into practice in the UK. Higher Education Institutions (HEIs) will have a central role in identifying graduates who have developed genuine and credible business ideas or entrepreneurial skills, and in endorsing and supporting them.

Only those institutions listed below are able to endorse graduates wishing to apply under this route:

  • Anglia Ruskin University
  • Arts University Bournemouth
  • Ashridge (Bonar Law Memorial) Trust
  • Aston University
  • Bangor University
  • Birmingham City University
  • Bishop Grosseteste University
  • Bournemouth University
  • BPP University Limited
  • Brunel University
  • Cardiff University
  • City University London
  • Coventry University
  • Cranfield University
  • De Montfort University
  • Edinburgh Napier University
  • Glasgow Caledonian University
  • Goldsmiths University of London
  • Heriot-Watt University
  • Imperial College of Science, Technology and Medicine
  • King’s College London
  • Kingston University
  • Lancaster University
  • Leeds Beckett University
  • Liverpool Hope University
  • Liverpool John Moores University
  • London Business School
  • London Metropolitan University
  • London School of Economics and Political Science London
  • South Bank University Loughborough University
  • Middlesex University
  • Newcastle University
  • Northumbria University
  • Newcastle Norwich University of the Arts Nottingham
  • Trent University
  • Oxford Brookes University
  • Plymouth University
  • Queen Mary University of London
  • Queen’s University of Belfast
  • Regent’s University
  • London Royal Academy of Music
  • Royal Agricultural University Royal Central School of Speech and Drama
  • Royal College of Art
  • Sheffield Hallam University
  • SOAS, University of London
  • Southampton Solent University
  • Swansea University
  • Teesside University
  • University College London
  • University for the Creative Arts
  • University of Aberdeen
  • University of Bath
  • University of Birmingham
  • University of Brighton
  • University of Bristol
  • University of Buckingham
  • University of Cambridge
  • University of Derby
  • University of Dundee
  • University of East Anglia
  • University of East London
  • University of Edinburgh
  • University of Essex
  • University of Exeter U
  • niversity of Glasgow
  • University of Greenwich
  • University of Hertfordshire
  • University of Huddersfield
  • University of Hull
  • University of Kent
  • University of Leeds
  • University of Leicester
  • University of Lincoln
  • University of Liverpool
  • University of Manchester
  • University of Northampton
  • University of Nottingham
  • University of Oxford
  • University of Portsmouth
  • University of Reading
  • University of Roehampton
  • University of Salford
  • University Of Sheffield
  • University of South Wales
  • University of Southampton
  • University of St Andrews
  • University of Stirling
  • University of Strathclyde
  • University of Sunderland
  • University of Surrey
  • University of Sussex
  • University of the Arts London
  • University of the West of England
  • University of the West of Scotland
  • University of Warwick
  • University of Westminster
  • University of Worcester
  • Guildhall School of Music & Drama

Full information is available on the UKVI web-site.

Leave to Remain under Tier 2 (General) Visa Category: Supplementary Work

An application for further leave to remain can be refused on many different grounds. Before applying for extension one must ensure awareness of all the rules and conditions.

Under Part 6A of the Immigration Rules, anyone can check the different set of circumstances that apply to these types of applications. In regard to this particular visa, the Tier2 (General), a future applicant has to pay attention to the paragraphs 245H to 245HH.

When referring to the more specific regulations or conditions, one may fall under the misinterpretation of the concept of “supplementary work”. While working for the sponsor for which the Certificate of Sponsorship was assigned it is possible, under a number of provisions, to perform a supplementary work.

The conditions upon an employment is considered supplementary are the following:

  1. The employment must be at the same profession and at the same professional level as the one for which the Certificate of Sponsorship was initially issued. This means that the Applicant cannot enjoy two different jobs that vary greatly in responsibilities as well as in expertise.
  2. It will not be deemed supplementary employment if to perform this new job the applicant leaves, abandons or stops operating the position for which the Certificate of Sponsorship was granted.
  3. Such voluntary extra work cannot exceed 20 hours per week. It takes place outside the hours set to work for your sponsor in the employment for which your Certificate of Sponsorship was assigned. The time and hours stated to work for the sponsor cannot be modified due to the activity of such supplementary work.

If all the above-mentioned rules are satisfied one can have this supplementary work along the one for which the Certificate of Sponsorship was assigned. In the matter, that you no longer work for the sponsor due to whatever reason (loss of the job, termination, bankruptcy of the company among others) or any of the conditions are no longer met. It is necessary to notify the Home Office what has changed within your personal situation.

The first step to take once these changes occur in your employment, is to report to the Home office about what has changed. Then, subsequently, submit a further application for leave to remain as well as a new Certificate of Sponsorship in order to stay in the United Kingdom under the new conditions.

Hungarian passport

Appeal Allowed against Home Office’s Decision to Refuse Application for Residence Card of Spouse of Hungarian National

Sterling & Law Associates LLP were successful in an appeal heard on 14 June 2017 by the First-Tier Tribunal, this time, regarding the refusal to issue a residence card to non-EEA national, spouse of a Hungarian national.

The basis of the refusal was that the Home Office was not satisfied that the Appellant’s spouse and sponsor was an EEA national, thus not satisfying the requirements to be considered a “qualified person”.

The Home Office stated that after a visit the Appellant’s home address the enforcement officers said that the Sponsor was unable to provide a credible confirmation of the valid Hungarian citizenship and expressed concerns that his level of Hungarian was insufficient for him to be a Hungarian national. All of the above was referred in the Home Office’s decision as the basis to disregard an EEA Registration Certificate, a valid Hungarian passport and naturalisation certificate provided by the sponsor.

The Appellant then instructed Sterling & Law Associates LLP to represent the couple in their appeal against the Home Office’s decision. Upon further evidence on behalf of the clients, along some clarification regarding the special circumstances over the place of birth and Hungarian naturalisation process, the Judge found that there was enough proof to shift the balance of probabilities in favour of the Appellant.

The judge of the First-Tier Tribunal looked not only into the explanation of the “propiska” registration system, which caused a misunderstanding of the sponsor’s place of birth in the former USSR, but also emphasised that the Home Office had no reason to dispute the genuineness of the sponsor’s Hungarian nationality.

Subsequently, after a confirmation of the validity of the EEA national’s passport as an evidence of Hungarian nationality by the authorities as well as the credible explanation for the place of birth confusion, the appeal was allowed by reference to the Regulation 6 (Qualified Person) and Regulation 7 (Family Member) of the Immigration (EEA) Regulations 2006.

Successful appeal on the basis of Article 8 of the ECHR

Sterling & Law Associates LLP were successful in the appeal process at the First-tier Tribunal challenging a refusal of a client’s application for a Tier 2 (General) visa and of his dependants.

A victim of fraud by his previous legal representative, the appellant inadvertently submitted fraudulent documents to the Home Office with his Tier 2 (General) application. As soon as he realised the documents were false, he sought our advice and assistance. We immediately acted to inform the Home Office of the situation and made further representations on behalf of our client based on his family and private life in the UK.

The Home Office took a year to consider the outstanding application, but eventually refused the application due to the submission of the false documents.

Upon consideration of the appeal lodged by Sterling & Law Associates LLP on behalf of the client, the judge found that there was no public interest in removal of the person but, to the contrary, he was a witness in the criminal proceedings against his previous legal representative initiated by the OISC.

Therefore, the appeal was allowed on the grounds of Article 8 of the European Convention on Human Rights.

UK border

May’s proposal – Analysis of the policy paper on the safeguarding the position of EU citizens in the UK and UK nationals in the EU

The recent proposal of Theresa May from June 26th, 2017 has been quoted as a ‘generous offer’ to EU citizens offering everyone who had acquired permanent residence a new ‘settled status’.

 

At the face value, it appears to be a good deal, however when one reads the small print it becomes apparent that there is no value in the offer, and it lacks the certainty that Theresa May continuously refers to. The offer has come after the EU Council Decision of 22nd May proposing their policy on safeguarding the position of EU citizens in the UK and UK nationals in the EU, therefore both sides have now adopted their position. However, the UK’s offer is nowhere close to what EU would like to secure as a part of the exit deal.

 

The Government website provides a short summary of their ‘promise’.

 

“Since the result of the referendum last summer, the UK Government has made it absolutely clear how important it is that we secure as early as possible both the rights of EU citizens in the UK and UK nationals in EU member states. We are now seeking to provide EU citizens with certainty about their future by publishing a policy paper which sets out our offer to them.“

 

Theresa May has since triggering Article 50 made it clear that she wants nothing else but to provide the certainty for all EU citizens in the UK and for those Brits living in the Member States. However, the proposal offers no certainty and is lacking definitive answers and dates.

 

The UK continues to affirm that the rights of the EU nationals are protected and are to be complied with under the EU law until the official day of Brexit.

However, this gives little certainty as to the future rights of over 3 million EU citizens living in the UK even though the UK has proposed a new streamlined process for the European citizens to register in order to gain their new ‘settled status’ as per the generous offer of Theresa May.

 

This online application will apply to all EU citizens who have been continuously living in the UK for over 5 years. This requirement is the same as under current EU law where those with over 5 years of residence can apply for a document certifying permanent residence. Moreover, since the criteria that will apply are national, not based on EU law, the calculation of this period might differ. The proposals says ‘The type of application you’ll need to make will depend on your circumstances, when you moved to the UK and how long you’ve lived here’. The questions arise in terms of what type of circumstances an EU citizen needs to have in order to be able to stay?

 

While the UK promises to make the process as streamlined as possible for the EU citizens who already have the Permanent Residence Status, they will still need to apply for ‘settled status’ after Brexit in order to be able to remain in the UK. The UK position is that a document certifying permanent residence may mean nothing in the future. What is the reason for this? Does it mean that the future criteria will be certainty stricter?

 

Moreover, why the current permanent residence document under free movement rules is not sufficient to prove (for example, to employers or public service providers) that you have permission to continue living and working legally in the UK after Brexit. It seems that the criteria that are to be applied for the new ‘settled status’ will be much more stricter than under EU law if the Home Office cannot respect the now issued documents certifying permanent residence rights.

 

Further questions arise as to the cost of the new ‘settled status’.

Theresa May refers to a ‘reasonable’ cost but under the current British Immigration Rules the fee for indefinite leave to remain which is equivalent to the ‘settled status’ is set at £2,297. Will this be the price the EU nationals would have to pay in order to stay?

 

The offer gives some consideration to those citizens who will not qualify for ‘settled status’ as they will not complete their 5 years period before the ‘cut-off date’. However, nowhere in the proposal the date is mention. It may be the date of triggering Article 50 or the Brexit Day, but it could also potentially be historic.

If Theresa May wanted to give certainty to EU citizens she would have set the ‘cut-off date’. Those EU citizens who arrived and became resident before [un]specific date but who have not accrued five years’ will be able to apply for a temporary status. Moreover, those EU citizens that arrive after the [un]specified date will be allowed to remain in the UK at least temporary and may become eligible, however there should not have expectations of guaranteed settled status.

The proposal mentions ‘People who arrive after the cut-off date will be able to apply for a permission to remain after the UK leaves the EU, under the future immigration arrangements for EU citizens’.

What are the future immigration arrangements? Where is the certainty that Theresa May was offering?

 

The most troublesome part of the proposal is the lack of consideration for a Non-EU family members of EU nationals. What will happen with them since they no longer be able to live in the UK under the more lenient regulations of the EU. Those Non-EU nationals who have divorced their EU partners may also not be eligible to stay. The offer also fails to consider whether a UK citizen who currently is residing in Spain will retain their full free movement rights to move to Germany for example in the future.

 

Moreover, there is also no certainty as to what the ‘grace period’ will be for the EU citizens to apply for their new status. This will ‘be confirmed during negotiations’ and ‘if you haven’t received a document confirming your new immigration status by the end of this [again unspecified] period you will no longer have permission to remain in the UK. What if some EU citizens do not meet their future immigration requirements of which we have no mention whatsoever?

 

The UK offer fails to discuss the judicial enforcement, and while the EU wants the rights of EU nationals to be enforced by the Court of Justice of the European Union (CJEU), and the rules in the withdrawal agreement in accordance with pre-Brexit case law of the Court, the UK rules out the jurisdiction of the CJEU.

 

Much of the proposal uses words like ‘seek to ensure’ or ‘akin’ which does not by definition refer to certainty. It is clear that the UK position indisputably offers worse terms both for EU citizens in the UK and UK citizens in the EU. The EU proposal asked for the permanent residence documents to be respected without the need of ‘transferring’ of the status.

 

While the UK will exempt people from the requirement to have Comprehensive Sickness Insurance, it has been argued that the current UK law breaches EU law anyway. Therefore, it may seem like a ‘generous offer’ but in reality is nowhere close.

 

The proposal also is silent on British Citizenship, it does not mention anywhere how a ‘settled person’ can acquire British citizenship in the future. It only mentions that it will be possible. Does it mean that the criteria will be different and/or more expensive to those currently under EU law?

 

At the moment, it seems that the only way to completely guarantee your continued right to live and work in the United Kingdom is to become a British citizen. In order to do this, the first step is to acquire Permanent Residence.  Although, becoming a British citizen may also be a disadvantage for some nationals or if you have non-British family members living with you in the UK who are relying on your status under EU law. While, we are still awaiting a decision of CJEU in Lounes, the Advocate-General has said that non-EU nationals may be given the right to reside in a Member State in which an EU family member lived before the family member acquired the nationality of that country. However, since the UK wants to rule out the jurisdiction of the CJEU, there would be little time to benefit from any positive upcoming decision.

By Ilovetheeu (Own work) [CC BY-SA 4.0 (http://creativecommons.org/licenses/by-sa/4.0)], via Wikimedia Commons

Theresa May’s proposal – Analysis of the policy paper on the safeguarding the position of EU citizens in the UK and UK nationals in the EU

The proposal of Theresa May was quoted as a ‘generous offer’ to EU citizens offering everyone who had acquired permanent residence a new ‘settled status’.

At the face value, it appears to be a good deal, however when one reads the small print it becomes apparent that there is no value in the offer, and it lacks the certainty that Theresa May continuously refers to. The offer has came after the EU Council Decision of 22nd May proposing their policy on safeguarding the position of EU citizens in the UK and UK nationals in the EU, therefore both sides have now adopted their position. However, the UK’s offer is nowhere close to what EU would like to secure as a part of the exit deal.

The Government website provides a short summary of their ‘promise’.

Since the result of the referendum last summer, the UK Government has made it absolutely clear how important it is that we secure as early as possible both the rights of EU citizens in the UK and UK nationals in EU member states. We are now seeking to provide EU citizens with certainty about their future by publishing a policy paper which sets out our offer to them.

Theresa May has, since triggering Article 50, made it clear that she wants nothing else but to provide certainty for all EU citizens in the UK and for those Brits living in other Member States. However, the proposal offers no certainty and is lacking definitive answers and dates.

The UK continues to affirm that the rights of the EU nationals are protected and are to be complied with under the EU law until the official day of Brexit.

However, this gives little certainty as to the future rights of over 3 millions EU citizens living in the UK even though the UK has proposed a new streamlined process for the European citizens to register in order to gain their new ‘settled status’ according to the ‘generous’ offer of Theresa May.

This online application will apply to all EU citizens who have been continuously living in the UK for over 5 years. This requirement is the same as under current EU law where those with over 5 years of residence can apply for a document certifying permanent residence. Moreover, since the criteria that will apply are national, not based on EU law, the calculation of this period might differ. The proposal says ‘The type of application you’ll need to make will depend on your circumstances, when you moved to the UK and how long you’ve lived here’. The questions arise in terms of what type of circumstances an EU citizen needs to have in order to be able to stay?

While, the UK promises to make the process as streamlined as possible for the EU citizens who already have Permanent Residence Status, they will still need to apply in order to be able to remain in the UK. The UK position is that anyone with the document certifying permanent residence may mean nothing in the future. What is the reason for this? Does it mean that the future criteria will be certainty more stricter?

Moreover, why the current permanent residence document under free movement rules is not sufficient to prove (for example, to employers or public service providers) that you have permission to continue living and working legally in the UK after Brexit. It seems that the criteria that are to be applied for the new ‘settled status’ will be much more stricter than under EU law if the Home Office cannot respect the now issued documents certifying permanent residence rights.

Also, what will be the cost of the new ‘settled status’? Theresa May refers to a ‘reasonable’ cost but under the current British Immigration Rules the fee for indefinite leave to remain which is equivalent to the ‘settled status’ is set at £2,297. Will this be the price the EU nationals would have to pay in order to stay?

The offer gives some consideration to those citizens who will not qualify for ‘settled status’ as they will not complete their 5 years period before the ‘cut-off date’. However, nowhere in the proposal the date is mention. It may be the date of triggering Article 50 or the Brexit Day, but it could also potentially be historic.

If Theresa May wanted to give certainty to EU citizens she would have set the ‘cut-off date’.

Those EU citizens who arrived and became resident before [un]specific date but who have not accrued five years’ will be able to apply for a temporary status. Moreover, those EU citizens that arrive after the [un]specified date will be allowed to remain in the UK at least temporary and may become eligible, however there should not have expectations of guaranteed settled status.

The proposal mentions ‘People who arrive after the cut-off date will be able to apply for a permission to remain after the UK leaves the EU, under the future immigration arrangements for EU citizens’. What are the future immigration arrangements? Where is the certainty that Theresa May was offering?

The most troublesome part of the proposal is the lack of consideration for a Non-EU family members of EU nationals. What will happen with them since they will no longer be able to live in the UK under the more lenient regulations of the EU. Those Non-EU nationals who have divorced their EU partners will also not be eligible to stay. The offer also fails to consider whether the UK citizen who currently is residing in Spain will retain their full free movement rights to move to Germany in the future.

Moreover, there is also no certainty as to what the ‘grace period’ will be for the EU citizens to apply for their new status. This will ‘be confirmed during negotiations’ and ‘if you haven’t received a document confirming your new immigration status by the end of this [again unspecified] period you will no longer have permission to remain in the UK.’ What if some EU citizens do not meet the future immigration requirements of which we have no mention whatsoever?

The UK offer fails to discuss the judicial enforcement, and while the EU wants the rights of EU nationals to be enforced by the Court of Justice of the European Union (CJEU), and the rules in the withdrawal agreement in accordance with pre-Brexit case law of the Court, the UK rules out the jurisdiction of the CJEU.

Much of the proposal uses words like ‘seek to ensure’ or ‘akin’ which does not by definition refer to certainty. It is clear that the UK position indisputably offers worse terms both for EU citizens in the UK and UK citizens in the EU. The EU proposal asked for the permanent residence documents to be respected without the need of ‘transferring’ of the status.

While the UK will exempt people from the requirement to have Comprehensive Sickness Insurance, it has been argued that the current UK law breaches EU law anyway. Therefore, it may seem like a ‘generous offer’ but in reality is nowhere close.

The proposal also is silent on British Citizenship, it does not mention anywhere how a ‘settled person’ can acquire British Citizenship in the future. It only mentions that it will be possible. Does it mean that the criteria will be different and/or more expensive to those currently under EU law?

At the moment, it seems that the only way to completely guarantee your continued right to live and work in the United Kingdom is to become a British citizen. In order to do this, the first step is to acquire Permanent Residence.  However, becoming a British citizen may also be a disadvantage for some nationals or if you have non-British family members living with you in the UK who are relying on your status under EU law. While, we are still awaiting a decision of CJEU in Lounes, the Advocate-General has said that non-EU nationals may be given the right to reside in a Member State in which an EU family member lived before the family member acquired the nationality of that country. However, since the UK wants to rule out the jurisdiction of the CJEU, there is a little time to benefit from the upcoming decision.

If you would like to find out more about your rights in the UK or apply for the Permanent Residence/British Citizenship you can contact Angelika at 020 7822 1866 or email: angelika@sterling-law.co.uk

Another Appeal Was Allowed Regarding the Rights of the Mother of the British Child

lawyer

Sterling & Law Associates LLP were successful in an appeal heard by the First-Tier Tribunal regarding the refusal to issue a residence card to non-EEA national, mother of a British child. The appellant, a citizen of Belarus, had a Residence card valid until 2015 as an unmarried partner of an EEA national. Their relationship broke down leaving Appellant alone with her son from the relationship, who was British.

The Appellant’s application was dismissed as she failed to, in the view of the Home Office, provide enough evidence to demonstrate that (i) the child would be unable to reside in any EEA State with his EEA national father nor that (ii) she was a primary carer of their son.

Upon further evidence provided by Sterling & Law Associates LLP, on behalf of the client, along with some clarification regarding the misinterpretation of previous testimonies, the Judge found that there were enough reasons and proofs of sole dependency of the child upon the Appellant, as per Zambrano ruling.

The clarifications allowed to prove that the client was the sole carer of the British child after his father abandoned him and his mother and did not assume any responsibility for the care of their child. In this manner, the appeal was allowed as the Applicant fulfils the requirements under the Immigration (European Economic Area) Regulations 2016, regulation 15.

Successful Appeal of the Dependant Adult Child

Pre-Law

The Appellant, a national of Armenia, a dependant adult child (over 18) of a person present in the United Kingdom, was refused the grant to entry clearance for the purpose of settlement. The Sponsor (applicant’s father) and his daughter were separated from his son and wife in 2012 when they sought asylum in the UK. The appellant along with his mother applied for family reunion but only mother was issued a visa.

Despite the grant of entry clearance, the mother decided to stay in Armenia since the appellant needs daily care. Regardless of it, the Home Office decided to refuse his application since the Appellant was over 18 years of age and they thought that the Appellant did not submit sufficient evidence of dependency nor the evidence that the Appellant will be adequately maintained in the UK with no recourse to public funds.

Sterling & Law Associates LLP were instructed to represent the national of Armenia in his appeal at the First-Tier Tribunal. After considering the facts and evidence provided on behalf of the client, the judge found that there were reasons to believe that the exclusion of the appellant caused great conflict within their private and family lives, as well as the economic situation of both his Sponsor and sister would exempt the client from the burden of needing public funds.

Sponsor’s acts in Armenia saved many lives years ago but because he stood up against the powerful people in Armenia he had to leave the country leaving behind his wife and son. The First- tier Tribunal Judge looked not only on appellant’s circumstances but took into account Sponsor’s asylum claim and reasons why he fled Armenia.

Subsequently, the appeal was allowed on the grounds of Article 8 of the European Convention of Human Rights conjointly with the United Kingdom Immigration Rules.

AFTER 6 ATTEMPTS WITHOUT REPRESENTATION, FINALLY ISSUED A EEA FAMILY PERMIT

The Applicant, a citizen of Georgia, who has been married to an EEA National, was refused not once, but six times EEA Family Permit visa which he made without legal representation over the course of nearly two years. He had left the United Kingdom voluntary in 2015.

The first application was refused by the Home Office after they conducted a phone interview with the applicant. The first and then other 5 applications were refused based on the interview evidence provided during client’s first application.

Even though Entry Clearance officer had to consider each new application on its own merits, they failed to do so and refused all subsequent applications on the same ground.

Sterling & Law Associates LLP were instructed to make a seventh application of behalf of the client which was successful. After considering the facts and evidence provided by the client and six reasons for refusals Sterling & Law Associates LLP suggested the Georgian national to seek a Residence Permit in Estonia as a family member of a European Union national.

After a successful application, fresh compelling evidence and arguments brought by Sterling & Law Associates LLP, the Home Office issued a Family Permit to our client to join his wife in the UK.

“It was a huge task to challenge the Entry Clearance Officers after they have refused our client’s application six times and it was awarding not only for the client but for myself to “fight” for the visa for our client.” Daiga Barzdina

Daiga Barzdina

Absences from the UK for EEA Nationals

UK border

EEA nationals applying for permanent residence must do so either using the 85-page form or if eligible, by filling in an online application. 

Those who have managed to stay awake long enough to reach page 28 of the paper form will have come across question 5.3 which asks applicants to provide the following details for each of their absences from the UK: Country or countries visited, Date of departure, Date of return, Number of days of absences from the UK.

This is easier said than done. EEA nationals do not receive entry or exit stamps on their passports.  This can make it exceptionally hard to accurately recollect precise dates of entry and exit from the UK.  This question on the form has caused considerable stress and anxiety to a very large number of EEA nationals I have met recently.  The anxiety caused by the inability to answer this question is disproportionate to its significance. The purpose of the question is really to assess whether or not the applicant has been out of the UK for over 6 months in total in any 12 month period.  If the answer to that is no, then no further details need to be provided. This has now been clarified in the Home Office’s policy guidance document which was published in April. It states:

Please note, you only need to list your absences where you have been out of the UK for more than 6 months in total in any 12 month period. You do not need to list any absences that were before your qualifying period of residence.

One way around this question is simply utilising the online form which allows it to be bypassed if you have confirmed that you have not exceeded the absence thresholds. If still proceeding with the paper form, it would be sufficient for an applicant who does not exceed the thresholds to simply note this on the form and move on to the next section.  

If entry and exit records are still needed however, for example for use in a subsequent naturalisation application, it has recently been drawn to my attention that it is possible to obtain a record, which is often incomplete, from the Home Office. This contains flight details matching the individual making the request, and likely emanates from the carriers.  This can be done by Subject Access Request.