This policy details the procedure for complying with the regulatory requirements while marketing Imperial’s courses in international markets. It will help to ensure that our education and training services are marketed in a professional manner, and that the marketing activities maintain the integrity and the reputation of the industry as well as of Imperial.
The CEO or the delegate will be responsible for ensuring that marketing material maintains the integrity and reputation of the industry as well as of Imperial.
In this policy:
Marketing material refers to any kind of printed material used for publicising the courses and services of an organisation (prospectus, brochure, poster, leaflet, newspaper advertisement, forms, signboard, e-mail, and website or any electronic material or soft copies etc.).
- ‘Program fee’ means the tuition and other fees set by Imperial for its programs;
- ‘Programs’ are the registered courses offered by Imperial as listed on www.training.gov.au;
- ‘Prospective student’ is a person who intends to become, or who has taken any steps towards becoming a student at Imperial;
- ‘Student’ means prospective or enrolled student of Imperial;
- ‘Term’ means the shortest duration of a study period; and
- ‘Territory’ means the countries or regions.
In this policy, unless stated otherwise:
- The singular includes the plural and vice versa and words importing a gender include other genders;
- Other grammatical forms of defined words or expressions have corresponding meanings;
- Money is in Australian dollars unless otherwise stated and a reference to 'A$', 'AUD', '$A%', 'dollar' or '$' is a reference to Australian currency.
Imperial will ensure the following:
- The Imperial College of Australia (Imperial) being a registered training provider, has the obligation to adhere to professional and ethical practices while marketing its education and training services in the domestic and international market;
- Compliance with SNR 24 and the Education Services for Overseas Students Act 2000 (the ESOS Act) and Standard 1 of the National Code 2017 which impose certain obligations and requirements on the providers of education and training courses to overseas students and those providers’ agents, including the obligations set out in the National Code established under the ESOS Act 2000;
- Imperial remains registered by ASQA (Australian Skills Quality Authority) and Department of Education on Commonwealth Register of Institutions and Courses for Overseas Students
- Imperial’s marketing material helps to market courses and to recruit suitable prospective students for enrolment at Imperial and study in Australia (International Students), and demonstrates Imperial’s professionalism, honesty and integrity.
- Imperial ensures that it adheres to the requirements of above legislations while marketing its courses to suitable prospective students;
- Imperial is aware of the requirements of the VET Quality framework, SNR, ESOS and other Acts and regulations and has agreed to comply with those requirements.
Imperial will not disseminate false or misleading information, such as by:
- Giving inaccurate information about the location of its campus at which the courses will be provided;
- Making false or deliberately misleading comparisons with other providers;
- Making inaccurate claims about employment outcomes associated with a course;
- Giving misleading information about the fee structure and delivery methods;
- Implying automatic acceptance to another course; and
- Providing misleading information on migration outcomes after completion of the course.
Imperial will fulfil its obligations to ensure that:
- Its education and training services are marketed in a professional manner;
- Marketing activities maintain the integrity and reputation of the Australian education sector and Imperial;
- Marketing material reflects Imperial as a skilled professional in the field of education and training;
- Marketing material is edited with care by only responsible person and reflects the knowledge and specialisation of Imperial as an honest provider; and
- Marketing material clearly identifies the legal entity and trading name of Imperial (BJSB Pty Ltd Trading as The Imperial College of Australia) and RTO ID: 121966 and CRICOS ID: 02858M on electronic material and hard copies provided to students.
Marketing material used for recruitment purposes could include:
- Information about courses for domestic and international students including course outlines, if used to market courses and recruit students;
- Imperial’s website and pages relating to student recruitment and support services;
- Information about Australia, such as pertaining to living in Melbourne for international students;
- Information about types of visas and about visa application requirements that may assist overseas students to comply with the conditions of their visa;
- An advertisement of courses for prospective students in an Australian or overseas newspaper;
- Materials that promote and advertise courses with Imperial (including cards which may be considered more advertisements than conventional business cards);
- A letterhead, signature block or footer used in letters making offers to students, promoting courses or for other marketing purposes; and
- Emails that are sent to students offering enrolment or informing students of courses.
Marketing Information on the Website
Imperial will guarantee to check the following:
- That there is no general use of the Nationally Recognised Training (NRT) logo. The NRT logo must be used in direct connection to the title(s) of Nationally Recognised Qualifications i.e. directly beside, above or below the title(s) of Nationally Recognised Qualifications;
- Make sure that it has written documentation to back up any specific claims it makes about advanced standing with other educational institutions. If Imperial is going to make a general claim, that advanced standing may be a possibility, Imperial needs to be clear that no specific arrangements are being claimed as in the following statement:
“Graduates of Imperial may seek credits to the relevant degree programs in Australian Universities. Imperial has no special arrangements with any Australian University and there is no guaranteed entry into University programs. As a general rule students with high marks will have the best chance of being accepted by a University.”
- Include information on whether or not course credits may be available (i.e. RPL or Credit Transfer);
- Include information about course related fees;
- Check that all qualification codes and RTO and CRICOS codes are correct;
- Check that all qualification durations for international students match the CRICOS register(www.cricos.education.gov.au);
- Ensure that every page on Imperial’s website relating to the provision of courses to students includes the full Legal Name of Imperial and Imperial's CRICOS and RTO Number;
- Ensure that for every qualification there is an accurate description of the learning methods used and the assessment requirements. Ensure that there is a general description of facilities, equipment, learning and library resources available to students;
- Check that the address of every delivery site is included;
- Include information on the potential for fees to change before and during a student’s enrolment – i.e. specify whether the fees are fixed, or are subject to increase/decrease, and if they are subject to change, what sort of increase/decrease;
- Include information about the grounds on which the student’s enrolment may be deferred, suspended or cancelled. This should include any cancellation due to student’s misbehaviour resulting in Imperial cancelling their enrolment;
- Include a copy of the ESOS framework on the web site for international students.
- Obtain written approval from anyone whose photos or endorsements appear on the web site.
- Included information on living in Australia (for international students) including
- Indicative costs of living;
- Accommodation options;
- Schooling obligations and options for school-aged dependents including a statement that school-aged dependents may have to pay full school fees; and
- Information on accommodation options including the general rental market.
- Student support information, including description of the support services available, legal services contacts, emergency contacts, counselling and health services contacts, registered provider’s student contact person(s) name and phone number;
- Information about the complaints and appeals processes;
- Information about academic progress requirements – the National Code now mandates passing of a minimum of 50% of units in any study period;
- Information about the rules for transfer between registered providers for international students;
- The student discipline procedure;
- A statement that students are obliged to notify Imperial of change of address, phone number, fax number and email address once every six months; and
- A description of the process for claiming a refund.
Material Exempt from the Code
The material that may not have Imperial's name and the RTO and CRICOS number is:
- Business cards that give Imperial’s contact details only;
- Job advertisements unless they are used to promote studying with Imperial;
- General information;
- Any other information that is not used to market registered courses to students;
- Tourist brochures which provide information about life in Australia; and
- Links to useful external websites.
Procedure for Producing Marketing Material
The procedure for producing marketing material is as follows:
- The marketing material will comply with SNR 24 and Section 107 of ESOS Act 2000 and standard 1 of the National Code 2007;
- The marketing manager or the designated staff member of Imperial will prepare the draft of the marketing material and seek approval of the CEO;
- The draft of the marketing material will be matched with the approved copy of the marketing material to ensure accuracy of information;
- The marketing material will be checked on receipt from the publishers for accuracy before it is distributed;
- The education agents will be distributed updated marketing material by the designated staff member of Imperial; and
- For advertisement in an overseas newspaper the above procedure will be followed by the person assigned the job or the education agent as the case may be.
- Imperial will recruit and review marketing agents as per its policy on education agents under standard 4 of the National Code. In particular Imperial will regularly review the performance and conduct of our education agents to ensure consistency with expected standards of behaviour.
- Up-to-date marketing material will be given to agents by Imperial and the agents will be required to seek prior approval from the CEO for making their own marketing material about Imperial.
Access to PRISMS
- Education agents will not be given access to PRISMS under any circumstances.
Review of Marketing Material
The review of the marketing material will take place as follows:
- It will be reviewed on change of ESOS and NVR Act policy on marketing material;
- To incorporate any change in the course fee, delivery methods etc;
- On discovery of a mistake;
- On change of Imperial courses, campus location or department/court order etc.; and
- Any other reason to ensure Imperial compliance with relevant legislation(s).
Changes to the Marketing Material
- Changes to the marketing material are to be made on the directions of CEO or the delegate;
- All changes will be approved by the CEO in the same manner as for making of new marketing material and its records will be maintained in the marketing material folder;
- All CRICOS marketing material must be reviewed using the National Code 2017 Compliance Checklist as a general guide to the requirements; and
- The DET website must be checked for any revised information and advice on the requirements of part D of the National Code.