- Assessment Policy
- Complaints and Appeals Policy - International Students
- Course Progress Policy - International Students
- Critical Incidence Policy
- Deferment & Suspension or Cancellation Policy
- Education Agents Policy
- Entry Requirements and Selection Policy - International Students
- Fees & Charges and Refund Policy - International Students
- Health & Wellbeing and Safety Policy
- Industry Engagement Policy
- Informing and Protecting Learners Policy
- Marketing Policy - International Students
- Notice of Unsatisfactory Course Progress - Risk Intervention
- Overseas Student Transfer Policy
- Plagiarism and Academic Misconduct Policy
- Recognition of Prior Learning and Credit Transfer Policy
- Student Support Services Policy - International Students
- Training and Assessment Strategies Policy
- Validation Policy
- Volume of Learning Policy
INTRODUCTION
This policy is also in accordance with the National Code of Practice for Providers of Education and Training to Overseas Students 2018 (Standard 4: Education Agents).
Insight Institute of Further Studies (IIFS) must ensure that their education agents act ethically, honestly and in the best interest of overseas students and uphold the reputation of Australia’s international education sector.
POLICY
Insight Institute of Further Studies (IIFS) must:
• have a written agreement with each education agent they engage with;
• enter and maintain education agent details in Provider Registration and International Student Management System (PRISMS);
• ensure education agents have appropriate knowledge and understanding of the Australian International Education and Training Agent Code of Ethics;
• ensure education agents act honestly and in good faith;
• take immediate corrective action, or terminate a relationship if an agent (or an employee or subcontractor) is not complying with the National Code; and
• not accept overseas students from an education agent if it knows or suspects that the education agent is engaging in unethical recruitment processes.
The written agreement must outline:
• IIFS’s responsibilities, including for compliance with the Education Services for Overseas Students Act 2000 (ESOS Act) and National Code 2018;
• the requirements of the agent in representing Insight Institute of Further Studies (IIFS);
• Insight Institute of Further Studies (IIFS)’s processes for monitoring the education agent’s activities and ensuring the education agent gives overseas students accurate and up-to-date information;
• the corrective actions that may be taken and the grounds for termination of the written agreement with the education agent; and
• the circumstances which information about Insight Institute of Further Studies (IIFS)may be shared by the registered provider and Commonwealth or state and territory agencies.
Education Agents
Insight Institute of Further Studies (IIFS)must ensure the education agents they engage with act ethically, honestly and in the best interest of overseas students. This means that IIFS must ensure its education agents declare and take all reasonable steps to avoid conflicts of interest with its duties as an education agent of IIFS. This provision is to ensure transparency in the education agent’s activities.
Examples of conflicts of interest include, but are not limited to:
• when the agent charges services fees to both overseas students and IIFS for the same service;
• where an education agent has a financial interest in a private education provider; or
• where an employee of an education agent has a personal relationship with an employee of IIFS.
IIFS must also ensure education agents observe appropriate levels of confidentiality and transparency in dealings with overseas students while acting honestly and in good faith.
Education agents must also have appropriate knowledge and understanding of the overseas education system in Australia, including the Australian International Education and Training Agent Code of Ethics.
IIFS should ensure any education agents they engage with, including offshore agents, have up-to- date and accurate marketing information.
The Australian International Education and Training Agent Code of Ethics is based on the London Statement. These requirements ensure education agents adhere to and practice responsible business ethics, and that education agents understand their obligations to provide current, accurate and honest information to overseas students to help them make informed decisions about study in Australia.
Immediate corrective actions
• IIFS must take immediate corrective action if they are aware that or believe the education agent or its employee or subcontractor, have not complied with the education agent’s responsibilities under Standard 4. Corrective actions may include providing education agents with additional information or targeted training on expectations of the agent.
• If IIFS becomes aware, or has reason to believe that an education agent is engaging in false or misleading recruitment practices, they must immediately terminate their relationship with the agent.
• If the false or misleading recruitment practices were engaged in by an employee or subcontractor of the education agent, IIFS must require the education agent to terminate its relationship with those individuals.
• IIFS must not accept students from education agents if they believe the education agent is engaging in unethical recruitment practices. This includes education agents that provide migration advice to overseas students when they are not authorized to do so under the Migration Act 1958.
• IIFS must not accept overseas students from education agents that engage in, or have previously engaged in, dishonest recruitment practices. This includes education agents knowingly recruiting an overseas student in conflict with the registered providers’ obligations under Standard 7 (Overseas Student Transfers).
• IIFS must not accept overseas students from education agents if they believe the education agent is creating Confirmation of Enrolments (CoEs) in PRISMS for non bona fide overseas students or facilitating the enrolment of overseas students while knowing that the overseas student will not comply with the conditions of their visa.
EDUCATION AGENTS APPOINTMENT PROCESS
IIFS will ensure that it only partners with Education Agents after going through a rigorous selection process which includes doing reference checks and previous work history.
1. Prospective Agents must complete the Education Agent Application Form and submit this along with the required documentation to the IIFS Marketing Manager.
2. If the IIFS Marketing Manager determines that the prospective Agent is suitable to appoint, they must complete the Agent Reference check
3. Once Agent Reference Check has been completed, IIFS Marketing Manager will reassess the application to determine if prospective Agent is suitable to appoint.
4. IIFS Marketing Manager will then send out the Agent Agreement to the prospective Agent.
5. Upon receiving the signed Agent Agreement, IIFS CEO will sign this Agreement.
6. The countersigned copy will be provided to the Agent and also maintained on the Agent file by the Marketing Manager.
7. The Agent details will be updated on PRISMS
MONITORING EDUCATION AGENTS:
The Education Agents are often the first point of contact between prospective students and the Australian international education industry. Their activities and ethics are important to Australia’s reputation as a desirable destination for students. IIFS is therefore committed to ensuring its agents act ethically and appropriately. It is IIFS’s responsibility under The National Code (Standard 4) to monitor the activities of the Education Agent.
Agent Performance Review
• IIFS’s responsibilities, including for compliance with the Education Services for Overseas Students Act 2000 (ESOS Act) and National Code 2018;
1. The performance of each agent will be reviewed by the IIFS’s Marketing Manager annually using the Performance Review Form. The outcome of this review will be documented.
2. IIFS’s Marketing Manager will consider the performance of the agent to decide whether to:
• Maintain the agent’s appointment;
• Appoint the agent for a further period subject to certain conditions; or
• Terminate the agent’s appointment in accordance with Termination Procedure.
3. In considering the performance of the agent under Item 2, IIFS’s Marketing Manager, will consider:
• the agent’s compliance with the Agent Agreement and any conditions placed on the agent by IIFS;
• the number of students the agent has recruited and the conversion rate of:
o Student applications to IIFS offers; and
o IIFS offers to actual enrolment of student;
• the reasons why applications from potential students did not proceed to student enrolment status;
• the number of student Visa refusals for students recruited by the agent;
• any feedback or information from students or third parties regarding the agent;
• the quality, accuracy and currency of information and advice provided by the agent to students; and
• the quality of the appointment as assessed by IIFS.
4. Student Feedback
2. IIFS’s Marketing Manager will report the outcome of the Performance Review to IIFS’s CEO, who is ultimately responsible to ensure IIFS’s Compliance with The Standards for Registered Training Organizations 2015 and the National Code.
EDUCATION AGENTS TERMINATION PROCESS
1. IIFS monitor the activities of Agents work, if IIFS received evidence that the Agent does not follow the requirements outlined in this Agreement, IIFS reserves the right to cancel the agreement with written notice.
2. The Agent must provide a written response with 10 working days of the notice.
3. After 10 working days of the notice, IIFS will consider the Agent’s response to make a decision on whether the agent breached the conditions of the Agent Agreement and engaged in unprofessional conduct.
4. If IIFS knows or reasonably suspects the Agent to breach the conditions, it must terminate the Agreement and notify the involved parties.
5. IIFS will take immediate corrective and preventative action upon becoming aware if the Agent, or employees of these Agents are found to be negligent, careless or incompetent or being engaged in-false, misleading or unethical advertising and recruitment practices, including practices that could harm the integrity of Australian Education and Training as well as Provider.