The purpose of this policy is to provide guidelines for the marketing and advertising activities of Alphacrucis University College (AC).
Whole of AC
AC and its Education Agents will market all courses and training products with integrity, accuracy and professionalism, avoiding vague and ambiguous statements.
In the provision of information, no false or misleading comparisons will be drawn with any other education provider, course of study, training organisation or training product.
AC and its Education Agents will ensure that AQF qualifications and course information is accurate and consistent with the accreditation and its scope of registration in its marketing and advertising.
AC and its Education Agents will ensure that information and advice regarding payment of fees, FEE-HELP and VET Student Loans is marketed accurately and fairly, allowing students to make enrolment and payment decisions with clear understanding of their rights and obligations. AC will not offer any prohibited inducements.
AC and its Education Agents will ensure that any logos belonging to another body are only used in accordance with their condition of use.
AC and its Education Agents will not actively recruit students enrolled with another provider. Applications and enrolments from international students will be processed as set out in the Admissions Policy.
AC and its Education Agents will not give false or misleading information or advice in relation to:
- claims of association between providers
- the employment outcomes associated with a course
- automatic acceptance into another course
- possible migration outcomes,
- any other claims relating to the registered provider, its course or outcomes associated with the course.
- payment options, including FEE-HELP and VET Student Loans assistance.
AC use of Education Agents
AC abides by the regulations stipulated in the National Code of Practice for Providers of Education and Training to Overseas Students (The National Code 2018) in its dealing with education agents both on-shore (in Australia) and overseas.
AC will only enter into service arrangements/MOU with Education, Migration Agencies or Agents when their service activities have been agreed to and a written agreement is ratified and signed by the Director of Marketing or delegated authorised signatory.
AC will take all reasonable measures to use Education Agents that have an appropriate knowledge and understanding of the Australian International Education Industry, the ESOS Act and Regulations 2000, the Australian International Education and Training Agent Code of Ethics, as well as AC's current training packages and accredited courses available.
AC will not use Education Agents who are dishonest or lack integrity. All Education Agents engaged by AC are required to read and be aware of the regulations regarding international students as stipulated in The National Code 2018.
Credit Card Marketing
The advertising, marketing or merchandising of credit cards directed at students is prohibited at any AC delivery site. AC also prohibits the provision of lists of current students, who have not yet graduated from one of AC’s courses, to credit card companies for the purpose of offering credit cards to those students.
For the purpose of this policy, credit card marketing activity includes any activity designed to encourage students to apply for a credit card, including but not limited to:
- placing a display or poster together with credit card applications on campus;
- offering free merchandise to students to market credit cards; or
- offering incentives to students to market credit cards.
This policy does not apply to any advertising, marketing, or merchandising of credit cards by either AC or an agent of AC to non-students, nor does it prohibit the advertising, marketing, or merchandising of credit cards to students through direct mail, newspapers, magazines, or within any banking institution located on AC campuses or of any affinity-based credit card program to which AC is a party.
Responsible for implementation
Director of Marketing
All staff and students
Article 129-a of the Education Law
National Code of Practice for Providers of Education and Training to Overseas Students 2018
Education Agent Written Agreements
In entering into an agreement with an Education Agent, the Director of Marketing shall ensure that the Education Agent Written Agreement includes:
- the responsibilities of the registered provider, including that the registered provider is responsible at all times for compliance with the ESOS Act and National Code 2018;
- the responsibilities of the agent in representing AC;
- AC's monitoring procedures;
- corrective action procedures;
- termination conditions (immediate where failures to meet The National Code 2018 or Migration Act 1958 requirements are encountered);
- circumstances under which information about the education agent may be disclosed.
Monitoring of Education Agents
AC will use the methods below to monitors its Education Agents:
- regular face-to-face or telephone/teleconference meetings with Agent onshore or offshore;
- surveys of students recruited by particular Agent;
- collect data from PRISMS and other sources to monitor visa applications submitted by students referred by the Agent;
- collect data related to the performance and progression of students referred by the Agent; and
- request occasional reports and emails from the Agent.
Grounds for Corrective Actions or Dismissal of Agent
AC will immediately take corrective action or terminate the agreement with the Agent in writing, if it becomes aware of or reasonably suspects:
- the Agent being 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;
- dishonest practices by the Agent, including the deliberate attempt to recruit a student where this clearly conflicts with the obligations of registered providers under National Code Standard 7;
- AC may terminate the agreement with the Agent if a visa application for a student referred by the agent is refused by The Department of Home Affairs for reasons related to fraudulent documents or suspicion of fraud.
Notifying and Handling of Breaches
Any AC staff member who becomes aware of possible breaches of this policy must report it to either:
- their supervisor or manager;
- their Head of Department or School; or
- Vice President Advancement.
The VP Advancement is responsible for handling breaches and potential breaches for commercial entities.
Any AC student, or staff member found violating this policy shall be subject to formal disciplinary action in accordance with AC misconduct policies. Penalties may range from restriction of access to the delivery site or in some more serious instances criminal or civil proceedings.
AC will report illegal activities and corrupt conduct to appropriate authorities.