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Clause 4.1—Provide accurate and accessible information to prospective and current students

Clause 4.1

Information, whether disseminated directly by the RTO or on its behalf, is both accurate and factual, and:

a) accurately represents the services it provides and the training products on its scope of registration

b) includes its RTO code

c) refers to another person or organisation in its marketing material only if the consent of that person or organisation has been obtained

d) uses the NRT [Nationally Recognised Training] logo only in accordance with the conditions of use specified in Schedule 4

e) makes clear where a third party is recruiting prospective learners for the RTO on its behalf

f) distinguishes where it is delivering training and assessment on behalf of another RTO or where training and assessment is being delivered on its behalf by a third party

g) distinguishes between nationally recognised training and assessment leading to the issuance of AQF [Australian Qualifications Framework] certification documentation from any other training or assessment delivered by the RTO

h) includes the title and code of any training product, as published on the national register, referred to in that information

i) only advertises or markets a non-current training product while it remains on the RTO’s scope of registration

j) only advertises or markets that a training product it delivers will enable learners to obtain a licensed or regulated outcome where this has been confirmed by the industry regulator in the jurisdiction in which it is being advertised

k) includes details about any VET [Vocational Education and Training] FEE-HELP, government-funded subsidy or other financial support arrangements associated with the RTO’s provision of training and assessment

l) does not guarantee that:

  • i) a learner will successfully complete a training product on its scope of registration, or
  • ii) a training product can be completed in a manner which does not meet the requirements of clause 1.1 and 1.2, or
  • iii) a learner will obtain a particular employment outcome where this is outside the control of the RTO.

What clause 4.1 means for your RTO

The Standards for Registered Training Organisations 2015 (the Standards) require your RTO to provide clear and accurate information to students before enrolment to allow students to make informed choices.

The Standards make it clear the RTO is solely responsible for all advertising, marketing and recruitment done on its behalf—regardless of the channel or method used.

You must ensure students are provided with clear and accurate information. This is your RTO’s responsibility regardless of:

  • the medium used to advertise training (including your website and social media)
  • how students are recruited
  • who is actually providing the information (including education agents and brokers).

Your RTO is subject to all relevant consumer protection laws that apply in any jurisdiction where you operate.

Your RTO must honour all commitments it makes in all marketing materials. You must only promote training or assessment for training products that are currently on your scope of registration.

Including your RTO code

  • You must include your RTO code in all marketing material where an inference is made that nationally recognised training is offered.
  • The RTO responsible for the training and/or assessment and for issuing a qualification or statement of attainment must be absolutely clear to anyone viewing any marketing or advertising material.
  • If another person or organisation is delivering training under a third-party agreement with your RTO, your RTO code must be included on all marketing or other material created by that person or organisation that relates to that training and/ or assessment.
  • If another person or organisation is recruiting students under a third-party agreement with your RTO, your RTO code must be included on all marketing or other material created by that person or organisation.
  • If you are delivering under a third-party agreement with another RTO, that RTO’s code must also be included in all marketing or other material relating to those courses.

Using the Nationally Recognised Training logo

  • All nationally recognised training is listed on the national register of training providers and courses, at training.gov.au. The NRT logo is a recognised trademark that confirms training is nationally recognised. To maintain the credibility of the logo, it must be used only in accordance with the conditions of use in Schedule 4 of the Standards.
  • If your RTO delivers training that is not nationally recognised (including school and higher education programs), you must clearly separate marketing or other information about this training from marketing and information about training that is nationally recognised.It must be clear where training is not nationally recognised. 
  • RTOs can obtain a copy of the NRT logo by sending an email from an RTO contact listed on the national register at training.gov.au to enquiries [at] asqa.gov.au.

Including the code and full title of the training product

  • • Whether you offer qualifications, skill sets, accredited courses or individual units, all marketing material must include the code and the full title of the training product (as listed on the national register) to ensure there is no confusion about what is being offered and to allow potential students to verify the information. This also means that all RTOs are describing courses under the same title, reducing confusion in the marketplace.

When developing your marketing or advertising material, remember the likely audience, particularly for online marketing. Often, Australian states and territories have different regulatory arrangements and potential students must be able to clearly see where any licensing or accreditation outcomes may apply.

Your RTO’s marketing material must also be consistent with its training and assessment strategies, including any variations or additions for courses delivered to overseas students. For example, you must not claim a course takes two weeks to complete if students complete the course over a period of several months, including doing so by also undertaking a period of independent study.

Details about the amount of training should be clear and where necessary should provide information for all student cohorts.

If you use any reference to another person or organisation (such as testimonials or photos) in marketing or advertising material, you must gain consent from the person or organisation before you make that reference public. This applies to, for example, displaying photos of other training or educational institutions on your website, which can lead people to believe your RTO operates those facilities.

Where students may be accessing VET Student Loans (VSL) or any other government loan or subsidy, your RTO must provide details of the arrangements. You must provide details of:

  • any costs associated with the loan or subsidy (including interest or similar costs)
  • any debt that will be incurred.

You should also note that these funding programs may have additional marketing requirements with which you must comply. You should check the details of requirements with the relevant funding authority.

You must provide details of any loss of entitlement that may occur if a student undertakes a course at your RTO. This includes providing information about limited entitlement schemes (where students are only able to access one course or there are restrictions on what courses may be subsidised after a student completes their study at your RTO).

RTOs are not required to have marketing or advertising policies and procedures, but you should:

  • ensure all marketing material is checked and approved by an appropriate person before publication
  • monitor all marketing to ensure it remains current and accurate.

ASQA and other agencies receive many complaints about RTOs that make inaccurate or misleading statements in their marketing. Being vigilant about monitoring the accuracy of marketing about your RTO across all forms of media will increase student satisfaction and reduce the chance of students submitting complaints to regulators. You should be equally vigilant in monitoring any marketing carried out on your behalf by other parties, such as training directories or brokers.

Complaints ASQA receives about an RTO can lead to regulatory action.

Remember, your RTO is responsible for ensuring all marketing complies with the Standards, no matter who actually creates or publishes the material.

ASQA may review your RTO’s marketing when:

  • preparing for an audit
  • considering applications
  • investigating complaints
  • as part of regular data-gathering processes to inform an RTO’s risk profile.

ASQA’s reviews include conducting Internet searches to discover marketing about your RTO other than your RTO’s website, reviewing social media, and reviewing data and intelligence received about your RTO’s marketing processes.

A guide to compliance

Complaints about student information, enrolment and marketing are consistently among the top ten categories of complaints about RTOs that ASQA receives. This suggests that RTOs need to have rigorous processes in place to monitor and review their marketing and recruitment materials and practices.

Your RTO should retain copies of all actual advertising and marketing material, including any material created by third parties. Retaining copies and keeping a register of all approved material, while not mandatory, makes it easier for your RTO to monitor marketing and allows this evidence to be presented as part of an audit or in the investigation of a complaint.

Regardless of how your evidence is presented, it must demonstrate that all of the requirements of clause 4.1 have been complied with in full.

How can my RTO demonstrate and provide evidence of compliant practice?

You could show that your RTO has a systematic practice of reviewing all your marketing, advertising and recruitment materials and keep a register of the actions you have taken to ensure these materials remain accurate and up to date. For example, you could show that:

  • you review these materials whenever your training and assessment strategies are changed
  • you have an identified staff member responsible for checking the accuracy and currency of information before it is published
  •  you collect information from clients/students about whether they received the services they understood they would receive and keep records of any actions you take in response to student feedback.

If you reference another person or organisation in your advertising or marketing material you must retain evidence that permission was obtained prior to any material containing the reference being published. Evidence could include:

  • an exchange of email
  • a signed release form
  • a letter giving permission to use the relevant material
  • other relevant evidence.

If you regularly include information about students in social media (including photos where a student can be recognised), evidence might include a release clause in the enrolment form giving your RTO permission to use photos in public if you use this method (ensure you can demonstrate that these students actually agreed to the release and that students can ‘opt out’ if they wish).

Remember that ASQA will be seeking evidence that your marketing and recruitment practices align with all your RTO’s marketing and recruitment materials—no matter who they are published by, or in what format. For example, ASQA may interview or survey your students about their experience of your marketing. ASQA may also discuss your marketing and recruitment with third parties.

Tips on advertising

  • Ensure you never advertise superseded qualifications past the permitted transition period.
  • Carefully check that you do not claim that a qualification can be achieved in unrealistically short time frames.
  • Make sure that your marketing or advertising material only provides factual information about your training. You should never:
    • guarantee that a student will be issued with a qualification or statement of attainment
    • guarantee that any employment outcome will result from training and/or assessment at your RTO, unless you have arranged guaranteed employment for any student that successfully completes their training and/or assessment at your RTO
    • claim that a student will be eligible for any licence or accreditation as a result of your training and/or assessment, unless the issuer of that licence or accreditation has confirmed this to be the case
    • guarantee that a student will successfully complete a training product or that a training product can be completed in a manner that does not meet the requirements of clause 1.1 or 1.2 of the Standards.
  • Ensure any third parties you use in marketing and recruitment comply with this Standard and that your advertising makes it clear if any third parties are involved in delivering services on your behalf.

Additional requirements for VET Student Loans–approved training providers

Training providers that have been approved to enrol students whose training is supported by loans under the Australian Government Department of Education and Training (DET) VET Student Loans (VSL) program must ensure that their marketing practices enable students to select a course based on the content, quality and price of training offered. The VET Student Loans Rules 2016 have specific requirements for any marketing that mentions the possible availability of a VET Student Loan.

The VET Student Loans program does not allow:

  • for any social media marketing to mention the availability of a VET Student Loan
  • for providers to engage in cold-calling to market courses and offer a VET Student Loan
  • for third parties (agents or brokers) to provide any information about a VET Student Loan
  • the offering of benefits such as laptops/tablets, prizes or vouchers of greater than a $30 value to encourage students to sign up for a VET Student Loan
  • the description of training that is paid for through the student’s VET Student Loan as being ‘free’, ‘government-funded’, or any other term that implies it is ‘not a loan’.

Any marketing or advertising material must clearly state that VET Student Loans must be repaid. For more information, please refer to the DET’s Information for VET Student Loans providers.

Advice for enterprise RTOs

Training programs delivered by enterprise RTOs for their employees or volunteers are generally determined by the requirements of their job (for example, after recruitment or promotion). In many cases employees are required to undertake these training programs as a condition of employment. It is rare for an enterprise RTO to advertise and market its training services to prospective clients or to charge any fees for the provision of those services.

Within the enterprise RTO training environment, the information given to students will reflect their primary status as employees of the enterprise, rather than prospective clients of a training provider.

While clause 4.1 may be of limited relevance to enterprise RTO students, it is important that the documentation provided by the enterprise is accurate, factual and current.

Your RTO should consider:

  • providing employees with information about the enterprise RTO, including the RTO code, scope of registration, and key business objectives
  • providing employees with information stating the RTO’s responsibility for ensuring the quality of the training and assessment through compliance with the Standards
  • explaining the meaning of nationally recognised training and assessment and the potential value of AQF certification documentation
  • clearly distinguishing between the nationally recognised training and assessment being provided and any other training or assessment that may be delivered to employees by the enterprise
  • clearly explaining the purpose and objectives of the training and assessment activities to be undertaken by the student.

Guidance for applicants for initial registration

You may not yet have all your marketing material fully developed. Provide any draft materials as evidence of what will be used and show that all requirements of clause 4.1 have been adhered to.

Case study—Monitoring the market

YZA Training delivers training in allied health from four locations in New South Wales and South Australia. In addition, it has a third-party agreement with Quality Health Education to deliver first aid units at workplaces in New South Wales, Victoria and South Australia.

The RTO’s marketing manager approves all new marketing and promotional materials, and any other public information about the RTO, before it can be used. A register is kept of all approvals, along with a complete copy of the material. This requirement is included in the third-party agreement with Quality Health Education.

Regular monitoring is carried out on all currently approved material, particularly online material, to ensure it remains consistent with the RTO’s scope of registration and operations. When material is no longer in use, it is marked as ‘non-current’ in the register after being confirmed as no longer in circulation.

The marketing manager conducts regular searches of the internet for ‘YZA Training’, ‘Quality Health Education’ and other relevant terms that could reveal any information about the RTO. On one occasion, a search discovered that Quality Health Education had entered information about first aid courses into a ‘careers directory’ online and did not identify YZA Training as the RTO. As this information had not been approved by the RTO, Quality Health Education was required to have the material removed. Shortly after, Quality Health Education submitted a request for advertising on the same site to be approved. As the request now included all required information and was accurate, the marketing manager approved the request, the information was entered in the directory and the item was added to the register for future checking.