INTERNATIONAL EDUCATION AGENT POLICY
Date first approved:
Date of effect:
1 March 2017
Date last amended:
(refer to Version Control
Table)
Date of Next Review:
March 2020
First Approved by:
University Council
Custodian title & email address:
Manager, International Recruitment
Author:
Manager, International Recruitment
Responsible Division
& Unit:
Student Services Division (SSD)
Supporting
documents,
procedures & forms:
Agency Application Form
Relevant Legislation
&
ESOS Framework including the National Code of Practice for Registration
Authorities and Providers of Education and Training to Overseas Students
External
Documents:
Higher Education Threshold Standards
Audience:
Public
Agency Contract Template
Submit your feedback on this policy document using the Policy Feedback Facility.
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International Education Agent Policy
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Contents
1
Purpose of Policy
3
2
Definitions
3
3
Application & Scope - Exclusions or Special Conditions
4
4
Policy Principles
4
5
International Education Agent Functions
4
6
Appointment of International Education Agents
5
7
Review of International Education Agents Performance
6
8
Termination of International Education Agents
6
9
International Education Agent Remuneration
7
10
Communication with International Education Agents
7
11
Promotional Material and Events
7
12
Roles & Responsibilities
7
13
Version Control and Change History
9
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1
2
Purpose of Policy
1.
This document sets out the University of Wollongong's (UOW) policy in relation to the
recruitment, management and termination of International Education Agents.
2.
This policy aims to ensure that the actions of its appointed International Education Agents are
ethical and comply with UOW and UOW College’s obligations under the:
a.
ESOS Framework;
b.
Higher Education Threshold Standards; and
c.
Migration Act and Regulations.
Definitions
Word/Term
Definition (with examples if required)
Agency Agreement
A legal agreement between the University and an International Education Agent,
and in some circumstances, UOW College outlining the obligations and
responsibilities of all parties to the agreement.
Agency Principal
The owner or individual with delegated authority from the agency to sign an
individual agency agreement.
Counsellor
Employee of an Agent who provides recruitment advice to prospective students.
ESOS Framework
The Education Services for Overseas Students Framework is a bundle of
parliamentary acts and legislative instruments that regulates Australian education
providers in their interactions with international students and includes the
Education Services for Overseas Students Act 2000 of the Commonwealth of
Australia (the “ESOS Act”) and related regulations.
Genuine Student
A Genuine Student is considered a genuine temporary entrant to Australia for the
purpose of study as defined by the Department of Immigration and Border
Protection.
Higher Education
Threshold Standards
The Higher Education Standards Framework (Threshold Standards) 2015
comprises a set of standards that has been approved by the Commonwealth
Parliament effective 1 January 2017.
International
Education Agent
An individual person or organisation acting as an approved representative of
UOW and/or UOW College for the purpose of recruitment of international
students via an individual Agency Agreement.
National Code
National Code of Practice for Registration Authorities and Providers of
Education and Training to Overseas Students 2007. The National Code is a
legislative instrument and forms part of the ESOS Framework.
Prospective
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A person who intends to become, or who has taken any steps towards becoming
an 'overseas student' or 'intending overseas student' as defined by the ESOS Act.
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International
Student
3
4
Application & Scope - Exclusions or Special Conditions
1.
This Policy applies to all staff of UOW and UOW College and International Education Agents
engaged on behalf of the University and UOW College, both onshore and offshore.
2.
This policy does not apply to the University of Wollongong in Dubai (UOWD) which has its
own version of this policy.
3.
International Education Agents will be engaged in a manner consistent with the Higher
Education Threshold Standards by a collaborative partner, for the purpose of recruitment of
students into UOW courses, delivered in association with that partner. This is covered by the
terms of the Collaborative Delivery Agreement with the partner institution.
Policy Principles
1.
5
UOW and UOW College will:
a.
select only reputable International Education Agents and ensure those agents act
honestly and with integrity;
b.
manage their International Education Agents in a professional and responsible
manner;
c.
enter into a written agreement with each International Education Agent approved
to represent it in accordance with the agent assessment process as described under
Section 6 below;
d.
maintain an accurate list of approved International Education Agents, which will
be published on their respective websites;
e.
ensure all relevant UOW and UOW College business units have access to the
accurate list of authorised International Education Agents;
f.
include the name of the International Education Agent on the Confirmation of
Enrolment (CoE) where applicable;
g.
require their International Education Agents to have appropriate knowledge and
understanding of the Australian international education industry;
h.
provide adequate training and information for International Education Agents,
including their obligations under this policy, the individual Agency Agreement
and Australian migration laws; and
i.
ensure that International Education Agents have access to accurate and up-to-date
marketing information.
International Education Agent Functions
1.
Individual persons or organisations, onshore or offshore, may be engaged by the UOW
and/or UOW College as an International Education Agent to assist UOW and UOW College in
recruiting international students pursuant to the terms of individual Agency Agreements.
2.
International Education Agents are representatives only within the terms of individual Agency
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Agreements.
6
3.
As an agent of UOW and UOW College, all International Education Agents must abide by the
principles of the National Code and the terms of their signed individual agency agreement.
4.
The principles of the National Code, as they relate to the conduct of International Education
Agents, are derived from Standard 4.3. An International Education Agent must not:
a.
be engaged in, or have previously been engaged in, dishonest practices, including
the deliberate attempt to recruit a student where this clearly conflicts with the
obligations of registered providers under Standard 7 (Transfer between registered
providers);
b.
be currently facilitating, or have previously facilitated, the enrolment of a student
who the education agent believes will not comply with the conditions of his or her
student visa;
c.
use the Provider Registration and International Students Management System
(PRISMS) to create Confirmations of Enrolment for other than a bona fide student;
or
d.
provide immigration advice where not authorised under the Migration Act 1958 to
do so.
Appointment of International Education Agents
1.
An International Education Agent is appointed by signing a formal written Agency
Agreement with UOW and/or UOW College.
2.
Prior to engaging a new International Education Agent, UOW will request the completion of
an Agency Application Form which incorporates the requirement for a declaration of interests
on the part of the applicant.
3.
UOW will undertake an assessment to satisfy itself that the potential agents will represent the
University appropriately and will not pose risks to UOW, UOW College, staff, students or
prospective students. This may include:
4.
a.
Assessing that the agent is registered to operate in their local jurisdiction.
b.
Assessing the agent’s history and track record in recruiting students for the
Australian market.
c.
Assessing the agent's knowledge of the Australian international education industry,
understanding of the principles of the National Code and other requirements
relating to the provision of their services.
d.
Inspecting the agent’s premises to ensure that they are appropriate and present a
professional image.
e.
Interviewing counsellors to assess their performance in advising students..
f.
Obtaining information on the display of UOW and UOW College promotional
materials.
The individual Agency Agreement is signed by the delegated authority in accordance with the
UOW Delegations of Authority Policy and the Agency Principal. Where the individual
Agency Agreement includes UOW College, the Agency Agreement will be executed by a
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delegated authority on behalf of UOWC.
5.
7
8
A database of approved International Education Agents and respective Agency Agreements is
maintained by the Student Services Division.
Review of International Education Agents Performance
1.
UOW Student Services Division will manage ongoing operational performance monitoring of
agents throughout the contract period. Where UOW College is a party to an Agency
Agreement they will contribute to monitoring and performance reviews as appropriate.
2.
UOW and UOW College will monitor International Education Agent performance on a
continuous basis and will conduct formal reviews of such performance at least every five
years, or prior to each contract renewal period, whichever is sooner. UOW College may
contribute to agency performance reviews when party to an Agency Agreement between an
International Education Agent and UOW.
3.
Formal International Education Agent performance reviews will be conducted for those
contracts up for renewal.
4.
The review will incorporate both UOW and UOW College student recruitment performance
and may include (but is not limited to):
a.
Recruitment volume;
b.
Application conversion rates;
c.
Visa success rates;
d.
Quality and completeness of applicant documentation;
e.
Compliance with the individual Agency Agreement;
f.
Student performance on post enrolment;
g.
Quality of advice and information provided to students; and
h.
Student feedback.
5.
Renewal of an Agency Agreement will only be approved if the performance of the
International Education Agent is found to be satisfactory.
6.
Where, on review, the performance of an International Education Agent is found to be
unsatisfactory, action may be taken as specified in their individual Agency Agreement.
7.
Each year, a review report will be produced by Student Services Division which summarises
the performance of International Education Agents. This report will be forwarded to the
University Internationalisation Committee which has governance oversight of agent
management. This report will also be provided to UOW College.
Termination of International Education Agents
1.
In the event that an International Education Agent has been found to breach the terms and/or
conditions of the individual Agency Agreement, a party to the contract may terminate their
Agency Agreement in accordance with the terms of the individual Agency Agreement.
2.
In the event that an International Education Agent has been found to have acted dishonestly,
the University will terminate the individual Agency Agreement immediately in accordance
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with the terms of the individual Agency Agreement.
3.
9
A party to the Agency Agreement may terminate an Agency Agreement with an International
Education Agent who does not comply with requirements as set out in the terms of the
individual agency agreement, and in accordance with this policy. UOW College will advise
UOW of identified agent non-compliance warranting termination of an Agency Agreement.
International Education Agent Remuneration
1.
International Education Agents are remunerated by UOW and UOW College through either
direct payment for particular services or payment of commissions based on enrolments
attributable to an agent.
2.
The amounts payable, and terms of payment are determined by the individual Agency
Agreement.
3.
Any other conditions will be specified in the individual Agency Agreement.
10 Communication with International Education Agents
1.
UOW and UOW College will ensure there is timely and relevant communication with its
International Education Agents.
2.
Contact with, and management of the activities of the agent network is primarily the
responsibility of the Student Services Division.
3.
An International Education Agent newsletter will be distributed to all active International
Education Agents by Student Services Division on a regular basis and as needed. This
International Education Agent newsletter will also be provided to UOW College.
4.
Copies of communications relating to updates, commission payment and individual Agency
Agreements are retained by Student Services Division.
11 Promotional Material and Events
1.
The Strategic Marketing and Communications Unit is responsible for the development of
promotional materials in conjunction with the International Recruitment staff.
2.
International Education Agents and other organisations are notified of the availability of new
material by International Education Agent updates. International Education Agents who
request materials are referred to the UOW International Representatives website, where a form
can be downloaded.
3.
International Education Agent engagement is coordinated by Student Services Division
4.
Where International Education Agent visits are arranged external to Student Services Division;
details of these visits and any outcomes should be directed to Student Services Division for
inclusion in recruitment planning to ensure coordination of representatives.
12 Roles & Responsibilities
1.
International Education Agents are responsible for:
a.
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promoting the University of Wollongong and UOW College
to prospective
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students;
2.
3.
4.
5.
b.
recruiting genuine students to the University of Wollongong and UOW College;
c.
complying with the terms and condition of their individual agency agreement; and
d.
maintaining understanding and compliance with this policy and related
International Recruitment Representative Procedures.
Student Services Division is responsible for:
a.
entering into Agency Agreements that are on terms consistent with this policy;
b.
managing the agent relationship on behalf of the University;
c.
managing the agent selection, monitoring, and review process;
d.
maintaining communications with the agent network;
e.
maintaining the agent database and online listing;
f.
distributing appropriate promotional material to agents;
g.
providing adequate training to agents;
h.
Coordinating International Education Agent engagement; and
i.
Undertaking agent performance monitoring and reviews and reporting annually to
the University Internationalisation Committee.
Faculty Recruitment Staff are responsible for:
a.
providing adequate faculty and course specific information to agents;
b.
where appropriate, maintaining agent relationship with the respective faculty; and
c.
providing Student Services Division with information on agent interactions and
their outcomes.
UOW College are responsible for:
a.
entering into Agency Agreements that are on terms consistent with this policy;
b.
providing adequate UOW College course specific information to agents;
c.
where UOW College is the primary agent contact, managing training and
communications;
d.
contributing to agent performance reviews;
e.
providing Student Services Division with information on agent interactions and
their outcomes.
Strategic Marketing and Communications Unit is responsible for:
a.
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developing promotional material appropriate for source markets in conjunction
with International Recruitment staff.
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13 Version Control and Change History
Version
Control
Date Effective
Approved By
1
01 March2017
University Council
Amendment
2
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