HESF Domain 7: Representation, information and information management

Scope and intent of the Domain

This Domain (Sections 7.1-7.3) of the Higher Education Standards Framework (Threshold Standards) 2021 (HES Framework) encompasses:

  • whether the providers' representations (whether directly or through other parties) about themselves and the course(s) of study they offer are accurate, ethical and not misleading in their claims (Section 7.1)
  • whether there is sufficient publicly available information to assist students in making informed choices about selecting a course of study, to enable effective and informed participation in a chosen course of study and to resolve grievances if necessary, including the particular needs of international students studying in Australia (Section 7.2)
  • the existence of a readily accessible public description of the provider and its operations
  • the requirement that the provider’s information management system meets certain critical requirements concerning content, security and integrity (Section 7.3).

Our commentary

7.1 Representation

TEQSA’s main interest will be in the materials that the provider uses to represent itself and its offerings, whether to particular students or more generally. This can include marketing materials, claims about career outcomes arising from courses of study and the like. Where a provider is represented by agents, we will seek evidence of a formal contractual engagement with the agent(s) that is consistent with the requirements of the Standard, that agents are correctly informed about the provider’s operations and offerings and that the performance of agents is monitored, including that corrective action is taken if necessary. It is expected that much of the evidence required in relation to representation will already be in the public domain (e.g. websites, brochures, prospectuses, advertisements etc.) and that it will be easy for providers to direct us to that material (some materials may be equally applicable to other Sections such as 7.2 and 7.3). We will need to be satisfied that the provider’s representations are accurate, ethical and not misleading.

In relation to Standard 7.1.4, a short narrative about the provider’s use of agents accompanied by examples of existing contractual arrangements, the resources provided to agents and an outline of monitoring arrangements and any corrective actions undertaken could illustrate that this Standard is met, where required. The Standards also call for providers to have controls in place over the way its courses are represented to prospective and current students by any third party, including through third party websites.

7.2 Information for Prospective and Current Students

Standards 7.2.1 and 7.2.2 require the public disclosure of a range of information, aimed largely at informed choices and participation by students (including international students if applicable). Information about the design and structure of courses, factors taken into account in selection (such as the use of ATAR and other requirements), all obligations and liabilities incurred by students (such as fees and charges and HELP liabilities), and the student support and facilities being made available, must be disclosed transparently. Students should be able to readily access all information needed for them to estimate realistic prospects for admission to each course. All information relating to professional accreditation of the course must be disclosed, as discussed in relation to Section 1.1 and Standard 3.1.5.

TEQSA will need to be satisfied that the information required is indeed publicly available, accessible (including to individuals with special needs) and accurate. While Standard 7.3.1 requires a ‘repository of publicly-available current information about the higher education provider’, we do not require the creation of a dedicated repository that is separate from a provider’s existing sources of information, nor do we seek to prescribe the format of its presentation. For example, a provider may for operational reasons, choose to present its information in groupings or blocks of data that are different from the groupings specified by the Standard, and in various sections of its website. This is not of concern, provided that the information requirements of the Standard are met (providers should note that Standards 7.3.1 and 7.3.2 impose particular requirements on the content of some information required by Section 7.2).

In relation to Standard 7.2.3, where applicable, we will expect a provider to be able to describe, and illustrate by example, the mechanisms that are in place to monitor achievement of statutory obligations in relation to the Education Services for Overseas Students Act 2000 and the National Code of Practice for Providers of Education and Training to Overseas Students 2018 in relation to international students.

In relation to Standard 7.2.4, we will expect to see that any formal offer made to students contains warnings of potential changes to fees and charges or other known changes expected in an intended course of study.

Information in the public domain is subject to monitoring at any time. This may mean that a provider will not always be required to submit evidence in relation to Section 7.2 in submissions for regulatory purposes. On the other hand, monitoring of a provider’s public information may raise concerns that lead to a request for further information/clarification outside of the provider’s normal regulatory cycle.

7.3 Information Management

Standard 7.3.1 contains a number of specific requirements for publicly available information. As mentioned in relation to Section 7.2, TEQSA does not seek to specify the form of presentation of this information, however it does expect the requirements of Standard 7.3.1 to be readily accessible, ideally from a single starting point. There could be, for example, a link from a provider’s website home page to another page that will in turn link to all of the types of information listed in 7.3.1 (a to m). 

The information to be made available about the provider’s financial standing is specified in a separate Guidance note and is designed to give prospective students some assurance that the provider is a going concern. This information is separate to what we require in order to assess the financial risk of a provider, either as part of the annual risk assessment or as part of the assessment for registration, re-registration, course accreditation or re-accreditation. 

Information about enrolment numbers (7.3.1i) in the list of a provider’s course(s) should give prospective students an indication of the scale of the provider and learning environment. The information should be based on recent actual enrolments in the case of an existing course, or realistic projections in the case of a new course. A range could be used (e.g. ‘we expect to enrol between x and y students’). In the case of nested courses, the numbers should be for the whole course. 

As long as the requirements of Standard 7.3.2 are met in achieving Section 7.2, we will not require further reiteration in relation to 7.3.2. For Paragraph 7.3.3a, we will require a description and, possibly, a demonstration of the capability of the provider’s information system to meet the requirements of this Standard. Achievement of Paragraph 7.3.3b will require identification of the policies, processes and practices in sufficient detail for us to be satisfied that this Standard is met and that predictable risks are being mitigated as far as is reasonably possible for the nature and scale of the provider’s operations - including the onus on the provider to issue qualifications legitimately (as required by Paragraph 6.2.1h). In relation to Standard 7.3.3d, we will require a description of the systems, processes and reporting that support achievement of this Standard (and support the corporate accountability of the governing body in this respect [Standard 6.1.1]). This may be achieved by reference to mechanisms already described in relation to other Standards (e.g. Institutional Quality Assurance or Governance and Accountability) and, if so, reiteration of the detail for the purpose of demonstrating compliance with this Standard will not be required.

Once we are satisfied that a provider has demonstrated that its systems meet, and are likely to continue to meet, Standard 7.3.3 (a-c), we may require only limited evidence of continuing compliance with these Standards. However, will always have an interest in reviewing the management of complaints and misconduct (Paragraph 7.3.3c), irrespective of the capability of a provider’s information management systems. 

Reference points

  • Australian Government, Australian Consumer Laws (Schedule 2 of the Competition and Consumer Act 2010) and the Trade Practices Act 1974
  • Australian Government, National Code of Practice for Registration Authorities and Providers of Education and Training to Overseas Students 2018
  • Australian Government, Privacy Act (1988) and the Australian Privacy Principles
  • Australian Government (July 2009), Using Education Agents
  • British Council, Statement of Principles for the Ethical Recruitment of International Students by Education Agents and Consultants (The London Statement) (2012) released by the British Council
  • International Education Association of Australia, Education Agent Code of Ethics (2016)
  • Web Content Accessibility Guidelines Working Group (WCAG WG), Web Content Accessibility Guidelines Version 2.0

Relevant guidance notes

The following guidance notes can be accessed at our Guidance notes page, or from the links below:

Last updated: