(1) This Policy sets out Macquarie University’s approach to the appointment, management, and termination of international education agents (Agents). (2) The objective of the Policy is to ensure the University complies with the following legislation when appointing, managing, and reviewing suitable Agents to represent the University locally and internationally: (3) This Policy applies to all University staff, contractors, and Agents who recruit international students on the University’s behalf. (4) Global and Domestic Student Recruitment is responsible for the appointment, management, and termination of Agents. The responsibilities include: (5) The role of an Agent is to provide prospective students with accurate and comprehensive information about the University and its courses, and submit prospective students' applications to the University with all required information and genuine documentation. Once a student has received a letter of offer from the University, Agents who are also registered migration agents are expected to assist students with visa preparation and lodgement, as well as pre-departure and travel formalities. (6) The University will ensure that: (7) Agents are generally referred by the University’s Regional Directors for consideration by the University for appointment. Prospective Agents may be invited to complete the agent application form and submit all required documents for consideration by the University. (8) Before an Agent is appointed, Global and Domestic Student Recruitment will conduct and document due diligence and assess the prospective Agent’s suitability to represent the University in accordance with the International Education Agent Management Procedure against the following factors: (9) In relation to clause 8(d), foreign corporations that operate on a commercial basis are exempt from the notification requirements of the Australia’s Foreign Relations (State and Territory Arrangements) Act 2020. This includes international education agents when they are commercial entities operating on a commercial basis. If a written arrangement is contemplated with an Agent that is not a commercial entity operating commercially, compliance advice will be sought from the National Security and Defence Coordinator (Research Support Services) via foreign.relations@mq.edu.au prior to the execution of any written arrangements with this entity. (10) The University will not enter into an Agent Agreement with any agent that it knows or reasonably suspects to be: (11) Agents who are assessed as meeting the University’s expectations for a quality Agent and the Australian International Education And Training Agent Code of Ethics, will be appointed with a written Agent Agreement that is in a form approved by the Office of General Counsel to represent the University and promote courses with the intention of recruiting quality students who meet admissions, visa and Genuine Temporary Entrant requirements, on a non-exclusive basis. (12) Global and Domestic Student Recruitment will publish an up-to-date list of appointed Agents on the Find a Representative webpage, maintain records of Agent Agreements and due diligence undertaken, and enter and maintain each Agent's details in PRISMS. If requested by the Agent, the University will provide a certificate confirming the Agent Agreement. (13) The University will maintain regular contact with Agents via telephone, written communication, virtual meetings, and office visits to provide training, up-to-date and accurate information on courses, and marketing materials to enable Agents to conduct their business, including advice on: (14) Global and Domestic Student Recruitment will provide training to Agents during visits and through online forums as required. Agents will be encouraged to visit the University to undertake training sessions and familiarise themselves with the University and its facilities. (15) Agents will be expected to co-operate with the University in undertaking regular training on relevant topics and provide the University with evidence of any external training undertaken. As a minimum requirement, Agents must have appropriate knowledge and understanding of the Australian International Education And Training Agent Code of Ethics. (16) The University will endeavour to provide information and training in an accurate and timely manner. However, Agents are expected to be proactive in undertaking their own training and familiarising themselves with changes to courses, policies, admissions, marketing materials, application processes, visa rules, and international education regulations and legislation. (17) Global and Domestic Student Recruitment will monitor the performance and activities of all Agents recruiting students into the University's courses, on an ongoing basis, to ensure that the University is only using reputable and productive Agents. (18) The University will carry out a formal performance review of each Agent in accordance with the International Education Agent Management Procedure at least annually. (19) The University may also conduct an audit of Agents' compliance with the Agent Agreement and this Policy at any time. (20) Ongoing monitoring and formal performance reviews will be undertaken in accordance with the terms of the Agent Agreement and this Policy, and may include but not be limited to: (21) The University will maintain, where practical, confidential guidelines on the minimum required benchmarks Agents must achieve in the relevant performance indicators in clause 20 in order for their performance to be deemed satisfactory. (22) Information and data for the review and monitoring of Agent performance will be collected through qualitative and quantitative mechanisms. This includes, but is not limited to, internal University data, PRISMS data, student surveys and questionnaires, reviews of publicly- and non-publicly available materials and resources, meetings and discussions with Agents and their staff, observations of events and interactions with prospective students, and feedback from individuals. This also includes feedback from relevant stakeholders, such as Admissions and Scholarships, Shared Services, or Faculties. (23) When monitoring processes indicate a deficiency or the University becomes aware, or has reason to believe, that the Agent or an employee or subcontractor of that Agent has not complied with the agent’s responsibilities under the Agent Agreement or when it is identified that the Agent has been negligent, careless or incompetent or engaged in false, misleading or unethical advertising or recruitment practices, the University will investigate into the matter in accordance with the International Education Agent Management Procedure and take immediate corrective action. This may include: (24) The monitoring and review of agents will be used to assess the status of the relationship and inform renewals and terminations. (25) Following the annual review of each Agent, or identification of a deficiency or non-compliance through ongoing monitoring, Global and Domestic Student Recruitment will provide a report summarising the performance of each Agent and recommended actions to the Chief Student Recruitment Officer (Global and Domestic) who will approve one of the following actions: (26) Global and Domestic Student Recruitment will communicate with the Agent as part of monitoring and review processes. Should the University propose to take adverse corrective action, or not renew or terminate the Agent Agreement, the Agent will be provided with an opportunity to respond on the proposed action. (27) The University may invite an Agent to renew or extend their relationship with the University in accordance with the terms in the Agent Agreement. (28) The University may terminate an Agent Agreement with any Agents in accordance with the provisions of clauses 4g, 23, and 26 of this Policy and the International Education Agent Management Procedure. (29) To ensure compliance with the National Code of Practice for Providers of Education and Training to Overseas Students 2018, the University will keep appropriate records of all Agents engaged by the University to formally represent it in the recruitment of international students, including: (30) Nil. (31) The following definitions apply for the purpose of this Policy:International Education Agent Policy
Section 1 - Purpose
Scope
Section 2 - Policy
Responsibility
Top of PageSection 3 - Procedures
Appointment of Agents
Agent Training and Information
Monitoring and Review
Renewal, extension, and termination
Records and Compliance
Top of PageSection 4 - Guidelines
Section 5 - Definitions
View Document
This is the current version of this document. To view historic versions, click the link in the document's navigation bar.