Request

Sales Manager, BD team or Management

Email is sent to Branding team member, BD team & Compliance requesting creation of flyer/marketing material

Creation

Branding team member or BD team member

Log in to Canva to create flyer/marketing material

Check

Compliance & Curriculum

Once flyer/marketing material is created, email Compliance so they can review. This step cannot be missed.

Approval

Compliance

Compliance will email necessary parties that the flyer/marketing material has been reviewed. Compliance will upload the final Copy to hubspot so staff can provide to clients and prospective students

Records Keeping

Branding team member or BD team member

Release

Branding team member or BD team member

Marketing Audit

Compliance and Management

Principle One - No Third-Party Marketing

Only Strategix, as the approved provider to deliver training for a funded program by the DESBT, is permitted to market or advertise that program. A third party is any entity, other than Strategix. A third party operates as a separate entity, either with or without a contract or agreement.

Marketing for any program (C3G, UC, VETiS Funding, HLS, etc.) can only be marketed by Strategix.

Principle Two - Clearly Identify the Program

All marketing must include the Skills Assure identifier (word mark and positioning statement) in line with the usage guidelines.

All marketing must include the correct and full name of the funding program if it is used in the advertising.

It is not acceptable to use abbreviations. For example, ‘Certificate 3 Guarantee program’ or ‘Certificate 3 Guarantee’ and not C3G or Certificate III Guarantee

Principle three - Queensland Coat of Arms

Do not use the Queensland Coat of Arms or other Queensland Government intellectual property, with the exception of public vocational education and training (VET) providers with the required Queensland Government authorisation to do so.

Principle Four - Advertise Appropriate Qualification Levels

In most cases, a SAS is only permitted to market or advertise the vocational qualification level primarily targeted by the funding program (for example, Certificate 3 Guarantee targets Certificate III level vocational qualifications). The marketing or advertising of lower-level vocational qualifications is only permissible when the qualification is either:

• A pre-apprenticeship qualification providing basic trade skills to facilitate recruitment into a related apprenticeship

• Delivered as part of a VET in Schools (VETiS) program.

Advertise:

• School-based traineeship

• VETiS Program (funded)

• Certificate 3 Guarantee

• User Choice

• Higher Level Skills

Do not advertise:

• Foundation Skills units

Principle Five — Responsible Marketing Practice

Do not market or advertise itself to the marketplace for a program prior to the start date approved by the department

Don't advertise funding or a program before being approved

Do not market or advertise a qualification or course under a program prior to the start date approved by the department

Only advertise qualifications as per the agreement and only after it is approved.

Do not market or advertise qualifications that are not eligible for Queensland Government funding under the program, or suggest they are part of a Queensland government-funded program

Strategix must not market a training subsidy as an approved program, this includes:

• Boost / Back to Work

• SQW

Do not market, advertise or offer any gift or other benefit to a student, prospective student, employer or any other person which, in the department’s reasonable opinion, is considered to be an inducement or likely to influence the student, prospective student, employer or any other person to enrol with the SAS

Getting your Forklift licence with the qualification is considered an inducement, listing the units is acceptable practice in place of mentioning getting a licence.

Do not indicate the training is free or fee-free when a co-contribution fee is mandated under the program policy for the student cohort

Do not market or advertise program details which are inaccurate or no longer current

Do not make references to government funding that could be misleading.

Information disclosure requirements

The following information must be supplied to consumers prior to enrolment - The SAS must provide specific information about the program, qualification or course and co-contribution fee charges as prescribed in the relevant program policy. This includes the requirement to refer prospective students to the department’s student fact sheets developed for programs, so they have access to independent advice and a point of contact within the department if needed. These factsheets can be accessed at http://www.desbt.qld.gov.au/training/providers/funded

• Fees should include the $ per unit on marketing material along with the full cost

• Units are not required to be listed on Flyers unless advertising something along the lines of “Getting your Forklift licence” as this is classified as an inducement.

The following information must be supplied to consumers prior to enrolment - The SAS must disclose and publish in a prominent location on its RTO website the concessional and non-concessional co-contribution fees it will charge for each qualification it is approved to deliver under a program, and include with the fee information all pertinent information about the offering (see appendix 1 of the Skills Assure Supplier Policy 2021-23). The fee must be labelled as the ‘co-contribution fee’ on the RTO website so it is easily identifiable. The co-contribution fee must represent the total cost to the student to enrol in the offering, undertake training and be awarded the qualification.

• The website must have the concessional and non-concessional co-contribution fees clearly visible

The following information must be supplied to consumers prior to enrolment - The SAS must provide a copy of, or access to, its complete refund policy terms and conditions.

The following information must be supplied to consumers prior to enrolment - The SAS must disclose if training and/or assessment is being delivered on its behalf by a third party.

The Provider can only market, publicise or otherwise communicate in connection to Smart and Skilled in accordance with the contract.

Smart and Skilled Operating Guidelines 1/1/2017 – 31/12/2017: 1.1

Smart and Skilled Contract Terms and Conditions 2017: 7 (m) (i)

The Provider must develop and implement strategies for the effective marketing of Smart and Skilled including all of their Approved Qualifications. These strategies must not rely solely on activities undertaken by the Department and via the Smart and Skilled website for promotion.

Smart and Skilled Operating Guidelines 1/1/2017 – 31/12/2017: 1.1

Smart and Skilled Contract Terms and Conditions 2017: 7 (m) (i)

Record keeping obligation: The provider must keep a copy of these strategies and all marketing and promotion materials, and demonstrate the implementation of the strategies

Smart and Skilled Operating Guidelines 1/1/2017 – 31/12/2017: 1.1

Use reasonable endeavours to carry out the marketing and promotion of all Approved Qualifications in accordance with the Operating Guidelines

Smart and Skilled Contract Terms and Conditions 2017: 7 (q) (i)

S.49 Provider must not use broker or agent

(1) An approved course provider contravenes this subsection if the provider enters into an arrangement (whether written or not) that provides for another person to do one or more of the following in relation to an approved course:

(a) enrol students, or accept applications for enrolment, in the course;

(c)* provide information or advice in relation to VET student loans (however described) for the course;

(d) assist students to complete or submit applications for a VET student loan for the course;

(e) assist, or provide support for, students who could be eligible for a VET student loan for the course to complete any assessments required to show that students are academically suited to undertake the course.

(2) Subsection (1) does not apply in relation to an arrangement that is:

(a) a contract of employment; or

(b) specified in the rules.

Note: Employees of approved course providers will be covered by other requirements that apply to approved course providers.

*Sect 49 in VET Student Loans Act 2016 is missing (b) and goes straight from (a) to (c).

An approved course provider must not enter into an arrangement with another person for that person to do any of the following in relation to an approved course [Act s 49]:

• Enrol students, or accept an application to enrol students, in the course

• Provide information or advice in relation to vet student loans for the course

• Assist students to complete or submit applications for a VET Student Loan for the course

• Assist, or provide support for, students who could be eligible for a VET Student Loan to complete any assessments required to show that students are academically suited to undertake the course.

This prohibition against arrangements with brokers or agents applies whether the arrangement is in writing or not.

This prohibition does not apply in relation to an arrangement that is a contract of employment [Act s 49] or with a member of the Australasian Conference of Tertiary Admission Centres [Rules s 96].

S.60 - Misrepresenting VET student loans

An approved course provider contravenes this section if the provider represents, whether by publishing or otherwise, that a VET student loan:

(a) is not a loan; or

(b) does not have to be repaid.

S.61 - Offering certain inducements

(1)  An approved course provider contravenes this subsection if:

   (a)  the provider:

         (i)  offers or provides a benefit; or

         (ii)  causes a benefit to be offered or provided; and

   (b)  the benefit would be reasonably likely to induce a person to apply for a VET student loan for a course.

(2)  Subsection (1) does not apply in relation to a benefit specified in the rules.

S.62 - Engaging in cold‑calling

(1)  An approved course provider contravenes this subsection if:

   (a)  the provider cold‑calls another person to market, advertise or promote a course; and

   (b)  when doing so, or as a result of doing so, the provider mentions the possible availability of a VET student loan (however described) for students undertaking the course.

(2)  Cold‑calling includes making unsolicited contact with a student:

   (a)  in person; or

   (b)  by telephone, email or other form of electronic communication.

Note: Student includes a prospective student: see section 6.

(3)  The rules may set out conduct that is taken to be cold‑calling.

An approved course provider must not when cold-calling another person to market, advertise or promote a course, mentions the possible availability of VET student loans for students undertaking the course [Act s 62(1)].

Cold-calling includes making unsolicited contact with a student (or prospective student) in person, or by telephone, email or other form of electronic communication [Act s 62(2)].

S.63  Use of third party contact lists

(1)  An approved course provider contravenes this subsection if:

(a)  the provider receives a student’s contact details from another person; and

(b)  the provider contacts the student to market, advertise or promote a course, or enrol the student in a course; and

(c)  when doing so, or as a result of doing so, the provider mentions the possible availability of a VET student loan (however described) for students undertaking the course.

(2)  Subsection (1) does not apply in circumstances specified in the rules.

An approved course provider must not use contact details received from another person to contact a student (or prospective student) to market, advertise or promote a course or enrol the student in a course, and in doing so mention the possible availability of a VET student loan [Act s 63].

This does not apply where the student (or prospective student) has given express consent to be contacted by the particular approved course provider [Rules s 138(1)]. A student is taken to have provided express consent if all the following are met [Rules s 138(2)]:

• Information in the request was presented clearly, and set out the specific purpose for which the student’s personal information would be used if consent were given, and

• The request was prominent, and

• The student was able to give consent in a separate optional tick box from other consents, and

• The request was not a required field to be answered in order for a person to submit other information, and

• The request did not include a default tick for consent, and

• The request named the provider, and

• The request detailed any referral fee or other fee that would be paid to the person who made the request and any other benefit that would be provided to the person who made the request. 

A student is also taken to have provided express consent if the student initiates contact with a third party for the purposes of giving information to a provider, or getting information from a provider, relating to education and training [Rules s 138(3)]. The purpose of this provision is to allow students who are deliberately seeking information on courses from a particular provider to agree to being contacted.

S.64  Other marketing requirements

(1)  The rules may set out requirements in relation to marketing of courses in circumstances where tuition fees for the courses could be covered by VET student loans.

(2)  An approved course provider contravenes this subsection if the provider fails to comply with rules made for the purposes of subsection (1).

Division 4 Retaining information and documents   

S.105  Information and documents to be retained for 5 years

The following information and documents must be retained by an approved course provider for a period of 5 years:

(j)  marketing and promotional material relating to approved courses.

Marketing and promotional material relating to approved courses to be retained for 5 years

Division 8, Subdivision A—Offering certain inducements

This Subdivision is made for the purposes of subsection 61(2) of the Act.

S.136 - Benefits that may be offered

The following benefits are specified:

(a) the content and quality of the course;

(b) the amount of the tuition fees for the course;

(c) the availability of a VET student loan for the course;

(d) marketing merchandise up to the total value of $30 per person.

Division 8, Subdivision B—Use of third party contact lists

This Subdivision is made for the purposes of subsection 63(2) of the Act.

S.138  Use of third party contact lists

(1)  Subsection 63(1) of the Act does not apply if the student has given express consent to being contacted by the provider.

(2)  The student is taken to have provided express consent if:

(a)  information in the request was presented clearly, and set out the specific purpose for which the student’s personal information would be used if consent were given; and

(b)  the request was prominent; and

(c)  the student was able to give consent in a separate optional tick box from other consents; and

(d)  the request was not a required field to be answered in order for a person to submit other information; and

(e)  the request did not include a default tick for consent; and

(f)  the request named the provider; and

(g)  the request detailed any referral fee or other fee that would be paid to the person who made the request and any other benefit that would be provided to the person who made the request.

(3)  The student is taken to have provided express consent if the student initiates contact with a third party for the purpose of:

(a)  giving information relating to education and training to the provider; or

(b)  getting information relating to education and training from the provider.

Division 8, Subdivision C—Other marketing requirements

This Subdivision is made for the purposes of subsection 64(1) of the Act.

S.140  Information that must be provided

An approved course provider must ensure that any marketing of its approved courses prominently mentions:

(a)  the provider’s name and any registered business name or other business name that the provider uses; and

(b)  the provider’s registration code; and

(c)  the maximum tuition fees for the course.

Referring to (c) The approved course provider must ensure that any marketing of an approved course it is offering or provides prominently mentions the maximum tuition fees for the course

The estimate must not exceed the maximum tuition fees for the course mentioned in marketing of the course

S.141  Information about fees

An approved course must not be marketed unless the tuition fees for the course:

(a)  have been published on the provider’s website in a way that is readily accessible by the public; and

(b)  have been given to the Secretary in accordance with section 115.

An approved course must not be marketed unless the tuition fees for the course (including tuition fees for units/parts of courses) have been published on the provider’s website in way that is readily accessible by the public. In addition, maximum course fees must be published on the My Skills website at http://www.myskills.gov.au ) [Rules s 141]. See ‘Giving the Secretary a list of fees’)

S.142  Marketing that mentions VET student loans

An approved course provider must ensure that any marketing in which the provider mentions the possible availability of a VET student loan (however described) for students undertaking a course:

(a)  prominently mentions:

(i)  the provider’s name and any registered business name or other business name that the provider uses; and

(ii)  the provider’s registration code; and

(iii)  that VET student loans will not be approved for students who do not meet eligibility requirements; and

(iv)  that a VET student loan gives rise to a VETSL debt that continues to be a debt due to the Commonwealth until it is repaid; and

(b)  presents the information covered by paragraph (a) in a font size that is approximately the same as any other marketing information that accompanies it; and

(c)  if the marketing is online—presents the information covered by paragraph (a) on the same webpage as the other marketing of the course; and

(d)  if the marketing uses the VET student loans logo—presents the logo in accordance with the style guide for the use of the logo published on the Department’s website.

An approved course provider must ensure that any marketing in which the provider mentions the possible availability of a VET student loan (however described) for students undertaking a course [Rules s 142]:

• Prominently mentions:

  • That VET student loans will not be approved for students who do not meet eligibility requirements and 

  • That a VET student loan gives rise to a HELP debt that continues to be a debt due to the Commonwealth until it is repaid

• Presents the information above in a font size that is approximately the same as any other marketing information that accompanies it and

• If the marketing is online, presents the information covered above on the same webpage as the other marketing of the course and

• If the marketing uses the VET student loans logo, presents the logo in accordance with the style guide for the use of the logo published on the department’s website (see Section 4.10.9).

An approved course provider must ensure the approved VET Student Loans logo is used in its complete and original form as provided by the Department. It cannot be rearranged or split into individual elements.

An approved course provider may use or co-brand the VET Student Loans logo with their own organisation’s logo and visual identity. The approved placement for the VET Student Loans logo is to the right of an approved course provider’s own logo.

The VET Student Loans Logo may be published on an approved course VET Student Loans provider’s website on the page outlining information about VET Student Loans. It may not be used on any other materials or printed publications such as office stationery, business cards, letterheads, signs and pamphlets. The VET Student Loans Logo may not be used by third parties.

The VET Student Loans Style Guide is available from https://www.dewr.gov.au/vet-student-loans/resources/vet-student-loans-style-guide.

S.143  Marketing through social media

An approved course provider must ensure that any marketing of the provider or its courses through social media does not mention the possible availability of a VET student loan (however described) for students undertaking a course.

An approved course provider must ensure that any marketing of the provider or its courses through social media does not mention the possible availability of a VET student loan for students undertaking a course [Rules s 143].

Social media includes, for example, Facebook, Instagram and Twitter.

1.1 The registered provider must ensure that the marketing and promotion of its courses and education services in connection with the recruitment of overseas students or intending overseas students, including through an education agent (in accordance with Standard 4), is not false or misleading, and is consistent with Australian Consumer Law

National Code of Practice for Providers of Education and Training to Overseas Students 2018

1.2 The registered provider must, in seeking to enter into written agreements with overseas students or intending overseas students, not provide any false or misleading information on:

1.2.1 its association with any other persons or organisations the registered provider has arrangements with for the delivery of the course in which the student intends to enrol or may apply to enrol

1.2.2 any work-based training a student is required to undertake as part of the course

1.2.3 prerequisites—including English language proficiency—for entry to the course

1.2.4 any other information relevant to the registered provider, its courses or outcomes associated with those courses.

1.3 The registered provider must not:

1.3.1 claim to commit to secure for, or on the student or intending student’s behalf, a migration outcome from undertaking any course offered by the registered provider

1.3.2 guarantee a successful education assessment outcome for the student or intending student.

1.4 The registered provider must include its CRICOS registered name and registration number in any written or online material that it disseminates or makes publicly available for the purposes of:

1.4.1 providing or offering to provide a course to an overseas student

1.4.2 inviting a student to undertake or apply for a course, or

1.4.3 indicating it is able or willing to provide a course to overseas students.

1.5 The registered provider must not actively recruit a student where this conflicts with its obligations under Standard 7 (Overseas student transfers).

Standard 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;

Refer to https://training.gov.au/Organisation/Details/31418

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 Logo only in accordance with the conditions of use specified in Schedule 4;

Schedule 4:

Advertisements and promotional information in any medium (print, television, radio, banners, internet, etc.):

• RTOs registered by any VET Regulator may use the NRT Logo to promote nationally recognised training provided that training is within the RTO’s scope of registration.

• Impressions must not be created that may lead an observer to conclude the NRT Logo applies to all training provided by the RTO, if this is not the case. The NRT Logo cannot be used by an RTO where the training is accredited, but is outside the scope of registration of the RTO. Where training is being promoted and does not meet the requirements stipulated in the VET Quality Framework or is outside the RTO’s scope of registration, it must be made clear the NRT Logo is not associated with that training.

• Use of the NRT Logo is only permitted where there is a direct relationship to an AQF qualification and/or unit of competency as specified within training packages or VET accredited courses.

Student information (brochures, course handbooks, prospectuses, etc.):

• When an RTO is promoting the training it offers and wishes to use the NRT Logo, its promotional material such as brochures, handbooks and prospectuses must clearly distinguish between nationally recognised training within the scope of registration and that which is not nationally recognised.

Corporate stationery, business cards, buildings, training resources and marketing products:

• The NRT Logo must not be used on products such as corporate stationery, business cards, building signage, mouse pads, pens, satchels, packaging around products nor learning resources supporting training.

Currently not using NRT Logo on any marketing material.

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

Definition from Standards: “Third party means any party that provides services on behalf of the RTO but does not include a contract of employment between an RTO and its employee.”

In short; anyone who is not employed by Strategix who is marketing services is defined as a third party.

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;

Any third-party training or assessment needs to be included in the marketing material

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

Non-accredited courses must be identified as such on any marketing material and not reflect anything relating to accredited training. i.e. don't use course codes or names from training.gov.au on non-accredited training.

h)    includes the code and title of any training product, as published on the National Register, referred to in that information*;

Refer to ASQA Fact Sheet - Marketing and Adverstising for further guidelines

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

Never market qualifications not on scope or past their transition period

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 FEE-HELP, government-funded subsidy or other financial support arrangements associated with the RTO’s provision of training and assessment; and

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.

Clause 1.1 and 1.2

1.1. The RTO’s training and assessment strategies and practices, including the amount of training they provide, are consistent with the requirements of training packages and VET accredited courses and enable each learner to meet the requirements for each unit of competency or module in which they are enrolled.

1.2. For the purposes of Clause 1.1, the RTO determines the amount of training they provide to each learner with regard to:

a) the existing skills, knowledge and the experience of the learner;

b) the mode of delivery; and

c) where a full qualification is not being delivered, the number of units and/or modules being delivered as a proportion of the full qualification.

Referring to point ii), Strategix must only advertise as per the TAS. If no TAS, do not market.

• List here

See Funding

• SNR 4.1, 5.1-5.4

• CRICOS 1

List the Contract, audit evidence requirements, standards etc. and the applicable section or clause from each document

Name here

Details / Decisions: