Marketing and Recruitment is the first phase of the learner’s journey. It impacts their decision about what units, courses and RTO is the right fit for them. Learners need information that is precise, easy to understand, and accessible to aide them in making informed choices about their training.
But... according to ASQA, complaints about RTOs’ student information, enrolment and marketing are consistently high. This seems to indicate that RTOs must enact a diligent process to analyse all marketing, advertising and recruitment materials and methods.
Here, we discuss and summarise Clause 4.1: Provide accurate and accessible information to prospective and current students, and what RTOs can do to stay compliant.
Provide accurate information about your RTO’s services and the training products on your scope of registration
The information provided by RTOs must be clear and accurate and enable learners to make informed choices. Remember, RTOs are entirely responsible for all advertising, marketing and recruitment done on their behalf, no matter the means of distribution.
RTOs must not make misleading claims to prospective learners by promising that they will receive a qualification simply by enrolling in a course, or that employment is guaranteed. Additionally, courses are not to be guaranteed to be completed in a set amount of time, as this can vary widely depending on the individual needs of the learners.
RTOs are subject to all relevant consumer protection laws in all jurisdictions of operation and must honour all promises made in marketing materials.
Include your RTO code
Your RTO code must be included on all marketing and advertising materials. This includes marketing and advertising for training products, courses and qualifications.
Include your RTO Code:
- In your website header or footer. That way, it is visible on every web page.
- In your social media profile name, that way it automatically appears on every post.
Use the Nationally Recognised Training (NRT) logo, but ONLY when applicable!
All marketing and advertising materials for nationally recognised training must include the NRT logo. All nationally recognised training is listed at training.gov.au. The logo must only be used in accordance with the conditions in Schedule 4 of the Standards.
RTOs must separate marketing and information about training that is and is not nationally recognised, and make the distinction clear. This is to make it easy for learners to distinguish between them.
Include the title and code of any training product as it appears on the national register
All advertising and marketing material must include the code and full title of the training product (as it appears on the national register). This applies to qualifications, skill sets, accredited courses and individual units. This eliminates confusion and allows learners to verify information about training products.
Courses must be in this format: (Course code) (Course name) and contain a roman numeral instead of a number (if required) as published on training.gov.au.
BSB42415 Certificate IV in Marketing and Communication
Do not make guarantees about training or employment
In essence, don’t make promises you can’t keep! This includes stating things like:
- "Learners will be successful in completing training"
- "A learner will be employed upon completion of training." (Unless prior arrangements have been made with employers)
In addition to these statements it is advised not to state that a training product can be completed in a manner that does not meet the requirements of clause 1.1 and 1.2
ASQA also states that when RTOs are advertising or marketing to potential learners they must:
- Engage a third party individual or organisation in their marketing material only if their consent has been given
- Clarify where a third party is recruiting on their behalf
- Differentiate where training and assessment is being delivered on behalf of another RTO or third party
- Differentiate between training and assessment leading to AQF certification documentation from other training and assessment they deliver
- Advertise or market a non-current training product while it remains on their scope of registration
- Advertise or market a training product they deliver will enable learners to obtain a licensed or regulated outcome when confirmed by the industry regulator
- Include details about VET FEE-HELP, government-funded subsidy or other financial support associated with their provision of training and assessment
Third Party Involvement
If your RTO has entered into a third party agreement, it is important to keep written documentation setting out the rules and expectations for the advertising and marketing materials. For example, the third party is not to advertise any courses under its own name, unless they are an RTO with the applicable courses on its own scope.
While not a compliance requirement, it is good practice to retain copies of all advertising and marketing materials created by third parties. This makes it easier to monitor as well as provides evidence in the instance of an audit or an investigation of a complaint.
Providing Evidence of Compliant Practice
Creating and implementing a comprehensive review practice for all of your advertising, marketing and recruitment materials, as well as keeping a detailed record of all actions taken to maintain the accuracy of the materials is a good starting point. Records should clearly state:
- That materials are reviewed whenever training and assessment strategies change;
- There is a designated staff member responsible for reviewing information to ensure accuracy and currency before publication; and
- Information is collected from learners that states whether they received the services as advertised, and that actions have been taken in response to this feedback.
- If a third party (person or organisation) is mentioned in your advertising or marketing materials you must keep evidence that you received their permission prior to publishing it. This evidence can be in the form of a letter, email or signed release form.
- The same applies for learners who may appear in any social media posts (if they can be identified). Including a release clause in the enrolment form that gives your RTO permission to use photos in public can be used as evidence of permission, as long as you can demonstrate that they actually agreed to the release and that they had the option to “opt out”.
It’s important to keep in mind that ASQA will look for evidence that your advertising, marketing and recruitment practices align with your RTO’s advertising, marketing and recruitment materials, regardless of who publishes them, or where. This could include ASQA conducting interviews or surveys with learners or third parties to discuss their experiences with your marketing.
All evidence kept and presented must demonstrate that all requirements of Clause 4.1 have been fully complied with.
To read Clause 4.1 - Provide accurate and accessible information to prospective and current students in full, click here.
For more insightful information on the Standards for Registered Training Organisations (RTOs) 2015, read about Volume of Learning, the Principles of Assessment, Student Support and Progression, and the Rules of Evidence.