Marketing Governance Procedure

Policy code: CG2043
Policy owner: Director, Marketing and Growth
Approval authority: Chief Learner Experience Officer
Approval date: 01 November 2024
Next review date: 23 February 2027

Purpose

The purpose of this document is to ensure that the appropriate measures and processes are in place so that all marketing and promotional activities undertaken by the University is done in accordance with internal and external compliance requirements.

The principal objectives of this Procedure are:

  • Only transparent, accurate and relevant information is provided to all prospective and current students; and
  • Prospective students are able to make informed decisions regarding studying at the University based on transparent, accurate and reliable information.

Scope

This procedure applies to:

  • All Universitystaff who produce marketing materials for the purpose of providing information to prospective and current students regarding the University and itsacademic courses; and
  • All forms of marketing material, regardless of the channel or method used, such as:
    • Advertising – newspaper, radio, television
    • Brochures or other hard copy publications
    • Websites – including Federation University’s own website and any other sites where the University is referred to
    • Social media – Facebook, Twitter, LinkedIn, TikTok, YouTube, Instagram
    • Online Directories
    • Online Advertisements
    • Any marketing by third parties that relates to the University or to any training and assessment that is provided.

Legislative Context

  • Federation University Australia Act 2010
  • The Tertiary Education Quality and StandardsAgency Act 2011 (TEQSA Act)
  • The Higher Education Standards Framework (Threshold Standards) 2021
  • National Vocational Education and Training Regulator Act 2011
  • Standards for Registered Training Organisations (RTOs) 2014
  • HESG VET Funding Contract (Dual Sector)
  • Education and Training Reform Act 2006
  • Education and Training Reform Regulations 2007 (Regulations 2007) Schedule 7
  • VRQA Guidelines for VET Providers 2016
  • Education Services for Overseas Students Act 2000
  • Education Services for Overseas Regulations 2001
  • The National Code of Practice for Registration Authorities and Providers of Education and Training to Overseas Students 2018

Definitions

Term Definition
AB – Academic Board

Academic Board:

The principal academic body of the University whose purpose is twofold: firstly, to provide academic oversight of prescribed academic courses and unit of study of higher education and VET in the University; and secondly to provide advice to Council on the conduct and content of those courses and units.

Specific responsibilities in the context of this Quality Framework are

  • creating awareness of and providing leadership in relation to contemporary educational issues;
  • establishing a quality assurance framework for learning, teaching and research;
  • recommending and reporting to the Vice-Chancellor on matters relating to learning, teaching and research;
  • regularly reviewing and evaluating the performance of the Academic Board and reporting outcomes to Council.

Academic Board is supported in these duties by its Standing Committees.  Please refer to Standing committees for further detail on these committees.

AQF Australian Qualifications Framework. A nationally consistent set of qualifications for all post-compulsory education and training in Australia.
ASQA The Australian Skills Quality Authority. The national regulator for Australia's vocational education and training sector. ASQA regulates qualifications and training providers to ensure nationally approved quality standards are met.
Course Finder

http://study.federation.edu.au

The Federation University Australia online course catalogue.

ESOS Education Services for Overseas Students Act 2000
HECC Higher Education Curriculum Committee
HESG The Higher Education and Skills Group manages the Victorian Government funded training market, public provider governance and accountability, and the apprenticeship system.
International Student A person holding an Australian student visa and is defined as an 'Overseas Student' in the ESOS Act.
National Code 2018 The National Code of Practice for Registration Authorities and Providers of Education and Training to Overseas Students 2018.
NVR Standards

Standards for National VET Regulator Registered Training Organisations. The objectives of the NVR Standards are to ensure nationally consistent, high-quality training and assessment services within Australia’s VET system.

Continual compliance with the Standards is a condition for all NVR registered training organisations and for applicants seeking registration under the Act.

Regulator Standards The Higher Education Standards Framework (TEQSA) and the Australian Skills Quality Authority ASQA under the National Vocational Education and Training Regulator Act 2011.
Scope The Scope of Registration details the nationally recognised training an RTO is approved to provide. FedUni's Scope can be viewed on the www.training.gov.au website. In this procedure the University’s Scope of Registration will be referred to as "the Scope".
Current Award Courses Registar The Current Award Courses Registar, lists all current sealed awards which can be awarded by the University. The Registar is maintained by the Manager, Registrar Services and includes all qualifications/courses included on the Scope.
TEQSA The Tertiary Education Quality and Standards Agency is Australia’s independent national quality assurance and regulatory agency for higher education.
University Governance and Management Committees

Relevant committees that support the academic, operational and quality governance of the University's Vocational Education and Training programs and Higher Education courses.

These include, but not limited to, the following committees or their replacements: Academic Board, Curriculum Committee, Learning and Teaching Committee and VET Curriculum and Quality Committee.

VCAL Victorian Certificate of Applied Learning
VETCQC VET Curriculum and Quality Committee
VTAC Victorian Tertiary Admissions Centre

Actions

1. VET Programs

  ACTIVITY RESPONSIBILITY STEPS
A. Programs must be on the University’s Scope of Registration prior to any marketing activity being undertaken. Education Manager
  1. Refer to: www.training.gov.au, the UniversityRTO number is 4909, to confirm whether a program is on the University’s Scope of Registration.
  2. Refer to the VET Program Approval and Maintenance Procedure for the processes required to extend and amend the University’s Scope of Registration.
B. The addition or updating of content on Course Finder. Education Manager
  1. As most of the information that populates Course Finder comes from the University’s student management system, it is the responsibility of Progam Managers to ensure that this information is current and accurate.
  2. Course Finder request forms must be completed for these pages to be added / updated.
    The request forms are located at: Course Finder Updates
  3. The Marketing Summary form must be completed to ensure that PMC and Marketing have up-to-date details for the University’s student management system and any advertising that Marketing may undertake.
C. Marketing materials must acknowledge government support of training services and any implications of the provision of funding Marketing Director or delegate
  1. All promotional publications, reports, signage or other prepared materials (including radio and television) must include an acknowledgement in a prominent way that the Training Services are provided to Eligible Individuals with Funds made available by the Victorian and Commonwealth Governments (for example, a statement that ‘this training is delivered with Victorian and Commonwealth Government funding’).
  2. If students are accessing any government funding entitlement that may reduce their ability to access such funding in the future, they must be informed of this prior to enrolment.  A statement should be included in marketing materials to this effect, eg Applicants / students should be aware that enrolling in this qualification may affect any government training entitlements and funding arrangements in relation to the enrolling in any future study. For further information please refer to : Eligibility criteria.
D. Marketing activities must include particular details to meet all external regulatory requirements Marketing Director or delegate
  1. To ensure compliance with all relevant VET regulatory bodies, including ASQA, HESG and the VRQA, all program marketing activities must meet the following requirements:
  • All promotional publication, report, signage or other prepared materials (including website, social media pages, radio and television) must include the University’s Legal Name (Federation University Australia) and CRICOS Provider No. 00103D | RTO Code 4909 | TEQSA PRV12151 (Australian University).
  • All marketing materials must include the National Code and Title of any AQF Qualification, Skill Set or VET course (as published on the National Register / Scope of Registration).
  • There is an estimated duration of the services listed, training hours and commitment required.
  • The nature and requirements of the proposed training is accurately identified.
  • Financial arrangements in respect of the training, including the cost to and any other financial impacts on prospective learners is provided.
  • Any third party training and assessment arrangements must be accurately identified.
  • Expected locations at which the services will be delivered is listed (eg. Gillies Street Campus, SMB Campus).
  • Expected modes of delivery are listed (eg. Online, Flexible, classroom).
  • Any required workplacement arrangements to gain the program are listed.
  • Program pathway information is clear.
  • Materials and resources required, particularly those that must be supplied by the student.
  • Entry requirements applicable for programs must be clearly identified such as, a current working with children check.
  • Possible employment and licencing outcomes from the training program is identified.
E. Marketing activities must meet all principles as detailed by the external regulatory requirements Director Marketing or delegate

The University is responsible for ensuring that:

  1. prospective students are provided with transparent and accurate information;
  2. that the promoting / marketing of a program is always done in an honest, ethical and responsible manner and programs are marketed / promoted with integrity and accuracy;
  3. that when promoting / marketing a program staff must not take advantage of a prospective student’s vulnerabilities to recruit them into a program; this includes age, disabilities or illiteracy;
  4. staff must not engage in false or misleading advertising, promotion or recruitment practices; and
  5. staff must not pay, provide or offer, either directly or indirectly, incentives to undertake government subsidised training, whether to an Eligible Individual or to an entity (such as an employer or social organisation).
F. Prospective students must be provided with details relating to government financial support arrangements Program Manager / Director Marketing or delegate

Prospective and current students must be provided with details regarding VET Student Loans.  This is an Australian Government loan program that helps eligible students enrol in an approved course pay for all or part of their VET tuition fees.

For further details of this scheme refer to: VET Student Loans

G. Review of marketing / promotional materials Education Manager / Director Marketing or delegate Course Finder and any existing brochures / promotional materials must be reviewed and updated annually to ensure the currency and compliance of documentation and electronic information.

2. Higher Education Courses

  Activity Responsibility Steps
A. Courses must be on the University’s Current Award Courses Registar prior to any marketing activity being undertaken. Coordinators Programs, Program Support & Technical Services
  1. Refer to: Current Award Courses Registar, to confirm whether a program is on the University’s Current Award Courses Registar.
  2. Refer to the Approval and Maintenance of Award Programs Higher Education Procedure for the processes required to extend and amend the University’s Current Award Courses Registar.
B. The addition or updating of content on Course Finder. Coordinators Programs, Program Support & Technical Services
  1. As most of the information that populates Course Finder comes from the University’s student management system, it is the responsibility of Coordinators Programs, Program Support & Technical Services to ensure that this information is current and accurate.
  2. Course Finder request forms must be completed for these pages to be added / updated.

The request forms are located at: Course Finder updates.

C.

Marketing activities must include particular details to meet all external regulatory requirements.

Marketing activities includes any activities that provide prospective students with digital or hardcopy, takeaway or printable information.

Marketing Director or delegate
  1. To ensure compliance with all relevant higher education regulatory requirements, as provided by TEQSA, all program marketing activities must meet the following requirements:
  • The nature and requirements of the proposed course is accurately identified, this includes course design and prerequisites.
  • Expected locations at which the course will be offered is listed (eg. Mt Helen Campus, Churchill Campus).
  • There is an estimated duration of the course listed and commitment required.
  • Application details for the program.
  • Arrangements for recognition of prior learning and standing credit transfer.
  • Course and employment pathway information is provided, along with eligibility for registration to practice where applicable.
  • Expected modes of delivery are listed (eg. Online, Flexible, classroom).
  • Financial arrangements in respect of the course, including the cost to and any other financial impacts on prospective learners is provided.
  • Any third party arrangements must be accurately identified.
  • Any required workplacement arrangements to gain the course are listed
  • Materials and resources required, particularly those that must be supplied by the student.  This should also include technical requirements for access to IT systems.

Where a course leads to professional registration or licensing, details of any additional requirements must be provided.

Course accreditation information must be available, demonstrating that the course is currently accredited with the registering body.

The above information can be provided through links to appropriate sections of the University's website, however this information must be easily accessible and current.

D. Marketing activities must meet all principles as detailed by the external regulatory requirements Marketing Director or delegate

The University is responsible for ensuring that:

  1. prospective students are provided with transparent and accurate information;
  2. that the promoting / marketing of a course is always done in an honest, ethical and responsible manner and courses are marketed / promoted with integrity and accuracy; and
  3. staff must not engage in false or misleading advertising, promotion or recruitment practices.
E. Prospective students must be provided with details relating to government financial support arrangements Coordinator, Programs / Marketing Director or delegate

Prospective and current students must be provided with details regarding the Higher Education Loan Program HELP.  The Commonwealth Government administers this scheme which consists of four HELP loan schemes to assist eligible students with the cost of their fees.

For further details of this scheme refer to: Help loans and VET Student Loans

F. Review of marketing / promotional materials Coordinator, Programs / Marketing Director or delegate Course Finder and any existing brochures / promotional materials must be reviewed and updated annually to ensure the currency and compliance of documentation and electronic information.

3. International Marketing

To ensure all marketing materials targeted at international students are produced in accordance with the National Code 2018 (Standard 1) and the ESOS Act (2000) the University has the following procedures in place:

A. Marketing Information and Practices

The ESOS Requirements for Marketing Materials specifically the National Code of Practice for Providers of Education and Training to Overseas student 2018, Part B – Standard 1 – Marketing information and practices and the TEQSA Act will be covered in this section.

Federation University Australia’s CRICOS provider code is 00103D.  It applies to Higher Education and TAFE teaching locations in Australia where Federation University Australia’s courses are offered to international students. The correct configuration to be used is as follows:

  • In short: CRICOS 00103D | RTO 4909 | TEQSA PRV12151 Provider Category: Australian University or
  • In long: CRICOS Provider No. 00103D | RTO Code 4909 | TEQSA Provider ID: PRV12151 Provider Category: Australian University

Requirements for Marketing Materials

All marketing material produced must adhere to National Code of Practice for Providers of Education and training to Overseas Student 2018, Standard 1 – Marketing information and practices.

Please note the following for ESOS requirements for marketing materials:

  • All marketing material must align to the University’s branding guidelines including the use of the University’s logo, brand colouring and templates.
  • CRICOS provider code, RTO Code and TEQSA provider ID should appear in all University written and electronic publications, materials and correspondence which may be viewed by a prospective international student, or the material must indicate is not intended for use by international student. This includes but is not limited to:
    • Every page of the website that is pertinent to international students.
    • Prospectus and pre-application information (if in booklet form).
    • Application Form. (Digital or hardcopy)
    • Business cards of key personnel e.g., marketing staff.
    • Email signature blocks of key personnel e.g., marketing staff.
    • Letterhead / e-mails or footer used in letters making offers to students, promoting courses or for other marketing purposes.
    • Marketing tools, such as banners, PowerPoint template, flyers, etc.
    • Removable section of pull out or tear away sections of promotional material.
    • Pull up banners or flyers. e.g., used at Education exhibitions
    • An advertisement for courses for international students in an Australian or foreign newspaper.
    • Online social media advertising.
    • Student Handbooks, Information Guides and the like.
  • All international marketing material pertaining to the recruitment of international students to Federation University Australia requires approval through the Global Professional School.
  • If CRICOS registration has been applied for and has not been received, then a course must not be promoted or published until Federation University
  • Australia has been advised that CRICOS registration has been approved to relative staff on-campus and at partner teaching locations.
  • The University will only promote full-time study options to international students. When a publication is aimed at both domestic and international students and part-time study options are be listed, a reference to international students being expected to complete their course within the duration specified on their CoE or undertake full-time study while enrolled in a course.

In addition, for all onshore Partner Providers:

  • All promotional materials for the University partner providers will carry the registered business name, CRICOS provider number and TEQSA number of the University and if applicable the provider’s own Provider Code (if CRICOS registered). 
  • Onshore Partner Providers must adhere to National Code of Practice for Providers of Education and training to Overseas Student 2018, Standard 1 – Marketing information and practices and the branding guidelines of the University.
  • All marketing material pertaining to Federation University Australia and its courses, must be approved by the University prior to use.
  • Promotional material will clearly indicate that the course is being delivered by the onshore partner provider institute and must include details about the location and facilities of partner provider institute. If the partner provider has several teaching sites at which the course/s are offered, the partner provider should include information specific to the that campus and its location.

B. International Marketing Material Approval Process

  Steps Responsibility Comments
1. Review Marketing Information and Practices Procedure Partner Provider Located on University policy website
2. Produce marketing material artwork. Partner Provider  
3. For material requiring academic course content approval, Marketing will liaise with relevant Institute/School. Marketing, or approved delegate

Academic course content, such as:

  • unit outline
  • entry requirements
  • RPL
  • unit objectives
  • teaching resources
  • delivery methods
  • learning facilities
  • career opportunities and
  • assessment.
4. Forward marketing material to Global Academic Services in Global Professional School for review. Marketing, or approved delegate  
5.

Marketing materials academic content is checked and approved by Global Academic Services with Global Professional School.

Global Professional School

Academic course content, such as:

  • unit outline
  • entry requirements
  • RPL
  • unit objectives
  • teaching resources
  • delivery methods
  • learning facilities
  • career opportunities and
  • assessment.
6. Quality Assurance Services is advised of approval via email. Global Professional School  
7. Marketing material is reviewed for ESOS Compliance. Marketing, or approved delegate  
8. Where branding approval is required the marketing material will be forwarded to Manager, Brand Marketing. Marketing, or approved delegate  
9. Partner is advised of approval or required changes. Marketing, or approved delegate  

4. Sponsorship Requests to the University

Introduction

Sponsorships are used to maintain and enhance the University’s corporate image and identify its role as a good corporate citizen. Limited funds are made available annually for this purpose.

The University receives many requests for sponsorship, support, prizes and assistance from a wide variety of organisations, schools, community groups and individuals. While we would like to help everybody, we are unable to proceed with requests that do not fit within our sponsorship objectives. In addition, budgetary constraints can limit our involvement with sponsorships.

While we are always open to requests for sponsorship, please bear in mind that we may not always be able to help.

Proposals that are clear, concise and well researched make it easier for the sponsorship team to consider proposals.

Evaluating against assessment criteria

Proposals should ideally address the criteria outlined below while being considerate of the return on investment, without overly committing academic and professional staff.

This includes both monetary contribution and in-kind support. The true value of any in-kind support should be calculated prior to sponsorship approval.

The strategic intention for sponsorships is that they not only include branding opportunities but are multilayered, clearly supporting the University’s strategic plan. The University will evaluate all sponsorship proposals on a case-by-case basis taking into consideration the following criteria:

1. Alignment with the University's values and our transformational community focus.

(This information can be found in the Strategic Plan 2021-2025)

The table below presents the objectives of the University Strategic Plan under the three broad aims. The proposed new partnership needs to align with some of the objectives in the table. In evaluating the proposals received, greater consideration will be given to those addressing areas not already covered by other partnerships.

2. Offers potential research collaboration

The three broad areas of research at Federation are:

  • Health and wellbeing – developing preventive treatment and care
  • Society and the environment – Understanding and managing the world in which we live.
  • Virtual, digital, and computational environments – exploring, analysing, and creating new realities through innovative technologies

A partnership may provide research opportunities through our Federation Schools or research centres. To explore research opportunities, contact the research office (director.research@federation.edu.au) or School Dean’s office.

3. Likely to create one or multiple student placements

The following items should be considered:

  • Are there prospects of gaining studentplacements for one or more Federation School programs?  Can a minimum of placements be stated on a per annum or other basis within the agreement?
  • Which audiences will be touched by this agreement and how will the communication lead to potential new students?
  • What is the cost to reach the potential membership or other audiences on a cost/1,000 and how does this compare with standard advertising costs (to be assessed/provided by the marketing team)?
4. Potential to drive student recruitment for TAFE/ HE/ HDR

Applications will be assessed against opportunities to promote brand, programs and facilities to prospective students. Alternatively that the organisation seeking sponsorship actively recruits students and agrees to deliver enrolments as part of the agreement. The recruitment maybe directed to members/players of the organisation or their business partners. If the agreement includes delivering x enrolments that stay past census this may partially or fully cover the sponsorship.

5. Potential to contribute to commercial outcomes

Applications will be assessed against potential to provide or increase commercial revenue/ to the University.

6. Potential to contribute to high impact community engagement

Applications will be assessed against opportunities to achieve community engagement with the University, Programs and Facilities that aligns with strategic plan imperatives.

7. Demonstrated tangible benefits to the University and the community

Applications will be reviewed to assess what tangible benefits the partnership will deliver.

8. Other considerations

Evaluations of sponsorship proposals will also consider the following:

  • The University’s existing sponsorship commitments
  • Available budget and financial allocation
  • Achieving balance and variety in the types of sponsorship applications we approve

Guidelines to take into consideration

  • While we are always open to all types sponsorship requests, applications that reflect the core activities and purpose of the University i.e. education, research and community engagement may be given higher priority
  • The over-arching principle guiding decision-making in relation to requests for sponsorship must be that of mutual benefit. There must be clear benefits both to the sponsorship seeker and to University as a sponsor
  • Servicing of a sponsorship should not require the significant use of staff time and University resources
  • Requests for renewal cannot be guaranteed and require the applicant to re-submit an application

Sponsorship requests that will not be approved

  • Repeat requests for sponsorship (for example an annual event). The University endeavours to support new ventures and community events
  • Sponsorship that conflicts with, or is too similar to an existing University sponsorship
  • Retrospective sponsorship of any project, event or organisation
  • Specific activities or events run by Schools or Sections within the University – these should be the subject of funding proposals as part of the University’s own internal budgetary process
  • Requests from organisations having no direct association with the University's key regions - Wimmera, Ballarat, Berwick and Gippsland, because they would not generally meet the mutual benefit principle
  • Requests for sponsorship by individuals participating in a group activity, on the grounds that this may discriminate against others within the group
  • Requests not aligned with core educational values and functions of the University
  • Individuals seeking support or raising money
  • Fundraising organisations or aid appeals
  • Sponsorship arrangements with the University that require product endorsements
  • Sponsorship and/or signage that in any way conflicts with the images, reputation or the good name of the University
  • Sponsorship that conflicts with the University policies or principles or with existing sponsorship arrangements
  • Proposals linked to tobacco, alcohol or other products which could prove controversial or divisive

Applying for sponsorship

  1. All Vice Chancellor sponsorship applications must be made via email to marketingrequests@federation.edu.auor through the ServiceNow portal.
  2. Queries can also be directed to marketingrequests@federation.edu.auor through the ServiceNow portal.

Approvals

  1. All sponsorships must be valued for cost of both cash and in-kind contribution.
  2. All sponsorships must be formally approval by management under the financial delegation process.
  3. All sponsorships must be approved by the sponsorship sub-committee who will meet as needed to review applications.
  4. The sponsorship sub-committee will comprise of the Director Marketing; Executive Director Commercial Asset Program; Manager Commercial Services and where relevant Dean or Campus Head or nominee, Other staff may be co-opted depending on nature of request.
  5. Outcome notifications – the sponsorship sub-committee will determine the appropriate responder for outcome notifications.
  6. All applications must be responded to within 8 weeks.

Conditions of funding

  • Successful applicants enter into a formal agreement or contract that details the mutually agreed sponsorship conditions
  • The sponsorship sub-committee's decision will be final regarding funding under this sponsorship process
  • The University does not provide additional revenue for advertising associated with a sponsored event
  • We may, but shall be under no obligation to, give reasons for not accepting any applications
  • The University reserves the right to decline proposals that do not meet the above criteria, and to terminate agreements if they fail to meet agreed commitments
  • Successful applicants must be able to provide an invoice on company letterhead and must have a registered ABN.
  • It is requested that all successful sponsors consider the Commercial Services operations of the University and seek a quotation for their sponsored event needs where appropriate- this may include accommodation, venues, catering and printing needs.

Responsibility

Role Responsibilities
Chief Learner Experience Officer Overall responsibility for the quality and compliance of all VET and academic marketing and promotional materials used across the University.
Director, Marketing and Growth or delegate

Work with Coordinators Programs, Program Support & Technical Services / Education Managers in the development of effective and compliant marketing materials.

Contribute to the development of Course Finder pages and updates to ensure full compliance with University policy and external regulatory requirements.

Process requests for use of approved social media platforms for marketing purposes.

Coordinator, Programs, Program Support & Technical Services/ Education Managers

Ensure only approved marketing products are used within Institutes.

Ensure that course information in Course Finder is current and accurate.

Work collaboratively with marketing team in the development and publication of marketing material.

Complete compliance check prior to submission of marketing product to Marketing Manager for approval.

Monitor relevant webpages to ensure they remain compliant and accurate.

Promulgation

The Marketing Governance Procedure will be communicated throughout the University community in the form of:

  1. an Announcement Notice via FedNews website and on the ‘Recently Approved Documents’ page on the ‘Policies, Procedures and Forms @ the University’ website to alert the University-wide community of the approved Procedure;
  2. distribution of e-mails to Executive Dean / Head of Department / Universitystaff.

Implementation

The Marketing Governance Procedure will be implemented throughout the University via:

  1. an Announcement Notice via FedNews website and on the ‘Recently Approved Documents’ page on the ‘Policies, Procedures and Forms @ the University’ website to alert the University-wide community of the approved Procedure;
  2. Staff induction sessions
  3. Training sessions

Records Management

Document Title Location Responsible Officer Minimum Retention Period
University Publications - hardcopy Forward to Record Management Services for archiving Director Marketing Seven Years
University Publications - electronic The University’s approved policy management system Director Marketing Seven Years