Agent Recruitment and Performance Management Policy

1. Policy

Keystone College of Business and Technology (KCBT) has a firm recruitment, monitoring and termination practices in place for Education Agents that recruit students for KCBT. KCBT takes all reasonable measures to only use Education Agents that have appropriate knowledge and understanding of the Australian Education Industry and does not use education agents who are dishonest or lack integrity.

This policy covers the recruitment, management and termination of Education Agents and their compliance with KCBT’s obligations under the ESOS Framework.

2. Related Documents

• Education Agent Application Form
• Education Feedback Form
• Education Reference Check
• Education Agent Agreement

3. Relevant Legislation

• National Code (2018), Standard 7
• The Migration Act 1958

4. Policy and Procedure

Education Agent Appointments

1. KCBT enters into a formal written agreement that governs the appointment of Education Agents engaged to represent KCBT.
2. KCBT does not accept students from an Education Agent if it reasonably suspects that the Education Agent, their employee or sub-contractor:
3. Engaged in, or previously involved in dishonest practices, including the deliberate attempt to recruit a student, where it conflicts with National Code Standard 7.
4. Facilitated the enrolment of a student who the Education Agent believes will not comply with the student visa conditions.
5. Provided immigration advice where it is not authorised under the Migration Act.

Education Agent Recruitment Procedure

Agent Application

1. The Education Agent contacts KCBT for an expression of interest to represent the KCBT .
2. The Education Agent completes the Application to become an Agent and sends it to the Director of Marketing , along with:
   1. Business details including
   2. Business name
   3. Name of the contact person
   4. Postal, email, website and telephone
   5. Primary countries of operation
   6. Membership of Professional Associations
   7. Other (Refer to Agent application form: Agent Application form)

Assessment for suitability

1. The Director of Marketing assesses the application based on:
2. The quality of the documentation provided by the agent
3. The applicant’s business references

2. The Director of Marketing ensures that the education agent declares and takes all reasonable steps to avoid conflicts of interest with its duties as an education agent of KCBT. Examples of conflicts of interest include, but are not limited to:
3. When the agent charges services fees to both overseas students and registered providers for the same service;
4. Where an education agent has a financial interest in a private education provider; or
5. Where an employee of an education agent has a personal relationship with an employee of the education provider.

3. If the application from Education Agent is successful it is signed off by the Director of Marketing or CEO. The Director of Marketing provides the Education Agent with a KCBT Education Agent Agreement and access to all relevant KCBT current marketing and promotional documents etc including the KCBT Student Handbook, the course flyers/brochures, KCBT course intake dates and fees and charges and other marketing material that may assist the agent to represent KCBT .
4. An Agent Profile is created by the Director of Marketing on the KCBT, and ensures PRISMS and ASQAnet are updated.

If the application is incomplete, the Director of Marketing advises the Education Agent that the application will not be processed until all required information is provided. The agent is reminded of the same through email reminder, the application is not processed until all the documentation is submitted.

Where applicants are not successful, the Director of Marketing advises the applicant accordingly.

Education Agent Approval

1. Successful applicants are provided with an Education Agent Agreement, which must be read, understood, signed and sent back to KCBT before the Education Agent is approved.
2. The duties and responsibilities of KCBT and the Education Agent are listed in the KCBT Education Agent Agreement.
3. Upon receipt of the signed Education Agent Agreement, KCBT sends a formal and written letter advising of the decision.
4. Approved agents are provided with KCBT promotional materials and is given an induction.
5. All approved agents are provided with a KCBT Agent confirmation notice.
6. All approved agents are placed on KCBT Education Agent Register on the PRISMS, ASQAnet, and the KCBT website.
7. ASQAnet is updated via ASQAnet no more than 30 days after the agent has been approved.
8. All approved Education Agents have an Education Agent file that holds the Education Agent Agreement and any other relevant documentation between KCBT and the Education Agent. The files are stored by the Director of Marketing.
9. The Director of Marketing ensures that all marketing, promotional and relevant KCBT policies and procedures are updated and that the information is passed immediately to its approved Education Agents to ensure prospective students are provided only with accurate and current information.

• Education Agent Agreements are approved according to the agent agreement, which is renewed dependent upon performance and student feedback.

International Education Agent Remuneration

1. International Education Agents are remunerated by KCBT in form of a marketing contribution for particular services or events, or payment of commissions based on enrolments attributable to the agent.
2. The amounts payable, and terms of payment are an agreement between the individual Agency and KCBT.
3. Any other conditions are specified in the Education Agency Agreement.

Communication with International Education Agents

1. Management of the activities of the agent network is primarily the responsibility of the marketing department, KCBT ensures there is timely and relevant communication with its International Education Agents by maintaining:
   1. Contact via emails, phone calls, and other electronic media.
   2. Copies of communications relating to updates, commission payment and individual Agency Agreements are retained by the Director of Marketing.

Promotional Material, Events, Training and Meetings

The Director of Marketing is responsible for the development of promotional materials.

1. International Education Agents are notified of the availability of new material through communication by the Director of Marketing.
2. International Education Agents who request materials are referred to the Director of Marketing.
3. Where International Education Agent visits are arranged, the Director of Marketing undertakes the following activities based on the agent’s needs:
4. Training and update of the KCBT courses, prices and other information
5. Workshops for promotion and marketing
6. Updates about courses and changes to agreement or standards.
7. Meetings held via audiovisual connection (Skype, WhatsUP, WeChat, MS team, etc.) are documented by the Director of Marketing
8. The Director of Marketing is responsible for such communication and takes every opportunity both in Australia and overseas, to ensure that there is regular and ongoing communication with agents

Monitoring and Review

The Director of Marketing reviews each agent’s performance and activities annually. This review helps ensure Keystone College of Business and Technology has a good understanding of its agents’ performance over time and that training can be targeted.

The review may include:

• Analysis of quality and quantity of applications on behalf of prospective students
• Analysis of conversion rates from applications lodged to actual enrolments at KCBT
• Analysis of visa grants and refusals for KCBT
• Adherence to KCBT admissions processes
• Progress and conduct of students
• Analysis of recorded instances where a student claims to have been misinformed by the agent about his or her studies at KCBT; and/or
• The number of recorded instances where the agent has shown a lack of knowledge of student visa requirements or other matters relating to a student’s stay in Australia.

Where monitoring processes indicate a deficiency or non-compliance with legislation or the National Code, training and/or the provision of additional information in relation to the expectations of KCBT will be provided specific during visits to an Education Agent’s office or online.

Agents found to be in breach of the Education Agreement and or the Standards, or where complaints have been received by a student, are contacted by the Director of Marketing. The Director of Marketing may terminate an agent’s agreement if deemed necessary.

Where any practices by an Education Agent are identified as being negligent, careless or incompetent or being engaged in false, misleading or unethical advertising and recruitment practices, or engaged in practices that could harm the integrity of the KCBT or Australian education and training, the Director of Marketing takes immediate corrective and preventative action.

Education Agent Termination

Where KCBT becomes aware of, or reasonably suspects that an Education Agent, their employee or sub-contractor has breached KCBT Education Agent Agreement, the ESOS Act 2000, or the National Code 2018, KCBT terminates the agreement. This includes, but is not limited to the Education Agent, their employee or subcontractor:

2018. Being engaged in, or being previously engaged in dishonest practices, including the deliberate attempt to recruit a student where clearly conflicts with the obligations of the registered provider under the National Code 2018.
2019. Facilitating the enrolment of a student who the education agent believes will not comply with the conditions of his or her student visa.
2020. Providing immigration advice where not authorised under the Migration Act 1958 to do so.

The Director of Marketing may terminate and Education Agreement at any time or may decide not to renew the agreement. Reasons for both must be recorded in the Agent Profile.

Terminated agreements or agreements that are not renewed are marked as inactive in the KCBT system, ASQAnet and PRISMS, and will be updated on ASQAnet accordingly.

Education Agents may appeal any decision made by KCBT, in line with KCBT Complaints and Appeals Policy.

Link to Agent List

Education agents are an important part of the international education sector in Australia. KCBT ensures that our education agents act ethically, honestly and in the best interest of overseas students and uphold the reputation of Australia’s international education sector.

Find a reputable Education Agent from our list of Registered Education Agents or suggest a new Agent to us.

Agent List