VET sector compliance obligations under the Student Identifiers Act 2014

We suggest that VET providers circulate the information below to all relevant staff members.

Non-compliance

Types of non-compliance under the Act fall into 3 primary categories:

• not meeting privacy requirements
• issuing qualifications and awards to a student without a Unique Student Identifier (USI)
• creating duplicate USIs, altering a USI Vocational Education and Training (VET) transcript or creating a fake USI VET transcript.

Privacy

To remain compliant with privacy requirements we remind you of your obligations to obtain permission from a student when creating, or finding a USI. A Privacy Notice must be issued to the student if you are creating a USI on their behalf.

Under section 11 of the Act, any personal information and identity documents obtained to create a USI must not be retained, unless you are required by another law to keep the information.

If storing a record of a USI you must take reasonable steps to protect that record from misuse, interference, loss, unauthorised access, modification or disclosure.

Issuing Qualifications

Under section 53 of the Act, a registered training organisation must not issue a VET qualification or statement of attainment to an individual without a verifiable USI, or an exemption from being assigned one. If an exemption letter is provided on official Student Identifiers Registrar letterhead, it should be accepted without asking the student why they are exempt, and/or requesting they sign a government-based privacy notice.

International students who have completed all their study outside of Australia do not need a USI.

Australian students studying overseas with an Australian education or training provider do need a USI. They can create a USI whilst they are not in Australia using their Australian passport.

Creating Duplicates

There are civil penalty provisions under Part 3A of the Act where it is an offence for an individual to knowingly make an application to create a duplicate USI or authorise an entity to do so. To remain compliant, you must attempt to find an existing student’s USI before creating one on their behalf.

Document Verification Service Override (DVSO)

Organisations who have access to use the Document Verification Service Override (DVSO) can only use this functionality to assist students who do not have access to verifiable identification and identify as Aboriginal and/or Torres Strait Islander, or are incarcerated.

For additional information please see our Provider Guide.

Further details on how we regulate compliance with the Act can be found on our compliance web page.

If you think you have identified non-compliance with the Act you can complete the report non-compliance form.