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Placement Policy

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Section 1 - Purpose and Context

(1) Western Sydney University seeks to enhance student learning experiences by enabling students to engage in the culture, expectations and practices of a profession, workplace or discipline. Placements, or professional experiences, facilitate the student's entry into the work place, enhance their employability skills, and may be required for professional accreditation.

(2) The purpose of this policy is to provide the principles and procedures for the approval and management of student placements undertaken as a requirement of any unit, course or program of study of the University. Schools, The College, University Research Institutes and third-party providers arrange relevant experiences in accordance with this policy. Under advice and direction of their School or third-party provider, some students may be able to arrange their own placements in accordance with this policy and in line with their School's requirements.

(3) The University manages risk in relation to placements and ensures quality in accordance with this policy.

(4) Placements for international students may be required as part of a unit or program of study where the placements are part of the course registration under the Commonwealth Register of Institutions and Courses for Overseas Students (CRICOS).

(5) The policy does not apply to placements for which students receive remuneration or other payments, or are otherwise in an employment relationship, which must comply with the Fair Work Act 2009 (Cth), or to placements where students elect to voluntarily undertake experience that is not required as part of a unit or program of study.

(6) In addition to the procedures required by this policy, Schools, The College, University Institutes or third party providers may implement the policy through local guidelines, handbooks and/or flow charts.

(7) The policy should be read in conjunction with the Student Code of Conduct, the Progression and Unsatisfactory Academic Progress Policy, the Enrolment Policy, the Assessment Policy - Criteria and Standards-Based Assessment, the Travel Policy, the Student Misconduct Rule and the Working with Children (Workers and Students) Policy, and the Student International Mobility Policy and Student International Mobility Procedures.

(8) The policy operates in the context of the University's student placement management system.

(9) This policy takes into account the Higher Education Standards (HES) Framework requirements, that:

  1. placements and other community-based learning experiences are well-conceived and educationally sound, quality assured and monitored by the University, and include assurance of the quality of supervision of student experiences.
  2. where students may identify their own placement opportunity, under the HES Framework, placement arrangements must not be ad hoc, they must be well-defined or have well-defined purposes, and that students undertaking these placements have appropriate guidance and support.
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Section 2 - Definitions

(10) For the purposes of this policy:

  1. CRICOS means the Commonwealth Register of Institutions and Courses for Overseas Students
  2. HES Framework means the Higher Education Standards Framework (Threshold Standards) 2015.
  3. Inherent Requirements means the essential components of a course or unit that demonstrate the abilities, knowledge and skills to achieve the core learning outcomes of the course or unit. 
  4. Placement means a unit, unit component or other work integrated learning activity, required as part of a unit or program of study (including elective unit), that gives students unpaid practical experience (as per the Fair Work Act 2009) in the application of theoretical concepts and knowledge in a workplace environment, and may include clinical practice, clinical placement, practicum, internship, professional placement, professional experience, industrial experience, work experience or professional practice.
  5. Placements Hub means a service unit of the University that supports Schools by ensuring the University fulfils its policy responsibilities in relation to student compliance, contract management and the implementation of the University's placement management system.
  6. Placement Integration Plan (PIP) means a document established with a Disability Advisor outlining the 'reasonable adjustments' that support a student to undertake a placement experience.
  7. Placement Levy means an encumbrance to be placed on the student’s record to prevent them attending a further placement.
  8. Placement Organisation means the organisation at which a student's placement is undertaken, and may include a business, government agency, primary or secondary school, early childhood setting, higher education institution, community organisation, not-for-profit, or volunteer organisation in Australia or overseas or a higher education institution.
  9. Program of study means a course or degree offered by the University.
  10. Reasonable Adjustment means modifications made to a workplace environment or working arrangements for a person with a disability to complete a job or work task. They can be administrative, environmental or procedural alterations in the employment or learning situation to remove barriers for people with a disability so that they can perform the inherent requirements of a placement. An adjustment is defined as ‘reasonable’ if it balances the interests of all parties affected including not causing ‘unjustifiable hardship’ to the educational institution.
  11. School means a University School or discipline, The College, University Institute (providing coursework placements) or third-party provider, and not a school in the context of a placement organisation as defined in (h) above.
  12. Special Requirements means the requirements related to enrolment in courses or units where clinical, practical or work placements are part of a course or unit structure.
  13. Student Placement Agreement means a written agreement or contract, which is the formal agreement between the University and an external organisation where a student is undertaking a placement or professional experience.
  14. Third-Party Provider means an organisation who delivers a course or unit on behalf of the University.
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Section 3 - Policy Statement

(11) Placements are intended to provide authentic experiential learning, support and assist a student’s learning and preparation for their chosen profession or discipline.

(12) The University will actively promote good relationships with current and prospective placement organisations, which are usually external to the University.

(13) The parties involved in placements must be adequately prepared to meet their responsibilities as set out in this policy.

(14) Placements must be managed in accordance with the procedures in this document, and any procedures or guidelines that reference this document.

(15) Placements must also be managed in accordance with any external polices and frameworks that reference external accreditation requirements or accreditation bodies for a particular industry.

Part A - Inherent Requirements, Special Requirements and Reasonable Adjustments

Inherent Requirements

(16) Students need to understand and must meet all inherent requirements that may apply in relation to their course or a unit that includes a placement experience throughout their enrolment.

Special Requirements

(17) Students must meet and acknowledge any special requirements relevant to their course or a unit that incorporates a placement experience, including confirming their compliance with mandatory legal requirements valid for their entire course, including but not limited to:

  1. a national criminal history check or obtaining a clearance or authority document or conditional letter;
  2. first aid, allergy and anaphylaxis training;
  3. a working with children check and or relevant child protection training;
  4. any identified accreditation requirements;
  5. mandatory compliance undertakings including immunisation and relevant assessments; or
  6. complete any required documentation and forms within required deadlines.

Reasonable Adjustments

(18) The University will provide reasonable adjustments for students with a current Placement Integration Plan.

(19) A student does not have an obligation to disclose their disability or health condition, however adjustments cannot be undertaken unless the student has registered with Disability Services and consented to the distribution of a Placement Integration Plan.

(20) Reasonable adjustments must not fundamentally change the nature of the inherent requirement relating to the course.

(21) In addition to the above responsibilities, Schools, The College, University Institutes and third-party providers must:

  1. ensure any reasonable adjustments set out in a student's Placement Integration Plan are in place prior to the student commencing placement and are implemented during the placement;
  2. ensure any adjustment that assists a student to participate is reasonable, does not compromise the experience, does not compromise the academic integrity of the program, does not compromise the capacity of the student to demonstrate any relevant external accreditation requirements, and reflects the interests of the student, the University, the placement organisation and other students; 
  3. liaise with the University's Disability Service in relation to the student's Placement Integration Plan, as provided in the Student Disability Principles and Procedures; and
  4. consult with a Disability Advisor should a student’s disability or health condition impact upon their placement undertaking.

Part B - Responsibilities

University

(22) The University will oversee and support:

  1. Schools, The College and University Institutes to develop Student Placement Agreements with external placement organisations in relation to placements required within a unit or course that they, or their students arrange, unless otherwise advised by the Office of General Counsel.
  2. the identification of currency and recording of all Student Placement Agreements in accordance with the University's records and archive management system, and within the University's student placement system.
  3. Schools, The College, University Institutes and third-party providers and their students to adhere to any mandatory policies and procedures that stipulate compliance to inherent and special requirements.
  4. Schools, The College, University Institutes and third-party providers to record all unit and course required placement experiences within the University's student placement management system.

(23) The University must, in all cases, be able to demonstrate that placements are quality assured, including an assurance of the quality of supervision of student experience, and that these quality assurance mechanisms demonstrate that these placements meet the relevant standards of the HES framework.

(24) The University, through assessment and course design policies and procedures, will ensure placements are designed and assessed appropriately in order to inform curriculum development and improve future placements.

(25) The University acknowledges that Schools, The College, University Institutes and third-party providers have a responsibility to ensure public safety is paramount in the design and implementation of units requiring placement experiences.

(26) The University, through its Schools, The College, University Institutes and third-party providers, will have effective management processes in place to ensure that students undertaking placements have the ability to practice competently and safely.

(27) The University will ensure students are covered by adequate insurance for their placement, including providing the placement organisation, if requested, with a copy of the University's relevant certificates of currency.

(28) Prior to admission, the University will provide information to international students about the Australian employment context and relevant workplace legislation.

(29) The University, in conjunction with Schools, The College, University Institutes and third-party providers, will ensure students understand that compulsory placement hours do not count towards the 40 hours per fortnight work limit that applies to student visa holders during study sessions, but that in undertaking work beyond the compulsory placement, students must comply with the limitations imposed by their student visa.

Schools, The College, University Institutes and Third-Party Providers

(30) Schools, The College, University Institutes and third-party providers are responsible for:

  1. Managing risk by:
    1. ensuring the quality of the experience and supervision has been addressed in the development and revision of all units, including any impact of co-ownership of units between disciplines;
    2. providing placement organisations and students with appropriate preparation for undertaking a placement, including the assurance that students are prepared for placement;
    3. maintaining a relationship with a placement organisation, documented through a current and signed Student Placement Agreement in relation to placements they or their students arrange;
    4. monitoring the health and safety of students whilst they are on placement, obtaining confirmation from placement organisations of their obligations through a current Student Placement Agreement to comply with work health and safety legislation, additional industry frameworks and guidelines;
    5. monitoring placements and student progress in accordance with University policies and procedures and any other School, University Institute or third-party provider policies and procedures governing placements;
    6. ensuring the placement environment is accessible in accordance with the Disability Discrimination Act 1992 (Cth), where required, and obtaining the placement organisation's agreement to implement an individual student's reasonable adjustments as outlined in their Placement Integration Plan, and consult with Disability Advisors for advice regarding any adjustments;
    7. regularly communicating with the student and placement organisation during the placement;
    8. ensuring all parties are aware of the procedures to follow when a student experiences unlawful or inappropriate behaviour from an employer, colleague or other person whilst on placement;
    9. taking action to prevent further student placements at organisations that do not provide a safe and appropriate placement for students, and communicating such action to relevant University Schools, Institutes, third-party providers or relevant unit and the Placements Hub; and
    10. evaluating the suitability of the placement for future use.
  2. Managing placement requirements and allocations by:
    1. ensuring the placement arrangements comply with any relevant professional accreditation requirements;
    2. maintaining a current written record of the criteria used to select and approve individual placements, and capturing the placement location, including address and contact details of placement sites within the University's placement management system;
    3. maintaining appropriately trained staff to coordinate and administer all placement requirements;
    4. ensuring a clear communication system is in place to deal with students' issues or queries, and keeping accurate records of all such dealings;
    5. ensuring the placement contact, the placement organisation and the student understand the assessment requirements and the role of each person in the assessment process;
    6. ensuring University staff, the placement organisation and the student understand:
      1. the inherent requirements of the course;
      2. the work to be undertaken during the placement;
      3. the duration of the placement; and
      4. the processes for managing a student at risk of not satisfactorily completing a placement.
  3. Managing student requirements by:
    1. ensuring students have met all pre-determined special requirements, where applicable, before allocation to a placement;
    2. ensuring students have opportunities to provide feedback about the placement to their placement organisation, Schools, The College, University Institutes and third-party providers or through another identified mechanism; and
    3. ensuring students are aware of any particular requirements stipulated by the placement organisation, for example meeting all special requirements, placement education and training modules, wearing a required uniform, dress code, required equipment, professional behaviour, personal hygiene, infection control, relevant medical and physical requirements.
  4. Managing additional requirements for international students by:
    1. ensuring placements for international students comply with Education Services for Overseas Students - Information for Staff and Students (ESOS) National Code (in particular Standards 2 and 3 of the 2018 ESOS National Code) in relation to course and unit design;
    2. reviewing their course details registered with CRICOS to ensure the placement is registered as compulsory and assessable to ensure the hours are not counted as part of the 40 hours per fortnight limit.
  5. Managing offshore placements by:
    1. identifying, managing and assessing the risks for an offshore or international placement, and identifying any other international mobility requirements relating to offshore placements;
    2. assisting students as far as practicable with any administrative arrangements required to prepare for placements offshore, including international special requirements, insurance and travel requirements; 
    3. recording the assessable offshore placement experience within the identified student placement system if it relates to an enrolled unit.

Students

(31) Students must undertake and complete placements that are a requirement of their unit or program as scheduled, and notify their Schools, The College, University Institutes and third-party providers of any matter that is a serious disruption to their studies.

(32) When enrolling into a placement unit, students must:

  1. understand and meet the inherent requirements of their course, to be able to meet the expectations of their placement;
  2. become familiar with the competencies required by the particular course relevant to the placement;
  3. complete any program requirements or prerequisites;
  4. ensure they meet any special requirements relevant to their placement organisation including confirming their compliance with mandatory legal requirements within identified deadlines such as police and working with children checks and immunisation requirements;
  5. complete any required documentation within identified deadlines;
  6. consider the possible impacts of a disability or health condition that may affect their placement and, if adjustments are required, speak to a Disability Advisor to develop a Placement Integration Plan;
  7. provide consent, following discussion with relevant placement staff, for the release of any necessary information to the placement organisation;
  8. disclose any identified possible or perceived conflict of interest, such as a relative being responsible for supervision, or that the student is in paid employment with the placement organisation; and
  9. communicate with the placement organisation as advised by the placement coordinator.

(33) Before undertaking and during a placement experience, students must:

  1. be enrolled in their course and usually the relevant placement unit, and complete any special requirements, program requirements or prerequisites;
  2. adhere to all requirements of the Student Code of Conduct;
  3. uphold standards of professional behaviour; and where applicable, wear the designated Western Sydney University uniform (or otherwise approved standard of dress);
  4. take due care with the placement organisation's equipment and other property;
  5. undertake their experience in a manner that is safe, actively participate in any health and safety training orientation, induction and follow instructions required by the placement organisation;
  6. comply with any laws that apply to the placement in the relevant jurisdiction, and the University's and the placement organisation’s health and safety instructions and policies, rules or procedures and child protection requirements;
  7. demonstrate their understanding of Work Health and Safety through methods including but not limited to completing relevant Work Health and Safety training, an identified Checklist, or participating within another mechanism as identified by their Schools, The College, University Institutes and third-party providers or organisation at the beginning of their placement for their placement location;
  8. be present at the agreed site during agreed working hours and participate fully in the assigned tasks and activities and any required training;
  9. carry their University identification at all times;
  10. make contact, as required with their placement coordinator, to report on progress of the placement;
  11. report to the placement coordinator and their placement organisation any matters that might affect their concerns, or ability, or fitness to undertake or continue to undertake the placement or any task or activity;
  12. inform both the placement coordinator and the placement organisation of any absences from the placement as soon as possible as per School, University Institute or third-party provider procedures;
  13. notify the placement coordinator and the placement organisation immediately of any hazards, incidents, injuries, near miss or illness that occurs whilst on placement;
  14. communicate any concerns about the placement environment to their placement coordinator;
  15. advise the placement coordinator of any requests the placement organisation makes of the student to undertake work that is beyond the agreed tasks and activities;
  16. meet any expenses associated with the placement the University prescribes (excluding insurance costs or costs of implementing reasonable adjustments), such as those related to accommodation and travel to and from the placement, specific requirements of the placement organisation including attire, and any levies imposed by the University relating to attendance or non-attendance at the placement; and
  17. consult with their placement coordinator in a timely manner if they are withdrawing from a placement.

Placement Organisations

(34) Placement organisations will enter into a Student Placement Agreement with the University that outlines the relationship between the University and the organisation while students are undertaking a placement experience.

(35) The Agreement identifies the following responsibilities of a placement organisation, including but not limited to:

  1. having appropriate public liability insurance in place, where applicable;
  2. providing students with appropriate orientation, induction and training in the organisation’s policies, procedures and rules, including safe work practices;
  3. providing a safe and healthy work environment for students, in accordance with work, health and safety legislation, and ensuring, so far as is reasonably practicable, the health and safety of students so that they are not put at risk during the placement;
  4. providing feedback to the Schools, The College, University Institutes and third-party providers or the student about the student’s performance and about any circumstances which may affect the student successfully completing the placement;
  5. unless otherwise agreed, providing a suitably qualified person to supervise the student while at the organisation, including monitoring any work health and safety and other risks, and providing feedback to the placement coordinator;
  6. providing the necessary equipment, other resources and training to the student to undertake assigned tasks and activities;
  7. implementing agreed reasonable adjustments in consultation with Schools, University Institutes and third-party providers and student prior to placement, based on a student's Placement Integration Plan, where applicable;
  8. managing placement requirements and allocations by:
    1. ensuring supervisory staff are suitably trained in their responsibilities to undertake the supervisions of students in their placement, unless otherwise arranged with the School;
    2. ensuring a clear communication system back to the School, University Institute or third-party provider is in place to deal with students' issues or queries, and keeping accurate records of all such dealings;
    3. ensuring they understand:
      1. the assessment requirements and the role of each person in the assessment;
      2. the work to be undertaken during the placement;
      3. the duration of the placement;
      4. the processes for managing a student at risk of not satisfactorily completing a placement, including if any special requirements are not met by students; and
    4. ensuring a student has the opportunity to provide feedback about the placement to their placement coordinator or nominated staff member.
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Section 4 - Procedures

Part C - Criteria for Identifying Placement Sites

(36) A School, The College, University Institutes and third-party providers will ensure appropriate criteria are applied when identifying suitable placement opportunities for students, including:

  1. the placement involves skills, knowledge and experience relevant to the student's unit or program of study;
  2. the placement organisation has agreed to its responsibilities under these procedures;
  3. the placement organisation can adequately accommodate the student for the placement period; and
  4. the placement coordinator has determined the placement is suitable having regard to:
    1. the objectives and/or course learning outcomes and University graduate attributes of the relevant program or unit;
    2. the ability of the organisation to provide the student with the experience of working in the organisation;
    3. the outcomes of a cyclical risk assessment undertaken in relation to the placement, where the results inform and improve quality assurance; and
    4. accessibility for the student undertaking the placement at the placement environment, as relevant, which may be assessed by an independent assessor where a Placement Integration Plan is in place for the student.

(37) Schools may also approve a workplace or organisation as a placement location which has been approved by a relevant government agency or professional association for the purposes of registration or other accreditation.

Part D - Assessment

(38) Assessment of students undertaking placements must be designed to assess the learning outcomes from the placement, and assessments are to be undertaken in accordance with the Assessment Policy - Criteria and Standards-Based Assessment.

(39) Assessment of a placement should include, where practicable, input from a person at the placement organisation who was responsible for supervising the student.

(40) If students undertake an offshore experience, prior to gaining approval to align the experience to a particular unit, there is no assurance that retrospective credit will be awarded for the time or activities undertaken.

Part E - Unsatisfactory Performance or Placement Breakdown

(41) Schools, The College, University Institutes and third-party providers must manage unsatisfactory performance by a student at a placement, and manage where a student has not met standards for placement assessment, in accordance with the relevant University policies.

(42) The terms and conditions of the signed Student Placement Agreement in relation to terminations and cancellations of agreements, will come into effect where:

  1. there is a breakdown of a placement due to the student's performance, unforeseen circumstances or other similar factors affecting the student;
  2. a student has withdrawn from a placement for a specified period and subject to specific conditions, or for the remainder of the placement period;
  3. there is a breakdown of a placement due to unlawful or inappropriate behaviour of a person(s) at the placement organisation, other than the student, or arising from other circumstances at the organisation.

(43) If dispute resolution is required, this will be undertaken as per the terms and conditions of the signed Student Placement Agreement.

Part F - Non-Payment of Placement Levy

(44) Where a School, The College, University Institutes and third-party provider has a placement-related levy on a student and the levy is not paid by the specified date, they will arrange for an encumbrance to be placed on the student's record.

(45) The encumbrance will prevent the student attending a further placement, and may prevent the student from obtaining examination results and other records, enrolling in new units, accessing University facilities, including learning management systems, the library and information technology resources, and graduating. The encumbrance will be removed once the levy is paid.

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Section 5 - Guidelines

Fair Work Ombudsman – Student Placements
Student International Mobility Policy