Updates to the Queensland Non-State Schools Accreditation Review Program Guidelines

Published
01 August 2019

At least once every five years, the Queensland Non-State Schools Accreditation Board (NSSAB) assesses whether each non-state school in Queensland has met the legal obligations required for accreditation. To help schools with this process, the NSSAB issues its Non-State Schools Accreditation Board’s Review Program Guidelines (Guidelines).

The Guidelines were updated on 14 June 2019. In this article we explain the updates and what they mean for Queensland schools.

 

The Updates in a Nutshell

 The updates affect one section of Appendix 2 and one section of Appendix 3 to the Guidelines. In both cases, that section is entitled “Administration and governance: School survey data and associated documents.”

In Appendix 2, the updates expand the sources of evidence that you can use to demonstrate that you’ve met certain registration requirements regarding the types of school data that is collectable. In Appendix 3, the updates increase the list of “Example evaluation questions” that you can use for guidance when drafting a compliance review report. Specifically, the new example evaluation questions relate to whether school survey data and associated documents are kept in a way that ensures the integrity and security of the data and documents (Education (Accreditation of Non-State Schools) Regulation 2017 (Qld) (Regulation), Reg 5(1)(b)).

 

Do the Updates Impose Any New Obligations?

No. The updates expand the resources that you can use to help you meet your accreditation requirements. They do not add or change any obligations. However, the changes do require schools to be aware of the NSSAB’s increased evidentiary expectations which may require some schools to examine their internal record keeping requirements, policies and procedures. From a NSSAB perspective, a school’s failure to address the new types of evidence in their review report may lead to an “if not, why not?” NSSAB response.

 

The Updates to Appendix 2

Appendix 2 deals with “statutory requirements to be covered in a review”. The purpose of Appendix 2 is to show you some of the “sources of information and types of evidence” that you can use to demonstrate that you’ve met the regulatory requirements set out in the Regulation.

The updated Guidelines have expanded the list of “sources of information and types of evidence” with regard to “Administration and governance: School survey data and associated documents”.

Here is a breakdown of the changes:

Appendix 2: Administration and governance – School survey data and associated documents
Sources of information or types of evidence you can use to meet this requirement
Old version of the Guidelines Updated version of the Guidelines
Enrolment records – including identify as an Aboriginal or Torres Strait Islander person; visa for overseas students. Enrolment records – including:
  • enrolment date
  • date of birth/age
  • residential address
  • whether the student identifies as an Aboriginal or Torres Strait Islander person
  • whether the student identifies as English not being the first or main language spoken at home
  • copy of the visa for overseas students and domestic students who are not Australian citizens.
Verification and audit processes to ensure integrity and security of data collected. System security and data integrity – including:
  • type of system(s) used by the school to record enrolment and attendance
  • access controls – who has add/edit/delete access to the system(s)
  • controls in place to ensure security and integrity of electronic records as well as any paper-based records received or kept at the school
  • system audit logs.
Robustness and sufficiency of the school’s regular and systematic review program for ensuring the integrity and security of the data and associated documents.                    
Records for attendance and absenteeism of students – illness, holidays, medical reason for student or family member, natural disaster, cultural requirement. Records for attendance and absenteeism of students up until and including Census day – illness, holidays, medical reason for student or family member, natural disaster, cultural requirement. Documented proof that the student’s absence was beyond the control of the student’s parent/guardian or the student (if the student is living independently of the student’s parents or guardians).

Policy and procedures for accurately recording absence types or reasons for those absences.
Verification processes for ESL, or students with disability Verification processes for ELS – including documented annual assessment process.                                                                                                         Verification process for students with disability completed before Census day and the review date for verification has not expired.
Distance education – records of regular engagement between teachers and students. Distance education – records of regular engagement between teachers and students – time sheets or student ‘log’ in records, monitoring completion of assigned work, assessment of student work by teachers, communications records between teachers and students.

The substantially expanded list of sources of information or types of evidence operates as a form of checklist for schools to complete. Despite being described as “examples only” and not an “exhaustive list”, it is unclear whether the NSSAB expects schools to collect all the information/evidence listed.

 

The Changes to Appendix 3

Appendix 3 provides a list of “example evaluation questions and statements” to help you frame your compliance review report.

The updated Guidelines have made some minor changes to the language and added 14 more evaluation questions to the section on “Administration and governance: School survey data and associated documents.”  In particular, the new sections 3.2.1 to 3.3.2 address the existing obligation in Regulation 5(1)(b) that a school must keep school survey data “in a way that ensures the integrity and security of the data and documents”.

Here is a breakdown of the changes:

Appendix 3: Administration and governance – School survey data and associated documents
Example evaluation questions and statements
3.1 Does the school have sufficient systems in place to ensure that school survey data for the school and associated documents (outlined in sections 27 - 30 of the Regulation) is kept for at least 5 years after which the data relates? [Regulation s.5(1)(a)] 3.1 Does the school have sufficient systems, policies and procedures in place to ensure that school survey data for the school and associated documents (outlined in sections 5(3) and 27 - 30 of the Regulation) is kept for at least 5 years after which the data relates? [Regulation s.5(1)(a)]
3.2 Is the school survey data kept in a way that ensures the integrity and security of the data and documentation? [Regulation s.5(1)(b)] 3.2 Is the school survey data kept in a way that ensures the integrity and security of the data and documentation? [Regulation s.5(1)(b)]

For electronic record keeping:

3.2.1 What system(s) is/are used by the school to record enrolments and attendance?

3.2.2 Who has access to the system(s)

3.2.3 What controls are in place to ensure the security and integrity of information arriving at the schools electronically?                                              
3.2.4 Who enters enrolment data?

3.2.5 Who records attendance data and who often is the data recorded?

3.2.6 Are audit logs available in the system(s) to track any changes to attendance data?

3.2.7 Does the school perform regular reviews of the integrity and security of the data?

For paper-based record keeping:

3.2.8 Where are the enrolment forms and attendance lists stored?

3.2.9 Who has access to the forms and lists?

3.2.10 What controls are in place to ensure the security and integrity of information arriving at the school via hard-copy?

3.2.11 Who records attendance data and how often is the data recorded?

3.2.12 What controls are in place to ensure the security and integrity over physical storage?

3.3 Does the school keep a record of the reason for a student’s absence from the school and why the absence was considered to be for a reason beyond the control of the student’s parents or guardian or the student if the student is living independently of the student’s parents or guardians? [Regulation s.5(2)] 3.3 Does the school keep a record of the reason for a student’s absence from the school and why the absence was considered to be for a reason beyond the control of the student’s parents or guardian or the student if the student is living independently of the student’s parents or guardians? [Regulation s.5(2)]

3.3.1 Does the school have a policy and procedures for accurately recording absence types or reasons for those absences?

3.3.2 What internal controls are in place to ensure that all absences are recorded?

The new sets of questions on the different types of record keeping suggests that the NSSAB wants to see evidence of a school’s record keeping policies and procedures, as well as evidence that those policies and procedures address the questions posed in sections 3.2.1 to 3.2.12.  Schools may need to review and update their record keeping policies and procedures to addresses those questions. The addition of sections 3.3.1 and 3.3.2 addressing how absences are recorded also indicates that schools should have robust procedures in place in this area.

 

What Do the Updates Mean for Queensland Schools?

The updates do not directly impose any new obligations on schools, but by expanding the resources that you can use to demonstrate compliance and meet the requirements for accreditation, the NSSAB has increased its expectations of what evidence a school should have.  The expanded list of resources will be helpful for schools who have upcoming NSSAB reviews.

Mark Bryan

Mark is a Legal Research Consultant at CompliSpace. Mark has worked as a Legal Policy Officer for the Commonwealth Attorney-General’s Department and the NSW Department of Justice. He also spent three years as lead editor for the private sessions narratives team at the Royal Commission into Institutional Responses to Child Sexual Abuse. Mark holds a bachelor’s degree in Arts/Law from the Australian National University with First Class Honours in Law, a Graduate Diploma in Writing from UTS and a Graduate Certificate in Film Directing from the Australian Film Television and Radio School.