Guidelines for self-review of performance against the Code of Practice

These guidelines are for schools and tertiary education organisations (TEOs) who are signatories to the Education (Pastoral Care of International Students) Code of Practice 2016 (the Code).

The Guidelines for self-review of performance against the Education (Pastoral Care of International Students) Code of Practice 2016 (PDF, 330KB) have been developed to support Code signatories to undertake and document self-reviews of their performance against the required outcomes and processes in the Code.

Self-review tool

NZQA has developed a self-review tool (DOCX, 286KB) for signatories to the Education (Pastoral Care of International Students) Code of Practice 2016 (including 2019 amendments).

Signatories do not have to use it, but it contains evaluative questions to help signatories cover all areas of the Code and review their performance against it.

The purpose of self-review

Self-review (also called self-assessment or internal evaluation) is examining an organisation’s practices to identify strengths and weaknesses so the organisation can make actual, worthwhile improvements to their practice.

Self-review is a proven basis for effective quality assurance practice. It is the most powerful method for an education organisation to understand and improve its educational performance.

The importance of self-review has long been reflected in New Zealand’s education sector regulatory environment, and it is a core component of quality assurance policies and criteria across all types of education organisations.

Self-review is also a specific requirement under the Code:

Clause 37 (1) – Each signatory must undertake and document self-reviews (at the frequency specified by the code administrator) of its performance against the required outcomes and processes set out in this code.

Self-review for different types of education organisations

There is a wide range of information on organisational self-review in different education settings.

The links below have information about the key features, organisational benefits, and regulatory requirements for self-review in your type of education organisation:

Self-review in New Zealand universities

Self-assessment for Te Pūkenga and private training establishments

Internal evaluation in schools

Different approaches to self-review against the Code

Each Code signatory school or tertiary education organisation (TEO) decides how it undertakes its self-review of performance against the Code, and how to document that review.

For example, review of performance against the Code may be incorporated into wider organisational self-review processes and reporting.

Alternatively, your organisation may decide that self-review of Code performance is more effective when it is a separate, specific process.

NZQA has no view on whether the process should be stand-alone or integrated, only requires that the process takes place and is documented and reported.

The difference between self-review and annual attestation

It is important to distinguish between your organisation’s ongoing processes for self-review of performance against the Code and your attestation to NZQA that Code self-review is taking place.

What is self-review?

The Code self-review process, like any internal evaluation process, is not something done every few years in preparation for an external agency’s review, or even once a year for attestation purposes. Self-review is ongoing. It consists of the everyday information that an organisation gathers to do its business well, rather than extra information gathered to report to an external quality assurance agency.

NZQA expects that any competent education organisation will be engaged in continuous processes of self-review. Ongoing organisational self-assessment is a core component of NZQA’s approach to quality assurance and is included in policies and criteria across all types of education organisations.

What is annual attestation?

Attestation is a declaration made to NZQA that Code self-review is taking place. The attestation is required annually, and is made by submitting a one-to-two page attestation form signed by the CEO/Principal/Chair of the Governing Board.

NZQA expects that on request a signatory can provide documentation to support that attestation. In the Code, this documentation is referred to as a ‘self-review report’. It is important not to confuse the two documents: the attestation form (PDF, 207KB) (which all signatories must submit annually to NZQA) and the self-review report (which some randomly-selected signatories will be asked to submit following annual attestation).

The annual attestation is part of NZQA’s external monitoring of compliance with the Code. It is currently annual until NZQA is confident that signatories have effectively embedded the 2016 Code. The frequency of attestation may change in the future.

NZQA as the Code Administrator

NZQA, as the Code Administrator, is required to use a signatory’s self-review report as a tool to monitor performance:

Clause 37 (2) – The code administrator must monitor each signatory’s performance against the required outcomes and processes by scrutinising the signatory’s self-review reports and any other information that the code administrator considers appropriate.

How self-review reports are used to monitor signatory performance

NZQA requests signatories’ self-review reports as part of routine, random monitoring or when NZQA is concerned about a signatory’s compliance with the Code.

The report gives NZQA an indication of how well the signatory is managing its processes of self-review and, therefore, its own performance under the Code.

NZQA checks the report carefully for whether a signatory has processes that contain the four core components of self-review (see the Getting started section).  

After looking at the signatory’s self-review processes, NZQA will follow up with the signatory in a range of ways, i.e.:

  • provide feedback on what, if anything, the signatory needs to do to improve its self-review processes in the future
  • request further information (for example, some of the evidence referenced in the report, or copies of certain policies and procedures)
  • phone the signatory to discuss and clarify the information provided in their report
  • arrange to visit the signatory to validate its compliance on-site.

While NZQA cannot confirm your compliance with the Code through a self-review report, it is the initial way NZQA looks at a signatory’s practice. A poor-quality self-review report will lead to compliance monitoring that can result in NZQA taking serious action.

Getting started

Before undertaking Code self-review, your organisation must understand how to interpret and apply the requirements of the Code.

Your organisation needs to be familiar with the Code (PDF, 736KB).

NZQA’s self-review tool for signatories to the Code contains key evaluative questions to guide your assessment of performance against the prescribed processes and outcomes of the Code.

For more information, email or call 0800 697 296 and ask to speak to a member of the Code team.

1.1 - The core components of self-review of performance against the Code

While there is no prescribed format for self-review, it is not a case of ’anything goes’.

There are four core components of self-review of performance against the Code:

  • Systematic information gathering
  • Robust analysis of data that leads to valid conclusions
  • Reflective processes that involve all relevant people in the organisation
  • Decision-making for ongoing improvement connected to the outcomes of a self-reflective process.
Question Self-review process
How do we comply? Consider if you have the required policies, procedures, and practices in place
How well do we meet the processes and outcomes? Consider the overarching outcomes for learners and think evaluatively about your practices
How do we know? Use evidence and draw conclusions, to validate your Code activities and practices
How can we improve? Identify improvements (if needed)

1.2 - Good quality evidence

Good quality evidence is vital for comprehensive and meaningful self-review.

The process of self-review will also identify any gaps or weaknesses in your organisation’s processes for identifying, gathering, and analysing evidence. Then your organisation can address those weaknesses.

What is good quality evidence?

Good quality evidence is data gathered systematically from multiple, diverse sources within and connected to your organisation. Good quality evidence is directly relevant to the questions your organisation is trying to answer. This evidence may be qualitative or quantitative.

NZQA’s self-review tool for signatories to the Code contains examples of possible evidence for each outcome. The tool also includes suggested evaluative questions to help you gather relevant evidence for each outcome and process.

1.3 - What if I have no international students enrolled?

To maintain approved Code signatory status, an organisation must complete and document a self-review against the Code and attest to it annually. This requirement applies even if you have no international students enrolled within the period of the self-review.

Signatories who no longer intend to enrol international students may choose to withdraw as a Code signatory.

1.4 - How do I review my Code practice when no international students are enrolled?

If an organisation has no international students enrolled during the period of the review, its self-review report will be different.

In this situation, self-review is not a review of performance, but a review of documented policies and procedures. The self-review can look at how up-to-date your policies are, and how prepared your organisation is for any international student enrolling in the future.

At each process and outcome, your organisation needs to work through the first part of the self-review process. Consider the question ’How?’. Does your organisation have the expected policies and procedures in place to enrol an international student? Does it understand its obligations? Is it ready to implement the required processes?

The self-review process can be used to identify any gaps in your preparedness and to plan for improvements.

Making self-review part of everyday practice

Organisational self-review of performance against the Code requires:

  • adequate resourcing (e.g. number of staff and their capability), planning and implementation of ongoing processes
  • the systematic gathering, analysis, and reporting of good quality evidence
  • identifying organisational strengths and weaknesses
  • linking findings to plans for actual, worthwhile improvements.

2.1 - The first self-review

The first time your organisation does a self-review it may be a large job and take some time. The amount of time and work required will depend on:

  • your school or TEO’s particular context
  • number of staff and their capability
  • how embedded self-review processes already are within your organisation.

NZQA expects that the process of self-review of performance against the Code will become shorter and easier once your organisation has the required systems, processes, and capability.

2.2 - Tips for establishing an ongoing process of self-review

  • Make self-review processes ongoing, paired with everyday reflective practice.
  • Begin the process of self-review well in advance of the attestation due date. This avoids the situation where one staff member must complete the task alone a couple of weeks before attestation is due.
  • Collect and organise data on an ongoing basis.
  • Spread the review of different outcome areas of the Code across the calendar year and all relevant staff.

2.3 - Some applied examples

For example:

  • Record and file meeting notes with students and follow-up actions.
  • Log ad hoc student or parent feedback according to the relevant Code outcome.
  • For Outcome 5: Orientation, review and report on orientation as soon as it takes place, involving all relevant staff and some new students.

2.4 - Get guidance and advice from other professionals

For more guidance on integrating self-review into your everyday practice, try approaching colleagues at other similar organisations. You can also seek advice from peak body representatives or other sector-based associations for professional development.

The most useful guidance will come from professionals working in a context similar to your own.

Documenting your self-review of performance against the Code

Each signatory can decide how it completes its review of performance against the Code, and how to document the review.

3.1 - How do I document the self-review?

You can use NZQA’s self-review tool for signatories to the Code. This is optional. You may prefer to use a tool or template developed by peak bodies, private companies or organisations in your sub-sector. You could also choose your own way to document the self-review.

3.2 - What do I need to document?

Your self-review needs to contain and address the four core components of self-review (see the Getting started section). When choosing an approach or resource to guide your self-review, check if it covers these core components.

3.3 - What is NZQA really after in a self-review report?

Self-review is about measuring the overall effectiveness of what your organisation does to ensure quality pastoral care outcomes for its international students. The self-review report needs to reflect what you learned about your Code practices and what evidence you have of their effectiveness.

Self-review is more than ticking off a check list to prove that the paperwork, processes, procedures and practices are in place. While this kind of audit is a starting point for self-review, it does not show the required evidence-based, evaluative thinking.

Whatever template you use, it is still possible to complete a poor quality self-review using a good-quality template. What is important is the quality of thinking and the quality of evidence on which that thinking is based.

Reviewing performance against an outcomes-focused Code

Your organisation must understand the nature and intent of the Code, and how to navigate the different parts of it, to successfully complete a self-review.

4.1 - Understanding the nature and intent of the Code

The Code is outcomes-focused. It does not always tell an organisation what to do to comply with a process or meet an outcome. Some processes specify requirements while other processes can be demonstrated in your own way.

Ultimately, the Code emphasises ‘what’ rather than ‘how’ because ‘how’ will look different in each signatory, e.g.:

  • particular international learners
  • different numbers of international students
  • different educational outcomes.

As a signatory, your organisation needs to take a tailored approach and work out its own ‘how’.

4.2 - Taking a tailored approach to pastoral care

Taking a tailored approach is more difficult, but has some important advantages:

  • It can apply to a wide range of signatories, organisation types and international learners.
  • Organisations can find the optimal way for them to do things, and plan to make targeted improvements.
  • As ‘trusted experts’, signatories have the flexibility and responsibility to innovate and tailor Code practice for their international students.
  • It fosters a reflective culture of continuous improvement. This will build a high-performing sector.

How to navigate the different parts of the Code

The different parts of the Code require different approaches.
See the sections below to find out more about the different parts of the Code.

5.1 - Specified process requirements

When the Code makes a specified process requirement, it must be followed.

For example, Clause 14 (b) is a specified requirement. It states:

“Each signatory must enter into written contracts with each of its agents”.

To comply with this clause, it is clear what signatories need to do: develop and keep an agent agreement, signed by the signatory and each of its agents.

How do I review this requirement?

A review of this clause would:

  • check that there is a current written contract on file for each of the signatory’s agents
  • note in the self-review report if the signatory has complied with this requirement
  • indicate the available evidence to support this assessment (i.e. the written contract for each agent which is on file)
  • (if the signatory has not complied with the requirement) outline planned and/or actioned improvements to ensure compliance now and in the future.

5.2 - Non-specified process requirements

When the Code makes a non-specified requirement, each signatory needs to consider the intent of the overarching outcome. Signatories can then develop a tailored response to the requirement.

For example, Clause 25 (1) (a) is a non-specified process requirement. It states:

“Each signatory must ensure that appropriate measures are put in place to address the needs and issues of international students at risk or with special needs”.

Here, a signatory must determine what measures are “appropriate” for its learners. This takes into account the signatory’s context, and the particular needs, issues, and desired outcomes of the international students. The precise approach (i.e. what the exact “measures” are) is up to each signatory.

Make defensible decisions based on quality evidence

Effective practice is based on thorough assessment of a student at risk or with special needs, using quality evidence. This informs what a ‘need’ or ‘appropriate measure’ is for the signatory.

A signatory must make defensible, evidenced-based decisions. An outsider should be able to examine the same evidence and reach a similar conclusion.
This evaluative, evidence-based approach should give a signatory confidence in its decision-making.

How do I review this requirement?

A review of this clause, aligned to the overarching intent of the outcome, would:

  • consider the profile of any learners at risk or with special needs (e.g. the student’s age, ethnicity, English language ability, level of need for first language support, length of enrolment period to date, communication with parents, desired educational outcomes, history of risk or special needs, information previously given, temperament, existing support network)
  • determine what measures would address the needs and issues of these learners (e.g. first language support, counselling, extra tutoring, communication with parents/homestay carer, medical assessment, medication, hospitalisation, deferral, extension, change of programme, mentoring, student buddy, adapted educational programmes/learning environments/materials/equipment)
  • assess whether the measures implemented during the review period have been appropriate (i.e. identify, gather, and analyse evidence) (e.g. information about students’ wellbeing, academic progress and achievement, integration, student/parent/residential caregiver/agent feedback, medical reports or confirmation letters, meeting notes, emails, academic and welfare monitoring notes)
  • use findings to plan for and/or make improvements (e.g. findings may suggest the organisation needs to communicate with parents and homestay carers earlier, routinely take notes at student welfare monitoring meetings, seek professional medical advice, identify more options for counselling support in the student’s first language).

5.3 Outcome statements

When assessing performance against the outcome statements of the Code, you need to review your organisation’s performance against the processes related to that outcome. Then you can consider if your organisation has met the overall outcomes.

Note that meeting all the processes does not necessarily mean you have met the outcome. The processes are minimum required processes. There may be more you need to do to meet the outcome, given your organisation’s context and your particular international learners.

For example, Outcome 1 states:

“Signatories must ensure that the marketing and promotion to prospective international students of services provided by signatories includes clear, sufficient, and accurate information enabling those students to make informed choices about the services provided.”

How do I review this outcome?

A self-review of this outcome would include:

  • checking your compliance with the specified and non-specified process requirements listed in clause 12 (i.e. “Did we develop and provide information to international students and keep it up-to-date?”
  • examining gathered information to consider performance against the outcome itself (i.e. “Did we develop and provide information that was “clear, sufficient, and accurate”? “What evidence tells us that this was so?”)
  • using your findings to plan for and/or make improvements.

Aim to be a high-performing organisation

The self-review process aims to give signatories confidence that they can manage their own performance. An organisation that embeds self-review know its strengths and weaknesses, what is working and what is not, and what it is doing about it and when.

A high-performing organisation does not have to be 100 per cent compliant at the time, or always exceeding every outcome of the Code. Instead, a high-performing organisation engages in reflective practice, continually reviewing its performance with an eye for improvement and progress.

It is an organisation that can be trusted to manage its own performance.

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