IHEA Submission | Higher Education Standards Committee Consultation Paper

IHEA's submission was lodged with the Higher Education Standards Committee on 7 September.  The Consultation Paper is seeking views to inform whether, and how, research security and national security governance expectations should be reflected in the Threshold Standards but does not set out specific proposed amendments for consultation.

IHEA considers that any changes to the Threshold Standards should build on the existing framework. The existing Threshold Standards already provide a substantive foundation for providers to identify, manage and provide assurance over risks relevant to these areas, including Standard 7.3.3(b), Sections 4.1, 5.2, 5.4, 6.2 and 6.3. Together, these provisions provide an existing framework through which relevant cyber security, research security and national security risks can be identified, managed and subject to appropriate assurance. The focus should therefore be on ensuring that these existing requirements are applied consistently and proportionately, rather than assuming that new prescriptive requirements are necessary.

IHEA is also concerned about the growing regulatory burden on providers arising from an approach of developing bespoke regulatory requirements to address each specific issue, rather than building on performance-based regulation and supplementing it with clear, practical guidance.

IHEA therefore recommends that a TEQSA SRE and supporting guidance would provide the additional clarity needed to apply and assure the existing Threshold Standards in relation to cyber security, research security and relevant national security risks. An SRE could explain how TEQSA expects the existing Threshold Standards to be interpreted and assured in relation to these risks.