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The Risks of Online Delivery of the White Card

Whether white card training can be effectively delivered online is primarily a matter of risk management. The risk management process requires that the risks involved in delivering the course online need to be identified, control measures put in place to control the identified risks, and these control measures monitored and periodically reviewed.

Identified risks.

ASQA’s national strategic review of the white card identified many issues with the existing delivery of the white card online. Two that stood out were verifying of the identity of a student, and delivery and assessment methodologies that tested not just the knowledge of the students, but also their skills.

In the white card course, the skills that needed addressing were specifically identified as verbal communication skills.

The primary risks identified were with regard to:
• Risk 1: The authenticity of the student
• Risk 2: The validity of the assessment processes

Risk control measures.

The control measures implemented by the Regulator to control these risks were:
• The use of a Statutory Declaration signed by the student and an observer, that the student completed the course without assistance, and
• Having the student’s identification documents certified by a Justice of the Peace

The control measure used to control the risk of student assessments not receiving adequate training in knowledge and skills, was to phone-verify 5% of students by the issuing RTO.

In summary, the primary risk control measures put in place were:
• Control 1: Statutory Declaration
• Control 2: JP certifying a student’s ID
• Control 3: Review 5 % of white card recipients

Monitor and Review the control measures.

A critical link in the risk management process is to monitor and review the effectiveness of control measures, and make changes if the controls are not effective.

This poses some important questions regarding the online delivery of the White Card.

At any stage has a review been conducted on the effectiveness of Statutory Declarations as an effective control measure?

Is the review of just 5% of recipients by an RTO sufficient in measuring the quality of training received, and just as importantly that the Statutory Declarations are working as a control measure as intended?

Has the Regulator conducted its own verification of White Card recipients to determine whether training outcomes are being achieved?

The use of a Statutory Declaration as a risk control measure has significant problems. Although the penalty for fraudulently signing as Statutory Declaration may act to some degree as a deterrent, it is very difficult to imagine how the Regulator could determine that some form of malpractice has occurred. The person completing the course or the observer would need to make admissions to the Regulator that they made a false declaration with regard to how the training had been conducted. And for that matter, has anyone ever confirmed the details of the JP who has signed the Statutory Declaration?

There is another aspect of the online delivery of the white card from a risk management perspective that is worth looking at. That is the Hierarchy of Risk Control.

The Risk Management Hierarchy of Control

  1. Eliminate the Risk
  2. Substitute with a lesser risk
  3. Isolate the risk
  4. Engineer out the risks
  5. Administration controls
  6. PPE n/a

The purpose of the Risk management hierarchy of control is to identify the best way in which control methods should be implemented in a system. The goal is to strive to achieve the highest level of risk control possible, with the elimination of risk the preferred option. Excluding the use of PPE which is not relevant to delivering the white card, Administrative controls are the lowest level of risk control.

At present, most of the online delivery of the white card relies primarily on the Statutory Declaration as a risk control measure. Since this is an administrative control, it is the lowest level of risk control in the hierarchy.

By using Ammonite’s VAT system we are striving for the highest control measure – trying to eliminate the risk.

For the risk involving the authenticity of the student, this is twofold.

It involves confirming the identity of the student using their webcam to record their photo identity and profile picture, and recording images of the student as they complete each assessment during the course.

For the risk involving the validity of assessment, it involves ensuring that not only is the student’s knowledge tested in a manner that assures they understand the material delivered, but critically that they are tested in their comprehension and verbal communication skills.

This is done using Ammonite’s unique assessment methodology and video assessment technology using the webcam.

So in my opinion the argument that the use of Statutory Declarations is an effective control measure in the online delivery of the white card is inherently flawed because it simply defies good risk management processes. It is the very least that could be done to ensure that online training is free from risk.

And aside from this, it is very clear from ASQA’s national strategic review into the online delivery of the white card that industry and other stakeholders have lost faith in the current online delivery methods. That in itself indicates a failure in the use Statutory Declarations as a risk control process.

Ammonite’s approach to online delivery has been described by some as ‘overkill’. I see it as simply striving to achieve the best outcomes for our students and industry – renewed confidence in online training.

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