Policy directive for training programs with online or hybrid delivery formats

Policy directive overview

The following overview summarizes this policy directive. Read the official directive.

The Superintendent of Career Colleges has established this policy directive to identify how a career college must operate when training students using an online delivery format instead of an in-person delivery format.

The policy directive states that career colleges must:

• Provide details of their online programming when they apply for approval of their program with the ministry.
• Confirm they will operate according to the superintendent's requirements (the standards for online and hybrid delivery) by signing an attestation, which is an agreement with the ministry.
  Note: The attestation template is available to registered career colleges when they apply for program approval.
• Inform students about any specifics of working online instead of in-person, such as the technical requirements, security concerns, student supports and impacts to schedules. These details must be added to the student contract when a student enrols, and the student must acknowledge the information by signing a student acknowledgement document.

Any policy directive establishes legal requirements that are binding and that must be followed by career college operators. Not meeting the requirements could lead to enforcement actions taken by the superintendent.

Policy directive

Authority

Subsection 53(1)(a) of the Ontario Career Colleges Act, 2005, authorizes the Superintendent of Colleges to issue policy directives setting out standards for vocational programs or classes of vocational programs.

Subsection 53(2) of the Ontario Career Colleges Act, 2005, establishes that policy directives issued by the Superintendent of Colleges are legal requirements that are binding on all career colleges. Every career college must comply with and operate in accordance with these policy directives.

Effective: March 14, 2022

Program approval

Pursuant to subsection 23(1) of the Ontario Career Colleges Act, 2005, vocational programs offered by career colleges require program approval by the Superintendent of Career Colleges. Career colleges seeking approval for programs which will include online or hybrid delivery formats must submit to the superintendent a program approval application that complies with the mandatory requirements outlined below and includes the supporting documents outlined below.

Mandatory requirements

Career colleges must meet the program standards set out below in the Standards for online and hybrid delivery for approval from the Superintendent of Career Colleges.

Applications for program approval must include:

• details of online or hybrid delivery in all relevant sections of the application
• a copy of the Attestation for online and hybrid delivery, completed and signed by the signing authority for the career college

• a copy of the student acknowledgement that the career college will provide to students, which identifies the mandatory supports and disclosures for students in programs with online or hybrid delivery formats

  Note: Career colleges may use the example provided in Student acknowledgement–online and hybrid delivery, or include the same mandatory supports and disclosures listed in the Student acknowledgment within their own student contract. This acknowledgment must be completed by students at the time the student contract is signed.

Enforcement

Under subsection 24(1) of the Ontario Career Colleges Act, 2005, a career college's program approval may be revoked if the superintendent believes that the program fails to meet the applicable standards set out in the superintendent's policy directives. If a career college does not comply with the requirement set out above, any or all of the following enforcement actions may be taken:

• issuance of a Notice of Program Revocation
• issuance of a Compliance or Restraining Order
• application to a court for a Judicial Restraining Order
• Proposal to Revoke or Refuse to Renew Registration
• prosecution for offences under the Ontario Career Colleges Act, 2005

Standards for online and hybrid delivery

Standards overview

The following overview summarizes the standards for delivering vocational training online. Read the complete delivery standards.

The requirements address important aspects of the delivery such as:

• Learning platforms
  The technology used to get program content to students who are not attending in person must be reliable, flexible, accessible, and secure.
• Student identity
  Students' personal information and identity must be protected and each individual student must be validated when they are working online.
• Orientation and training
  The requirements for technical support and orientation to ensure students can succeed online.
• Interactivity
  Students must be provided with an engaging postsecondary experience to enhance the learning potential.
• Copyrights, licenses and permissions
  Online programming must comply with any laws that apply to the material being delivered such as copyright or licensing requirements.
• Equipment for training
  Career colleges have to clearly outline what kind of device is needed to do their online program or provide the equipment to students and staff.
• Third-party program delivery partners
  If a career college partners with an organization to create program content, they are still responsible for the program.

Delivery standards

The career colleges seeking approval for programs which will include online or hybrid delivery formats must commit to meet the minimum requirements below by completing and submitting the Attestation for online and hybrid delivery in its program approval application.

An attestation is a formal declaration by the career college that the minimum requirements set out in this policy directive have been met.

Note: The attestation template is available to registered career colleges when they submit an application for program approval.

Falsely attesting to meeting the requirements set out below may be grounds for enforcement action under the Ontario Career Colleges Act, 2005. It is an offence under the Act to provide false information in a program approval application.

Supporting documentation may be requested by the superintendent to support the claims made in the attestation, as part of the ministry's oversight of career colleges and vocational programs.

Supporting documentation must be provided upon request.

Learning platforms

Note: A learning platform refers to program software or program technology specifically used to facilitate online learning, not to software, applications or computer programs required to perform functions also required for in-person learning. For example, if every student, regardless of whether they learn in-person or online, must use a certain program to prepare a report, create a schematic or complete a spreadsheet, that tool is not a learning platform.

Minimum requirements

1. Learning platforms must be reliable and flexible for students to access course content at their convenience.

• There must be at minimum an 18-hour daily access window, 7 days per week, for any online learning platforms where program content/materials are stored or where communications or skills building are expected to take place. This requirement applies to online learning platforms, not to synchronous instruction provided by staff.
• Software and technology for online learning must be supported, with a minimum support window of 2 years past the program application date. Once a software or technology is no longer supported, a plan to retire the legacy software or technology must be put in place and a program change initiated with the superintendent. If a  career college wishes to continue using legacy software or technology for historical or other purposes, the superintendent may request a rationale for their use.
• Videoconferencing software must have the following functions: lock meeting, waiting room and remove, suspend, or report participant.
• Audio/video hardware requirements must not extend beyond basic sound cards, speakers, and video players unless needed to meet learning outcomes/objectives.
• Audio/video software requirements must be compatible with multiple operating systems and require only a standard, free plug-in, unless needed to meet learning outcomes/objectives.
• Planned service outages that affect user access must be communicated 24 hours in advance and scheduled outside of students' daily access window when possible.
• Students must be provided with individual user access, limited to student-only functions, for any platform where program contents/material are stored, or where communications or skills building with respect to the program are expected to take place.
• Potential students must be given the opportunity to access a sample of the learning platform prior to enrolment.
• Access to the learning platform cannot be limited or restricted to less than the total number of potential users (including administrators, instructors and students) at any time during the daily access window.

2. Learning platforms must be reinforced with technical and administrative support.

• Career colleges must provide any student enrolled in online or hybrid programs with direct contact information and the service schedule for at least one career college administrative staff member who will:
  • have the knowledge and technical ability to provide basic assistance to navigate and operate the learning platforms used for all programs.
  • be responsible for assisting students and instructors and liaising with technical professionals as needed if unable to resolve the IT issue.
  • have sufficient workload capacity to assist students and instructors with complex IT issues within two business days of a request.
• Students waiting to have IT issues resolved must be provided with alternative instruction from a qualified instructor so that students can continue learning.

3. Career colleges must have protocols/policies regarding security breaches.

• Career colleges must create or update protocols/policies for security breaches.
• Security breach protocols/policies must apply to information stored in all databases and platforms used for online or hybrid instruction. They must outline the process for investigating these breaches and for preventing future breaches.
• Confidentiality agreements must be in place for all staff and administrators of all databases and platforms used for online or hybrid instruction.

4. Learning platforms must be reinforced with security features to protect student personal information or coursework stored within the platform.

• If personal information is collected from users of learning platforms used for online or hybrid instruction, a notice of collection must be provided to the users (for example, students, instructors, administrators, etc.) regarding the collection, use, retention and disclosure of their personal information. Any existing collection notices must be updated to include reference to online learning platforms and any data kept within.
• Career colleges must regularly monitor information storage services to ensure the least amount of access is maintained (for example, to remove old/non-active users, re-evaluate permissions needed, etc.) Any necessary information linked to the user should be backed-up and stored under an administrator access level to meet obligations for record retention (for example, attendance records).
• Any learning platforms or databases used for online or hybrid instruction must have encryption capabilities for e-mail and stored documents if those features are available.
• Career colleges must tailor user access according to the specific functions and authority of the user.
• Learning platforms or databases must be reinforced with regular updates and patches to ensure any new security features are applied to the technology in use.

5. Learning platforms and internal resources must incorporate design elements to improve accessibility for a variety of learners.

• Design elements that must be incorporated to improve accessibility include the use of visual contrast between the text colour and background, the use of non-decorative font, the appropriate use of typographical emphasis (for example, bolding, underlining, colour changes) and appropriate use of white space and alignment.
• Program materials to support online or hybrid delivery must indicate that supports and alternative materials may be made available on request to learners who require accommodations

Student identity

Minimum requirements

1. Career colleges must establish a system for verification of student identity.

• For learning platforms that career colleges provide for students to access independently, a secure user ID and password must be assigned. If not already verified as part of the student's enrolment, the student's identification must be validated and recorded by the career college in order to receive this user ID and password. If a student is unable to supply photo ID as part of this verification process, an in-person or online synchronous confirmation must be included in the validation. Students must be prompted by the learning platform to log-in at the beginning of every online session.
• For platforms where students do not have independent access, visual or audio confirmation of identify must be performed at the beginning of any online synchronous training session.
• All students must be required to keep passwords and user credentials confidential and not permit someone else to take part in their online evaluations in their place. This expectation must be communicated to the student by the career college and acknowledged by the student upon enrolment.

2. Career colleges must establish a secure method of conducting student evaluations, including any asynchronous evaluations.

• Written evaluations must be communicated through a secure method only accessible by the relevant student and instructor (e-mail, secure mailbox in learning platform, secure cloud service such as a drive or Drop-box).
• Online synchronous evaluations must be performed in an environment where a student can provide visual confirmation of their attendance (enable a camera) or performed in an in-person location.
• Students must agree to keeping passwords and usernames confidential and to not permit someone else to take part in their online evaluations in their place. This expectation must be communicated to the student by the career college and acknowledged by the student upon enrolment.

Orientation and training

Minimum requirements

• Instructors must be provided with a specific written training supplement or training session on the learning platform(s) and the features particular to instructor access level.
• Students must be provided with specific written orientation supplement or orientation session on the learning platform(s) and the features particular to student access.
• The above supplements and sessions must explain how to access technical and administrative support (see above requirements for technical and administrative support) and additional training/orientation materials.
• Students must be informed of the superintendent's policy directive for training programs with online and hybrid delivery formats.
• Students must be informed of how a career college's refund policy, expulsion policy and complaint procedure apply when studying via an online or hybrid delivery format.

Interactivity

Minimum requirements

• Instructors must communicate expectations for independent study (asynchronous hours) at the beginning of the program and provide preferred contact methods and details for support and questions.
• Learner-instructor synchronous interaction must be present in at least one subject in the subject outline of the application for program approval.
• Student contracts must list the delivery format by subject and confirm that the student and career college agree on the format for program delivery, including which online subjects require synchronous participation.

Copyright, licenses, and permissions

Minimum requirements

• Music, images and content present in the curriculum or instructor lessons must be obtained legally and not subject to any outstanding royalties or copyright limitations.
• Online sourced materials must be listed in a bibliography and provided to students.
• Links and online source materials must be tested prior to each cohort's start date.
• Licenses purchased for learning platforms or technology must be kept on file and available to the superintendent on request.
• Career colleges must not rely upon free trials for technology, software, or applications present in the online or hybrid curriculum or in instructor lessons.

Equipment for training

Minimum requirements

• Equipment and software made available to instructors must be in good working order, in the format required and be sufficient for the anticipated number of students.
• Equipment and software provided to students directly must be in good working order and in the format required.
• Students must be provided with clear standards for their own equipment and software (in writing) prior to enrolment in the program. These standards must be included as pertinent program details in any program description.
• Minimum standard of internet service required for studies must be communicated (in writing) to students prior to enrolment in the program and included as pertinent program details in any program description.

Third-party program delivery partners

Minimum requirements

• Career colleges must provide a description in the program application of how the third-party program delivery partner will deliver any aspects of the program.
• Career colleges must disclose the name of any third-party provider of program content or instruction in the program development section of the program application. It is not necessary to identify in the program development section any third party contracted to provide IT or internet services to support the technical delivery of online or hybrid delivery.
• Career colleges' Attestation for online and hybrid delivery must include confirmations that:
  • learning platforms maintained by third parties also meet the minimum requirements outlined in this policy directive.
  • third-party agreements do not release the career college from the obligation to deliver the program as approved by the superintendent.
• Career colleges must be prepared to provide an alternative path for students to continue learning in the event the third-party experiences technical difficulties or fails to produce the content within a reasonable time frame for any reason.

Student acknowledgement

The student acknowledgement documents detailed below must be attached to a student enrolment contract when a student participates in online or hybrid programming delivered in-person or online.

Career colleges may use the example provided below or include the same mandatory supports and disclosures listed here within their own student contract. This acknowledgment must be completed by students at the time the student contract is signed.

Note: A program delivery breakdown, noted in the example student declaration below details the program's components. It can be added to an original contract, to the student acknowledgement document or as a separate document added as an attachment to the contract.

Example student declaration