The architecture has two layers. The internal layer is your own process — a complaint, then an internal appeal if the student is dissatisfied. The external layer is independent. For private providers, the Overseas Students Ombudsman investigates complaints about provider actions — covering conduct, services, refund handling, and most administrative disputes. Where a matter concerns a tuition or academic decision, your policy should still name a clear external avenue. The essential point is that students must be able to escalate to someone who is not you, at little or no cost.