You want to show what it’s like to work at your clinic: the team, the rosters, how new graduates are supported. You also know the advertising rules for health services are strict, and you’d rather not find out where the line is from a letter.
The short answer: you can show workplace culture if the content is about the job (rosters, mentoring, tools, the team) and not about clinical care. Check it as carefully as you’d check patient advertising, because patients will see it too.
This article gives you three questions to ask about any post, page or video, a way to sort culture content into safe and risky, and rewrites for lines that cross the line. It also says plainly where the rules are unclear.
Before you rely on this
This is general information, not legal advice. It draws on Ahpra’s published advertising guidelines and advertising FAQ. Ahpra can update these, so check the current versions.
Terms: Ahpra is the Australian Health Practitioner Regulation Agency. It works with the National Boards for each profession. The advertising rules sit in the Health Practitioner Regulation National Law. “Culture” here means workplace culture, not cultural safety.
Scope: the rules cover advertising a regulated health service, meaning a service provided by, or usually provided by, a registered health practitioner. If your clinic offers only services that aren’t regulated, other codes may apply.
Not covered: building an employee value proposition or setting pay. See what candidates check before applying.
Quick answers
| Your question | Short answer |
|---|---|
| Can we post team photos? | Yes, with accurate titles and sensible clothing and captions. |
| Can staff say why they like working here? | Yes, if they talk about the job. |
| Can staff praise the quality of our care? | No. Treat it as a testimonial risk. |
| Can we put patient reviews on a careers page? | No. We’d keep them off recruitment pages. |
| Can we show our Google star rating? | Unclear. We’d leave it off. |
| Can staff share our posts on their own accounts? | Yes, with a short policy. |
| Can we film a day in the life of a clinician? | Yes, with no patients and no claims about results. |
| Can we use the word “specialist”? | Only if the person has specialist registration. |
| Do the rules cover job ads? | Unclear. Treat anything patients can see as advertising. |
| Can we show a patient’s thank-you card? | No. |
| Who is responsible if our agency posts it? | Assume you are. The agency may share the risk. |
Why culture content can fall under the advertising rules
Section 133 of the National Law lists five things advertising for a regulated health service must not do:
- Be false or misleading.
- Offer a gift or discount without stating the terms.
- Use testimonials.
- Create unrealistic expectations of results.
- Encourage people to use health services they don’t need.
Nothing on that list mentions workplace culture. Posts about rosters, mentoring or team size aren’t what the rule is aimed at. Culture content gets caught in one of three ways:
- It refers to clinical care. That turns a comment into a testimonial (defined below).
- Patients can see it and read it as promotion. Ahpra tells advertisers to think about the overall impression, including who the audience is and what the content will mean to them.
- You control it or have adopted it. Ahpra treats the “advertiser” as whoever publishes or approves the content, or can edit or remove it. That includes content written by a staff member or an agency. Sharing someone else’s comment about clinical care can count as advertising.
The rest of this article helps you spot those three things early and fix them.
What counts as a testimonial under AHPRA?
Under Ahpra’s guidelines, a testimonial is a recommendation or positive statement about the clinical aspects of a regulated health service, used in advertising. Clinical aspects include symptoms, diagnosis, treatment and outcomes.
Comments about non-clinical things, such as friendly staff or easy parking, aren’t testimonials. Fake testimonials are also banned. Ahpra calls them “purported” testimonials. Ahpra’s testimonials page explains the test and confirms the ban is still in force.
You may still see articles saying the ban is about to be lifted. A proposal to remove it in 2022 was withdrawn that September, and Health Ministers said the question would be reviewed later. Check Ahpra’s current position before you rely on any older article.
Do the rules cover recruitment content?
We couldn’t find an Ahpra statement that settles this, and Ahpra says it can’t approve advertising in advance or give advice on it. Be wary of any page that gives a flat yes or no.
Here is the problem. Ahpra defines advertising by its purpose: communication that promotes a provider to attract a person to the provider or its services. Section 133 also covers advertising a business that provides a health service. And the wording is “attract a person”, not “attract a patient”. That could be read to include job applicants, which is one reason for the cautious approach below.
What matters more in practice is that a careers page rarely stands alone. It sits on the clinic website, often under the same footer as patient reviews. It’s linked from the same Instagram profile and Google Business Profile that patients use. A page written for candidates is still read by patients.
| Status | Where things stand |
|---|---|
| What is clear | The advertising rules apply to anyone who advertises a regulated health service, registered or not. A testimonial is about clinical care. Ahpra won’t approve content in advance. |
| What is unclear | Whether a job ad or recruitment post counts as advertising. How Ahpra would treat a careers page that patients can also see. |
| What we’d do for now | Treat anything patients could plausibly see as advertising, until a health lawyer, your indemnity insurer or your professional association tells you otherwise. |
This costs you very little. The content it allows is also what candidates compare clinics on.
Where patients are likely to see your content (our estimate)
| Channel | Patients likely to see it? | Who controls it | What to do |
|---|---|---|---|
| Careers page on the clinic website | High | You | Follow the advertising rules |
| Practice Instagram, Facebook or TikTok | High | You | Follow the advertising rules |
| Clinic LinkedIn page | Medium | You | Follow the advertising rules |
| Job board listing or employer profile (SEEK, Indeed, HealthcareLink, AusDoc Jobs) | Low to medium | You | Be cautious |
| Employer reviews on SEEK, Indeed or Glassdoor | Low to medium | The platform | Don’t quote selectively |
| Staff personal accounts | Varies | The individual | See the staff accounts section below |
Three questions to ask about any post, page or video
Ask these in order.
- Do we control it? Did we publish it, approve it, or adopt it by sharing, pinning or embedding it? If not, it isn’t our advertising, but don’t promote it either. If yes, go to question 2.
- Could a patient read it as promoting us? If you’re unsure, answer yes. If not, your exposure is lower. If yes, go to question 3.
- Does it contain any of the warning signs below? If not, publish. If yes, rewrite it or get advice.
| Warning sign | Examples | Why it matters |
|---|---|---|
| A reference to clinical care | Symptoms, diagnosis, treatment, results, a practitioner’s skill | This turns a comment into a testimonial |
| A results claim, comparison or superlative | “Best”, “leading”, “we get results” | Can be misleading or create unrealistic expectations |
| Patient material | Reviews, thank-you cards, stories, photos, voices | A testimonial problem and a privacy problem at once |
| A discount or gift for patients | Offers, especially without terms | Section 133 requires the terms to be stated |
| A title or look that suggests registration | “Dr”, “specialist”, scrubs on non-registered staff | Can mislead about who is registered |
For anything you’re unsure about, try Ahpra’s self-assessment tool. It helps you check your content but doesn’t approve it. Your profession’s National Board may also publish its own advertising statements.
Sorting culture content into green, amber and red
This is our own way of sorting content. It isn’t an Ahpra classification.
| Tier | What it covers | Examples | What to do |
|---|---|---|---|
| Green | Facts about the job, with no mention of patients | Rosters, mentoring, CPD funding, clinical software, team size, how long people stay, how to apply | Publish, and check it regularly |
| Amber | People content close to care | Team pages and bios, “why I joined” quotes, awards, ratings | Check against the warning signs, then have someone approve it |
| Red | Anything that refers to clinical care or uses patient material | Results stories, patient reviews, skill claims, before-and-afters, patient discounts | Don’t publish without advice |
Staff testimonials vs patient testimonials
The short answer: a staff comment about working at your clinic (mentoring, rosters, support) isn’t a testimonial under Ahpra’s definition, because it isn’t about clinical care. A staff comment that praises the quality or results of care is likely to be treated as a testimonial, or at least as a claim about care that needs evidence. We’d treat it as red.
This causes confusion because employer-branding advice often says “use testimonials” while AHPRA guides say “don’t”. They mean different things. Staff recommending the job is standard employer-brand material. Patient testimonials about clinical care are what the National Law prohibits in advertising.
The risk is drift. “I have a named mentor and I finish on time” is about the job. “Our patients get brilliant results here” is about care. Staff slide from one to the other easily, because patient outcomes are what motivate most people in healthcare. Ask three questions about every staff quote:
- Would it still be true for someone in a non-clinical job?
- Does it say anything about results or the quality of care?
- Does it hint at a patient?
Yes, no, no is probably fine. The quote must also be the person’s real words, and they must have approved it. A quote the person never said, including one written by AI, would be misleading anyway.
Advice that collides with the rules
Some employer-branding advice is written for employers generally and ignores the advertising rules.
| The advice | The problem | What to do instead |
|---|---|---|
| “Show how your patient outcomes have improved” | A clinical claim in content patients can see | Show your supervision, teaching and support structures |
| “Share testimonials from your team” | Fine if about the job, risky if it praises care | Use the three staff-quote questions above |
| “Show patient reviews to prove you’re busy” | Quoting or embedding reviews on your own pages is using them to advertise | Keep patient reviews off recruitment pages |
| “Have a senior clinician write up an unusual case to show depth” | Invites patient identification and claims about skill or results | Explain how supervision and case discussion work, without cases |
| “Add a general disclaimer” | We found nothing suggesting a disclaimer fixes a breach | Fix the content |
What good green content looks like
Knowing what to avoid is half the job. These formats are low risk and give candidates something to compare. The captions are patterns, so fill the brackets with facts that are true today.
| Format | What to show | Caption pattern |
|---|---|---|
| A week on the roster | Sessions, hours, appointment length, admin time | “[Role] at [clinic]: [X] sessions a week, [X]-minute appointments, admin time on [day].” |
| Meet the mentor | Who mentors new starters and how it works | “[Name] mentors every new [role]. First month: [X] hours a week together.” |
| First 90 days | A colleague describing their own start, in their own words | “[Name] started in [month]. Here’s what weeks 1, 6 and 12 looked like.” |
| Tools and rooms | Software, equipment, treatment rooms with no patients | “What you’ll use here: [software], [equipment], [X] rooms.” |
| How supervision works | The structure, with no cases | “Case discussion runs [day] at [time], led by [role].” |
| Study and CPD | Funded courses, study leave, who completed what | “[X] days of study leave a year. This quarter: [course].” |
| Getting here | Parking, transport, nearby schools, local life for people relocating | “[X] minutes from [station]. Parking on site.” |
| How we hire | Steps, timeline, who you’ll meet | “Apply, [X]-minute call, visit, offer within [X] days.” |
Asset by asset: what to publish, change or hold back
What should a careers page include, and what should it leave out?
Publish: role details, session structure, the team, tools, supervision, how to apply.
Change: check the page template. Review widgets and testimonial banners can be set to show on every page, including pages you think of as “for staff”. If the template is the problem, it’s a website structure fix, not a copywriting one.
Hold back: links from careers content to results pages or outcome statistics.
Can we show our team and use titles like “Dr” and “specialist”?
Publish: names, roles, qualifications, languages spoken, accurate titles.
Change: if “Dr” is used for someone who isn’t a registered medical practitioner, Ahpra says the advertising should make clear which profession they’re registered in. Words such as “specialist” and “specialises in” are likely to mislead unless the person holds specialist registration. “Substantial experience in” and “working primarily in” are less likely to. The FAQ covers titles in detail.
Hold back: photos of non-registered staff in scrubs or with stethoscopes under a “clinical team” caption. Clothing and captions shouldn’t suggest a registration someone doesn’t have.
Can staff talk about why they joined?
Publish: the job itself: supervision, flexibility, development, how the team works.
Change: anything about “the care we provide” or “the difference we make”.
Hold back: any story involving a patient, however much you de-identify it. In a small community, “a patient came in for X” can identify the person to everyone who knows them.
Can we film a day in the life?
Publish: schedules, rooms, equipment, handovers, team routines.
Change: voiceover claims such as “watch how fast we fix this”. Check screens, whiteboards and charts in the background. Get written consent from staff who appear, with a way to withdraw it.
Hold back: any patient in frame.
Can we show awards, ratings and employer reviews?
Publish: a third-party award badge, with the awarding body and year. Ahpra’s FAQ says a symbol, rating or title of an award from a review website doesn’t fit the meaning of a testimonial. That answer is about awards, and Ahpra’s example is an award based on patient reviews. Publishing the award is not likely to breach the ban unless you also republish the testimonials behind it.
Change: employer reviews are about the job, so the testimonial rule isn’t the main worry. Selective quoting is. Ahpra warns that editing reviews can make them misleading. If an employer review praises clinical quality, treat it as red content.
Hold back: an overall star rating from your own patient reviews. The FAQ doesn’t address this directly. A health lawyer may tell you it’s fine, but until then we’d leave it off careers pages.
What about job boards, recruiters and employer profiles?
Ahpra treats content you approve, or direct someone to publish, as yours, and that includes agencies. If a recruiter or job board runs copy you supplied or approved, treat it as your advertising. Employer profile pages with staff recommendations are fine when the recommendations are about the job.
Pay claims must be true and the conditions stated, and job ads must avoid discrimination. For how to structure the ad itself, see our guide to writing a GP job ad.
Can staff share our posts on their own accounts?
If staff reshare posts you’ve approved, that’s simply distribution. The risk starts when they add their own claims (“our results are brilliant”), because anything that promotes the clinic can count as advertising.
Registered practitioners have a second layer. They must also meet their profession’s code of conduct on any account they hold, and Ahpra’s social media guidance explains how. Staff who aren’t registered aren’t bound by those codes, but your employment terms can set rules for them.
A “views my own” line in a bio doesn’t change how the regulator sees a registered practitioner. For the channel side, see using social media to attract clinicians.
Do cosmetic clinics face extra rules?
Yes. Ahpra publishes separate guidelines for advertising higher-risk non-surgical cosmetic procedures, on top of section 133, and naming a prescription-only medicine can raise therapeutic goods advertising issues that sit with the TGA, not Ahpra. Take legal advice before publishing any culture content that shows procedures.
The rewrite library
Below are risky culture lines next to safer versions. The examples are made up, so replace the [brackets] with your own facts, and only use a rewrite if it’s true for your clinic today.
| Risky line | Safer version | Why the original is risky |
|---|---|---|
| “Join the team that changes lives.” | “Four days a week, [X]-minute appointments, a nurse who runs recalls.” | Promises results |
| “Our physios get patients moving again, fast.” | “Every new physio has a named mentor and a protected hour each week.” | Promises results |
| “Join the best dental team in [suburb].” | “[X] dentists, [X] assistants, [X] front desk staff, with on-site sterilisation.” | Unproven claim |
| “Australia’s leading GP clinic.” | “A [X]-GP practice with on-site pathology and a registrar supervisor.” | Unproven claim |
| “A patient hugged me today. This is why we do it.” | “[Name] joined as a new graduate in March. Here is what her first 90 days looked like.” | Works like a testimonial |
| “‘The quality of care here is the best I’ve seen.’ [Name], Nurse” | “‘[Their own words about supervision, rostering or support.]’ [Name], Nurse” | Praises care, so works like a testimonial |
| “Meet Dr [Name], our skin specialist.” | “Dr [Name], GP with substantial experience in skin checks.” | Can mislead about registration |
| “Our clinical team” (front desk staff pictured in scrubs) | “Our front desk team” in business clothing, or captions that state each role | Suggests a registration someone doesn’t have |
| “Staff get free treatments!” | “Benefits are set out in the offer pack.” | Offer without terms |
| “Earn $400k with us.” | “Paid [X]% of billings, with a $[X] an hour guarantee for [X] months.” | Unsupported claim |
| “Watch Dr [Name] fix a back in 30 seconds.” | “Dr [Name]’s Tuesday: handover at 8:00, first appointment at 8:30, admin time at 12:30.” | Promises results |
| “Voted best clinic by our patients!” | “[Award name], [year], [awarding body].” | Works like a testimonial if you republish the reviews behind it |
What you control and what you have adopted
You aren’t responsible for every review a patient leaves on a site you don’t control. Ahpra’s FAQ says so. You are responsible for what you publish and for what you adopt. A review sitting on Google belongs to the platform. The same review quoted in a Highlight or pinned to your profile is yours.
The FAQ also answers whether you can edit reviews, whether a birth story counts as a testimonial, and how award symbols work. Read those answers before you decide.
Audit what you have adopted
- Review widgets or plugins on any page, including footers and page templates
- Facebook reviews tab and recommendations. Ahpra treats the ability to delete reviews or turn the review function off as control.
- Pinned comments, Highlights and Stories
- Posts you’re tagged in, and anything you’ve reshared
- Replies that celebrate an outcome (“so glad we fixed your knee!”)
- Google Business Profile posts, photos and Q&A
- Old posts by former staff or former agencies
- Admin access held by people who have left
For public replies to patient feedback, we’d keep it to a short thank-you that confirms nothing clinical.
Who is responsible: owners, staff and agencies
Ahpra treats the advertiser as the person or business who controls or approves the content, including content written by a staff member or a marketing agency. It says advertisers must check content produced for them by others. Assume you carry the risk, and expect that your agency may share it.
A minimum system
- One named owner for every account, including old ones.
- A check before anything is published using the three questions above.
- Separate consent for patients and for staff photos or video. A patient’s consent covers privacy. It doesn’t stop a testimonial being a testimonial. Ahpra’s FAQ says a birth story shared on a clinic’s own channels is likely to count as one.
- A clause about personal accounts in employment and contractor agreements.
- Approval rights in any agency agreement, so nothing about treatment, results or offers goes out without your sign-off.
- A habit of taking things down when something goes out that shouldn’t have.
- One fact sheet (sessions, hours, team, tools, how to apply) that every careers page and job ad draws from, with an owner and a last-checked date. Our employer branding guide shows how to build it.
A sample clause about personal accounts. Have a health lawyer check this before you use it.
You may share the practice’s approved posts. When you promote the practice, don’t post about patients and don’t make claims about treatment results or the quality of our care. Don’t present personal views as the practice’s. Registered practitioners must also meet their professional conduct obligations on every account they hold.
If you run several sites: set the rules and templates centrally for green and amber content. Let each site add local stories within those templates. Never create red content locally. Our post on central versus local marketing for groups covers the wider approach.
If content that breaks the rules is already live
- List your public content, starting with whatever patients are most likely to see.
- Fix the worst first. Anything that refers to clinical care, uses patient material, or hasn’t been checked in a long time comes before the rest.
- Remove your own use of reviews and patient stories. Don’t edit or cherry-pick reviews.
- Write down what you changed and when.
- If a complaint arrives, correct the content quickly and get advice from your indemnity insurer, professional association or a health lawyer.
Ahpra’s FAQ says low and medium-risk breaches are generally handled administratively and closed once corrected. If breaches aren’t corrected, or keep happening, the National Board can consider placing conditions on registration.
High-risk matters are prioritised for investigation, prosecution or disciplinary action. Visible content carries risk whether or not anyone is actively looking. Maximum penalties for advertising offences have increased in recent years, so check Ahpra’s current figures instead of relying on older articles.
Questions that are still open
For every question below, the right person to ask is a health lawyer, your indemnity insurer or your professional association.
| Question | What we know | What we’d do for now |
|---|---|---|
| Do job ads and careers pages count as advertising? | Ahpra defines advertising by its purpose, and section 133 also covers businesses. Nothing we found settles recruitment content. | Treat anything patients can see as advertising |
| Can we show an overall Google rating near culture content? | The FAQ covers award symbols and ratings from review websites, not an overall rating on your own page. | Leave it off |
| Is an AI-generated team photo or staff quote a problem? | Untested. A quote the person never said is misleading anyway. | Don’t use them |
| Can we advertise staff discounts on treatment as a perk? | A public offer might fall under the rule on gifts and discounts, which requires terms to be stated. | Describe benefits in the offer pack, not publicly |
| Does a separate careers website change things? | Only if the audiences really differ. A shared brand, footer or link means patients can find it. | Treat it the same |
Where a marketing partner fits
A health lawyer, insurer or professional association can tell you whether specific content breaks the National Law, settle the open questions above, and help if Ahpra writes to you. A marketing partner can’t do any of that.
What a marketing partner can do is the practical work: building a check and approval process your team will use, auditing your site and profiles for review widgets, pinned comments and old posts, and producing green content such as team pages, video and careers pages.
That’s where Pracxcel can help, through organic social and Google Business Profile support and website work. We don’t give legal advice, and no agency can certify your content as compliant. If you’d like to talk through what you have live now, contact the Pracxcel team.
