You will need to develop your own business process and maintain evidence of each student’s permission to create a USI on their behalf.
By accepting the Terms & Conditions of access to the USI Registry System, you declare that you have given to the individual, on whose behalf you are applying for a USI, the privacy notice that seeks their consent. The text of the privacy notice is built into the Terms & Conditions and you can also downalod the privacy notice here.
The legislation requires you to acknowledge that you have the student's permission in the terms and conditions on the USI Registry System. View the Student Identifiers ACT 2014