Complaints Policy and Procedures November 2024 Information Classification: Internal If printed this document becomes uncontrolled Document Reference Number 5POAD10 Complains Policy and Procedure V21.0 November 2024 Page 2 of 9 Information Classification: Public If printed this document becomes uncontrolled Version 21.0 Contents 1. Introduction ............. .................................................................................................... 3 1.1. Purpose .................................................................................................................................................... 3 1.1.1. Scope of policy .................................................................................................................................. 4 2. The regulators ........................................................................................................................................... 4 2.1. Regulatory requirements..................................................................................................................... 4 2.1.1. Situations brought to our attention by the regulators ............................................................ 4 3. Responsibilities ......................................................................................................................................... 4 4. Confidentiality and data protection ..................................................................................................... 4 4.1. Anonymous complaints ....................................................................................................................... 5 5. Review arrangements .............................................................................................................................. 5 6. Learner complaints about a CSDTA................................................................ 5 7. Making a complaint about CSDTA................................................................................. 6 8. Regulator contact information .......................................................................................... 7 Document Reference Number 5POAD10 1. Introduction 1.1. Purpose In keeping with our core values, we understand how important it is for you to receive a first class service; however we recognise that sometimes things can go wrong. It is therefore important that we have an effective means for you to bring this to our or the approved centres’ attention, with an expectation of resolution. The complaints policy: • • • • • • outlines the complaints process defines what constitutes a complaint indicates which other policies and procedures might be more applicable sets out the process for making a complaint to CSDTA explains the steps taken to resolve complaints and timescales outlines how to escalate a complaint to the relevant regulator A complaint is an expression of dissatisfaction with an aspect of the service provided by your centre or awarding organisation, which is deemed to have fallen below your expectations and our/your centres’ own standards. Customers who wish to convey an expression of dissatisfaction should make sure they follow the relevant policy and/or procedure. Issues relating to assessment decisions should be addressed using the Enquiries and Appeals Policy and Procedure and others may be covered by the Malpractice and Maladministration Policy and Procedure. All policies are available on the CSDTA https://www.cityskindoctor.com Complainants who are unsure of the correct policy or procedure to follow should contact us for advice: +44 (0) 2920486868 / info@cityskindoctor.co.uk Complaints should be made by the centre/person(s) directly affected by the matter, or a person acting on their We, with their written permission. Complaints can normally be resolved informally; if this is not achieved a formal complaint can be raised without delay and by no later than 20 days after the occurrence of the issue which gave rise to the original complaint. Complains Policy and Procedure V21.0 November 2024 Information Classification: Public Page 3 of 9 If printed this document becomes uncontrolled Document Reference Number 5POAD10 1.1.1. Scope of policy This policy is provided for the use of: • • • learners who are or have been registered for CSDTA qualifications; personnel with responsibilities for managing, delivering, assessing and quality assuring qualifications in approved centres offering CSDTA qualifications; members of the public accessing our services; who wish to make a complaint in relation to the qualifications and associated services offered by CSDTA or one of its approved centres offering CSDTA qualifications; 2. The regulators 2.1. Regulatory requirements This policy addresses the requirements of the relevant regulatory authorities’ criteria. 2.1.1. Situations brought to our attention by the regulators Where the regulators notify us about failures that have been discovered in the assessment process or other activities of another awarding organisation, we will review whether or not a similar failure could affect our own processes and arrangements. 3. Responsibilities CSDTA personnel are required to follow the related procedures in order to investigate complaints as transparently, consistently and effectively as possible. Centres are responsible for ensuring that all personnel involved in the management, delivery, assessment and quality assurance of CSDTA qualifications are fully aware of the policy and conversant with the related procedures. Centres must have their own internal complaints policy and procedures in place to deal with complaints from learners and members of the public, and must provide easy access to them. Centres who fail to have their own complaints policy and procedures, or to make them available to learners and members of the public, are in breach of the centre agreement. 4. Confidentiality and data protection In following this process an individual might provide us with confidential information, and during our investigation we may need to request information of a confidential nature. Complainants are assured that CSDTA complies fully with data protection legislation at all stages. We ensure that confidential information is kept securely and used only for the purposes for which it is intended. Complains Policy and Procedure V21.0 November 2024 Information Classification: Public Page 4 of 9 If printed this document becomes uncontrolled Document Reference Number 5POAD10 4.1. Anonymous complaints Anonymous complaints cannot be considered. CSDTA will note their contents and may seek to verify them if this is possible and appropriate. We may include related information in our review activities. 5. Review arrangements This policy is reviewed annually as part of CSDTA’ self-evaluation activity, which includes consideration of customer and regulatory feedback and good practice guidance. A policy review may also be triggered as an action resulting from the outcome of the investigation of a complaint. 6. Learner complaints about a CSDTA centre Your training centre is the organisation that is responsible for delivering your course and who you have signed up to and paid money to. If you have a complaint about your centre you must take this up with the centre through their complaints process in the first instance. If you are unable to locate your centre's complaints policy please contact the centre directly by phone/post or in person. If you are not satisfied with any of the following then you must take this up with the centre directly as CSDTA do not have any remit to intervene in such matters. • Financial transactions with the centre • Business, service and communications with the centre Escalation In some cases, excluding the matters listed above, once a learner has exhausted the centre’s complaints procedure they may be able to escalate their complaint toCSDTA. If a learner escalates a complaint they must be able to provide evidence that the centre's complaints procedure has been exhausted. CSDTA may not always be in a position to take escalated complaints forward, as their responsibility is to ensure qualifications are delivered in line with their assessment, quality assurance and regulatory requirements. If at any point the complainant or others involved in the complaint wish to be legally represented in relation to any aspect of the complaint, CSDTA must be informed. CSDTA reserve the right to be legally represented and to act upon legal advice. To escalate a complaint please complete the complaint submission form. Complains Policy and Procedure V21.0 November 2024 Information Classification: Public Page 5 of 9 If printed this document becomes uncontrolled Document Reference Number 5POAD10 This form must be submitted within 7 days of the centre’s final decision; CSDTA reserve the right not to accept submissions after this timeline. Providing a submission is received within 7 days of the centre’s final decision then CSDTA will: • Review the complaint within 10 days of receipt  upon review, if CSDTA determine that the complaint falls within their responsibility to investigate a complaint manager will be allocated and the complainant will be informed  upon review, if CSDTA determine that the complaint does not fall within their responsibility to investigate the complainant will be informed Complaint managers aim to resolve complaints within 30 working days of acknowledgement, however; in more complex cases this may not be possible. In these circumstances we will ensure that we keep you updated on the progress of your complaint. If a complainant remains unsatisfied with the outcome of a complaint, they may request a senior manager review. Requests for a senior manager review must be made within 7 days of the complaint decision; CSDTA reserves the right not to accept requests after this timeline. A senior manager’s decision is final and the complaints procedure has been exhausted. Once CSDTA’ complaints procedure has been exhausted, the complaint may be able to refer to the applicable regulator; relevant contact information can be found in section 8 of this policy. 7. Making a complaint about CSDTA If a centre, learner or member of the public feel that we have not met their expectations, we kindly request that they in the first instance raise the matter with the relevant department so that they may investigate and put it right. If you are unsure which department to contact please call or email our Customer Support team, providing details about the expression of dissatisfaction so that they may signpost you to the appropriate department: +44 (0) 2920486868 / info@cityskindoctor.co.uk If a complainant remains unsatisfied after raising an expression of dissatisfaction with relevant department, they may complete the complaint submission form within 7 days of the initial outcome. • review the complaint within 10 days of receipt  upon review, if CSDTA determine that the complaint falls within their responsibility to investigate, a complaint manager will be allocated and the complainant will be informed  upon review, if CSDTA determine that the complaint does not fall within their responsibility to investigate the complainant will be informed Complains Policy and Procedure V21.0 November 2024 Information Classification: Public Page 6 of 9 If printed this document becomes uncontrolled Document Reference Number 5POAD10 Complaint managers aim to resolve complaints within 30 working days of acknowledgement, however; in more complex cases this may not be possible. In these circumstances we will ensure that we keep you updated on the progress of your complaint. If a complainant remains unsatisfied with the outcome of a complaint, they may request a senior manager review. Requests for a senior manager review must be made within 7 days of the final complaint decision; CSDTA reserve the right not to accept requests after this timeline. A senior manager’s decision is final and the complaints procedure has been exhausted. If at any point the complainant or others involved in the complaint wish to be legally represented in relation to any aspect of the complaint, CSDTA must be informed. CSDTA reserve the right to be legally represented and to act upon legal advice. Once CSDTA’S complaints procedure has been exhausted, the complaint may be able to refer to the applicable regulator; relevant contact information can be found in section 8 of this policy. 8. Regulator contact information England: Ofqual 1. https://www.gov.uk/government/organisations/ofqual 2. Using the search function search complaints Wales: Qualifications Wales 1. https://www.qualificationswales.org/ 2. Using the search function search complaints Northern Ireland: CCEA 1. https://ccea.org.uk/ 2. Using the search function search complaints Complains Policy and Procedure V21.0 November 2024 Information Classification: Public Page 7 of 9 If printed this document becomes uncontrolled Document Reference Number 5POAD10 Scotland: SQA accreditation 1. https://accreditation.sqa.org.uk/accreditation/home 2. Using the search function search complaints 3. The following relates to complaints regarding public service organisations in Scotland only. Should you have undertaken a qualification in Scotland through a public service organisation and wish to make a complaint and you have exhausted the procedures of VTCT and SQA Accreditation, if applicable, then you do have one final route of complaint. Please contact the Scottish Public Services Ombudsman (SPSO) directly, details can be located on their website: www.spso.org.uk Complains Policy and Procedure V21.0 November 2024 Information Classification: Public Page 8 of 9 If printed this document becomes uncontrolled Document Reference Number 5POAD10 Complains Policy and Procedure V21.0 November 2024 Page 9 of 9 Information Classification: Public If printed this document becomes uncontrolled Document amendment history page Version Document Owner Issue Date Changes Role V19.0 Customer Support Manager 10/07/2024 Link to submission form reinstated Customer Support Manager V20.0 Customer Support Manager 01/10/2024 Submission forms updated; Resolution SLA added Customer Support Manager V21.0 Customer Support Manager 21/10/2024 Content transferred to new updated Customer Support Manager Document Review Role Review Status Quality and Processing Manager Reviewed Chief Academic Officer Reviewed and amended Document Owner Document Owner Document shared with Quality and processing Manager Assessment, Qualifications, Whole organisation Customer Support Manager Whole organisation Document Sign-off Role Sign-off Date Executive Director of Awarding 13/02/2018 Executive Director of Awarding 01/03/2018

CSD Complaints Policy and Procedures November 2024 Information Classification: Internal If printed this document becomes uncontrolled Document Reference Number 5POAD10 Complains Policy and Procedure V21.0 November 2024 Page 2 of 9 Information Classification: Public If printed this document becomes uncontrolled Version 21.0 Contents 1. Introduction .................................................................................................................................................... 3 1.1. Purpose .................................................................................................................................................... 3 1.1.1. Scope of policy .................................................................................................................................. 4 2. The regulators ........................................................................................................................................... 4 2.1. Regulatory requirements..................................................................................................................... 4 2.1.1. Situations brought to our attention by the regulators ............................................................ 4 3. Responsibilities ......................................................................................................................................... 4 4. Confidentiality and data protection ..................................................................................................... 4 4.1. Anonymous complaints ....................................................................................................................... 5 5. Review arrangements .............................................................................................................................. 5 6. Learner complaints about a CSDTA................................................................ 5 7. Making a complaint about CSDTA................................................................................. 6 8. Regulator contact information .............................................................................................................. 7 Document Reference Number 5POAD10 1. Introduction 1.1. Purpose In keeping with our core values, we understand how important it is for you to receive a first class service; however we recognise that sometimes things can go wrong. It is therefore important that we have an effective means for you to bring this to our or the approved centres’ attention, with an expectation of resolution. The complaints policy: • • • • • • outlines the complaints process defines what constitutes a complaint indicates which other policies and procedures might be more applicable sets out the process for making a complaint to CSDTA explains the steps taken to resolve complaints and timescales outlines how to escalate a complaint to the relevant regulator A complaint is an expression of dissatisfaction with an aspect of the service provided by your centre or awarding organisation, which is deemed to have fallen below your expectations and our/your centres’ own standards. Customers who wish to convey an expression of dissatisfaction should make sure they follow the relevant policy and/or procedure. Issues relating to assessment decisions should be addressed using the Enquiries and Appeals Policy and Procedure and others may be covered by the Malpractice and Maladministration Policy and Procedure. All policies are available on the CSDTA https://www.cityskindoctor.com Complainants who are unsure of the correct policy or procedure to follow should contact us for advice: +44 (0) 2920486868 / info@cityskindoctor.co.uk Complaints should be made by the centre/person(s) directly affected by the matter, or a person acting on their We, with their written permission. Complaints can normally be resolved informally; if this is not achieved a formal complaint can be raised without delay and by no later than 20 days after the occurrence of the issue which gave rise to the original complaint. Complains Policy and Procedure V21.0 November 2024 Information Classification: Public Page 3 of 9 If printed this document becomes uncontrolled Document Reference Number 5POAD10 1.1.1. Scope of policy This policy is provided for the use of: • • • learners who are or have been registered for CSDTA qualifications; personnel with responsibilities for managing, delivering, assessing and quality assuring qualifications in approved centres offering CSDTA qualifications; members of the public accessing our services; who wish to make a complaint in relation to the qualifications and associated services offered by CSDTA or one of its approved centres offering CSDTA qualifications; 2. The regulators 2.1. Regulatory requirements This policy addresses the requirements of the relevant regulatory authorities’ criteria. 2.1.1. Situations brought to our attention by the regulators Where the regulators notify us about failures that have been discovered in the assessment process or other activities of another awarding organisation, we will review whether or not a similar failure could affect our own processes and arrangements. 3. Responsibilities CSDTA personnel are required to follow the related procedures in order to investigate complaints as transparently, consistently and effectively as possible. Centres are responsible for ensuring that all personnel involved in the management, delivery, assessment and quality assurance of CSDTA qualifications are fully aware of the policy and conversant with the related procedures. Centres must have their own internal complaints policy and procedures in place to deal with complaints from learners and members of the public, and must provide easy access to them. Centres who fail to have their own complaints policy and procedures, or to make them available to learners and members of the public, are in breach of the centre agreement. 4. Confidentiality and data protection In following this process an individual might provide us with confidential information, and during our investigation we may need to request information of a confidential nature. Complainants are assured that CSDTA complies fully with data protection legislation at all stages. We ensure that confidential information is kept securely and used only for the purposes for which it is intended. Complains Policy and Procedure V21.0 November 2024 Information Classification: Public Page 4 of 9 If printed this document becomes uncontrolled Document Reference Number 5POAD10 4.1. Anonymous complaints Anonymous complaints cannot be considered. CSDTA will note their contents and may seek to verify them if this is possible and appropriate. We may include related information in our review activities. 5. Review arrangements This policy is reviewed annually as part of CSDTA’ self-evaluation activity, which includes consideration of customer and regulatory feedback and good practice guidance. A policy review may also be triggered as an action resulting from the outcome of the investigation of a complaint. 6. Learner complaints about a CSDTA centre Your training centre is the organisation that is responsible for delivering your course and who you have signed up to and paid money to. If you have a complaint about your centre you must take this up with the centre through their complaints process in the first instance. If you are unable to locate your centre's complaints policy please contact the centre directly by phone/post or in person. If you are not satisfied with any of the following then you must take this up with the centre directly as CSDTA do not have any remit to intervene in such matters. • Financial transactions with the centre • Business, service and communications with the centre Escalation In some cases, excluding the matters listed above, once a learner has exhausted the centre’s complaints procedure they may be able to escalate their complaint toCSDTA. If a learner escalates a complaint they must be able to provide evidence that the centre's complaints procedure has been exhausted. CSDTA may not always be in a position to take escalated complaints forward, as their responsibility is to ensure qualifications are delivered in line with their assessment, quality assurance and regulatory requirements. If at any point the complainant or others involved in the complaint wish to be legally represented in relation to any aspect of the complaint, CSDTA must be informed. CSDTA reserve the right to be legally represented and to act upon legal advice. To escalate a complaint please complete the complaint submission form. Complains Policy and Procedure V21.0 November 2024 Information Classification: Public Page 5 of 9 If printed this document becomes uncontrolled Document Reference Number 5POAD10 This form must be submitted within 7 days of the centre’s final decision; CSDTA reserve the right not to accept submissions after this timeline. Providing a submission is received within 7 days of the centre’s final decision then CSDTA will: • Review the complaint within 10 days of receipt  upon review, if CSDTA determine that the complaint falls within their responsibility to investigate a complaint manager will be allocated and the complainant will be informed  upon review, if CSDTA determine that the complaint does not fall within their responsibility to investigate the complainant will be informed Complaint managers aim to resolve complaints within 30 working days of acknowledgement, however; in more complex cases this may not be possible. In these circumstances we will ensure that we keep you updated on the progress of your complaint. If a complainant remains unsatisfied with the outcome of a complaint, they may request a senior manager review. Requests for a senior manager review must be made within 7 days of the complaint decision; CSDTA reserves the right not to accept requests after this timeline. A senior manager’s decision is final and the complaints procedure has been exhausted. Once CSDTA’ complaints procedure has been exhausted, the complaint may be able to refer to the applicable regulator; relevant contact information can be found in section 8 of this policy. 7. Making a complaint about CSDTA If a centre, learner or member of the public feel that we have not met their expectations, we kindly request that they in the first instance raise the matter with the relevant department so that they may investigate and put it right. If you are unsure which department to contact please call or email our Customer Support team, providing details about the expression of dissatisfaction so that they may signpost you to the appropriate department: +44 (0) 2920486868 / info@cityskindoctor.co.uk If a complainant remains unsatisfied after raising an expression of dissatisfaction with relevant department, they may complete the complaint submission form within 7 days of the initial outcome. • review the complaint within 10 days of receipt  upon review, if CSDTA determine that the complaint falls within their responsibility to investigate, a complaint manager will be allocated and the complainant will be informed  upon review, if CSDTA determine that the complaint does not fall within their responsibility to investigate the complainant will be informed Complains Policy and Procedure V21.0 November 2024 Information Classification: Public Page 6 of 9 If printed this document becomes uncontrolled Document Reference Number 5POAD10 Complaint managers aim to resolve complaints within 30 working days of acknowledgement, however; in more complex cases this may not be possible. In these circumstances we will ensure that we keep you updated on the progress of your complaint. If a complainant remains unsatisfied with the outcome of a complaint, they may request a senior manager review. Requests for a senior manager review must be made within 7 days of the final complaint decision; CSDTA reserve the right not to accept requests after this timeline. A senior manager’s decision is final and the complaints procedure has been exhausted. If at any point the complainant or others involved in the complaint wish to be legally represented in relation to any aspect of the complaint, CSDTA must be informed. CSDTA reserve the right to be legally represented and to act upon legal advice. Once CSDTA’S complaints procedure has been exhausted, the complaint may be able to refer to the applicable regulator; relevant contact information can be found in section 8 of this policy. 8. Regulator contact information England: Ofqual 1. https://www.gov.uk/government/organisations/ofqual 2. Using the search function search complaints Wales: Qualifications Wales 1. https://www.qualificationswales.org/ 2. Using the search function search complaints Northern Ireland: CCEA 1. https://ccea.org.uk/ 2. Using the search function search complaints Complains Policy and Procedure V21.0 November 2024 Information Classification: Public Page 7 of 9 If printed this document becomes uncontrolled Document Reference Number 5POAD10 Scotland: SQA accreditation 1. https://accreditation.sqa.org.uk/accreditation/home 2. Using the search function search complaints 3. The following relates to complaints regarding public service organisations in Scotland only. Should you have undertaken a qualification in Scotland through a public service organisation and wish to make a complaint and you have exhausted the procedures of VTCT and SQA Accreditation, if applicable, then you do have one final route of complaint. Please contact the Scottish Public Services Ombudsman (SPSO) directly, details can be located on their website: www.spso.org.uk Complains Policy and Procedure V21.0 November 2024 Information Classification: Public Page 8 of 9 If printed this document becomes uncontrolled Document Reference Number 5POAD10 Complains Policy and Procedure V21.0 November 2024 Page 9 of 9 Information Classification: Public If printed this document becomes uncontrolled Document amendment history page Version Document Owner Issue Date Changes Role V19.0 Customer Support Manager 10/07/2024 Link to submission form reinstated Customer Support Manager V20.0 Customer Support Manager 01/10/2024 Submission forms updated; Resolution SLA added Customer Support Manager V21.0 Customer Support Manager 21/10/2024 Content transferred to new updated Customer Support Manager Document Review Role Review Status Quality and Processing Manager Reviewed Chief Academic Officer Reviewed and amended Document Owner Document Owner Document shared with Quality and processing Manager Assessment, Qualifications, Whole organisation Customer Support Manager Whole organisation Document Sign-off Role Sign-off Date Executive Director of Awarding 13/02/2018 Executive Director of Awarding 01/03/2018

Cookie Policy The CSDTA web site use “cookies” to help you personalise your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the web server that you have returned to a specific page. For example, if you personalise CSDTA pages, or register with CSDTA site or services, a cookie helps CSDTA to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same CSD web site, the information you previously provided can be retrieved, so you can easily use the CSD features that you customised. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you do choose to decline cookies, you may not be able to fully experience the interactive features of the CSDTA services or web sites you visit.

Data Protection Policy October 2024 Version 15 Data Protection Policy_v15 October 2024 Information Classification: Public Page 1 of 18 If printed this document becomes uncontrolled Document Reference Number 4POTD14 Data Protection Policy_v15 October 2024 Page 2 of 18 Information Classification: Public If printed this document becomes uncontrolled Contents 1. Introduction ........................................................................................................................................................ 3 2. Scope ................................................................................................................................................................... 3 2.1. Personal Data ............................................................................................................................................ 3 2.2. Special Category Data ............................................................................................................................ 4 3. Principles ............................................................................................................................................................. 4 4. Accountability and Governance ..................................................................................................................... 6 5. Company Responsibilities ................................................................................................................................7 6. Staff Responsibilities ........................................................................................................................................7 7. Contractor/Casual Staff Responsibilities .....................................................................................................7 8. Responsibilities on termination or change of employment .................................................................... 8 9. Data Subject Rights .......................................................................................................................................... 8 10. Subject Access Requests ................................................................................................................................ 9 11. Personal Data Systems .................................................................................................................................... 9 12. Register of Processing Activities ................................................................................................................... 9 13. Data Breach Reporting ..................................................................................................................................... 9 14. Complaints ......................................................................................................................................................... 10 15. Information Security and Data Transmission ............................................................................................ 10 15.1. VTCT Statutory Reporting ...................................................................................................................... 11 15.2. Classification of Data .............................................................................................................................. 11 16. Contacts .............................................................................................................................................................. 11 17. Compliance, Audit and Review ...................................................................................................................... 11 Appendix 1 – Good practice in information handling ..................................................................................... 12 Appendix 2: Staff Data Protection and Privacy Notice................................................................................... 15 Document Reference Number 4POTD14 1. Introduction This document sets out how CSDTA establishes, manages and implements its internal system of controls to meet the requirements of the UK Data Protection Act 2018 (the Act) incorporating the UK General Data Protection Regulation (UK GDPR) and associated measures to uphold the rights and freedoms of individuals in relation to processing of their personal data. Data protection compliance and the appropriate and proportionate use of personal data is important to CSDTA . Everyone has rights regarding the way in which their personal data is used and CSDTA is fully committed to maintaining those rights and for complying with the associated legislation. CSDTA is accountable for maintaining governance and compliance over its processing of personal data in accordance with the Act and has chosen to adopt recognised privacy and security standards of best practice (ISO 27001) as a means of formally demonstrating accountability and governance and to put compliance at the heart of CSDTA’s business processes wherever appropriate. 2. Scope This Policy and any other associated documents form part of CSDTA’s Information Security Management System (ISMS) framework and set out the basis on which CSDTA will process any personal data which the organisation collects directly from individuals (known as ‘data subjects’) or personal data entrusted to CSDTA by other sources. The purpose of this Policy is to ensure that everyone whose role requires them to access, use, process and/or be responsible for personal data understands those responsibilities and demonstrate good data protection practice. Additionally, acknowledging that CSDTA staff are data subjects too, this document also sets out what CSDTA does with staff personal data and the relevant data subject rights. 2.1. Personal Data Personal Data as defined under UK GDPR is any information which are related to an identified or identifiable natural person. The data subjects are identifiable if they can be directly or indirectly identified, especially by reference to an identifier such as a name, an identification number, location data, an online identifier or one of several special characteristics, which expresses the physical, physiological, genetic, mental, commercial, cultural or social identity of these natural persons. In practice, these also include all data which are or can be assigned to a person in any kind of way. For example, the telephone, credit card or personnel number of a person, account data, number plate, appearance, customer number or address are all personal data. Data Protection Policy_v15 October 2024 Information Classification: Public Page 3 of 18 If printed this document becomes uncontrolled Document Reference Number 4POTD14 2.2. Special Category Data In addition to general personal data, one must consider above all the special categories of personal data (also known as sensitive personal data) which are highly relevant because they are subject to a higher level of protection. These data include genetic, biometric and health data, as well as personal data revealing racial and ethnic origin, political opinions, religious or ideological convictions or trade union membership. It is the policy of CSDTA that during its acquisition or development of software, systems, equipment and services which support its information assets, they must be risk assessed and, if used for the processing of personal data, subject to a Privacy Impact Assessment (PIA) resulting in appropriate information security requirements or controls being determined and implemented. 3. Principles CSDTA must meet its obligations to ensure that all personal data (including the personal data relating to its staff) is managed fairly, lawfully, accurately and securely. The processing of personal data must be aligned with the following fundamental principles: Personal data must be processed lawfully, fairly and in a transparent manner (‘lawfulness, fairness and transparency’). Data must be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (‘purpose limitation’). What this means for CSDTA in practice: Fairness and transparency: This requires CSDTA inform data subjects about why and how CSDTA will use their personal data. CSDTA must inform its staff, Centre staff, learners and suppliers about the purposes which CSDTA will use their data and who else might have access to it. Lawfulness: CSDTA must always have a legal justification for using personal data in the way is needed which may require careful analysis on a case-by-case basis. It is very important that data collected for a particular business reason is only used for that purpose as CSDTA may not have a legal justification to use it for any other purpose. Sometimes CSDTA may be required to obtain consent from individuals for certain types of processing. For example, processing sensitive (also referred to as ‘special category’) data relating to learners will often require explicit consent and some types of marketing also requires consent. Staff must only use or access personal data where this is needed for the normal performance of a job role. This is especially important when using someone’s data in a way that might not be obvious to (or expected by) the individual as this is likely to breach data protection law or infringe data subject rights. Staff must contact CSDTA’s Data Protection Officer (DPO), or the Information Security Officer (ISO) if they are unsure. In addition, if staff want to use a new software application or have Data Protection Policy_v15 October 2024 Information Classification: Public If printed this document becomes uncontrolled Page 4 of 18 Document Reference Number 4POTD14 Data Protection Policy_v15 October 2024 Page 5 of 18 Information Classification: Public If printed this document becomes uncontrolled identified a new supplier or business purpose for processing personal data, they must first engage with key stakeholders to manage any risks involved and ensure that CSDTA can use the data in a way that protects the rights of the individuals concerned. Personal data must be accurate and where necessary, kept up to date (‘accuracy’). What this means for CSDTA in practice: CSDTA is required to implement processes and policies to ensure the ‘quality’ of personal data and make sure that it can be kept up to date and accurate. Although this is ultimately a CSDTA responsibility, CSDTA will often be reliant on data subjects themselves to tell us of changes to their personal data. From a practical perspective it is often useful to encourage data subjects to contact us if personal data CSDTA hold about them becomes out of date or if they are aware of any inaccurate data CSDTA hold about them. If a data subject informs CSDTA that their personal data are incorrect, or if their circumstances have changed, CSDTA must ensure that its records for that individual are promptly updated, including any associated data sets and records. Appropriate policies and processes must be followed (e.g. to periodically review, cleanse and validate existing data sets). Caution must also be exercised when correcting alleged inaccurate personal data records as CSDTA must take steps to ensure that there are no accuracy disputes involved. Personal data must not be kept for longer than is necessary for the purpose or purposes that SDTA requires it (‘storage limitation’). What this means for CSDTA in practice: CSDTA must not keep personal data in an identifiable form for longer than necessary. If personal data is no longer required for the purposes for which it was collected, it must be securely deleted beyond any ability to re-identify the individuals concerned or securely destroyed. Equipment that has been used to process CSDTA personal and business data must be returned to the IT department for secure cleansing prior to re-issue or destruction. Personal data must not be retained ‘just in case’ it might be useful later. If it is no longer required for the original business purpose it must be deleted in accordance with the retention period for the prescribed information asset. The organisation adopts a default retention period of 6 years plus the current year unless other prescribed by law or statutes. As an Awarding Body, learner achievement data is held for 65 years. Retention periods for information assets are recorded in the Data Retention Schedule. If staff wish to retain personal data for longer than the stated periods, this may be possible but will require the approval of the DPO who may need to identify new legal justification for doing so. Personal data must be processed in a manner that ensures appropriate security is applied to protect the data, including protection from unauthorised or unlawful processing and against accidental loss, destruction or damage using appropriate technical and organisational security measures. Document Reference Number 4POTD14 Data Protection Policy_v15 October 2024 Page 6 of 18 Information Classification: Public If printed this document becomes uncontrolled What this means for CSDTA in practice: CSDTA must implement policies and processes to ensure that all personal data is kept secure and confidential and that access to it is only granted to those who have a need to access it. CSDTA has invested in the implementation of internationally recognised standards of best practice in the management of information security. Staff must comply with all information security policies, and both demonstrate and encourage positive security behaviour and the secure handling of personal data. Wherever CSDTA shares personal data with regulators, service providers or suppliers, CSDTA must ensure that the security of personal data is factored in at the earliest stage of negotiating the relationship and that CSDTA build appropriate protections for the data into CSDTA’s contracts with these third parties. Staff are reminded that personal data must be handled in a secure and confidential manner. Contracts of employment or service agreements also contains general confidentiality obligations. Personal data must only be shared or disclosed when the recipient is entitled to have it. This includes the personal data relating to internal colleagues. Where it is necessary to share personal data with external organisations on a regular basis, data sharing agreements may need to be put in place and the electronic transmission is subject to CSDTA data handling rules. People will often attempt to obtain personal data through deception for example, they may pretend to be the data subject to whom the personal data relates, or they may try to take records from hard-copy files. Similarly, human error is often a factor in breaches of security such as sending data to the wrong recipient or losing unsecured devices. Cyber-attacks are becoming increasingly prevalent, and staff must be alert to any unusual activity or potential assaults on CSDTA’s security defences. Any concerns relating to the use of personal data, whether real or suspected, must be reported to the DPO via the inbox (DPO@vtct.org.uk). 4. Accountability and Governance CSDTA’s approach to data protection management is one of sensible risk management and continual improvement which is driven by CSDTA’s core values as listed below: • Partnership: be on the side of our customers and learners • Ease: Simplify complexity to identify the best route forward • Expertise: Lead with confidence, using our heritage and experience • Collaboration: Work together for greater impact; don’t do it alone • Energy: Inspire others with passion and warmth Document Reference Number 4POTD14 5. Company Responsibilities As an employer, CSDTA recognises its corporate responsibility under the Act as data controller in respect of staff personal data processed for the purposes of administration of employment and management of staff. CSDTA is also the data controller in relation to the personal data (business contact details) CSDTA records relating to third party suppliers. In respect of learner data, each party shall be a data controller in respect of any personal data. The DPO is responsible for data protection compliance and is required to draw up guidance and promote compliance with this policy in such a way as to ensure the easy, appropriate and timely provision of guidance and compliance information. All new members of staff must receive an introductory briefing on the Data Protection Policy as part of their induction. 6. Staff Responsibilities All staff, particularly those engaged in accessing or processing of personal information about learners, centre contacts, other staff members or other individuals must comply with the requirements of this policy. Staff must ensure that: • All personal information entrusted to them in the course of their employment is kept confidential and stored securely • No personal information is disclosed either verbally or in writing, accidentally or otherwise to any unauthorised third party • Where they are unsure about authorised third parties to whom they can legitimately disclose personal/sensitive data they seek advice from their line manager or the DPO 7. Contractor/Casual Staff Responsibilities CSDTA is responsible for the use made of personal data by anyone working on its behalf. Managers who engage contractors or employ casual staff must also comply with this policy and ensure that: • Any personal data collected or processed during work undertaken for CSDTA is kept securely and confidentially. This applies equally to where the data is an integral part of the work, or where it is contained on media etc. which is accessed and applies whether or not CSDTA has made specific mention of the data in the contract for work/services • All personal data is returned to CSDTA on completion of the work, including any copies that may have been made. Alternatively, the data is securely destroyed and CSDTA receives notification in this regard from the contractor or casual member of staff Data Protection Policy_v15 October 2024 Information Classification: Public Page 7 of 18 If printed this document becomes uncontrolled Document Reference Number 4POTD14 • CSDTA receives details of any disclosure of personal data to any other organisation, subcontractor or any person who is not a direct staff of the contractor • Any personal data made available by CSDTA or collected in the course of the work is neither stored nor processed outside the European Economic Area (EEA) without formal written consent from CSDTA • All practical and reasonable steps are taken to ensure that contractors, short term or other casual staff do not have access to any personal data beyond what is essential for the work to be carried out properly 8. Responsibilities on termination or change of employment After termination or change of employment, all staff must continue to: • Maintain confidentiality of personal information • Not disclose company confidential information to unauthorised third parties • Maintain adherence to the UK GDRP and Data Protection Act (2018) regulations This applies to contractors and casual staff, as well as permanent employees. 9. Data Subject Rights The Data Protection Act provides the following rights for individuals: • The right to be informed – Individuals have the right to be informed about the collection and use of their personal data. This is a key transparency requirement which is usually satisfied by the provision of a privacy notice (described in further detail below) at the point where the personal data is collected by CSDTA • The right of access – Individuals have a right to access their personal data which is commonly referred to as a Subject Access Request (SAR) • The right to rectification – Individuals have a right to have inaccurate personal data rectified, or completed if it is incomplete. This right is closely linked to the accuracy principle • The right to erasure – Individuals have a right to have personal data erased which is also known as the right to be forgotten. This right is not absolute and only applies in certain circumstances • The right to restrict processing – Individuals have the right to request the restriction or suppression of their personal data. This right is not absolute and only applies in certain circumstances • The right to data portability – Individuals have the right to obtain and reuse their personal data for their own purposes across different services. This right allows individuals to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without restriction and without it affecting usability Data Protection Policy_v15 October 2024 Information Classification: Public Page 8 of 18 If printed this document becomes uncontrolled Document Reference Number 4POTD14 • The right to object – Individuals have the right to object to the processing of their personal data in certain circumstances, including an absolute right to stop their data being used for direct marketing • Rights in relation to automated decision making and profiling – Individuals have the right not to be subject to a decision based solely on automated decision-making using their personal data 10. Subject Access Requests CSDTA is required to provide individuals with access their own personal data held by CSDTA via a subject access request. Any individual wishing to exercise this right must do so in writing or verbally to the DPO at the address listed in the Contacts section. This does not prevent staff requesting copies of personal data items routinely available from HR should they wish to do so. All staff receiving a formal request from a data subject wishing to exercise any of the above rights must forward the request immediately to the DPO to arrange fulfilment. Only approved staff who are appropriately trained are permitted to respond to data subject access requests. CSDTA aims to comply with requests for access to personal information as quickly as possible but will ensure that it is provided within the time limits set down by the Data Protection Act, i.e. 31 days. More details are available in the document: “GDPR Subject Access Request Process and Right to Erasure Process”. 11. Personal Data Systems The IT department will maintain an inventory of all electronic systems which include personal data held withinCSDTA. 12. Register of Processing Activities The DPO will maintain a register of personal data processing activities in electronic form as part of CSDTA’s record keeping responsibilities as a data controller. This register should be disclosed to the Information Commissioner’s Office (ICO) upon request. 13. Data Breach Reporting Any breach of this Policy, whether real or suspected, or potential breach of the Act, including but not limited to misuse, unauthorised access, potential unauthorised disclosure (including verbal disclosure), loss, damage and destruction of personal data or the CSDTA systems and equipment used for processing must be reported in accordance with the Incident Management Policy and to the DPO (DPO@vtct.org.uk). Data Protection Policy_v15 October 2024 Information Classification: Public If printed this document becomes uncontrolled Page 9 of 18 Document Reference Number 4POTD14 All reports of any suspected breach of the Act or the requirements of this Policy will be recorded, investigated and, where proven, may result in disciplinary action, up to and including dismissal or result in referral to law enforcement or regulatory bodies where warranted. Contractors and third parties responsible for non-compliance may have their contracts terminated. More details are available in the documents: • Supplier Security Policy • Incident Management Policy Under no circumstances must staff attempt to prove, ‘test’ or investigate any perceived security incident unless they are specifically authorised to do so by the DPO. 14. Complaints The DPO will co-ordinate appropriate responses to any complaints received in respect of this policy. The complaint must be addressed to the DPO in the first instance. Complaints must be acknowledged immediately, and every reasonable effort made to provide a comprehensive reply within 21 days. If the complainant is not satisfied with the reply, then they must inform the DPO within 21 days and will be dealt with in accordance with CSDTA’s General Complaints Procedure or the CSDTA Grievance Procedure as appropriate. If complainants are dissatisfied with the outcome of the Complaints Procedure relating to personal data processing, they are entitled to seek an independent assessment from the ICO. Requests for review by the ICO must be made in writing to: The Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF Tel: 01625 545700 15. Information Security and Data Transmission CSDTA has a legal obligation to protect personal data throughout its lifetime, from creation to destruction, and is aware of its legal obligations under the Act. CSDTA’s ISMS framework provides robust technical and organisational security controls designed to meet this obligation. As part of this security framework and to ensure a common approach to data transfers is implemented across the organisation, the Information Classification Policy and Information Handling and Transfer Procedure apply to both personal data and sensitive business and commercial data. Data Protection Policy_v15 October 2024 Information Classification: Public Page 10 of 18 If printed this document becomes uncontrolled Document Reference Number 4POTD14 15.1. CSDA Statutory Reporting CSDTA has a statutory obligation to provide data (in an approved and documented format) to its regulators. These reports are produced (normally quarterly) and submitted by various teams via, for example, RITS, SQA portal and email – e.g.: • Ofqual returns • Bath Data returns • TS Series exam returns 15.2. Classification of Data CSDTA classifies information in accordance with the Information Classification Policy and information is handled per the Information Handling and Transfer Procedure. For the avoidance of doubt, any information containing personal data (which could result in an individual being identified) will always have an Internal categorisation as a minimum and consideration should be given as to whether Sensitive is the appropriate categorisation. 16. Contacts General enquiries regarding CSDTA’s policy and approach to management and compliance with the Data Protection Act incorporating the EU General Data Protection Regulations may, in the first instance, be addressed to CSDTA’s Customer Support Team – info@cityskindoctor.co.uk or by phone to CSDTA ’s main switchboard – 02920486868 More specific enquiries, data subject right fulfilment requests and complaints relating to data protection must be addressed to: Data Protection Officer CSDTA Aspire House Annealing Close Eastleigh Hampshire SO50 9PX 17. Compliance, Audit and Review For details regarding the compliance requirements and compliance breach penalties of this document, the audit criteria, and the review frequency, please see sections 9, 10 and 11 of the Information Security Policy. Data Protection Policy_v15 October 2024 Information Classification: Public Page 11 of 18 If printed this document becomes uncontrolled Document Reference Number 4POTD14 Appendix 1 – Good practice in information handling Who is this guide for? This guide has been written for all CSDTA staff who collect, manage, transfer or use data about learners, staff or other individuals during the course of their work. Its aim is to raise awareness of where potential breaches of security could occur. Following these guidelines will help you to prevent data from being lost or used in a way which may cause individuals harm or distress and/or prevent the loss of reputation CSDTA might suffer if you lose personal data about individuals. Your roles and responsibilities As a staff member or contractor of CSDTA, you have a shared responsibility to secure any sensitive or personal data you use in your day-to-day professional duties. Why protect information? CSDTA holds personal data on learners, staff and other people in the course of its daily business activities. Some of this data could be used by another person or criminal organisation to cause harm or distress to an individual. The loss of personal data could result in adverse media coverage, and potentially damage the reputation of CSDTA. This can make it more difficult for CSDTA to use technology to benefit learners. What Information do you need to protect? You must secure any personal data you hold about individuals and any data that is deemed sensitive or valuable to CSDTA. As with any organisation, CSDTA has a Data Protection Officer. This falls within the remit of the Chief Financial Officer (CFO), who has responsibility for working out exactly what information needs to be secured, how information is securely handled, how the information changes over time, who else is able to use it and why. Data security do’s and don’ts There are plenty of things that you must do (or not do) that will greatly reduce the risks of sensitive information going missing or being obtained illegally. Many of these guidelines will apply to how you handle your own personal information. Using these practices will help you to protect your own privacy. When working online: Do… • Make sure that you follow CSDTA’s policies on keeping your computer up to date with the latest security updates. Get advice from the IT department if you need help Data Protection Policy_v15 October 2024 Information Classification: Public Page 12 of 18 If printed this document becomes uncontrolled Document Reference Number 4POTD14 • Turn on relevant security warnings in your web browser (for example, the automatic phishing1 filter available in many browsers) • Make sure that you only install software that the IT department has checked and approved and only download programs from sources you trust. If in doubt, talk to the IT department • Ensure that you have read and understood the acceptable-use policies which are available on the CSDTA Intranet and ensure you follow them Don’t… • Browse sites that are not business-related or are prohibited under the Acceptable Use of Assets policy. Remember, CSDTA reserves the right to monitor websites which staff are visiting • Enter credit card or payments details into any site that does not have a valid security certificate, and where the URL does not start with “https://” Email and messaging: Do… • Read the CSDTA relevant policies available on the Intranet and report any spam or phishing emails to the IT department that are not blocked or filtered • Report phishing emails to the organisation they are supposedly from • Use the CSDTA contact/address books contained within Outlook. This helps to stop email being sent to the wrong address • Encrypt2 any attachments to emails which contain personal information and do not include personal information in the body of the email Don’t… • Click on links in unsolicited emails. Be especially wary of emails requesting or asking you to confirm any personal information, such as passwords, bank details and so on • Turn off any email security measures that the IT department has put in place or recommended • Email sensitive information unless you know it is encrypted • Try to bypass CSDTA’s security measures to access your email off-site (for example, forwarding email to a personal account) • Reply to chain emails 1Phishing is an attempt to obtain your personal information (for example, account details) by sending you an email that appears to be from a trusted source (for example, your bank). 2Encryption is a way of scrambling information. It helps stop anyone using the information if they do not have an electronic key or password to unscramble it. Data Protection Policy_v15 October 2024 Information Classification: Public Page 13 of 18 If printed this document becomes uncontrolled Document Reference Number 4POTD14 Passwords: Do… • Use a strong password (strong passwords are usually twelve characters or more and contain upper- and lower-case letters, as well as numbers and/or special characters) • Make your password easy to remember, but hard to guess • Change your password(s) if you think someone may have found out what they are, in any event, change them in line with the Acceptable Use of Assets Policy Don’t… • Share your passwords with anyone else • Write your passwords down • Use your work passwords for your own personal online accounts • Save passwords in web browsers if offered to do so Data Protection Policy_v15 October 2024 Information Classification: Public Page 14 of 18 If printed this document becomes uncontrolled Document Reference Number 4POTD14 Appendix 2: Staff Data Protection and Privacy Notice CSDTA takes great care to protect the personal information of all data subjects with whom the company interacts. Data Controller As your employer, CSDTA assumes the responsibilities required of a data controller under the UK Data Protection Act 2018 and the UK General Data Protection Regulations. A key responsibility is to inform you about how and why CSDTA processes your personal data. This notice is designed to fulfil that obligation. When you become staff or contractor CSDTA collects and processes your personal data where this is necessary for the purposes of administration of your employment, benefits administration, remuneration and for managing CSDTA’s employees. Your contract of employment or contractor agreement provides the legitimate basis for this processing. CSDTA Data Protection Policy CSDTA has established this policy to provide protection for the rights and freedoms of data subjects over the processing of personal data that is applicable to all staff (whether temporary, including associate contractors, or permanent). This document includes guidelines on how to comply and the latest version is published on the intranet. Categories of Data Processed In the context of employment, CSDTA processes the following categories of personal information where necessary, and where CSDTA is required to do so by law: • Name and contact information (address details, telephone numbers, email address) • Place of birth, gender, nationality and passport (or equivalent national identity papers) • Photographs and CSDTA images • Evidence of marital status, family, spouse and dependent’s details and next of kin • Recruitment data (e.g. CVs), including languages, references, qualifications, employment and education history • Training and skills development information • Membership of professional societies and internal teams • Employment vetting, including right to work checks • Employment contract or contractor agreement, roles and job placement, including project assignment and management reporting • Staff management data including onboarding, role changes, performance, service history, annual leave, special leave such as maternity, paternity leave, teleworking details, travel details, resignation, grievance and disciplinary information. • National driving licenses and vehicle registration Data Protection Policy_v15 October 2024 Information Classification: Public Page 15 of 18 If printed this document becomes uncontrolled Document Reference Number 4POTD14 • Financial information including salary and payroll data, pensions, travel and other expenses, bank account details or tax forms • Physical and mental health information including sick leave, fit notes, medical history and medical reports where applicable. • Ethnicity/equal opportunities monitoring Recipients of the Data Processed Where necessary for the purposes detailed above, and only in limited circumstances, such as When CSDTA are required to do so by law, CSDTA may share (or grant access to) your personal data with external official authorised bodies and regulators including: • DVLA • Department of Work and Pensions • Financial accountants • Screening & vetting partners • Workplace pension scheme administrators • HMRC and other government and regulatory bodies • Service providers or other partners who help us manage CSDTA’s business who may provide travel services, perform statistical analysis, host and manage or support CSDTA’s IT systems and software, or provide services to manage access to CSDTA offices. Where this is necessary, data sharing agreements ensure that your rights are maintained by CSDTA’s partner organisations. CSDTA may share your personal data with training course providers and event organisers. CSDTA only permit the transfer of your personal data outside of the EEA or to another international organisation if it is determined that adequate safeguards are in place to protect your rights over the processing of your personal data. Special Category Personal Data CSDTA will only process staff special category data (e.g. physical and mental health or disability, ethnic origin, religious, political or other beliefs, trade union membership, genetic or biometric data, sexual orientation including transgender and criminal convictions/alleged offences) where this is necessary in relation to your employment or where CSDTA are required to do so by a law or a regulatory obligation or where this is necessary in the context of your employment contract. CSDTA do not require your consent for this as an exemption applies. However, if CSDTA use your personal information for any other reason CSDTA will require your explicit consent to do so. Staff Vetting and Screening CSDTA may use your personal information to undertake staff screening and vetting where CSDTA are required to do so, Data Protection Policy_v15 October 2024 Information Classification: Public Page 16 of 18 If printed this document becomes uncontrolled Document Reference Number 4POTD14 e.g. to satisfy government requirements to check eligibility to work in the UK or where a specific role requires us to screen staff for trustworthiness and reliability as mandated by a regulator. Vetting may include an enhanced disclosure of criminal convictions or alleged criminal offences and special measures are required to justify this type of vetting and ensure that any such disclosure is conducted directly between staff and the vetting authority. CSDTA will not collect or record criminal conviction information internally, only the outcome. Credit checks may also be performed where employees are deployed in a role that carries a financial position of trust. Data Retention CSDTA will retain your personal data in an identifiable form only for as long as is necessary and in accordance with the CSDTA’s Data Retention Policy. Non-essential HR records will be removed from HR files after a period of 12 months from staff leaving date. Essential HR records including salary, tax, payroll and benefits information will be retained for a period of 6 years following termination of your employment. Associated financial records will be retained for 6 years following financial audit. This is necessary as CSDTA is required to keep specific records to comply with legal obligations. The following data records are also retained for a specific amount of time: • Annual leave, sick leave, and special leave records will be retained for 3 years. • Parental leave records will be retained for 5 years from the birth of a child /adoption date. • Pension information will be retained for 12 years after the benefit ceases. • CCTV images will be retained for a maximum of 1 year. • Entries reported in accident books for health and safety purposes will be retained indefinitely. Security of your Personal Data CSDTA adopts recognised security best practice standards and techniques to protect your personal data from unauthorised access, use or disclosure. CSDTA have adopted formal processes to deal with any suspected security incidents that may include notifying you of any breaches of your personal data or formal notification to the UK Data Protection supervisory authorities. Right of Access, Rectification, Erasure and Portability As defined earlier in this policy, staff have a right to access a copy of their personal data as well as to have any inaccurate data corrected and, in limited circumstances, erased or passed to another data controller in electronic format. If you are a current staff or contractor, you can do this by contacting the HR Director who will action your request where this falls within HR current working practice. If HR are unable to provide the personal data requested as part of routine service, or if you are a former staff or have any difficulties, you must contact the DPO, in writing via DPO@vtct.org.uk who will advise you what to do. Data Protection Policy_v15 October 2024 Information Classification: Public Page 17 of 18 If printed this document becomes uncontrolled Document Reference Number 4POTD14 Please ensure that you inform HR of any changes to your personal data to ensure CSDTA can keep your staff information up to date. You must also report any incidents involving misuse or unauthorised disclosure of personal data to DPO@vtct.org.uk or in person to the DPO or ISO in confidence. If you have a concern or complaint about the way that your personal data has been, or is being processed, please direct it to the DPO and CSDTA will try to resolve any issues initially. If CSDTA are unable to do that for any reason, you also have a right to lodge a complaint with the ICO and further information on your rights and how to exercise them is available on www.ico.org.uk. Changes to this Data Protection Policy CSDTA will occasionally update this Data Protection Policy to reflect organisational changes and feedback. CSDTA encourage you to periodically review this policy to stay informed on how CSDTA use and protect your data. Data Protection Policy_v15 October 2024 Information Classification: Public

Enquiries and Appeals Policy and Procedures October 2024 Version 14 Information Classification: Public If printed this document becomes uncontrolled Document Reference Number 5POAD3 Enquiries and Appeals Policy and Procedures_v14.0 October 2024 Page 2 of 14 Information Classification: Public If printed this document becomes uncontrolled Contents 1. Introduction ............................................................................................................................................... 3 1.1. Purpose ............................................................................................................................................. 3 1.2. Scope of the policy and grounds for appeal ............................................................................. 3 1.3. Regulatory authorities .................................................................................................................... 3 1.4. Responsibilities ............................................................................................................................... 3 1.5. Review arrangements ..................................................................................................................... 4 1.5.1. Situations brought to our attention by the regulators ........................................................ 4 1.6. Fees ................................................................................................................................................... 4 1.7. Complaints ....................................................................................................................................... 4 2. Enquiries about Results ..................................................................................................................... 4 2.1. Introduction ..................................................................................................................................... 4 2.2. Process .............................................................................................................................................. 5 2.3. Enquiries about results – flowchart ........................................................................................... 6 3. Appeals against assessment decisions ........................................................................................... 7 3.1. Introduction ..................................................................................................................................... 7 3.2. Process .............................................................................................................................................. 7 3.3. Appeals against assessment decisions – flowchart ................................................................9 4. Appendix B Enquiry about results – application form .............................................................. 10 5. Appendix C Appeals against results – application form ........................................................... 12 Document Reference Number 5POAD3 1. Introduction 1.1. Purpose This policy sets out information about our service for enquiries about results and appeals against assessment decisions, including those made relating to reasonable adjustments and special arrangements, the circumstances in which they may be made and the processes which must be followed. Learners or centres may wish to submit an enquiry about results, normally in cases where results vary considerably from those expected. The clerical check of results may conclude the enquiry, or a learner/centre may decide to progress to appeal. An appeal against an assessment decision may be submitted without having already submitted an enquiry about results. We publish this policy, procedure and process flowcharts on our websites and in centre handbooks, to support the process of appeal of assessment decisions in a timely manner. Where an associated investigation leads to the discovery of a failure in its assessment process, we take all reasonable steps to: • identify any other learner who has been affected by the failure; • correct or, where it cannot be corrected, mitigate as far as possible the effect of the failure; • ensure that the failure does not recur in the future. 1.2. Scope of the policy and grounds for appeal This policy is provided for the use of customers, being learners who are taking or have taken assessments, and personnel with responsibilities for managing, delivering, assessing and quality assuring qualifications in approved centres offering qualifications, who wish to appeal against decisions as set out above, because procedures were not applied consistently, properly or fairly. 1.3. Regulatory authorities This policy addresses the requirements of the relevant regulatory authorities’ criteria. 1.4. Responsibilities CSDTA as the awarding organisation is responsible for ensuring that all appeal decisions: • are taken by individuals who have no personal interest in the decision being appealed; • are dealt with by at least one decision maker who is not an employee of the awarding organisation, an assessor working for it, or otherwise connected to it; • are always taken by persons who have appropriate competence. CSDTA personnel are required to follow the related procedures in order to deal with enquiries about results and appeals as effectively as possible. Enquiries and Appeals Policy and Procedures_v14.0 October 2024 Information Classification: Public Page 3 of 14 If printed this document becomes uncontrolled Document Reference Number 5POAD3 Centres are responsible for ensuring that all personnel involved in the management, delivery and assessment of CSDTA qualifications are fully aware of the policy and conversant with the related procedures. Centres must have their own internal appeal arrangements in place and provide easy access to them for learners who wish to appeal against a decision taken by the centre. Where appropriate, the centre’s own appeals procedures must be exhausted before an appeal is raised with the awarding organisation. 1.5. Review arrangements This policy is reviewed annually as part of CSDTA' self-evaluation activity, which considers customer and regulatory feedback and good practice guidance. 1.5.1. Situations brought to our attention by the regulators Where the regulators notify us of failures that have been discovered in the assessment process of another awarding organisation, we will review whether or not a similar failure could affect our own assessment processes and arrangements. 1.6. Fees For an Enquiry About Results, CSDTA charges the appellant a fee of £25.00 per learner. For an appeal CSDTA charges the appellant a fee of £300 per learner which is refunded should the appeal be successful. The fee amount is subject to annual review. CSDTA’ Pricing and Fees Document contains the service fees for this academic year. 1.7. Complaints CSDTA has a separate complaints policy and procedure, which should be followed by centres/learners who are dissatisfied with any other aspect of our services than those listed above. For further information please contact the awarding organisation. 2. Enquiries about Results 2.1. Introduction The CSDTA Enquiries About Results service is available for centres to enquire about assessment results issued by CSDTA, normally in cases where the results vary considerably from those expected. An enquiry may be made on behalf of one or more than one learner. An enquiry about results is a formal written request from the centre to CSDTA for a review of the assessment decision relating to qualifications. An enquiry can be a request for an administrative check of the accuracy of the results themselves, or in relation to decisions made regarding reasonable adjustments and special considerations, or external quality assurance decisions. Enquiries and Appeals Policy and Procedures_v14.0 October 2024 Information Classification: Public Page 4 of 14 If printed this document becomes uncontrolled Document Reference Number 5POAD3 This may take the form of a request for one of the following: • a clerical check; • a remark of the assessment by a different marker. The request must be accompanied by the written permission of the learners for the centre to make the request. Receipt of requests unaccompanied by the written permission of learners may be treated as centre maladministration. To ensure that the enquiry can be dealt with as soon as possible after the related assessment, it is important to adhere to the timescales for submission set out in the process below. A fixed fee is charged for this service. The fee is refunded fully if the outcome of the assessment is changed because of the enquiry. Where the outcome of an enquiry brings into question the accuracy of other results, CSDTA will take all reasonable steps to protect the interests of all learners who are affected. If the centre or learner(s) are dissatisfied with the outcome of the enquiry, the centre should initiate the first stage Enquires About Results procedure. 2.2. Process • Send your request to the Assessment Department at CSDTA, with full details of the requested enquiry, accompanied by all supporting documentation and the written permission of each learner involved. • Submit the request within 14 working days or for series based assessment refer to the Key Dates document published, of the receipt of results by the centre examinations officer, or within 5 days in the case of an enquiry about a reassessment following a clerical check. • CSDTA acknowledges receipt of written enquiries about results within 7 working days from receipt. • CSDTA undertakes the check and notifies the designated centre contact within 14 working days from receipt of the application of the enquiry. If for any reason these timescales cannot be achieved, CSDTA informs the centre contact of the anticipated timescale. • The written report is sent by recorded delivery and provides details of any recommendations as well as the decision. • Possible outcomes of the enquiry are: ̵ no change; ̵ a change to the results which may be either higher or lower than previously issued. • CSDTA will amend its learner records accordingly. • If the centre or the learner(s) are not satisfied with the outcome of the enquiry, an appeal may be submitted in line with the CSDTA appeals procedures Enquiries and Appeals Policy and Procedures_v14.0 October 2024 Information Classification: Public Page 5 of 14 If printed this document becomes uncontrolled Document Reference Number 5POAD3 2.3. Enquiries about results – flowchart Enquiries and Appeals Policy and Procedures_v14.0 October 2024 Information Classification: Public Page 6 of 14 If printed this document becomes uncontrolled Document Reference Number 5POAD3 3. Appeals against assessment decisions 3.1. Introduction Approved centres offering qualifications are expected to have their own appeal policies and procedures in place. These procedures must be fully exhausted prior to any appeal to CSDTA as the awarding organisation being made. Appeals to CSDTA about an assessment decision or Enquiry About Results must be submitted within 20 working days of the publication of that decision. For this reason, all coursework should be retained for at least 20 days beyond the date of results notifications or the publication of Enquires About Results. Centres wishing to appeal on behalf of learners must obtain the written permission of the learner(s) concerned and advise the learner(s) that grades/results can go up or down following investigation. CSDTA undertakes to report its findings and decision to the centre/learner within 20 working days. Learners who are not satisfied with the outcome are given the option to retake the assessment. If at this stage the matter remains unresolved, then a further appeal for independent review of the case is possible. The outcome of the review will be made known within a further 8 weeks. The decision of the independent review panel is final. 3.2. Process • The centre completes the appeal application form (see page 14) and submits it to the CSDTA head office within 20 days of receipt of the related assessment decision(s) or completion of an enquiry about results. • All sections of the form must be completed and all supporting information including the centre's report on the outcome of its own appeal review must be attached. An incomplete application will be returned to the centre for completion before it is processed by the awarding organisation, and as such could delay the process. • The assessment is re-marked. In the case of an appeal against a practical examiner’s decision, the original examiner will produce a full report for review by an internal quality assurance panel to ascertain whether moderation is necessary, and if it is deemed so, this will take place. • If the assessment decision is deemed correct, CSDTA will notify the centre and learner, setting out the reasons for its decision in full. • If the assessment decision is revised, the revised result and certificate will be issued together with the report setting out the reasons for the decision in full. • If other assessment decisions may be affected by the result of the appeal, all similar results will be recalled and reviewed in the same way. • If the centre/learner is not satisfied with the appeal outcome, they may write to CSDTA within 15 days of receiving the outcome, to request reassessment or an independent review. Enquiries and Appeals Policy and Procedures_v14.0 October 2024 Information Classification: Public Page 7 of 14 If printed this document becomes uncontrolled Document Reference Number 5POAD3 • In the case of reassessment, the following will apply: ̵ The re-examination will normally take place within 8 weeks of the receipt of the written request. ̵ For theory assessments, a theory examination paper will be provided to the centre by the agreed date. Standard theory assessment regulations and procedures will apply. The assessment will be independently marked. If other assessment decisions may be affected by the result of such an appeal, all similar results will be recalled and reviewed in the same way. ̵ For practical assessments, reassessment will take place at the learner's own centre or another centre as agreed with the awarding organisation. The standard practical assessment regulations and procedures apply. A different practical examiner will conduct the assessment. The grade will be reviewed by a member of the quality assurance team. If other assessment decisions may be affected by the result of such an appeal, all similar results will be recalled and reviewed in the same way. • In the case of independent review, the following will apply: ̵ CSDTA will appoint a review panel comprising of a minimum of one senior manager and an independent person to review the case and come to a decision, normally within 20 working days of receipt of the appeal. The reviewer will have the necessary knowledge and skills to reach an appropriate decision about the appeal. ̵ The reviewer will review all the evidence and the procedures applied by the awarding organisation to ensure it has been fair, appropriate and consistent with the appeals policy and procedure. ̵ The review process may involve discussion with and a request for information from the appellant and awarding organisation personnel, and a centre visit. ̵ The reviewer will report their findings to the review panel which will reach a decision on the appeal. ̵ If at any stage of the process the assessment decision is proved to be incorrect and the appeal is upheld, CSDTA will: • issue the new results and certification; • update all related records held by the awarding organisation; • review related policies and procedures and take remedial action to prevent or mitigate a recurrence of the circumstances giving rise to the appeal; • recall and review in the same way all similar results for any other assessment decisions which may be affected by the outcome of such an appeal. Appellants may make a referral to the regulators. However, the regulator is unable to overturn assessment decisions or academic judgements. A referral can be made to SQA Accreditation, however, SQA Accreditation is unable to overturn assessment decisions or academic judgements. Enquiries and Appeals Policy and Procedures_v14.0 October 2024 Information Classification: Public Page 8 of 14 If printed this document becomes uncontrolled Document Reference Number 5POAD3 3.3. Appeals against assessment decisions – flowchart Enquiries and Appeals Policy and Procedures_v14.0 October 2024 Information Classification: Public Page 9 of 14 If printed this document becomes uncontrolled Document Reference Number 5POAD3 Enquiries and Appeals Policy and Procedures_v14.0 October 2024 Page 10 of 14 Information Classification: Public If printed this document becomes uncontrolled 4. Appendix B Enquiry about results – application form Enquiry about results application form Part A: Learner consent form Information for learners If your examination centre makes an Enquiry About the Result of one of your examinations or assignments after your subject grade has been issued, there are two possible outcomes: Your original mark • is confirmed as correct, and there is no change to your grade. • is changed, so your final grade may be higher or lower than the original grade you received. In order to proceed with the Enquiry About Results, you must sign the form below. This tells the head of your centre that you have understood what the outcome might be, and that you give your consent to the Enquiry About Results being made. Learner number: Learner name: Qualification: Unit code: I give my consent to the head of my examination centre to make an enquiry about the result of the examination or assignment listed above. In giving consent, I understand that the final subject grade awarded to me following an Enquiry About Results may be lower than, higher than, or the same as the grade which was originally awarded for this subject. Learner Signature:…………………………………………………………………………… Centre Name:…………………………………………………………………………………. Date:……………………………………… Document Reference Number 5POAD3 Enquiries and Appeals Policy and Procedures_v14.0 October 2024 Page 11 of 14 Information Classification: Public If printed this document becomes uncontrolled Part B: Centre consent form Information for centres VTCT Skills charges a fee per learner per unit for an Enquiry About Result. The fee will be refunded if the EAR is successful in changing the learner’s grade. It is only possible to submit an EAR for an examination if within 2 marks of a grade boundary. Details of enquiry Please state the reason for your enquiry e.g. for assignments, specify which learning outcome(s) you believe have been achieved and indicate where the evidence for these can be found within the assignment evidence: Centre number: Centre name: Reasons for enquiry: Signature on behalf of centre:…………………………………………………….. Date:…………………………………………………….. This form should be retained on the centre’s files for at least 6 months following the outcome of the Enquiry About Results. Once completed, please email this form to postresults@vtct.org.uk. Centre Contact Information Email address:……………………………………………………………………………………………. Phone number:………………………………………………………………………………………….. Document Reference Number 5POAD3 Enquiries and Appeals Policy and Procedures_v14.0 October 2024 Page 12 of 14 Information Classification: Public If printed this document becomes uncontrolled 5. Appendix C Appeals against results – application form Appeals against results application form Centre name: Qualification/unit title: Centre number: Date of assessment: Learner name: Date appeal submitted: Learner CSDTA Registration no.: Please provide the following information/attach the related evidence: The nature of the appeal The outcome of the appeal Evidence to support the appeal Centre representative Learner Name: Name: Role: Contact email: Contact email: Contact phone number: Contact phone number: Signature: Signature: Date: Date: Attach this form to the front of documents when submitting by mail, and send to: For CSDTA centres – info@cityskindoctor.co.uk When submitting electronically, please include all evidence as file attachments. Document Reference Number 5POAD3 Enquiries and Appeals Policy and Procedures_v14.0 October 2024 Page 13 of 14 Information Classification: Public If printed this document becomes uncontrolled Document amendment history page Version Document Owner Issue Date Changes Role v1 Assessment Manager January 2015 Created as a separate document and updated with relevant information Quality and Processing Supervisor v2 Assessment Manager March 2017 Updated with new process for assessment Assessment Manager v3 Assessment Manager April 2017 Updated with new branding Product Administrator v4 Assessment Manager 14/02/2018 Updated contact email addresses and new guidelines for branding Assessment Manager v5 Assessment Manager 03/03/18 Reviewed in response to feedback from SQA regarding UK regulators. Amended to ensure the policy covers the requirements of all UK regulators, in addition to Ofqual. Executive Director of Awarding v6 Assessment Manager 05/03/2019 Reformatted to new template Compliance Manager v7 Assessment Manager 07/06/2019 Removed CSDTA references Head of Qualifications and Processing v8 Head of Assessment 01/03/2021 Updated fee. Head of Assessment v9 Head of Assessment 19/03/2021 Minor amendment to Section 3.2 Head of Assessment v10 Head of Assessment 01/10/2021 Updated job titles Head of Assessment v11 Head of Assessment 08/04/2022 Updated footer and document owner. Email address changed for submission of EAR applications. Minor wording amendment to section 2.2 Head of Assessment v12 Head of Assessment 27/01/2023 Branding updated Head of Assessment Document Reference Number 5POAD3 Enquiries and Appeals Policy and Procedures_v14.0 October 2024 Page 14 of 14 Information Classification: Public If printed this document becomes uncontrolled v13 Head of Assessment 10/01/2023 Amended in response to feedback from SQA. Head of Assessment v14 Head of Assessment 26/10/2024 Branding updated. Minor amendment to Section 1.6 Head of Assessment Document Review Role Review Status Head of Assessment Reviewed Head of Standards Reviewed Document Owner Document Owner Document shared with Head of Assessment Head of Standards Document Sign-off Role Sign-off Date Head of Assessment 26/10/2024

Equality, Diversity, and Inclusion Policy September 2024 Version 9 Information Classification: Public If printed this document becomes uncontrolled Document Reference Number 1POHR08 Equality, Diversity, and Inclusion Policy_v9 September 2024 Page 2 of 9 Information Classification: Internal If printed this document becomes uncontrolled Contents 1. Introduction ......................................................................................................................................... 3 1.1. Equality Act 2010 ............................................................................................................................ 3 1.2. Policy Statement ............................................................................................................................. 4 2. Scope..................................................................................................................................................... 4 3. Responsibilities ................................................................................................................................... 4 3.1. Regulatory authorities .................................................................................................................... 5 3.2. Review arrangements ..................................................................................................................... 5 4. Definitions ............................................................................................................................................ 5 5. Employment ......................................................................................................................................... 6 5.1. Part-time, Temporary, Fixed-term, and Zero-Hour work ....................................................... 7 5.2. Disabilities ........................................................................................................................................ 7 6. CSDTA as a Service Provider ..................................................................................................... 7 6.1. Qualifications ................................................................................................................................... 7 6.2. Centres.............................................................................................................................................. 8 Document Reference Number 1POHR08 1. Introduction This policy aims to outline the commitment of CSDTA to ensuring equality of opportunity and equal treatment for employees, contractors, workers, trustees, and customers in terms of employment and access to services; and to provide guidance on anti-discriminatory practice. This policy is non-contractual. This policy also sets out the commitment of CSDTA to meeting the requirements of the Equality Act 2010, and to the principles of equality and diversity both as an employer and in the development, delivery and awarding of qualifications. 1.1. Equality Act 2010 The Equality Act 2010 combined more than 116 pieces of equality legislation into one Act, providing a legal framework which tackles discrimination in respect of the following personal characteristics, which are protected by the law: • age; • disability; • gender reassignment; • marriage and civil partnership; • race; • religion or belief (there are some education exceptions where there is valid segregation); • sex (there are some education exceptions where there is valid segregation); • sexual orientation; and • pregnancy and maternity. It defines the behaviour that is unlawful under the Act as: • direct discrimination; • indirect discrimination; • discrimination arising from disability; • victimisation; or • harassment. Section 53 of the Act refers specifically to awarding organisations, requiring them not to discriminate, harass or victimise a person in relation to the conferment or withdrawal of a qualification. Equality, Diversity, and Inclusion Policy_v9 September 2024 Information Classification: Internal Page 3 of 9 If printed this document becomes uncontrolled Document Reference Number 1POHR08 1.2. Policy Statement CSDTA: • is committed to ensuring equality of opportunity in employment and access to services for all who work for or with it; • values and celebrates differences in age, disability, gender reassignment, marriage and civil partnership, race, religion or belief, sex, sexual orientation, pregnancy and maternity; • believes that all forms of prejudice and discrimination are unacceptable, and will strive vigorously to tackle these and to remove conditions which place people at a disadvantage; • works to eliminate unlawful direct and indirect discrimination; • provides equality of opportunity as an integral part of good practice; • is committed to a working environment in which the contribution and needs of everyone are fully recognized and valued; • supports staff and contractors in challenging any inappropriate, violent or abusive behaviour from colleagues, other individuals, organisations and customers. CSDTA will provide equality of opportunity and equal treatment as an integral part of good practice. The organisation is committed to a working environment in which the contribution and needs of everyone are fully valued and recognised. We will support our employees, workers, trustees, contractors, and learners in not tolerating any inappropriate, violent or abusive behaviour from colleagues, other organisations, or customers. 2. Scope This policy is provided for CSDTA employees, approved centres and learners using CSDTA products and services. This policy applies to current employees, job applicants, clients, customers, suppliers and visitors; it also applies to workers, trustees, contractors and customers in terms of service provision. This applies in the workplace, outside the workplace (when dealing with customers, suppliers or other work-related contacts), and on work-related trips or events including social events. 3. Responsibilities CSDTA values its employees, workers, contractors, trustees and customers, and expects them to be treated in a respectful manner. Accordingly, all have a responsibility to treat others with dignity and respect. Equality, Diversity, and Inclusion Policy_v9 September 2024 Information Classification: Internal Page 4 of 9 If printed this document becomes uncontrolled Document Reference Number 1POHR08 CSDTA is responsible for ensuring that its staff and contractors are aware of this policy, current equality legislation and regulatory requirements in relation to equality and diversity. The head of centre is responsible for ensuring that its staff, contractors, and learners are aware of this policy, current equality legislation and regulatory requirements in relation to equality and diversity. Within CSDTA the People Team are responsible for providing advice and guidance on equality and diversity issues to all stakeholders and ensure the policy document is kept up to date and in line with regulatory requirements 3.1. Regulatory authorities This policy addresses the requirements of the relevant regulatory authorities’ criteria. 3.2. Review arrangements This policy is reviewed annually as part of CSDTA’ self-evaluation activity, which includes consideration of legal updates and feedback. A policy review may also be triggered as an action resulting from the outcome of the investigation of a complaint. 4. Definitions CSDTA’ commitment to anti-discriminatory practice relates to all kinds of discrimination, as set out below: • Direct discrimination – where someone is treated less favourably than another because they have a protected characteristic. • Indirect discrimination – when a provision, criteria or practice is applied to everyone which has a detrimental effect on a particular group or individual with a particular protected characteristic than others and is not justified. This applies even if there was not a deliberate intention to discriminate. • Associative discrimination – direct discrimination against someone because they associate with another person who has a protected characteristic. • Perceptive discrimination - direct discrimination against someone because others think they have a protected characteristic even if they do not possess that characteristic. • Disability discrimination – this includes direct and indirect discrimination, any unjustified less favourable treatment because of the effects of a disability, and failure to make reasonable adjustments to alleviate disadvantages caused by a disability. • Harassment – unwanted conduct related to a protected characteristic which violates a person’s dignity or creates an intimidating, hostile, degrading, humiliating or offensive environment for them. This applies even if the conduct is not directed at the individual or if they do not have the protected characteristic. Harassment is dealt with further in the Bullying and Harassment Policy. Equality, Diversity, and Inclusion Policy_v9 September 2024 Information Classification: Internal Page 5 of 9 If printed this document becomes uncontrolled Document Reference Number 1POHR08 • Third party harassment – potential liability for the harassment of employees by others such as clients or customers. • Victimisation – when someone is treated badly because they have made or supported a complaint under the Equalities Act, or it is thought that they have done so. 5. Employment CSDTA is committed to ensuring that personnel are recruited, selected, monitored and can progress within the organisation in a fair and equitable manner, based on their attributes, skills, experience and performance. CSDTA aims to promote equality and diversity as an employer and to ensure that no job applicant or employee receives less favourable treatment or is disadvantaged by conditions or requirements that cannot be shown to be justifiable in the context of the policy. Recruitment, promotion and other selection exercises, such as redundancy selection, will be conducted on the basis of merit, against objective criteria that avoid discrimination. If possible, more than one person should do Shortlisting. Vacancies should generally be advertised to a diverse section of the labour market. Advertisements should avoid stereotyping or using wording that may discourage particular groups from applying. Job applicants should not be asked questions, which might suggest an intention to discriminate on grounds of a Protected Characteristic. For example, applicants should not be asked whether they are pregnant or planning to have children, how old they are, or any other questions related to protected characteristics. Job applicants should not be asked about health or disability before a job offer is made, except in the very limited circumstances allowed by law: for example, to check that the applicant could perform an intrinsic part of the job (taking account of any reasonable adjustments), or to see if any adjustments might be needed at interview because of a disability. Where necessary, job offers can be made conditional on a satisfactory medical check. Health or disability questions may be included in equal opportunities monitoring forms, which must not be used for selection or decision-making purposes. Selection, recruitment, training, promotion, and employment practices will be subject to regular review to ensure that they comply with this Policy. CSDTA regards discrimination, abuse, harassment, victimisation or bullying of employees, contractors, workers, customers or others in the course of work as disciplinary offences that could be regarded as gross misconduct. Any discrimination, abuse, harassment, victimisation, or bullying will be dealt with as per our Disciplinary Policy (1POHR07). Employees who believe they have suffered discrimination can raise the matter through our Grievance Procedure (1POHR10) or Anti-harassment and Bullying Policy (1POHR04). Complaints will be treated in confidence and investigated as appropriate. Equality, Diversity, and Inclusion Policy_v9 September 2024 Information Classification: Internal Page 6 of 9 If printed this document becomes uncontrolled Document Reference Number 1POHR08 CSDTA takes a strict approach to breaches of this policy, which will be dealt with in accordance with our Disciplinary Procedure (1POHR07). Serious cases of deliberate discrimination may amount to gross misconduct resulting in dismissal. Employee’s must not be victimised or retaliated against for complaining about discrimination. However, any employee who is found to have made a false allegation deliberately and in bad faith will be dealt with under our Disciplinary Procedure (1POHR07). 5.1. Part-time, Temporary, Fixed-term, and Zero-Hour work Part-time, temporary, and fixed-term employees should be treated the same as comparable full-time or permanent employees and enjoy no less favourable terms and conditions (on a pro rata basis where appropriate), unless different treatment is justified. 5.2. Disabilities If an employee is disabled or becomes disabled, we encourage the employee to tell CSDTA about their condition so that CSDTA can consider what reasonable adjustments or support may be appropriate. 6. CSDTA as a Service Provider In developing its qualifications, including but not limited to; record of assessment books, qualification specification and materials, or its awarding organisation services (registration, entry, assessment, certification or web interfaces to the services), CSDTA will seek to ensure access to its customers and their learners. This will include, wherever practicable, making specific access arrangements for its customers, and their learners to whom any protected characteristics may apply. CSDTA will attempt to ensure that none of its policies discriminate directly or indirectly against any group or individual. We encourage any individual to whom a protected characteristic may apply to inform us so that we can consider what reasonable adjustments or support may be appropriate. 6.1. Qualifications CSDTA ensures that: • its qualifications are suitable for as diverse a range of learners as possible; • it adheres to regulatory conditions relating to the development, delivery, assessment and awarding of CSDTA qualifications, to ensure that qualifications contain no bias in content which might discriminate against or disadvantage any groups of learners sharing a particular characteristic, in terms of language, content or means of assessment, other than those directly related to the purpose of the units or qualifications; • if any such features or barriers of this type are necessary, their nature and the reason for their inclusion in the particular unit or qualification are clearly set out. Staff responsible for inducting learners on to qualifications must be fully briefed of such features. Equality, Diversity, and Inclusion Policy_v9 September 2024 Information Classification: Internal Page 7 of 9 If printed this document becomes uncontrolled Document Reference Number 1POHR08 New qualifications put forward for approval are scrutinised for the above before they are added to the portfolio. 6.2. Centres CSDTA ensures equality of opportunity for learners registered on its qualifications by requiring centres to demonstrate as part of the approval process that: • current equality legislation is adhered to; • there is an up-to-date equality and diversity policy in place; • staff and learners are aware of and have access to the equality and diversity policy; • assessment processes are carried out in a fair and objective manner; • an appeals policy and procedure is in place; • staff and learners are aware of and have access to the appeals policy and procedure; • Learner / candidate results are monitored in line with the centre’s equality and diversity policy; • equipment and accommodation used for learning and assessment create no barriers to access for any candidate; and • reasonable adjustments and special consideration(s) are made in line with CSDTA’ policy and procedures. Equality, Diversity, and Inclusion Policy_v9 September 2024 Information Classification: Internal Page 8 of 9 If printed this document becomes uncontrolled Document Reference Number 1POHR08 Document amendment history page Version Document Owner Issue Date Changes Role 7 HR Advisor April 2023 Updated template HR Advisor 8 HR Advisor January 2024 Amalgamation of Diversity and Equality Policy (HR) and Equality and Diversity Policy (AD) into one policy 9 HR Advisor September 2024 Updated template HR Advisor HR Advisor Document Review Role Review Status HR Advisor Update complete Document Owner Document Owner Document shared with HR Director HR Advisor Head of Standards Document Sign-off Role Sign-off Date HR Advisor September 2024 Equality, Diversity, and Inclusion Policy_v9 September 2024 Information Classification: Internal

External Whistleblowing Policy and Procedures October 2024 Version 7 Information Classification: Public If printed this document becomes uncontrolled Document Reference Number 5POAD12 External Whistleblowing Policy and Procedures V7 October 2024 Page 2 of 10 Information Classification: Public If printed this document becomes uncontrolled Contents 1. Introduction ............................................................................................................................................... 3 1.1. Purpose of the policy ..................................................................................................................... 3 1.2. Scope of the policy ......................................................................................................................... 3 1.3. Regulatory authorities .................................................................................................................... 4 1.3.1. Adverse effects ........................................................................................................................... 4 1.4. Definition of whistleblowing ......................................................................................................... 4 1.5. Responsibilities ............................................................................................................................... 4 1.5.1.CSDTA................................................................................................................................... 4 1.5.2. Centres.......................................................................................................................................... 4 1.6. Review arrangements ..................................................................................................................... 5 1.7. Confidentiality, anonymity and whistleblowing ........................................................................ 5 2. Whistleblowing - process .................................................................................................................. 6 2.5. External whistleblowing – flowchart .......................................................................................... 8 3. Appendix 1 – Whistleblowing report form ......................................................................................9 Document Reference Number 5POAD12 1. Introduction 1.1. Purpose of the policy This policy provides a definition of external whistleblowing. It sets out CSDTA approach to whistleblowing and the procedures which should be followed when raising a concern with a centre or withCSDTA. This document should be read in conjunction with the following related policies and procedures: • Malpractice and Maladministration Policy and Procedure; • Plagiarism, Collusion and Cheating Policy Sanctions Policy; • Adverse Effects Policy; • Conflict of Interest Policy and Procedures. This policy provides those wishing to make a disclosure about malpractice or other wrongdoing with a framework for doing so, in line with the Public Interest Disclosure Act 1998, which provides for protection of a person making a disclosure against dismissal or victimisation if the disclosure is made in good faith and believed to be true. More information about the Act is available via this link: https://www.gov.uk/government/publications/the-public-interest-disclosure-act. 1.2. Scope of the policy The External Whistleblowing Policy and Procedures apply to all CSDTA qualifications. This policy is provided for the use of CSDTA customers, being learners who are taking or have taken CSDTA assessments (or their parent/guardian), and centre personnel with responsibilities for managing, administering, delivering, assessing and quality assuring qualifications in centres approved to offer CSDTA qualifications. This policy and procedures does NOT apply to: • awarding organisation personnel or associates, for whom a separate, internal policy is available; • complaints about CSDTA qualifications or services, for which the Complaints Policy and Procedures should be used; • appeals against assessment decisions, for which the Enquiries and Appeals Policy and Procedures should be used. External Whistleblowing Policy and Procedures V7 October 2024 Information Classification: Public Page 3 of 10 If printed this document becomes uncontrolled Document Reference Number 5POAD12 1.3. Regulatory authorities In line with regulatory guidance, this policy sets out how whistleblowers should be treated by the centre and/or awarding organisation, ensuring that no individuals will be prejudiced by their actions. 1.3.1. Adverse effects It is essential for CSDTA to meet its obligations relating to notification of adverse effects to the regulators at all times. The awarding organisation will consider the implication of an allegation raised by a whistleblower in this context. 1.4. Definition of whistleblowing Whistleblowing is a term used when an individual discloses information relating to malpractice, maladministration, wrongdoing, bad practice, corruption and/or the covering up of any of these. The malpractice or wrongdoing is often committed by the individual’s employer, although this is not always necessarily the case. A disclosure might be made relating to, for example: • a criminal act such as fraud or bribery; • a failure to comply with a condition of the Centre Agreement; • action leading to illegal financial gain; • observation of an irregularity in assessment not reported through the normal channels; • failure to address health and safety issues. 1.5. Responsibilities 1.5.1. CSDTA. CSDTA will ensure that: it maintains high standards of ethical, moral and legal business conduct; it complies with relevant legislation at all times and stages; personnel are aware of, understand and receive training as appropriate about this policy and related procedures; personnel comply with this policy and procedures in addition to the Malpractice and Maladministration Policy and Procedures. 1.5.2. Centres The centre is responsible for ensuring that: External Whistleblowing Policy and Procedures V7 October 2024 Information Classification: Public Page 4 of 10 If printed this document becomes uncontrolled Document Reference Number 5POAD12 • centre personnel involved in the administration, management, assessment and quality assurance of CSDTA qualifications, and learners, are fully aware of the contents of this policy and have access to it; • full cooperation is given to any investigation which is instigated following disclosure by a whistleblower, in line with its own and the awarding organisation's malpractice and maladministration policy and procedures and this external whistleblowing policy and procedure; • the whistleblower is not subject to any prejudice as a result of making the disclosure; • personnel dealing with and involved in a whistleblowing case comply with the relevant legislation at all stages. 1.6. Review arrangements This policy is reviewed annually as part of CSDTA self-evaluation activity, which considers customer and regulatory feedback and good practice guidance, changes in CSDTA practices, actions from the regulators, changes in legislation, or trends identified from previous cases. In addition, this policy may be updated following consideration of operational feedback to ensure CSDTA arrangements for dealing with suspected cases of malpractice and maladministration remain effective. 1.7. Confidentiality, anonymity and whistleblowing CSDTA: • will maintain the confidentiality of information relating to all parties involved in the disclosure as far as possible (see 4th bullet point); • is normally unable to accept and act upon anonymous allegations about a centre; • may in some circumstances be prepared to investigate issues which are reported anonymously, after trying to confirm the allegation by means of a separate fact-finding exercise; • will strive to keep a whistleblower’s identity confidential where possible but may, for example, need to disclose their identity if the matter leads to issues that need to be taken up by other parties such as: ̵ the police; ̵ fraud prevention agencies or other law enforcement agencies; ̵ the courts (regarding any court proceedings); ̵ the regulators. Sometimes a person making an allegation of malpractice or maladministration may wish to remain anonymous. A whistleblower who is concerned that possible adverse consequences may occur if their identity is revealed to another party should raise this with CSDTA as soon as possible. External Whistleblowing Policy and Procedures V7 October 2024 Information Classification: Public Page 5 of 10 If printed this document becomes uncontrolled Document Reference Number 5POAD12 • The investigator(s) assigned to review the allegation will not reveal the whistleblower’s identity unless the whistleblower agrees, or doing so is necessary for the purposes of the investigation. • The investigator will advise the whistleblower if it becomes necessary to reveal their identity. • A whistleblower may be identifiable by others due to the nature or circumstances of the disclosure (eg the party against whom the allegation is made may identify possible sources of disclosure without such details being disclosed to them). • Once a concern has been raised, CSDTA has a duty to pursue the matter. It will not be possible to prevent the matter being investigated by subsequently withdrawing a disclosure, as CSDTA is obliged by the regulators to follow up and investigate all allegations of malpractice or maladministration. • In all cases the whistleblower will have the opportunity to raise with the investigators any concerns about the way the investigation is being conducted. It should be noted that CSDTA will not disclose details of all of the investigation activities, and it may not be appropriate to disclose full details of the outcomes of the investigation due to confidentiality. 2. Whistleblowing - process 2.1. Raising a concern with the centre • A member of staff should raise their concern in the first instance through the centre’s internal procedures. • A learner's first point of contact is their main tutor or assessor. 2.2. Raising a concern with CSDTA If the concerns are not addressed by the centre or the individual feels that it is not possible to raise the concerns internally, then the individual should raise their concerns by completing the form provided as an appendix to this document and submitting it to info@cityskindoctor.co.uk. • The disclosure should provide as much information as possible, including: • centre contact details; • qualification and units affected; • the date(s) of the alleged incident; • individuals involved in the alleged or suspected malpractice or maladministration, their roles and contact details; • full details of the allegation and those considered to be affected; • own name, role and contact details. (See section 1.7.) External Whistleblowing Policy and Procedures V7 October 2024 Information Classification: Public Page 6 of 10 If printed this document becomes uncontrolled Document Reference Number 5POAD12 2.3. Actions upon receipt of a disclosure Upon receipt of the disclosure CSDTA will: • consider the disclosure sensitively and carefully. Information received in a disclosure may be shared with third parties where considered necessary; • evaluate the matter raised and may ask for more evidence/information using the contact details provided on the whistleblowing form; • decide whether and how to pursue the matter. Any investigation instigated is conducted in line with the Malpractice and Maladministration Policy and Procedures. An update on any course of action proposed will be provided to the informant within 10 working days of receipt of the disclosure. • inform the regulator(s) of the matter raised if appropriate and the course of action to be taken, and update them regularly; CSDTA cannot respond to requests from whistleblowers for regular updates. 2.4. Conclusion of investigation Upon conclusion of any investigation, CSDTA will: • provide the whistleblower with a summary update of outcomes within 10 working days. The update will not contain detailed confidential information relating to any individuals involved in the case. • provide the regulators with full details of the investigation/evaluation. Where any serious issues are proven, other awarding organisations offering the same or similar qualifications will also be informed. External Whistleblowing Policy and Procedures V7 October 2024 Information Classification: Public Page 7 of 10 If printed this document becomes uncontrolled Document Reference Number 5POAD12 2.5. External whistleblowing – flowchart External Whistleblowing Policy and Procedures V7 October 2024 Information Classification: Public Page 8 of 10 If printed this document becomes uncontrolled Document Reference Number 5POAD12 External Whistleblowing Policy and Procedures V7 October 2024 Page 9 of 10 Information Classification: Public If printed this document becomes uncontrolled 3. Appendix 1 – Whistleblowing report form Section 1 – Your contact information Title: Forename(s): Surname: Role: Centre: Address for correspondence: Email address: Phone no.: Alternative phone no.: Section 2 – Disclosure Qualification and unit name (s): Date of incident being disclosed: Name and roles of individuals considered responsible for the incident: Full details of the incident and those affected by the incident: Signed: …………………………………………………………………………………………………………………………………… Date: ……………………………………………………….. Continue on to a second page if necessary. Submit the completed form to info@cityskindoctor.co.uk Document Reference Number 5POAD12 Document amendment history page Version Document Owner Issue Date Changes Role V1 Quality and Processing Manager 02/02/2018 New policy Quality and Processing Manager V2 Quality and Processing Manager Head of Quality 02/02/2018 Formatted and new branding template Qualifications Manager V3 V4 05/03/2019 Formatted and new branding template Quality Lead 16/03/2021 Review and minor amendments for consistency across policies Compliance Manager Quality Assurance Administrator V5 Head of Standards 10/05/2022 Update Owner Quality Assurance Administrator V6 Head of Standards 28/11/2022 Policy Integration Quality Assurance Administrator V7 Head of Standards 24/10/2024 Branding update Quality Assurance Administrator Document Review Role Review Status Head of Standards Reviewed Document Owner Document Owner Document shared with Head of Standards Quality Assurance Administrator Document Sign-off Role Sign-off Date Head of Standards 24/10/2024 External Whistleblowing Policy and Procedures V7 October 2024 Information Classification: Public Page 10 of 1

Instructions for Conducting Examinations October 2024 Version 21 Information Classification: Public If printed this document becomes uncontrolled Document Reference Number 5PRAD6 Instructions for Conducting Examinations_v21.0 October 2024 Page 2 of 26 Information Classification: Public If printed this document becomes uncontrolled Contents 1. Introduction ............................................................................................................................................... 4 2. Contingency planning ......................................................................................................................... 4 3. Preparing for the examination .......................................................................................................... 5 3.1. Preparation of learners .................................................................................................................. 5 3.2. Keeping question papers and other examination materials secure ...................................... 5 3.3. Timetabling of examinations ........................................................................................................ 6 3.4. Preparing for implementation of access arrangements .......................................................... 6 3.5. Preparing the examination room .................................................................................................. 6 3.6. Preparing for on-screen assessments ........................................................................................ 7 3.6.1. General .......................................................................................................................................... 7 3.6.2. Software ................................................................................................................................... 8 3.6.3. CSDTA online examinations: ......................................................................................... 8 3.6.4. CSDTA online examinations: ..................................................................................................... 8 4. Invigilation arrangements ..................................................................................................................9 4.1. Introduction .....................................................................................................................................9 4.1.1. Centre responsibilities ...............................................................................................................9 4.1.2. Invigilator responsibilities........................................................................................................ 10 4.1.2.1. Role and number of invigilators ......................................................................................... 10 4.1.3. Assessment material errors ..................................................................................................... 11 4.2. Conducting examinations ............................................................................................................. 11 4.2.1. Before the examination commences ..................................................................................... 11 4.2.2. During the examination ........................................................................................................ 13 4.2.3. At the end of the examination ........................................................................................... 15 4.3. Paper examinations ...................................................................................................................... 15 4.3.1. Accuracy and clarity in multiple choice questions ............................................................. 15 4.4. Online examinations ..................................................................................................................... 16 4.4.1. During the examination ............................................................................................................ 16 4.4.2. After the examination .......................................................................................................... 16 4.5. Invigilating learners with reasonable adjustments ................................................................. 17 4.5.1. Use of readers, writers, prompters and sign-language interpreters ............................... 17 4.5.2. Bilingual dictionaries (approval required) ......................................................................... 17 4.6. Functional Skills ICT Invigilation Guidance .............................................................................. 17 4.7. Invigilator role – flowcharts and checklists ............................................................................ 18 Document Reference Number 5PRAD6 Instructions for Conducting Examinations_v21.0 October 2024 Page 3 of 26 Information Classification: Public If printed this document becomes uncontrolled 4.7.1. Before the examination commences - paper-based and electronic .............................. 18 4.7.2. During the examination - paper-based ............................................................................ 19 4.7.3. During the examination - electronic ................................................................................ 20 4.7.4. After the examination ends - paper-based and electronic .......................................... 21 5. After the examinations ....................................................................................................................22 5.1. Results slips ...................................................................................................................................23 6. Copyright ............................................................................................................................................23 7. Retaining invigilation records ..........................................................................................................23 8. Monitoring the conduct of examinations .....................................................................................23 9. Appendix ............................................................................................................................................ 24 Document Reference Number 5PRAD6 1. Introduction These Instructions for Conducting Examinations set out the procedures to be followed for all CSDTA, onscreen and online examinations and other examinations for the following qualification types: VRQ, NVQ, SVQ, Functional Skills and Technical Qualifications. They are provided for the use of heads of centres, examinations officers, invigilators and all other personnel involved in the examination process, in plenty of time before the examinations, and should be available for reference during examination sessions. The head of centre is responsible for ensuring that all relevant personnel are familiar with and adhere to these instructions, and any supplementary instructions for specific CSDTA qualifications. These instructions are mandatory and should be read in conjunction with the following publications: • CSDTA Reasonable Adjustments and Special Consideration Policy and Procedures • CSDTA Malpractice and Maladministration Policy and Procedures • CSDTA Plagiarism, cheating and collusion document • CSDTA Sanctions Policy 2. Contingency planning All approved centres must prepare for possible disruption to examinations as part of their emergency planning. General guidance on this topic can be found at: https://www.gov.uk/government/publications/exam-system-contingency-plan-england-wales and-northern-ireland/what-schools-and-colleges-should-do-if-exams-or-other-assessments are-seriously-disrupted. If an assessment cannot take place because of an unforeseen situation out of the control of the centre, or the security of the assessment has been or may have been put at risk, CSDTA must be alerted immediately and the centre must follow CSDTA instructions. In these circumstances CSDTA will: • take all reasonable steps to mitigate any negative effect in relation to CSDTA qualifications arising from the disruption • provide clear and effective guidance to the centre • ensure that where an assessment is required to be completed under specified conditions, learners complete the assessment under those conditions (other than where any reasonable adjustments or special considerations require alternative conditions) • promptly notify the relevant regulators about any event which could have a negative effect on learners, standards or public confidence in the qualification Instructions for Conducting Examinations_v21.0 October 2024 Information Classification: Public Page 4 of 26 If printed this document becomes uncontrolled Document Reference Number 5PRAD6 • consider requests for special consideration for affected learners as appropriate. 3. Preparing for the examination 3.1. Preparation of learners • Learners should be given the opportunity to undertake mock examinations under examination conditions prior to the actual examination sitting • Where sample assessment materials are available, they can be downloaded from the qualification page on the CSDTA website • Functional Skills practice examinations are available on the CSDTA website • All learners should receive guidance on how to use the onscreen testing software • Learners for whom reasonable adjustments have been granted should be kept informed of arrangements and given the opportunity where appropriate to familiarise themselves with and practice with any related equipment or other resource 3.2. Keeping question papers and other examination materials secure CSDTA paper-based examinations: Paper-based CSDTA examination papers will be available to be printed from the e-testing system from the permitted window in advance of the scheduled start time of the examination. ITEC paper-based examinations: Paper-based ITEC examination papers will be despatched to arrive at least one working day before the scheduled examination (five working days for national series examinations) or will be printable from files supplied. Centres must: • have arrangements in place to ensure that examination materials are delivered only to those authorised by the head of centre to receive them • have a system in place to record the printing or receipt and dispatch of paper-based exam materials • store examination papers in the designated secure storage facility, in either a room designated for this purpose at the centre's registered address, or in a secure cabinet in a dedicated examinations office • ensure that the materials are stored securely at all times • ensure only authorised personnel have access to the centre's secure storage facility • be able to demonstrate that secure systems are in place to prevent unauthorised access to the exam materials • ensure that the materials are only accessed in accordance with awarding organisation instructions Instructions for Conducting Examinations_v21.0 October 2024 Information Classification: Public Page 5 of 26 If printed this document becomes uncontrolled Document Reference Number 5PRAD6 • maintain the confidentiality of learner responses and details • in the case of encrypted papers received via email for printing, store all papers as above In addition for ITEC paper-based examinations: • check the package, the delivery note/label and learner list supplied immediately, in the designated secure storage facility • if it is not possible to conduct an immediate check, keep the materials in the secure storage area until the check can be carried out by an authorised person • inform the awarding organisation immediately by telephone (CSDTA Customer Support on +44 (0) 2920486868 or ITEC Exams on +44 (0) 23 80 684503 or Functional Skills +44 (0) 121 270 5100) if it appears that the security of the package has been breached in transit, if there is damage to the package or if there are differences in the materials received from those expected 3.3. Timetabling of examinations All examinations must be taken at the scheduled time as notified to the learners. Learners who are allowed to take an examination earlier than the published starting time must be supervised by the centre until immediately after the starting time of the examination. These measures must be arranged and ensured by the centre. Learner answer papers must be kept in secure storage until after commencement of the scheduled assessment. Learners who are allowed to take an examination later than the published starting time must be supervised by the centre from 30 minutes after the published starting time to the commencement of the later session. 3.4. Preparing for implementation of access arrangements CSDTA Reasonable Adjustments and Special Consideration policy and procedures should be read in conjunction with this document. The examinations officer is responsible for ensuring that all requests for reasonable adjustments have received approval by the centre, and awarding organisation approval in accordance with the policy document, and that the agreed arrangements have been communicated to the learner and invigilator, and are put in place at the appropriate time. In cases where additional support is required to facilitate access arrangements, the head of centre is responsible for ensuring that invigilators and those facilitating access arrangements, such as readers, scribes and sign language interpreters, understand their role and responsibilities. All involved must be trained appropriately in their role. 3.5. Preparing the examination room Centres must ensure suitable accommodation is used for all examinations as follows: • the examination room must be of an adequate size for the number of learners Instructions for Conducting Examinations_v21.0 October 2024 Information Classification: Public Page 6 of 26 If printed this document becomes uncontrolled Document Reference Number 5PRAD6 • the poster provided in the appendix to this document must be displayed at the entrance to the examination room; • learners must have suitable seating arrangements, and desks or tables with adequate room to work independently without distractions • learners must be seated a minimum of 1.25 metres apart and facing in the same direction • each learner must have a separate desk and be placed far enough away from other learners to prevent them from seeing each other’s work • heating, lighting, ventilation and the level of outside noise must be controlled appropriately to allow the learners to take their examination comfortably • all relevant examination signage must be clearly displayed • there must be no display material visible in the room which might assist learners with writing their answers • there must be a working, accurate clock clearly visible to each learner • the invigilator must be able to move freely around the room and observe each learner with ease at all times • a board/flipchart/whiteboard should be visible to all learners, showing the: ̵ qualification/examination title and level ̵ scheduled start and finish times of the examination; ̵ if for any reason a centre wishes to provide examination spaces which differ from the above, e.g. screened booths, the prior approval of CSDTA must be gained. 3.6. Preparing for on-screen assessments 3.6.1. General Designated responsible personnel in the centre must check that: • all passwords and login details for onscreen exams are kept securely prior to the start of the examination • usernames and passwords have been issued allowing access to online tests if relevant • computers have been correctly logged in (in the case of non-Functional Skills) • where access to the internet is required, computers have a stable Wi-Fi or wired internet connection. The use of dongles is not permitted • any laptops used are connected to a mains supply so that they remain fully charged for the duration of the session • learners have been provided with their login details • learners check their personal details thoroughly. CSDTA should be notified immediately if any are incorrect or technical faults are apparent. Failure to adhere to any of these measures may result in disruption to learners during the assessment. Instructions for Conducting Examinations_v21.0 October 2024 Information Classification: Public Page 7 of 26 If printed this document becomes uncontrolled Document Reference Number 5PRAD6 3.6.2. Software Designated responsible personnel in the centre must check that: • any software required for on-screen examinations, such as SecureClient for Functional Skills, has been installed on all computers to be used for the assessment in plenty of time before the assessment; • all computers being used for Functional Skills assessments meet or exceed appropriate specifications to run SecureClient and operate allowable Windows or other operating systems. • if problems are encountered please contact: CSDTA Customer Support +44 (0) 2920486868 info@cityskindoctor.co.uk 3.6.3. CSDTA online examinations: CSDTA examinations are available as paper-based and online examinations. The following procedures must be followed to access online theory tests: • Go to https://www.vtct.org.uk/learners/ • Under the ‘Assessment and E-testing Linx2Achieve’ heading select the ‘Access’ button • Login: ̵ the learner’s login is typically their CSDTA learner number as the User ID ̵ the password will be issued by CSDTA. ̵ refer to the attendance and/or learner login sheets for details 3.6.4. ITEC online examinations: A username and password are issued to the centre by the ITEC exams office upon booking the online test. The following procedures must be followed to access online theory tests: • Go to the ITEC website www.itecworld.co.uk Instructions for Conducting Examinations_v21.0 October 2024 Information Classification: Public Page 8 of 26 If printed this document becomes uncontrolled Document Reference Number 5PRAD6 • Select Centres • Select College Admin V2 • Log in using the username and password issued by ITEC • Select the named centre • Select Theory Onscreen • Find the correct booking and select Onscreen Exam • Find the correct qualification and select Units • A list of learners and units is now displayed. • Select the required unit. • Select Theory Exam The examination should now be ready for the learner to start. 4. Invigilation arrangements 4.1. Introduction All CSDTA and ITEC written and online examinations and other examinations must be supervised by invigilators. Invigilators play a key role in the quality control of the examination process. They and all personnel responsible for their induction, training and deployment must ensure they are fully conversant with these regulations and any additional specific regulations for certain qualifications. Invigilators have the right to void the examination immediately if the regulations are contravened. If this occurs, the invigilator must provide a full report immediately. 4.1.1. Centre responsibilities It is the centre's responsibility to: • appoint invigilators and provide effective and regular invigilator training, which covers briefing on awarding organisation requirements, including malpractice and maladministration, familiarisation with CSDTA regulations and any specific requirements for certain qualifications • provide the appropriate number of invigilators for each examination • provide a copy of the Instructions for Conducting Examinations to all invigilators, either printed or electronically, and ensure there is a copy in the room at the time of the examinations • provide invigilators in a timely manner with the details of all reasonable adjustment arrangements agreed for any learner taking the examination • provide a declaration that all reasonable steps have been taken to ensure the integrity of the examination. This declaration is found in CSDTA invigilation report template Instructions for Conducting Examinations_v21.0 October 2024 Information Classification: Public Page 9 of 26 If printed this document becomes uncontrolled Document Reference Number 5PRAD6 • where possible, ensure that where sole invigilators are used, they have not taught, assessed or internally quality assured any learners taking the examination • provide impartial invigilators who are not current learners at the centre, or a friend, peer, or relative of a learner taking the examination • ensure that where readers, writers, prompters or sign language interpreters have been provided for learners with reasonable adjustments, an invigilator is also provided. The reader/writer/prompter must not act as invigilator • formulate and retain a seating plan for all VRQ, NVQ, SVQ, Applied General and Technical Qualification examinations. CSDTA’ seating plan template is published in the Document Library • provide invigilators with the examination papers in a sealed envelope at the agreed time prior to the assessment, together with an attendance list • have arrangements in place to ensure that the correct question paper envelopes are opened • ensure that unseen examination questions have not been communicated by or available to any persons connected with the examination prior to the agreed time for opening the sealed enveloped or releasing online examinations • ensure that invigilators are aware of the centre's policy and practice relating to late arrival of learners • complete an invigilation report for all VRQ, NVQ, SVQ, Functional Skills and Technical Qualification examinations. CSDTA’ invigilation report template is published in the Document Library • pay fees and expenses incurred by invigilators 4.1.2. Invigilator responsibilities The invigilator will know and understand the requirements of the Instructions for Conducting Examinations. They will have completed invigilator training, provided by the centre, in order to understand and fulfil their duties in this role. The invigilator must know and be familiar with all of the requirements relating to the three key stages of an examination: before the examination commences, during the examination and after the examination. 4.1.2.1. Role and number of invigilators The role of the invigilator is to: • ensure the security and integrity of all examinations before, during and after the examination • prevent learner plagiarism/collusion/cheating • minimise the impact on the learner of potential hardware failures • ensure previously agreed reasonable adjustments are put in place At least one invigilator for every 30 learners must be present at all times Instructions for Conducting Examinations_v21.0 October 2024 Information Classification: Public Page 10 of 26 If printed this document becomes uncontrolled Document Reference Number 5PRAD6 Sole invigilators must be able to access help easily without disturbing the learners. A sole invigilator is allowed to keep a mobile phone in silent mode in the room for use to summon assistance only. Learners must never be left unattended. 4.1.3. Assessment material errors CSDTA has a rigorous system in place to ensure that errors in assessment materials are rare. However, we recognise that errors can happen from time to time. The invigilator is required to notify the Exam’s officer immediately where learners suspect that there is an error in an assessment material. The Exam’s Officer will notify CSDTA immediately. Centres may notify CSDTA’ Customer Support Department by telephone or email, or may submit an Exam Officer Notification Form. • +44 (0) 2920486868 • info@cityskindoctor.co.uk • customerservice@itecworld.co.uk The Exam Officer Notification Form is available in the Document Library in the secure area of the website or directly from Customer Support. CSDTA will confirm the action instructions to the Exams Officer reporting the incident. 4.2. Conducting examinations 4.2.1. Before the examination commences Before learners are allowed to start the examination, the invigilator must always: • ensure that unauthorised items are left outside the examination room. These include mobile phones/smart watches/tablets/wrist watches with a data storage device/iPods/MP3/4 players. If this is not practical, learners must be required to leave these items in an area of the room removed from reach, which must be monitored by the invigilator at all times • ensure the examination room has been set up in accordance with the regulations and with the seating plan provided • confirm the identity of the learners in line with centre requirements for this purpose, usually photographic ID, and record verification on the attendance list. A learner without photographic ID may take the assessment if they are known to the invigilator. This should be noted on the attendance list • note any permitted additional learners and any absences on the attendance list • where it is impossible to identify a learner due to the wearing of religious clothing such as a veil, ensure that the learner is approached by a member of staff of the same gender and taken to a private room where they should be politely asked to remove the religious clothing for identification purposes. Once identification has been established, the learner should replace the clothing and proceed as normal to sit the assessment Instructions for Conducting Examinations_v21.0 October 2024 Information Classification: Public Page 11 of 26 If printed this document becomes uncontrolled Document Reference Number 5PRAD6 • ensure all learners are seated according to the seating plan and have been issued with the correct question paper. Any changes made to seating arrangements during the examination must be recorded on the seating plan. This must be made available to CSDTA upon request • identify learners with special requirements and ensure provision to support these learners is in place and as agreed • if a reader or scribe is required for the examination, ensure there is an invigilator also present and that no other learners are disadvantaged by this arrangement. Readers and / or scribes are not allowed access to the examination paper prior to the start of the examination • inform learners that they must follow the assessment regulations • ask learners to confirm they are sitting the assessment for the correct qualification and level • check that learners have the necessary equipment and materials for their assessment, e.g. calculators and source documents (where applicable) • check that no information is included inside calculator cases (where applicable) and that calculators are not programmable • ensure any pencil cases brought into the room are see-through • tell the learners about any erratum notices • confirm emergency procedures to all learners • read out the following (appropriate) information for learners before commencing the assessment: • do not turn over your question paper/booklet before you are instructed to do so • mobile phones or any other unauthorised devices must be handed in if you have not already done so. Failure to do so could lead to disqualification • you must not have in your possession any notes, books, dictionaries or other information unless it is allowed by the regulations. If you are in possession of any items that may not be allowed, please raise your hand now • you must not communicate with other learners or staff in any way. If you need attention, please raise your hand and wait for me/an invigilator to attend to you. Please do not make any noise or distract other learners • ensure that your answers are clear and legible • write your first name, surname, centre number, learner number and paper details on your answer booklet(s) and on any additional answer sheet(s) used; • sign and write your name exactly as it appears on the attendance register and fill in any other details as necessary • read each question carefully and attempt to answer questions as specified in the question paper • guidance on the questions or assistance in completing the assessment cannot be given Instructions for Conducting Examinations_v21.0 October 2024 Information Classification: Public Page 12 of 26 If printed this document becomes uncontrolled Document Reference Number 5PRAD6 • do all work, including rough work, in the question booklet and cross through rough work neatly (unless the rough work is mathematics workings out, which should be left) • write your answers in the designated sections of the answer booklet • if you finish your work and wish to leave, raise your hand and wait for permission. If it is given, please leave as quietly as possible, to avoid disturbing other learners • do not take any paperwork relating to the examination out of the room • note that by starting the examination, you agree that you understand and accept these rules • announce clearly to learners when they may begin and inform them of the duration of the assessment • only answer questions from learners about any instructions on the front of the question booklet. 4.2.2. During the examination During the examination the invigilator must: • supervise the learners throughout the examination and give complete attention to this duty at all times • move around the examination room quietly and at frequent intervals • be able to observe all learners (sole invigilator or between two or more invigilators) • permit late arriving learners to enter the room only in line with the centre's policy on late arriving learners and when permitted, ensure that the following takes place: ̵ the late learner must have been advised of the information for learners given above before entering the room by another member of staff or additional invigilator. Learners within the room must not be left unsupervised ̵ the full details of this are noted on the invigilator’s report in the relevant box • be vigilant and aware of emerging situations, looking out for cheating and malpractice or learners who may be feeling unwell. Any irregularities must be recorded on the invigilation report. CSDTA must be notified immediately after the assessment • if a learner needs to leave the examination room temporarily because they feel unwell or need to go to the toilet, ensure they are accompanied by a member of staff who must make sure the learner does not: ̵ speak to anyone else ̵ consult any notes ̵ have access to a mobile phone or any other electronic devices, eg iPods, smart watches etc. or make any calls ̵ do anything to breach the security of the examination • accurately complete the attendance register and invigilation report during the examination, specifying any learners who were absent from the assessment, and detailing fully any disruptions which occurred • provide learners with additional paper if required • adhere to the correct timings of the examination Instructions for Conducting Examinations_v21.0 October 2024 Information Classification: Public Page 13 of 26 If printed this document becomes uncontrolled Document Reference Number 5PRAD6 • ensure any disturbances/emergencies are dealt with appropriately, recorded on the invigilator's report and notified to CSDTA immediately • ensure in the case of an emergency such as fire alarm, bomb warning, etc. that: ̵ the examination room is evacuated in accordance with the instructions of the appropriate authority ̵ learners leave their question papers and learner answer sheets on their desk or their computer desk ̵ learners are kept apart and unable to converse with each other ̵ learners are unable to consult books, notes, mobile phones, the internet, etc. ̵ if satisfied the above has been adhered to, the assessment is resumed, and the remainder of allocated time is applied; ̵ if there has been a breach of the examination security, the examination is voided immediately and CSDTA is provided with full details • make sure advice is provided to learners if they suspect there is an error in a question. The invigilator will follow the procedure to notify CSDTA immediately • complete the attendance record ensuring all learners’ attendance is ticked as appropriate and that any additional details or incidents are added and signed by the invigilator, including any reasonable adjustment that was allowed • inform the learners of the time remaining 15 minutes and 5 minutes from the end of the assessment • ensure that all learners stop writing or typing immediately they are requested to do so. Learners who fail to stop should be warned that they face disqualification • instruct learners to check that the required details have been included correctly on booklets and additional paper, and that the additional paper has been attached to the booklet • put all the paperwork in the appropriate envelopes and seal them before they leave the examination room • The invigilator must not do any of the following. To do so constitutes malpractice: • carry out any unrelated activity during the examination • leave the room without another invigilator being present • carry out any other role, such as acting as reader or scribe, during the examination unless permission has been granted by CSDTA • direct learners to particular questions or particular sections of the question paper • read out any part of the question paper to a learner, other than the instructions given before the start of the examination • allow the use of correction fluid or erasable pens by learners • offer any advice or comment on the work of a learner • give information to learners where the invigilator or learners believe that there is an error or omission on the question paper, unless an erratum notice has been provided or permission has been given byCSDTA. The invigilator must refer the matter immediately to the exams officer • comment on the content of the question paper Instructions for Conducting Examinations_v21.0 October 2024 Information Classification: Public Page 14 of 26 If printed this document becomes uncontrolled Document Reference Number 5PRAD6 • rephrase a question for a learner • explain any subject-specific or technical terms to a learner • give any indication of the time elapsed or remaining except as specified in the regulations 4.2.3. At the end of the examination At the end of the examination the invigilator must: • clearly and promptly tell the learners to stop working, reminding them that examination conditions still apply • ensure all learners have entered their details correctly on their question booklets and included their name on all documents being submitting for marking • ensure all examination papers (used and unused), learner scripts and documents are collated prior to the learners leaving the room • ensure any learners granted extra time continue their examination • collect all examination materials, including rough paper from all learners at the end of the examination before the learners leave the examination room • when satisfied all materials are collected, allow the learners to leave the room • place all examination materials into envelopes, and seal envelopes before leaving the examination room 4.3. Paper examinations 4.3.1. Accuracy and clarity in multiple choice questions The invigilator must advise learners taking paper-based examinations: CSDTA examinations: • complete the question paper in black pen • to tick or draw a circle over the correct answer for multiple choice questions on the question paper • to draw a mark over the correct answer, eg ●, on the theory examination answer sheet provided • that if the selection of answer is unclear, or where more than selection has been made in single answer questions, no marks will be awarded • that to amend an answer, the incorrect answer should be clearly crossed out, eg X, and initialled by the learner ITEC examinations: • complete the answer sheet in black pen • to draw a mark over the correct answer, eg ●, on the theory examination answer sheet provided Instructions for Conducting Examinations_v21.0 October 2024 Information Classification: Public Page 15 of 26 If printed this document becomes uncontrolled Document Reference Number 5PRAD6 • that if the selection of answer is unclear, or where more than selection has been made in single answer questions, no marks will be awarded • that to amend an answer, the incorrect answer should be clearly crossed out, eg X, and initialled by the learner 4.4. Online examinations The following additional guidance must be adhered to when conducting all online examinations: 4.4.1. During the examination During the examination the invigilator must ensure that: • in the event of a problem with the examination or the software, the following guidelines are adhered to: ̵ pause the examination ̵ immediately contact:  CSDTA Customer Support on +44 (0) 2920486868 (for Functional Skills +44 (0) 121 270 5100) or  ITEC Exams on +44 (0) 23 80 684503  Functional Skills on +44 (0) 121 270 5100 • to seek advice and support; ̵ check that the examination resumes correctly and that the learner has not lost their work • in the event of a hardware failure, the centre’s IT department is contacted, and that the learner is allowed to resume the examination on a different workstation if necessary • 4.4.2. After the examination After the examination the invigilator must: • remind learners that they must select the on-screen ‘finish’ button; if there are any issues in submitting the online exam please contact: ̵ CSDTA Customer Support on +44 (0) 2920486868 ̵ ITEC Exams on +44 (0) 23 80 684503 ̵ Functional Skills on +44 (0) 121 270 5100 • ensure any rough paper notes made by learners are collected before the learner(s) leave the room • ensure all common user areas accessible to learners are clear of all work immediately after Instructions for Conducting Examinations_v21.0 October 2024 Information Classification: Public Page 16 of 26 If printed this document becomes uncontrolled Document Reference Number 5PRAD6 4.5. Invigilating learners with reasonable adjustments 4.5.1. Use of readers, writers, prompters and sign-language interpreters • The invigilator is responsible for ensuring that readers, writers, prompters and sign language interpreters and the learners they are enabling do not distract, or cannot be overheard by other learners • It is normal practice for these personnel and the learners they are assisting to be located in rooms separate from other learners • It is the centre's responsibility to provide additional invigilators as required; and the invigilator's responsibility to ensure that additional invigilators are present in the separate rooms. 4.5.2. Bilingual dictionaries (approval required) • A bilingual dictionary must only be used by a learner whose first language is not English, Irish or Welsh and must reflect the learner’s normal way of working • Bilingual dictionaries must be checked by the invigilator to ensure there are no notes, data or other unauthorised information available to the learner within it, and should be retained in the centre under secure conditions 4.6. Functional Skills ICT Invigilation Guidance Invigilators should adhere to the additional guidance provided for both paper-based and on screen tests set out in the publication CSDTA Functional Skills ICT Guidance. Instructions for Conducting Examinations_v21.0 October 2024 Information Classification: Public Page 17 of 26 If printed this document becomes uncontrolled Document Reference Number 5PRAD6 4.7. Invigilator role – flowcharts and checklists 4.7.1. Before the examination commences - paper-based and electronic Instructions for Conducting Examinations_v21.0 October 2024 Information Classification: Public Page 18 of 26 If printed this document becomes uncontrolled Document Reference Number 5PRAD6 Instructions for Conducting Examinations_v21.0 October 2024 Page 19 of 26 Information Classification: Public If printed this document becomes uncontrolled 4.7.2. During the examination - paper-based Invigilator responsibilities checklist Move around assessment room ☐ Observe ALL learners ☐ Follow centre policy for late arriving learners ☐ Advise learners who suspect error in question and contact VTCT Skills immediately ☐ Remain vigilant and record irregularities ☐ Ensure disturbances and emergencies dealt with promptly and appropriately ☐ Provide learners with additional paper if required ☐ Ensure learners who leave the room are accompanied ☐ Complete the attendance register and invigilation report ☐ Inform learners of time remaining 15 minutes and 5 minutes from assessment end ☐ Notify CSDTA of irregularities immediately after the assessment concludes ☐ Document Reference Number 5PRAD6 Instructions for Conducting Examinations_v21.0 October 2024 Page 20 of 26 Information Classification: Public If printed this document becomes uncontrolled 4.7.3. During the examination - electronic Invigilator responsibilities checklist Move around assessment room ☐ Observe ALL learners ☐ Follow centre policy for late arriving learners ☐ Advise learners who suspect error in question and contact CSDTA immediately ☐ If a technical problem occurs: • pause the assessment • contact support team • resume assessment • check learner has not lost work • move learner to another machine if necessary ☐ Remain vigilant and record irregularities ☐ Ensure disturbances and emergencies dealt with promptly and appropriately ☐ Ensure learners who leave the room are accompanied ☐ Complete the attendance register and invigilation report ☐ Inform learners of time remaining 15 minutes and 5 minutes from assessment end ☐ Notify CSDTA of irregularities immediately after the assessment concludes ☐ Document Reference Number 5PRAD6 4.7.4. After the examination ends - paper-based and electronic Instructions for Conducting Examinations_v21.0 October 2024 Information Classification: Public Page 21 of 26 If printed this document becomes uncontrolled Document Reference Number 5PRAD6 5. After the examinations For online examinations, the examinations officer must ensure the assessments have been submitted/uploaded/completed as required by each particular process. For paper-based assessments, where examination documents are returned to CSDTA and ITEC for marking, the examinations officer must ensure that: • all examination papers (used and unused), invigilation records, learner scripts and other documents (such as evidence for authorised absence) are dispatched to the CSDTA and ITEC exams’ office, immediately: Assessment Department Aspire House Annealing Close Eastleigh Hampshire SO50 9PX • if it is not possible to do this on the same day as the examination, all documents are stored in the centre’s secure location until no later than the following day, and CSDTA must be informed • all items are dispatched using a secure, signed for tracking service CSDTA: • does not accept liability for examination documents lost in transit or in the custody of the centre or any centre appointed personnel • takes every care to store completed answer sheets once they have been returned from centres • issues an acknowledgment to the centre upon receipt • in the unlikely event that papers are lost while in CSDTA’ possession, will send replacement papers and answer sheets at no charge to enable the examination to be retaken • will in circumstances where examination documents are lost in transit, supply a further set of papers and answer sheets for a new examination at a fee equal to the resit fee for the units involved. For paper-based assessments, which are not required to be returned to CSDTA and ITEC for marking, the examinations officer will ensure that: • all examination papers (used and unused), invigilation records, learner scripts and other documents (such as evidence for authorised absence) are stored appropriately Paper-based SVQ multiple choice examination papers do not need to be returned to CSDTA. Instructions for Conducting Examinations_v21.0 October 2024 Information Classification: Public Page 22 of 26 If printed this document becomes uncontrolled Document Reference Number 5PRAD6 5.1. Results slips Results slips are available for the examinations officer to access and download from the e testing systems. The results slips for on-demand online examinations are for centre records and not for learner notification. They are not to be stored in a learner’s portfolio. This specifically relates to the E assessment: Outcomes Report and Questions Answered Incorrectly Report. 6. Copyright All CSDTA and ITEC examination papers are subject to copyright. Unused examination papers must be returned to CSDTA. Under no circumstances should they be kept or destroyed by the centre. If it comes to light that a centre had retained copies of examination papers, it will be dealt with as malpractice and the regulatory authorities will be informed. 7. Retaining invigilation records The centre examinations office must retain signed records of the: • seating plan; • attendance register; • invigilation reports For each examination for a minimum of 6 months from the date of the examination, and 3 years from the date of the examination in the case of Functional Skills tests. CSDTA reserves the right to request copies of these records at any time and sample them as part of external quality assurance visits. 8. Monitoring the conduct of examinations CSDTA reserves the right to conduct unannounced invigilation audits; this will include a review of the centre’s secure exam storage. Any breach of these instructions and the invigilation process will be treated as maladministration and/or malpractice and will be dealt with in line with CSDTA’ Malpractice and Maladministration Policy and procedures. Instructions for Conducting Examinations_v21.0 October 2024 Information Classification: Public Page 23 of 26 If printed this document becomes uncontrolled Document Reference Number 5PRAD6 9. Appendix The following poster must be displayed in a prominent place both inside and outside each examination room. Instructions for Conducting Examinations_v21.0 October 2024 Information Classification: Public Page 24 of 26 If printed this document becomes uncontrolled Document Reference Number 5PRAD6 Instructions for Conducting Examinations_v21.0 October 2024 Page 25 of 26 Information Classification: Public If printed this document becomes uncontrolled Document amendment history page Version Document Owner Issue Date Changes Role v2.0 Assessment Manager 02/02/2018 New policy Assessment Manager v4 Assessment Manager 06/02/2018 Formatting and proofing Product Designer (Qualifications) v5 Assessment Manager 07/02/2018 Minor changes to wording Assessment Manager v6 Assessment Manager 01/03/2018 Minor changes to wording Assessment Manager v7 Assessment Manager 03/07/2018 Updated contact telephone numbers, email and postal address to 3.2, 3.6.2, 4.4, 5 Minor wording change to 4.3.1 Minor wording change to 4.7.2 and 4.7.3 Amendment to 4.1.1 Assessment Manager v8 Assessment Manager 29/08/2018 Minor wording change to 4.1.1 Assessment Manager v9 Assessment Manager 03/09/2018 Minor wording change to 1 Amendment to 5 Assessment Manager v10 Assessment Manager 05/03/2019 Formatting update Compliance Manager v11 Assessment Manager 04/04/2019 Amendment to 3.6.3 and 3.6.4 Assessment Manager v12 Head of Assessment 02/08/2019 Amendment to 4.1.1 and 4.1.2. Addition of 4.1.2.1 and 5.1 Formatting update to 7 Head of Assessment v13 Head of Assessment 27/09/2019 Minor amendment to 4.71 Addition of Section 4.1.2 Head of Assessment v14 Head of Assessment 01/03/2021 Minor amendment to 4.1.1 to support COVID-19 adaptation Head of Assessment v15 Head of Assessment 27/01/2023 Branding updated Head of Assessment v15 Head of Assessment 27/01/2023 Minor amendment to 4.1.1 Head of Assessment Document Reference Number 5PRAD6 Instructions for Conducting Examinations_v21.0 October 2024 Page 26 of 26 Information Classification: Public If printed this document becomes uncontrolled v16 Head of Assessment 21/07/2023 Minor amendment to 4.1.1 Head of Assessment v17 Head of Assessment 24/07/2023 Minor amendment to 4.1.1 Head of Assessment v18 Head of Assessment 22/11/2023 Document reference number updated Head of Assessment v19 Head of Assessment 28/03/2024 Minor amendment to 4.1.1 Head of Assessment v20 Head of Assessment 17/05/2024 Minor amendment to 4.1.1 Head of Assessment v21 Head of Assessment 24/10/2024 Branding updated. Minor update to Sections 1, 2, 3.11 and 6. Update to Section 3.5 to specify seating arrangements and desks or tables. Updates to Sections 3.6.2, 4.4.1 and 4.4.2 with the Functional Skills contact number Head of Assessment Document Review Role Review Status Head of Standards Reviewed Document Owner Document Owner Document shared with Head of Assessment Document Sign-off Role Sign-off Date Head of Assessment 24/10/2024

Invoicing Policy October 2024 Version 13 Information Classification: Public If printed this document becomes uncontrolled Document Reference Number 2POFF2 Invoicing Policy_v13 October 2024 Page 2 of 6 Information Classification: Public If printed this document becomes uncontrolled Contents 1. Introduction ............................................................................................................................................... 3 1.1. Purpose of the policy ..................................................................................................................... 3 1.2. Scope of the policy ......................................................................................................................... 3 1.3. 1.3 Regulatory authorities .............................................................................................................. 3 1.4. 1.4 Review arrangements ............................................................................................................... 3 2. Fees ....................................................................................................................................................... 3 3. Issuing of invoices ............................................................................................................................... 3 4. Content of invoices............................................................................................................................. 4 5. Payment terms .................................................................................................................................... 4 6. Payment of invoices ........................................................................................................................... 4 7. Credit control ...................................................................................................................................... 5 8. Retention of Invoices ......................................................................................................................... 5 9. Further information ............................................................................................................................ 5 Document Reference Number 2POFF2 1. Introduction 1.1. Purpose of the policy This policy sets out the processes followed by CSDTA in relation to the issue, payment and retention of invoices for its products and services. 1.2. Scope of the policy This policy is provided for all centres approved to deliver CSDTA qualifications and buyers of CSDTA regulated services. 1.3. 1.3 Regulatory authorities This policy addresses the requirements of the relevant regulatory authorities’ criteria. 1.4. 1.4 Review arrangements This policy is reviewed periodically as part of CSDTA 's self-evaluation activity. A policy review may also be triggered as an action resulting from the outcome of the investigation of a complaint. 2. Fees CSDTA 's service fees are: • published annually; • available on the website for UK customers. CSDTA reserve the right to produce and publish pricelists for non-UK markets on a variable basis driven by currency exchange movements. These are therefore not published on the website; • distributed following updates; • reviewed annually; • normally not increased above the rate of inflation. The effective fee periods are: • ITEC - 1 August to 31 July (UK); 1 January to 31 December (overseas); • VTCT - 1 August to 31 July. 1 January to 31 December (South Africa) VTCT and ITEC operate a centre registration and verification fee. 3. Issuing of invoices • VTCT invoices are issued within 14 days of provision of the related service. Invoicing Policy_v13 October 2024 Information Classification: Public Page 3 of 6 If printed this document becomes uncontrolled Document Reference Number 2POFF2 •CSDTA invoices are issued within 8 weeks of the first examination, except those for NVQs, which are issued upon processing the learner registrations. • Statements for any balances outstanding are produced monthly. • Duplicate invoices or statements are provided on request. • All invoices are sent to the centre's accounts department unless an alternative arrangement has been made. 4. Content of invoices Each invoice contains the following information: • centre name and address; • account number; • invoice number and date; • purchase order reference (if required by the centre); • item lines for the product/service provided; • item charges, the total charge and VAT amount where applicable; • payment methods and bank account details; • payment terms. Each statement contains the following information: • breakdown of invoices, credit notes or payments that have not yet been paid or allocated; • related invoice date, number and amount; • a reminder of payment terms. 5. Payment terms • All CSDTA invoices are due for payment 30 days from the invoice date unless the invoice states otherwise. 6. Payment of invoices • Centres are required to pay for invoices in full within the stated payment terms. • Invoices can be paid by BACS or credit card. • Details of how to make a payment are included on all invoices and statements. Invoicing Policy_v13 October 2024 Information Classification: Public Page 4 of 6 If printed this document becomes uncontrolled Document Reference Number 2POFF2 • Any bank charges incurred are the responsibility of the centre, including any charges for non-cleared cheques, conversion charges and any remittance charges for international monetary transfers. 7. Credit control • Centres receive statements detailing any outstanding balances and any amounts overdue. • Failure to pay invoices within payment terms may result in the application of sanctions in accordance with CSDTA’s Sanctions Policy. • Sanctions, which may include suspension of registration, will remain in place until the amount has been settled or a payment plan has been put in place. • CSDTA at its discretion, may apply late payment interest and charges to overdue invoices. • A centre which is experiencing temporary difficulties in meeting the payment terms, should disclose this to CSDTA’s finance/accounts department as soon as this becomes apparent. • CSDTA reserve the right to - determine and apply a credit limit for a centre as considered appropriate and will review and revise a credit limit for a centre when deemed necessary; - cease trading with a centre if the centre is deemed a risk to the business; - cancel a registration which is related to a non-payment of an invoice. • Where necessary, outstanding balances will be pursued to a legal conclusion and any fees incurred will be passed on to the centre. Overdue balances may be referred to a collection agency. 8. Retention of Invoices All invoices and credit notes are held electronically on the finance system for record retention purposes. 9. Further information If you have any queries about invoices or the contents of this policy, please contact CSDTA’s Finance Department, info@cityskindoctor.co.uk, tel +44 (0) 2920486868(Customer Support) or Invoicing Policy_v13 October 2024 Information Classification: Public Page 5 of 6 If printed this document becomes uncontrolled Document Reference Number 2POFF2 Document amendment history page Version Document Owner Issue Date Changes Role 10 18/10/2021 Added classification: Internal to footer 11 19/07/2023 Updated section 2 Finance Assistant Management Accountant 12 23/04/2024 Updated Section 5 – Payment Terms Assistant Accountant 13 October 2024 Updated for rebrand Executive Support & Governance Lead Document Review Role Review Status Finance Assistant New policy Document Owner Document Owner Document shared with Chief Financial Officer Document Sign-off Role Sign-off Date Chief Financial Officer 02/02/2018 Invoicing Policy_v13 October 2024 Information Classification: Public Page 6 of 6 If printed this document becomes uncontrolled

Plagiarism, Collusion and Cheating Policy October 2024 Version 7 Information Classification: Public If printed this document becomes uncontrolled Document Reference Number 5POAD2 Plagiarism, Collusion and Cheating Policy_v7.0 October 2024 Page 2 of 7 Information Classification: Internal If printed this document becomes uncontrolled Contents 1. Aim.............................................................................................................................................................. 3 2. Scope ......................................................................................................................................................... 3 3. Monitoring ................................................................................................................................................. 3 4. Plagiarism .................................................................................................................................................. 3 5. Collusion .................................................................................................................................................... 4 6. Cheating ..................................................................................................................................................... 4 Document Reference Number 5POAD2 1. Aim The aim of the Plagiarism, Collusion and Cheating Policy is to increase awareness of the type of behaviour that constitutes unacceptable practice and malpractice in order to supports CSDTA’ preventative approach to reduce instances through awareness and understanding. The policy provides CSDTA and centre staff with a basic understanding giving some common examples of plagiarism, collusion and cheating. CSDTA’ preventative approach will increase awareness and support centre staff with the adherence of the policy. Additionally, the learner will have increased awareness of the risk of being withdrawn from the qualification they are taking, or prevented from taking qualifications at the training centre of their choice due to contravention of the policy. 2. Scope This policy applies to all staff and registered learners involved in the delivery or studying of a CSDTA qualification or unit. 3. Monitoring There is strong collaboration between the Assessment and Quality Assurance Departments to identify and address any potential threats to the reliability, validity and integrity of assessments. CSDTA clearly publishes centre assessment controls relating to assessments in the qualification specification and proactively checks that centres have adhered to these controls through external quality assurance monitoring activity. There is strong collaboration between the Assessment and Quality Assurance Departments to identify and address instances of malpractice. Information about potential risks is gathered through External Quality Assurance monitoring of the activity of centres (via EQA reports), and the Assessment Department’s marking and moderation teams. All cases of suspected and confirmed malpractice are reviewed and managed through CSDTA’ Malpractice Committee. CSDTA’ External Quality Assurers will sample learner portfolios during verification visits, where they will check evidence and record keeping, to identify and report examples of plagiarism, collusion and cheating. Additionally, CSDTA has processes in place to identify instances of interest through its marking of examination papers or evidence submitted for external moderation. 4. Plagiarism Plagiarism can be described as using someone else’s work and changing words but retaining the structure and meaning without acknowledging the source or ownership of the originator of the work. Plagiarism, Collusion and Cheating Policy_v7.0 October 2024 Information Classification: Internal Page 3 of 7 If printed this document becomes uncontrolled Document Reference Number 5POAD2 There are many reasons why plagiarism occurs. Often this is because a learner does not realise that the method of gathering and preparing their evidence was not an acceptable practice, or through poor planning, that results in pressure for a learner to complete work when time is at a premium. Learners will generally know what method, activity or approach to research is considered to be plagiarism, however, there are examples where plagiarism is less obvious to the learner. Common examples include: • getting somebody else to do the work • giving false information about a source used • copying information from the internet Less obvious examples include: • copying all or some of another person’s work • getting a friend or family member to help, often including dictation of responses • copying and pasting from the internet • copying either word for word or extracts from a text without providing a reference to the source • copying from another learner’s portfolio with or without their consent • borrowing or taking another learner’s work 5. Collusion Collusion is considered to be a type of plagiarism if two or more people knowingly and with planned intent work together and submit work that is not solely their own. Examples include: • two or more learners sharing information leading to the production and submission of the work by both learners • passing off the work of another learner with their consent • a learner knowingly provides an opportunity for other learners to see their work; such as during an examination to the learner sitting next to them 6. Cheating Cheating is the planned intention to pass off work of others, claiming it to be their own. Centres are encouraged to ensure that safeguards are in place to prevent staff from assisting learners to improve achievement during the taking of examinations and to protect staff against any accusation from others that could lead to an adverse effect. For example, a learner claims Plagiarism, Collusion and Cheating Policy_v7.0 October 2024 Information Classification: Internal Page 4 of 7 If printed this document becomes uncontrolled Document Reference Number 5POAD2 that the invigilator provides some answers, and this is why the learner failed the examination. If another person is present, the invigilator will have some protection against potential claims of unfairness by the learner(s). Examples include: • having access to an examination paper prior to the examination taking place • assessors, tutors and/or invigilators helping learners while they are preparing and submitting information for assessment and/or marking • impersonating another learner with the purpose of giving an unfair advantage • encouraging or accepting help from others • copying or reading another person’s work • accessing a mobile phone during an examination Plagiarism, Collusion and Cheating Policy_v7.0 October 2024 Information Classification: Internal Page 5 of 7 If printed this document becomes uncontrolled Document Reference Number 5POAD2 Plagiarism, Collusion and Cheating Policy_v7.0 October 2024 Page 6 of 7 Information Classification: Internal If printed this document becomes uncontrolled Document amendment history page Version Document Owner Issue Date Changes Role v1 Quality and Processing Manager 01/10/2016 New Document Quality and Processing Manager v2 Quality and Processing Manager 19/04/2017 Updated with new branding Quality and Processing Supervisor v3 Quality and Processing Manager 12/02/2018 Formatted and updated to new branding Product Designer (Qualifications) v4 Assessment Manager 05/03/3019 Formatted and updated to new branding Compliance Manager v5 Head of Assessment 01/03/2021 Addition of Section 3. Minor amendments to other sections. Head of Assessment v6 Head of Assessment 27/01/2023 Branding updated Head of Assessment v7 Head of Assessment 24/10/2024 Branding updated Head of Assessment Document Review Role Review Status Head of Assessment Reviewed Document Owner Document Owner Document shared with Head of Assessment Head of Standards Document Sign-off Role Sign-off Date Document Reference Number 5POAD2 Head of Assessment 24/10/2024 Plagiarism, Collusion and Cheating Policy_v7.0 October 2024 Information Classification: Internal Page 7 of 7 If printed this document becomes uncontrolled

Privacy Policy Privacy Statement CSDTA is committed to protecting your privacy and developing technology that gives you the most powerful and safe online experience. This Statement of Privacy explains how we use the personal data you provide in compliance with UK data protection law and the General Data Protection Regulation EU 2016/679 (GDPR). For the purposes of the GDPR, CSDTA is the ‘controller’ of the personal data you provide to us. Who do we process personal data about? As a data controller, we process personal data about our customers, potential customers, business contacts, tutors, learning centre staff, our learners, third party service provider staff, consultants, legal advisors, our staff and other business partner contacts. Why do we need to process personal data? • We only process personal data where this is necessary for the purposes of fulfilling a service you have contracted to receive • Establishing or negotiating agreements to providing the services you have requested, • Promoting our own goods and services • Managing our accounts and records • If required by law, including responding to law enforcement authorities and competent bodies to prevent or detect crime, fraud and money laundering Uses of your Personal Information CSDTA uses your personal information to: • Operate, maintain and monitor the CSDTA group Web sites to ensure the quality, security and continual improvement of the service • Provide you with help, support and administration of any accounts you create to use our online software tools • Establish and deliver the products and services you have contracted to receive, including fulfilment of our own record keeping and regulatory reporting obligations • Complete payment transactions for goods and services you have ordered such as replacement qualification certificates or badges. • Email you with routine service updates or issues relating to your use of our services • Respond to your requests to be contacted or answer your queries including if you telephone, email or write to us • Resolve any complaints or disputes • Send you offers and promotional material relating to our own products and services if you have given us your consent to do so, including industry updates, awards, events and news which may be of interest to you. Sharing Personal Information CSDTA does not sell, rent or lease its customer lists to any third parties. CSDTA may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you but only where we have your consent to do so. In those cases, your unique personally identifiable information (e-mail, name, address, telephone number) is not transferred to the third party. CSDTA may share data with trusted partners including: • Legal and regulatory bodies, advisers, consultants and professional experts • When we are required to do so by law or similar obligation placed upon CSDTA or its affiliate companies. • Service providers who to help us deliver our goods and services, perform statistical analysis, manage email or postal mail services, provide customer support, or arrange for deliveries. All service providers are prohibited, under contract from using your personal information for any purpose except to provide these services to CSDTA r a member of the CSDTA group, and they are required to maintain the confidentiality, security and lawful use of your information. Special category (sensitive) personal data CSDTA may collect and process special category data, only where necessary. The special category data we use is limited to: • Evidence of physical or mental health or condition required to provide confirm eligibility for special learner adjustments. This may include evidence of your condition or needs such as a medical report, details of your needs relating to a disability, or learning difficulties. CSDTA will not process this information for any other purpose. You have a right to withdraw your consent for processing this special category information at any time except where the processing relates to an overriding legal or regulatory obligation placed upon CSDTA. Withdrawing consent for processing medical data may result in the withdrawal or refusal for learning support arrangements. • CSDTA may collect and process information such as race, religion and ethnicity where we are legally required to report on statistics relating to equal opportunities, discrimination and diversity. • CSDTA does not include special category personal information in relation to any automated processing or profiling activities. Marketing Where you have given your express consent to receive marketing communications, we may use your personal data to send you newsletters, surveys, information about our awards and events, offers, and promotions, related to products and services offered by CSDTA which may be of interest to you. Where you have consented to marketing communications, you may change your preferences or unsubscribe from marketing communications at any time by clicking the unsubscribe link in an email from us. International processing Where a third party recipient is located outside of the European Economic Area, we ensure that adequate safeguards are in place to protect your rights over the processing of your personal data, including approved EU contract clauses if the recipient country has not been previously approved by the EU data protection authorities. How long do we retain your personal data? We will retain your personal data for the duration of any contract between us, and for a period of seven years following its termination or expiry, to ensure we are able to comply with any contractual, legal, audit and other regulatory requirements. Security of your Personal Information CSDTA secures your personal information from unauthorised access, use or disclosure. CSDTA has adopted internationally recognised best practice standards and techniques to manage the security of your personal information throughout its lifetime, from creation to destruction and our security controls independently audited. We have robust processes in place to deal with any suspected security incidents that include notifying you and any regulatory bodies where we are legally required to do so. Our computer servers and applications operate in a controlled, secure environment, protected from unauthorised access, use, disclosure, damage or destruction. When personal information (such as a credit card number) is transmitted to other Web sites, it is protected through the use of encryption. Our computers that process your personal data online are routinely monitored and tested to protect against cybercrime. Where you create an account to use our online services and software tools, you are responsible for keeping your password confidential. We advise you not to share your password or use a password you commonly use on other websites as the transmission of information over the internet is not guaranteed to be secure. Your Rights Under the GDPR, and UK data protection law, you have specific rights over the processing of your personal data. These include: • A general right to be informed about the processing of your personal data • A general right to have your information processed securely • A right to request access (e.g. receive a copy of the personal data CSDTA holds about you). • A right to have inaccurate personal data corrected (rectification). • A right to be informed about how long your personal information will be retained. • A right to request erasure of your personal data if CSDTA has no legal, statutory or regulatory reason for processing it. • A right to restrict the processing of your personal information causing, or likely to result in harm or distress (subject to CSDTA’ legal obligations for processing). • A right to portability in certain circumstances (i.e. to have your personal data provided in machine readable format to another organisation without constraint) • A right to object to the processing conducted by CSDTA (e.g. for direct marketing purposes) • A right to have any automated processing and the logic used explained to you. • A right to complain to the UK data protection supervisory authority (the UK Information Commissioner if you believe your rights have been breached and CSDTA have been unable to resolve the issue, and a further right to obtain judicial remedy through the courts if your complaint is upheld. For more information in how to make a formal complaint to the regulator, visit www.ico.gov.uk) If you would like to exercise any of the rights listed above, please write to the CSDTA Data Protection Officer at the address below. We will explain any applicable exceptions to these rights in our response. Changes to this Statement CSDTA will occasionally update this Statement of Privacy to reflect company and customer feedback. CSDTA encourages you to periodically review this Statement to stay informed of how CSDTA is protecting your information. Contact Information CSDTA welcomes your comments regarding this Statement of Privacy. If you believe that SCDTA has not adhered to this Statement, or have any concerns about how we process your personal data please contact us at info@cityskindoctor.co.uk or write to us. We will use commercially reasonable efforts to promptly determine and remedy the problem. Chief Financial Officer, CSDTA 223 City Road CF24 3JD, Cardiff City Skin Doctor

Quality Management System Policy October 2024 Version 4 Document Reference Number 6POCED3 Contents 1. Quality Policy Document Reference Number 6POCED3 1. Quality Policy CSDTA will provide customers with services that conform to all applicable requirements. Only by providing quality qualifications backed up with robust quality assurance will we achieve our Mission: “To provide a direct line of sight to a job, enhancing knowledge and skills, improving career prospects. Ultimately supporting our charitable objective: for public benefit, through the advancement of education.” To help us achieve our quality policy we are committed to implementing a quality management system (QMS) that supports the strategic direction of our organisation and is certified to the ISO 9001 standard. We regularly review the performance of our quality management system and set quality objectives to help us continually improve. It is essential that our quality policy is communicated, understood and applied within CSDTA, both as part of new staff inductions and ongoing business as usual. Our quality policy is available to all interested parties.

Safeguarding Learners Policy Including Children, Young People and Adults September 2024 Version 11 Information Classification: Public If printed this document becomes uncontrolled Document Reference Number 1POHR23 Safeguarding Learners Policy_v11 September 2024 Page 2 of 18 Information Classification: Public If printed this document becomes uncontrolled Contents 1. Introduction.......................................................................................................................................... 3 1.1. Scope................................................................................................................................................. 3 1.2. Commitment .................................................................................................................................... 3 2. Legal and Regulatory Framework..................................................................................................... 4 2.1. Legal Context ................................................................................................................................... 4 2.2. Regulation ......................................................................................................................................... 5 3. Operational Framework ..................................................................................................................... 5 3.1. Structure .......................................................................................................................................... 5 4. Code of Practice – Safe Practice Guidance ................................................................................... 6 4.1. Code of Practice – Safe Practice Guidance ............................................................................... 6 4.2. Confidentiality and Information Sharing .................................................................................... 7 4.3. Recognition....................................................................................................................................... 7 4.4. Response .......................................................................................................................................... 8 4.5. Reporting .......................................................................................................................................... 8 4.6. Recording ..........................................................................................................................................9 4.7. Referral .............................................................................................................................................9 4.8. Allegation Against a Staff Member ..............................................................................................9 5. Safe Recruitment Practice Guidance ..............................................................................................9 5.1. Background Information ................................................................................................................9 5.2. Contracting with CSDTA........................................................................................................9 5.3. Further Support ............................................................................................................................ 10 6. Appendix 1: Flowchart of action to take in the event of an allegation or concern of abuse or neglect ............................................................................................................................................. 11 7. Appendix 2: Safeguarding Issue Reporting Form ........................................................................ 12 8. Appendix 3: Safeguarding Code of Practice Form ...................................................................... 13 9. Appendix 4: Types of Abuse and Harm ......................................................................................... 15 10. Appendix 5: CSDTA Trustees and Staff Responsible for the Policy ................................ 17 Document Reference Number 1POHR23 1. Introduction 1.1. Scope This document sets out Vocational Training Charitable Trust Skills’ (CSDTA’) responsibilities for staff and representatives with regard to safeguarding children, young people and adults, henceforth referred to as “Learners” for the purposes of this document. It is for both internal and external use. Specifically, this policy applies to all CSDTA employees, including Apprenticeship Assessors (AAs) and External Quality Assurers (EQAs), contractors, casual workers, agency workers and Trustees. It relates to all situations, both UK and International, where CSDTA comes into contact with learners. CSDTA has a primary responsibility for ensuring all assessments and the centres in which they are held are safe and exemplify good practice. While primarily intended to safeguard learners, this safeguarding policy also serves to protect staff and representatives from unsubstantiated allegations of improper conduct. This policy is divided into 6 sections: 1. Commitment; 2. Legal and regulatory framework; 3. Operational framework; 4. Code of practice; 5. Safe recruitment practice guidance; and 6. Document history. Appendices: 1. Flowcharts; 2. Safeguarding Issues Reporting Form; 3. Code of Practice Form; 4. Types of Abuse and Harm; and 5. Named Officers. 1.2. Commitment CSDTA, as a specialist provider of vocational qualifications in the UK, is committed to safeguarding the interests of all learners including learners who may require particular safeguarding. It believes that anyone who participates in any learning activities should be able to take part in an environment that is both safe and enjoyable which is CSDTA’ definition of safeguarding. Safeguarding Learners Policy_v11 September 2024 Information Classification: Public Page 3 of 18 If printed this document becomes uncontrolled Document Reference Number 1POHR23 Modern Slavery encompasses slavery, servitude, human trafficking and forced labour. CSDTA has a zero-tolerance approach to any form of modern slavery. CSDTA is committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain. CSDTA will endeavour to safeguard learners by: • valuing them, listening to and respecting them; • maintaining policy, procedures and a code of conduct (where applicable) for staff and representatives; • recruiting representatives safely by ensuring all necessary checks are made in line with government guidance and legislation; • updating staff and representatives on the policy and procedures and providing access to relevant information; • ensuring that all assessments, communications, documentation, records, materials, personnel deployment, processes and procedures promote the interests of all learners; • respecting confidentiality whilst sharing information about concerns with agencies who need to know and appropriately involving parents/guardians, children, young people and vulnerable adults; • identifying those who are suffering, or are likely to suffer significant harm or who are at risk of radicalisation; • working effectively with others as required by Working Together to Safeguard Children (2017); • ensuring there is an effective Safeguarding Policy in place together with a Staff Code of Conduct; and • providing effective support and management for staff and representatives. 2. Legal and Regulatory Framework 2.1. Legal Context For the purposes of this Policy, the term “children and young people” refers to a child who has not yet reached their eighteenth birthday in England, Wales and Northern Ireland and their sixteenth birthday in Scotland. “Vulnerable adult” refers to a person “Who is or may be in need of community care services by reason of disability, age or illness; and is or maybe unable to take care of themselves or protect themselves against significant harm or exploitation”. This definition of an Adult covers all people over 18 years of age. Safeguarding Learners Policy_v11 September 2024 Information Classification: Public Page 4 of 18 If printed this document becomes uncontrolled Document Reference Number 1POHR23 This policy is particularly informed by the requirements of the Children Act (1989), which provides a framework for the care and protection of children and young people and the Children Act (2004) which underpins the ‘Every Child Matters: Change for Children’ programme. 2.2. Regulation VTCT Skills operates as an awarding organisation/body within the regulatory requirements of the Office of Qualifications and Examinations Regulator (Ofqual), Scottish Qualifications Authority (SQA), the Council for the Curriculum, Examinations & Assessment (CCEA ‐ Northern Ireland) and Qualifications Wales. 3. Operational Framework 3.1. Structure The Board of Trustees appoints a Trustee with responsibility for safeguarding who provides a strategic oversight of safeguarding and reports at every meeting on current safeguarding concerns and activities. The Trustee works closely with the CEO and HR Director to ensure all safeguarding systems are fully operational and implemented. Chief Executive: • ensures the policy is implemented, monitored and reviewed; • receives regular reports from the HR Director on safeguarding issues; and • reports to the Safeguarding Trustee any safeguarding concerns. Leadership Team: • ensures the contents of the policy is communicated to managers and other appropriate individuals; • supports individuals who have received information regarding safeguarding issues; • co‐operates/liaises with the HR Director during the response and referral stages; • maintains confidentiality of information; and • supports any subsequent action required by third party or internal inquiry. Executive Board: • meets monthly and reviews any safeguarding issues that have arisen or may do so in the future. Safeguarding Learners Policy_v11 September 2024 Information Classification: Public Page 5 of 18 If printed this document becomes uncontrolled Document Reference Number 1POHR23 HR Director: • acts as the Designated Safeguarding Lead, commonly referred to as the Safeguarding Officer; if the HR Director is not available any safeguarding issues will be referred to the Chief Executive Officer; • maintains, monitors and reviews this policy to ensure effectiveness; • ensures staff recruitment, induction and People practices, policies and procedures reflect safeguarding best practice; • ensures the Safeguarding Policy is available to all CSDTA staff and representatives as listed in section 1.1; • receives concerns about safeguarding; • responds to the concerns by identifying the most appropriate course of action; • acts as a link with any external agencies; • keeps confidential records of concerns and actions; • keeps informed and up to date of any developments and issues in safeguarding and inform the Leadership Team and Board thereof; and • submits high level report/s of any issues of safeguarding or poor professional practice to the CEO and the Board of Trustees as appropriate. Directors and Managers: • ensure teams are familiar with the contents of the policy and the appropriate responses required if a safeguarding concern arises. Safeguarding panel: • Should a safeguarding matter arise, which could lead to the suspension of a staff member, the involvement of an outside agency or bring CSDTA into disrepute, the Safeguarding Trustee, CEO, and HR Director will meet either virtually or face to face to discuss the issues and agree what actions should be taken. They will co‐opt members as appropriate. 4. Code of Practice – Safe Practice Guidance 4.1. Code of Practice – Safe Practice Guidance These are guidelines for employees, contractors, casual workers, agency workers and Trustees when in contact with all learners: • Introduce yourself to the learner, show CSDTA identification and credentials, and explain assessment/End-point assessment process; Safeguarding Learners Policy_v11 September 2024 Information Classification: Public Page 6 of 18 If printed this document becomes uncontrolled Document Reference Number 1POHR23 • Do not have lone contact with learners. If this is unavoidable, ensure someone else is advised of what is taking place and why; • Do not transport learners in your car or offer to accompany them on public transport; • Conduct contact in an open environment avoiding private or unobserved situations; • Maintain a safe and appropriate distance from each person and do not have physical contact; • Ensure that language is appropriate, clear and cannot be misinterpreted; • Do not take photographs or videos of learners or use social media to contact learners unless the learner is over 18 and has given their written consent, if the learner is under 18 parental consent should be obtained; and • Ensure any concerns of the vulnerability or behaviour of the learner are reported to salon owner/college/training provider/CSDTA. 4.2. Confidentiality and Information Sharing • Ensure confidentiality protocols are adhered to, and information is shared appropriately; • If in doubt about confidentiality, seek advice from the HR Director or a Leadership Team member; • The HR Director or a Leadership Team member will only disclose information about an individual to other members of staff on a need‐to‐know basis, taking account of the best interests of the individual; • Colleagues must be aware that information any learner discloses regarding abuse of themselves or another person, must be shared as appropriate and cannot be kept secret. However, at all times consent should be sought and if it is to be overridden the person concerned must be told and reasons given; • Any exchange or disclosure of information much be in accordance with the UK Data Protection Act 2018; Human Rights Act 1998 and the Freedom of Information Act 2000; • Confidentiality is designed to safeguard the best interests of the individual and must not be confused with protecting the management interest of CSDTA; and • CSDTA operates Whistleblowing (1POHR21) and Grievance policies (1POHR10) if staff have any concerns about the conduct of their colleagues. 4.3. Recognition The ability to recognise in the presentation and behaviour of someone, the indications that they may have experienced abuse or other safeguarding issues is not always apparent. Abuse and exploitation can occur in a range of situations in which the vulnerable adult or young person may find themselves and they may manifest themselves in a range of different forms and Safeguarding Learners Policy_v11 September 2024 Information Classification: Public Page 7 of 18 If printed this document becomes uncontrolled Document Reference Number 1POHR23 create widely differing symptoms. It is important to keep an open mind but not to worry if you are unsure. Always discuss your concerns with your line manager. 4.4. Response Whenever you have a worry or a concern about potential or actual exploitation or abuse or any other safeguarding issues, always seek advice and report it. Remember that not reporting a matter may put a child or vulnerable adult at further risk. You do not have to fully understand the concern or its causes but in order to help us determine the most appropriate response, find out whether the allegation from a young person or vulnerable adult is against an employee, including AAs and EQAs, contractor, casual worker, agency worker, Trustee or another. • Is the disclosure from the person concerned alleging abuse to themselves or to another? • Is it the reporting of a concern or suspicion? • What, precisely, is the alleged to have happened? If you suspect or are told a child, adult or young person is being exploited or abused: • stay calm; • listen carefully to what is said; • allow them to speak, but be very careful not to say anything that may suggest or prompt a particular answer; • listen carefully to what you are told and make as accurate recording as you can taking care to note the time, place and those present at the disclosure; • reassure them that they are being carefully listened to and do not promise to ‘keep it confidential’. Make it clear that it may be necessary to tell someone else who can help to sort things out; • reassure them they have done the right thing in speaking about the issue; • tell the adult or young person what will happen next and with whom the information will be shared; • IMMEDIATELY report all Safeguarding concerns to the Designated Safeguarding Lead (HR Director) or a member of the Leadership Team; • ensure your Line Manager is also made aware; and • ensure you record all safeguarding concerns using the Safeguarding Issue Reporting Form found at Appendix 2. 4.5. Reporting You do not need to worry about whether abuse or exploitation has actually occurred. That is the responsibility of the professional agencies, following a referral from the Designated Safeguarding Learners Policy_v11 September 2024 Information Classification: Public Page 8 of 18 If printed this document becomes uncontrolled Document Reference Number 1POHR23 Safeguarding Lead. You are responsible for reporting your concerns in the first instance to the Designated Safeguarding Lead or failing that, to any Leadership Team member. Once you have completed a Safeguarding Issue Reporting Form, the record will be kept confidential, and the information will only be viewable by the referrer, Designated Safeguarding Lead and Leadership Team member. 4.6. Recording An accurate record should be made of what has been alleged, using the exact words of the vulnerable adult or young person if at all possible. Add, if appropriate, factual observations about the physical or emotional state of the individual sharing their concerns. Information will be recorded and stored securely, in line with CSDTA ’ data protection policy, and will only be accessible to those who need to access it as part of action to resolve a complaint or allegation. 4.7. Referral Only the Designated Safeguarding Lead, or failing that the CEO, can make the decision to refer a complaint or allegation to an outside agency, having gathered and examined all relevant information. 4.8. Allegation Against a Staff Member The above policy and procedures will operate in all circumstances. When the allegation is against a staff member, the HR Director will advise the person concerned that they will be immediately suspended, or their contractual duties suspended while an investigation is undertaken. 5. Safe Recruitment Practice Guidance 5.1. Background Information Two references will be obtained for new starters, including from the most recent employer where applicable. Evidence of identity will be required, such as a passport or a driving licence with photograph. If it is deemed a role is classed as a regulated activity, satisfactory Disclosure and Barring Service (DBS; Recruitment of Offenders and DBS Checks Policy (1POHR18)) clearance will be obtained. 5.2. Contracting with CSDTA Under the Criminal Justice and Court Services Act 2000, it is an offence punishable by imprisonment to apply for work with children and/or vulnerable adults if an individual has been: • convicted of a Schedule Four Offence 2; and/or • put on the Protection of Children Act List (POCA3); and/or Safeguarding Learners Policy_v11 September 2024 Information Classification: Public Page 9 of 18 If printed this document becomes uncontrolled Document Reference Number 1POHR23 • put on the Protection of Vulnerable Adults List (POVA4); and/or • considered unsuitable or banned from working with children under section 142 of the Education Act of 2002. If such information is received as a result of a criminal records check from the Disclosure & Barring Service (England & Wales) or Disclosure Scotland or Access NI, the individual must be immediately reported to the police. CSDTA will take the necessary appropriate action. It is also an offence for anyone knowingly to employ such a person in such a capacity, either on a voluntary or a paid basis. All employees, contractors and newly appointed applicants must read, sign and study the Code of Practice agreement which applies at all times. CSDTA complies fully with its obligations under the UK Data Protection Act 2018 and will ensure that any information contained in the Disclosure Declaration form is available only to those who need to have access in the course of their duties. CSDTA reserves the right to reject any applicant who refuses to comply with any of the above. 5.3. Further Support Involvement in safeguarding processes can cause distress and talking about the experience can relieve individuals of feelings and anxieties. Any individual requiring further support or advice can contact the NSPCC Child Protection Helpline on 0808 800 5000 which is open 24 hours per day 7 days per week. You can also report concerns and seek advice online at help@nspcc.org.uk. Safeguarding Learners Policy_v11 September 2024 Information Classification: Public Page 10 of 18 If printed this document becomes uncontrolled Document Reference Number 1POHR23 6. Appendix 1: Flowchart of action to take in the event of an allegation or concern of abuse or neglect 1 • You have been approached by a child who states they have been/are at risk of abuse. 2 • Immediately report all safeguarding concerns to the Designated Safeguarding Lead or a member of the Leadership Team. 3 • Ensure you record the safeguarding concerns using the Safeguarding Issue Reporting form. 4 • Designated Safeguarding Lead / CEO will evaluate the information and take the necessary steps. They can also make the decision to refer complaint or allegation to an outside resource. 5 • Designated Safeguarding Lead / CEO liaises with Trustee with Safeguarding Responsibility. NB: If you have immediate concerns that a child or vulnerable adult is at risk of significant harm contact Children’s Services or Adult Services. If you think a criminal offence has been committed, contact the police. Safeguarding Learners Policy_v11 September 2024 Information Classification: Public Page 11 of 18 If printed this document becomes uncontrolled Document Reference Number 1POHR23 Safeguarding Learners Policy_v11 September 2024 Page 12 of 18 Information Classification: Public If printed this document becomes uncontrolled 7. Appendix 2: Safeguarding Issue Reporting Form To be used to record Safeguarding Concerns/Allegations. All allegations of abuse or concerns about children and vulnerable adults must be recorded without delay. This is to ensure that accurate information is passed on to the relevant person and that there is a written record of the key information. Item Details Name and role of person completing report Source of information Name of vulnerable adult(s) or child(ren) Name and role of employee, including AA or EQA, contractor, casual worker, agency worker, Trustee whose behaviour is causing concern. Date and location of incident(s) Nature of concern/allegation (attach additional sheet if required) Concern/allegation discussed with: (name and job role of member of staff) Outcomes of discussion Actions Agreed Signed: Date: Actions resolved or details of any further actions as issue is addressed Signed: Date: Document Reference Number 1POHR23 8. Appendix 3: Safeguarding Code of Practice Form All CSDTA employees/representatives are required to acquaint themselves with the CSDTA Skills’ policies and procedures on Safeguarding learners. Code of Practice: All CSDTA employees/representatives when coming in contact with learners MUST: • listen, value and respect everyone as an individual; • appropriately involve learners in decision making; • encourage and praise achievement; • actively contribute to an organisational culture where inappropriate behaviour is not tolerated; • provide an example of the good conduct you wish others to follow; • ensure that whenever possible there is more than one adult present during activities with children, young people and vulnerable adults, or at least that you are within sight or hearing of others; • not give out personal information, or share email addresses, mobile phone numbers etc. with any child, young person or vulnerable adult; • report all allegations/suspicions of abuse by seeking further support and guidance, including any allegation made against yourself or other staff; • ensure that any concerns about inappropriate behaviour are quickly and appropriately reported on to the Designated Safeguarding Lead within CSDTA; • be aware that some learners may behave inappropriately. Any sanctions and approaches to discipline used must be appropriate to age and understanding; and • Employees/representatives who come into contact with children, young people and vulnerable adults should always avoid: o being alone or out of sight of others. Where privacy is required, the door should be left ajar having ensured that others have been informed and are within earshot; o o o o transporting learners by car; having unnecessary physical contact; engaging in or allowing sexually provocative games or activities; making or permitting suggestive or discriminating remarks to/or about the learners; Safeguarding Learners Policy_v11 September 2024 Information Classification: Public Page 13 of 18 If printed this document becomes uncontrolled Document Reference Number 1POHR23 o o o o o meeting children, young people or vulnerable adults outside of organised/formal interaction; entering a room where learners (or their clients) may be changing their clothes, or are not fully dressed; participating in, or tolerating any bullying; sexual relationships between staff/ consultants and learners where the former holds a position of trust over the learner are strictly forbidden and may constitute a criminal offence; and taking photographs or videos which include any participant unless authorised by the appropriate member of staff and the learner/parental (for children) consent has been given. This includes the use of camera phones. I agree to comply with all the requirements of this Code of Practice. Please retain a copy. Name (Block Capitals): Signature: Date: Address (inc. Postcode): Safeguarding Learners Policy_v11 September 2024 Information Classification: Public Page 14 of 18 If printed this document becomes uncontrolled Document Reference Number 1POHR23 9. Appendix 4: Types of Abuse and Harm Abuse may be a single incident or something that occurs over a long period of time. It can take many forms including, but not limited to: Domestic Abuse - is any type of controlling, bullying, threatening or violent behaviour between people in a relationship. But it isn’t just physical violence – domestic abuse includes emotional, physical, sexual, financial or psychological abuse. Sexual Abuse ‐ There are 2 different types of child sexual abuse. These are called contact abuse and non‐contact abuse: • Contact abuse involves touching activities where an abuser makes physical contact with a child, including penetration. • Non‐contact abuse involves non‐touching activities, such as grooming, exploitation, persuading children to perform sexual acts over the internet and flashing. Neglect ‐ is the ongoing failure to meet a child's basic needs and is the most common form of child abuse. A child may be left hungry or dirty, without adequate clothing, shelter, supervision, medical or health care. A child may be put in danger or not protected from physical or emotional harm. They may not get the love, care and attention they need from their parents. Online Abuse ‐ is any type of abuse that happens on the web, whether through social networks, playing online games or using mobile phones. Children and young people may experience cyberbullying, grooming, sexual abuse, sexual exploitation or emotional abuse. Physical Abuse ‐ Physical abuse is deliberately hurting a child causing injuries such as bruises, broken bones, burns or cuts. It isn’t accidental ‐ those who are physically abused suffer violence such as being hit, kicked, poisoned, burned, slapped or having objects thrown at them. Emotional Abuse ‐ is the ongoing emotional maltreatment. It’s sometimes called psychological abuse and can seriously damage a child’s emotional health and development. Emotional abuse can involve deliberately trying to scare or humiliate a child or isolating or ignoring them. Child Sexual Exploitation ‐ is a type of sexual abuse. Children in exploitative situations and relationships receive something such as gifts, money or affection as a result of performing sexual activities or others performing sexual activities on them. Female genital mutilation (FGM) ‐ is the partial or total removal of external female genitalia for non‐medical reasons. It's also known as female circumcision or cutting. Religious, social or cultural reasons are sometimes given for FGM. However, FGM is child abuse. It's dangerous and a criminal offence. Bullying and Cyberbullying ‐ Bullying is behaviour that hurts someone else – such as name calling, hitting, pushing, spreading rumours, threatening or undermining someone. Bullying that happens online, using social networks, games and mobile phones, is often called cyberbullying. A child can feel like there’s no escape because it can happen wherever they are, at any time of day or night. Safeguarding Learners Policy_v11 September 2024 Information Classification: Public Page 15 of 18 If printed this document becomes uncontrolled Document Reference Number 1POHR23 Child trafficking and modern slavery ‐ are child abuse. Children are recruited, moved or transported and then exploited, forced to work or sold. Grooming ‐ is when someone builds an emotional connection with a child/young person to gain their trust for the purposes of sexual abuse, sexual exploitation or trafficking. Children and young people can be groomed online or face‐to‐face, by a stranger or by someone they know ‐ for example a family member, friend or professional. Safeguarding Learners Policy_v11 September 2024 Information Classification: Public Page 16 of 18 If printed this document becomes uncontrolled Document Reference Number 1POHR23 10. Appendix 5: CSDTA Trustees and Staff Responsible for the Policy Position Name Designated Safeguarding Lead Contact Details Kate Cornhill HR Director Trustee with Safeguarding Responsibility Stephanie Richardson 07955 298056 Trustee Safeguarding Learners Policy_v11 September 2024 Information Classification: Public safeguarding@vtct.org.uk Page 17 of 18 If printed this document becomes uncontrolled Document Reference Number 1POHR23 Document amendment history page Version Document Owner Issue Date Changes Role 9 HR Advisor April 2023 Updated template 10 HR Advisor HR Advisor December 2023 Updated Safeguarding Lead HR Advisor 11 HR Advisor September 2024 Updated safeguarding lead, updated template, updated CLT to Leadership Team, updated Staff names Document Review Role Review Status HR Advisor HR Advisor Update complete Document Owner Document Owner Document shared with HR Director HR Advisor Chief Executive Officer Document Sign-off Role Sign-off Date HR Advisor September 2024 Safeguarding Learners Policy_v11 September 2024 Information Classification: Public

City Skin Doctor Clinic Malpractice and Maladministration Policy and Procedure August 2024 Contents 1. Introduction 3 1.1. Purpose of the policy 3 1.2. Scope of the policy 3 1.3. Regulatory authorities 3 1.3.1. Adverse effects 3 1.3.2. Malpractice / Maladministration 4 1.4. Responsibilities 4 1.4.1. CSDTA 4 1.4.2. Centres 5 1.5. Review arrangements 5 1.5.1. Situations brought to our attention by the regulators 6 2. Malpractice and Maladministration - Process 6 2.1. Introduction 6 2.1.1. Identifying possible or actual malpractice or maladministration 6 2.1.2. Anonymity and Whistleblowing 6 2.1.3. Timescale 7 2.1.4. Retention of materials 7 2.2. Process for dealing with suspected or actual case of malpractice or maladministration 7 2.3. Investigating a case of suspected or actual malpractice or maladministration 10 2.3.1. Use of sanctions during the investigation 11 2.3.2. Investigation outcomes and actions 11 2.4. Right to appeal 13 2.5. Process for dealing with an appeal against a decision or action relating to malpractice or maladministration 13 3. Appendix 1: Examples of Malpractice and Maladministration 14 3.1. Malpractice 14 3.2. Maladministration 16 1. Introduction 1.1. Purpose of the policy This policy provides definitions of malpractice and maladministration and sets out information about the procedures which CSDTA must follow for reporting and dealing with any suspected or actual cases of malpractice or maladministration. CSDTA publishes this policy, procedures and process flowchart, to support all parties involved in the handling of suspected or actual instances of malpractice or maladministration, by providing a framework for investigating and dealing with such instances in an effective and consistent manner. 1.2. Scope of the policy The Malpractice and Maladministration Policy and Procedures apply to all CSDTA qualifications. This policy is provided for the use of CSDTA customers, being learners who are taking or have taken CSDTA assessments, and personnel with responsibilities for managing, delivering, assessing and quality assuring qualifications in CSDTA centres, who suspect or become aware that malpractice or maladministration has occurred. Regulatory authorities This policy addresses the requirements of the relevant regulatory authorities’ criteria. 1.2.1. Adverse effects Attention is drawn to CSDTA’s obligations to consider risks caused by adverse effects, defined as an act, omission, event, incident or circumstance that gives rise to prejudice to learners or potential learners or adversely affects: • the standards of qualifications which the awarding organisation makes available or proposes to make available, or public confidence in qualifications. 1.2.2. Malpractice / Maladministration ‘Malpractice’, means any act, default or practice which is a breach of the Regulations or which: • gives rise to prejudice to candidates; • compromises public confidence in qualifications; • compromises, attempts to compromise or may compromise the process of assessment, the integrity of any qualification or the validity of a result or certificate; • damages the authority, reputation or credibility of any awarding body or centre or any officer, employee or agent of any awarding body or centre. Malpractice will generally involve some form of intent. It may also include circumstances where an individual has been negligent or reckless as to the consequences of their actions. Bias or discrimination could also lead to malpractice. Malpractice includes maladministration and instances of non-compliance with the regulations, and includes activity such as failure to adhere to the regulations regarding the conduct of controlled assessments, coursework, examinations and non-examination assessments, or failures of compliance with CSDTA requirements in the conduct of examinations/assessments and/or the handling of examination question papers, candidate scripts, mark sheets, assessment records, results and certificate claim forms. This list is not exhaustive. CSDTA are obliged to notify the regulators of certain malpractice incidents, in accordance with the regulators’ conditions. A list of examples of malpractice and maladministration is included in Appendix 1. It should be noted that this list is not exhaustive. 1.3. Responsibilities 1.3.1. CSDTA CSDTA is responsible for ensuring that all related investigations are conducted by individuals who: • have no personal interest in the issue; • have appropriate competence. CSDTA personnel are required to follow the related procedures to deal with cases of suspected and/or actual malpractice and maladministration as effectively as possible. CSDTA will be responsible for ensuring that investigations are carried out in a prompt and effective manner and in accordance with the procedures in this policy. CSDTA will allocate a suitable member of staff (e.g. a member of CSDTA’s Quality Assurance Team) to lead the investigation of a case, establish if malpractice or maladministration has occurred, and review any supporting evidence received or gathered by CSDTA. monitoring all investigations to ensure due process is being followed and appropriate evidence has been gathered and reviewed. The investigating officer may also be responsible for liaising with relevant external parties and keeping them informed. Where the allegation may affect another awarding organisation and their provision, CSDTA will inform that awarding body in accordance with regulatory requirements, and/or seek to undertake a joint investigation with the awarding body if appropriate. If CSDTA does not know the details of organisations that might be affected, the regulators will be asked to help identify relevant parties that should be informed. Where an associated investigation leads to the discovery of a failure in its assessment process, CSDTA takes all reasonable steps to: • identify any other learner who has been affected by the failure; • correct or, where it cannot be corrected, mitigate as far as possible the effect of the failure; • ensure that the failure does not recur in the future. 1.3.2. Centres The centre agreement sets out the specific duty not to put the awarding organisation in breach of its ability to fulfil its obligations under the General Conditions of Recognition. It is therefore important that adverse effects (see 1.3.1), malpractice and/or maladministration are notified to CSDTA immediately and dealt with in line with the policy and procedures. It is also important that staff involved in the management, assessment and quality assurance of CSDTA qualifications, and learners, are fully aware of the contents of the policy and that the centre has arrangements in place to prevent and investigate instances of malpractice and maladministration. The centre’s compliance with this policy and how it takes reasonable steps to prevent and/or investigate instances of malpractice and maladministration is reviewed periodically. When an investigation is conducted by the centre, the head of centre must: • ensure the investigation is carried out by competent investigators who have no personal involvement in the incident or interest in the outcome; • ensure the investigation is carried out in an effective, prompt and thorough manner; • ensure staff co-operate fully with the investigation, providing speedy and full responses to requests for information. 1.4. Review arrangements This policy is reviewed annually as part of CSDTA’s self-evaluation activity, In addition, this policy may be updated following consideration of operational feedback to ensure CSDTA’s arrangements for dealing with suspected cases of malpractice and maladministration remain effective. 1.4.1. Situations brought to our attention by the regulators Where the regulators notify us of failures that have been discovered in the assessment process of another awarding organisation, we will review if a similar failure could affect our own assessment processes and arrangements. 2. Malpractice and Maladministration - Process 2.1. Introduction CSDTA must be informed, promptly, of any and all suspected or alleged cases of malpractice or maladministration. Where malpractice or maladministration is suspected or has occurred in a centre, including any assessment site or a partner organisation involved in the administration or assessment of the qualification, the Awarding Organisation may apply sanctions immediately while investigations are underway. This may include preventing CSDTA from processing any further registrations and/or certification claims, and/or the removal of direct claims status. The Awarding Organisation reserves the right to withhold learner results for any qualification(s)/unit(s) they may be studying at the time of the investigation pending the outcome in order to mitigate any risk. 2.1.1. Identifying possible or actual malpractice or maladministration Any person may identify a matter that they think could constitute malpractice or maladministration. This will normally be a centre employee, a learner, an awarding organisation employee, a contractor (e.g. a moderator), or an external agency (e.g. the Education and Skills Funding Agency). CSDTA may identify cases of malpractice or maladministration through its routine work or in considering other matters, such as an appeal against results. Failure to report any suspected or actual malpractice or maladministration to the Awarding Organisation may result in sanctions being applied to CSDTA immediately while investigations are underway. Centres failing to report malpractice or maladministration may not have their approval status reinstated after the investigation is completed. 2.1.2. Anonymity and Whistleblowing Sometimes a person making an allegation of malpractice or maladministration may wish to remain anonymous. An informant who is concerned that possible adverse consequences may occur if their identity is revealed to another party should notify CSDTA. CSDTA will always aim to keep a whistleblower’s identity confidential where asked to do so, although it cannot be guaranteed. CSDTA may, for example, need to disclose an informant’s identity if the matter leads to issues that need to be taken up by other parties such as the police, fraud prevention agencies or other law enforcement agencies, the courts (regarding any court proceedings) or the regulators. The investigator(s) assigned to review the allegation will not reveal the whistleblower’s identity unless the whistleblower agrees, or doing so is necessary for the purposes of the investigation. The investigator will advise the whistleblower if it becomes necessary to reveal their identity. A whistleblower should also understand that they may be identifiable by others due to the nature or circumstances of the disclosure (e.g. the party against whom the allegation is made may identify possible sources of disclosure without such details being disclosed to them). Once a concern has been raised, CSDTA has a duty to pursue the matter. It will not be possible to prevent the matter being investigated by subsequently withdrawing a notification, as CSDTA is obliged by the regulators to follow up and investigate all allegations of malpractice or maladministration. In all cases the whistleblower will have the opportunity to raise with the investigators any concerns about the way the investigation is being conducted. It should be noted that CSDTA will not disclose details of all of the investigation activities, and it may not be appropriate to disclose full details of the outcomes of the investigation due to confidentiality or for legal reasons (e.g. action to be taken against the parties concerned). 2.1.3. Timescale CSDTA aim to action and resolve all stages of the investigation within 30 working days of receipt of the allegation. Please note that in some cases the investigation may take longer, for example, if a centre visit/investigation is required. In such instances, CSDTA may advise all parties concerned of the likely revised timescale. 2.1.4. Retention of materials CSDTA will: • ensure all materials collected as part of an investigation are securely kept; • retain, for a period of not less than 7 years, all records and original documentation concerning a completed investigation leading to sanctions against a centre; • retain, until the case and any appeals have been heard and for 7 years thereafter, all records and original documentation of an investigation leading to the invalidation of certificates, or criminal or civil prosecution. 2.2. Process for dealing with suspected or actual case of malpractice or maladministration • An initial notification of suspected or actual malpractice or maladministration should be submitted to info@cityskindoctor.co.uk no later than 2 working days after the occurrence of the event. The notification must include the following information: ̵ centre name and contact details of person submitting the notification; ̵ learner’s name and registration number (if applicable); ̵ name(s) and job role(s) of centre/awarding organisation personnel involved in the case; ̵ qualification(s) or service(s) affected; ̵ nature of the suspected or actual malpractice or maladministration and associated dates; ̵ declaration of any personal interest by the person making the allegation. • Within 5 working days of notification CSDTA: ̵ establishes/confirms the lead contacts for CSDTA for the impending investigation; ̵ carry out an investigation, ̵ clarifies the process for the investigation; ̵ notifies the , Awarding Organisation and subsequently updates them throughout the investigation; ̵ • The centre must: ̵ provide the Awarding Organisation with all the requested information; ̵ advise all parties implicated in the case of the allegation and possible outcomes; ̵ ensure all parties involved receive a copy of the Malpractice and Maladministration Policy and Procedures and are made aware of the timescales for the investigation; ̵ inform those parties of any actions taken pending the outcome of the investigation; ̵ advise all parties implicated that they have the right to respond to allegations and the right to appeal against any decisions for actions against them. • An investigation will be conducted. The investigation may involve but is not limited to the following: ̵ a request for further information from the whistleblower ̵ a request for further information from CSDTA personnel ̵ interviews (face to face or by telephone) with personnel and/or learners involved in the investigation CSDTA expect all parties, who are either directly or indirectly involved, to fully co-operate with the investigation. • If CSDTA is directed to investigate the case by the Awarding Organisation, for example, in the case of an allegation of collusion in an assessment, this internal investigation should be completed within 10 working days. A report should be submitted to the Awarding Organisation immediately upon completion. If there is a reason why this timescale cannot be met, CSDTA must notify the Awarding Organisation immediately, giving the reason. The report should cover the points set out in section 2.3 below. • If CSDTA investigates, it aims to complete this within 10 working days of notification and, where appropriate, will produce a draft report summarising, in line with the objectives set out in section 2.3: ̵ the origin of the issue or mode of discovery of the alleged irregularity; ̵ where the breach, if any, occurred; ̵ the facts of the case; ̵ any mitigating factors; ̵ with whom the responsibility for the breach lies; ̵ details of the investigation; ̵ the evidence provided; ̵ the conclusions drawn. • Where appropriate, the draft report is submitted to all parties concerned to check for factual accuracy. Any subsequent amendments are agreed between the parties and CSDTA. • CSDTA will produce and submit a final summary of outcomes to all relevant parties and inform the Awarding Organisation, in writing, of any actions to be taken and will adhere to any sanctions that may be imposed/removed. • CSDTA will make the final outcome available to other external agencies as required. In some circumstances the police or other external authorities may need to be alerted. • If an independent/third party notified CSDTA of the suspected or actual incident of malpractice, upon conclusion of any investigation, CSDTA may provide stakeholders with a summary update of outcomes within 10 working days. In doing so, some details may be witheld if to disclose such information would breach a duty of confidentiality, GDPR or any other legal duty. The update will not: ̵ contain detailed confidential information relating to any individuals involved in the case. ̵ provide the regulators with full details of the investigation/evaluation. • Where any serious issues are proven, other awarding organisations offering the same or similar qualifications will also be informed. The centre must: ̵ implement any actions required as a result of its own investigation or that carried out by CSDTA ̵ retain all relevant documentation securely and in line with its own policies; ̵ take actions to prevent a recurrence of the incident. CSDTA will: ̵ monitor the completion of actions and/or compliance with any sanctions imposed by the Awarding Organisation; ̵ provide the Awarding Organisation with updates and inform them when the actions have been completed; ̵ retain all relevant documentation in line with data protection legislation. 2.3. Investigating a case of suspected or actual malpractice or maladministration The fundamental principle of all investigations is to conduct them in a fair, reasonable and legal manner, ensuring that all relevant evidence is considered without bias. In doing so, investigations will be underpinned by terms of reference based around the following broad objectives: • to establish the facts relating to allegations to determine whether any irregularities have occurred; • to identify the cause of the irregularities and those involved; • to establish the scale of the irregularities and whether other qualifications may be affected; • to evaluate any action already taken • to determine whether remedial action is required to reduce the risk to current registered learners; • to preserve the integrity of the qualification; • to ascertain whether any action is required in respect of certificates already issued; • to identify any adverse patterns or trends. CSDTA will expect all parties who are either directly or indirectly involved in the investigation to co-operate fully with the investigation. In carrying out any investigation CSDTA will be sensitive to the effect on and the reputation of a centre and/or those members of staff or other individuals who may be subject to investigation. It will strive to ensure that the investigation is carried out as confidentially as possible. The organisation/person who is the subject of the allegation will have the opportunity to raise any issues with the investigator(s) at any stage about the proposed approach and conduct of the investigation. The investigation may involve a request for further information from relevant parties and/or interviews with personnel involved in the investigation. Interviews will be recorded, dated and signed by all involved. The person(s) accused of malpractice or maladministration may choose to be accompanied in the interview by a work colleague, trade union representative or other person, and must be advised of this right in time to be able to arrange to be accompanied. Children, young people and vulnerable adults must be accompanied at the interview by an appropriate adult. CSDTA may find that the complexity of a case or a lack of co-operation means that it is not possible to complete an investigation. In such circumstances the relevant Awarding Organisation is consulted to determine how best to progress the matter. Where a member of CSDTA staff is implicated in any actual or potential malpractice or maladministration, CSDTA will investigate. This will be through the CSDTA HR policies and procedures. 2.3.1. Use of sanctions during the investigation 2.3.2. Investigation outcomes and actions If the investigation confirms that malpractice or maladministration has taken place, CSDTA considers what action to take to: • minimise the risk to the integrity of the qualification(s); • maintain public confidence in the delivery and awarding of qualifications; • discourage others from carrying out similar instances of malpractice or maladministration; • ensure there has been no gain from compromising CSDTA’s standards. The actions CSDTA may take regarding centre/centre staff malpractice may include: • requiring specific centre staff to undergo additional training and/or scrutiny by the IQA/Centre Manager if there are concerns about their ability to undertake their role effectively in the delivery of CSDTA qualifications; • not permitting specific centre staff to be involved in the delivery or assessment of CSDTA qualifications (e.g. invigilation); • informing relevant third parties (e.g. funding bodies) of CSDTA’s findings in case they need to take relevant action in relation to the centre; • the issue of a written warning to the member of staff, including an agreed action plan; The actions CSDTA may take regarding learner malpractice may include: • warning; • implementation of any actions advised by the Awarding Organisation CSDTA must inform the Awarding Organisation whenever it finds evidence that a certificate may be invalid and must agree with the Awarding Organisation any appropriate action that may be required. Any qualification certificates are deemed invalid if any of the following are found to have occurred: • the evidence assessed is not the learner’s own work; • the learner has not finished the qualification before the certificate has been claimed; • the certificates have been claimed based on falsified records; When the decision is taken, by the Awarding Organisation, to invalidate certificates, CSDTA must ensure that it promptly follows the principle of seeking to protect the interests of learners as far as reasonably possible in the circumstances. CSDTA will: • inform the affected learners of the action the Awarding Organisation is taking and that their original certificates are invalid; • return the invalid certificates to the Awarding Organisation if possible; • amend its records to show that the original awards are invalid. 2.4. Right to appeal An appeal can be made against a decision or action taken/to be taken following an investigation into maladministration or malpractice. See section 2.6 for the related process. 2.5. Process for dealing with an appeal against a decision or action relating to malpractice or maladministration A staff member or learner may submit an appeal against a decision or action to be taken following an investigation into maladministration or malpractice. This section sets out the process to be followed to appeal against such a decision or action. For clarity, this appeal process is separate from appeal against an assessment decision, unless an assessment decision is the subject of the appeal following an investigation into malpractice or maladministration. • The appellant should submit a report to the Centre Manager setting out the reasons for the appeal, together with any supporting evidence, as soon as possible and no later than 15 working days after the date of receipt of the decision. Please note that appeal applications without supporting evidence will not be accepted. • The following information must be included in the appeal: ̵ Centre name and number; ̵ Learner name(s) and registration number(s) if relevant; ̵ The affected service; ̵ The name of the qualification involved; ̵ Details of any investigation carried out relating to the issue; ̵ The appellant’s name, position and signature. • CSDTA will: ̵ consider if it will accept the appeal and notifies the appellant of this decision, normally within 10 working days of receipt of the appeal; - Inform the Awarding Organisation of the receipt of the appeal and follow its guidance • Possible outcomes are as follows: ̵ the appeal is not upheld; ̵ the decision has been judged to be unreasonable, and has been removed or changed; ̵ procedures were judged to have not been applied consistently, properly or fairly. The subsequent decision is reviewed and revised accordingly. • The Awarding Organisation’s decision is final and completes the internal appeals procedures. No further appeal will be accepted. 3. Appendix 1: Examples of Malpractice and Maladministration 3.1. Malpractice The following list provides examples of centre and learner malpractice. This list is not exhaustive and is intended as guidance on CSDTA’s definition of malpractice. • Deliberate failure to adhere continually to the Awarding Organisation’s centre approval and/or qualification approval requirements or actions assigned to the centre within stated timelines; • Denial of access to premises, records, information, learners and staff by any authorised Awarding Organisation representative and/or the regulatory authorities; • Inadequate centre procedures for the induction of staff or any contracted person involved in the delivery of qualifications; • Failure to carry out internal assessment, internal moderation or internal verification in accordance with Awarding Organisation requirements; • Deliberate failure to adhere to the Awarding Organisation’s learner registration and certification procedures; • Deliberate failure to maintain appropriate auditable records, e.g. certification claims, and/or forgery of evidence. • Fraudulent claim for certificates; • Intentional withholding of information from the Awarding Organisation which is critical to maintaining the rigour of quality assurance and standards of qualifications; • Deliberate misuse of the Awarding Organisation’s logo and trademarks or misrepresentation of CSDTA’s relationship with the Awarding Organisation and/or its recognition and approval status with the Awarding Organisation • Collusion or permitting collusion in exams/assessments, e.g. allowing another learner to copy work or the unsanctioned collaboration between a learner or another individual in the production of work to be submitted; • Learners still working towards a qualification after certification claims have been made; • Persistent instances of maladministration within the centre; • Deliberate contravention by centre staff and/or its learners of the assessment arrangements as specified for Awarding Organisation qualifications; • Loss of, theft of, or a breach of confidentiality in any assessment materials; • Plagiarism of any nature by learners and/or staff; • Copying from another learner (including using ICT to do so); • Impersonation - assuming the identity of another learner or having someone assume the identity of the named learner during an assessment; • Unauthorised amendment, copying or distributing of exam/assessment papers/materials; • Inappropriate assistance to learners by centre staff (e.g. unfairly helping them to pass a unit or qualification); • Deliberate submission of false information to gain a qualification or unit; • Deliberate failure to adhere to, or attempts to circumnavigate the requirements of the Awarding Organisation’s Reasonable Adjustments and Special Considerations Policy; • Failure to effectively and continuously supervised examinations/assessments and/or learners; • False ID used at the registration stage; • Creation of false records; • Cheating; • Disruptive behavior in the examination/assessment setting; • Selling examination papers/assessment details/certificates; • Failure to manage and prevent conflicts of interest; • Failure to provide learners and staff, including contractors, with the knowledge of their responsibilities through policies and procedures; • Failure to review systems, policies and procedures to ensure they remain fit for purpose; • Failure to carry out delivery, internal assessment, internal moderation or internal quality assurance in accordance with Awarding Organisation requirements; • Failure to conduct assessments or other external assessment according to Awarding Organisation procedures or regulations; • Inaccurate recording of learner assessment decisions leading to invalid claims for certification; • Deliberate falsification, fabrication or forgery of assessment/examination evidence, records or authentication statements by centres or learners; • Failure to retain accurate learner assessment decision for the specified timescale; • Deliberate destruction or theft of another’s work; • Obtaining examination or assessment material without authorisation; • Introduction of unauthorised material into an assessment room, for example notes, study guides, own blank paper, calculator (where prohibited), dictionary (where prohibited), translation devices, personal stereos, mobile phones, smart watches and other similar electronic devices. • Obtaining, receiving, exchanging or passing on information during an assessment (or the attempt to) by any means; • Failure to follow CSDTA’s own malpractice and maladministration policy and/or report occurrences to the Awarding Organisation; • Tampering with learners' scripts or other assessed work after collection; • Non-compliance with invigilation requirements during assessments; • Failing to keep assessment papers secure prior to assessment; • Withholding of information from the Awarding Organisation, by deliberate act or omission, which is required to assure it of CSDTA’s ability to deliver qualifications appropriately. • Failure by a centre to notify, investigate and report to an awarding organisation all allegations of malpractice or suspected malpractice; 3.2. Maladministration The following list provides examples of centre and learner maladministration. This list is not exhaustive and is intended as guidance on CSDTA definition of maladministration. • Failure to adhere to the Awarding Ogranisation’s learner registration and certification procedures; • Failure to adhere to the Awarding Organisation’s centre agreement and/or qualification requirements and/or associated actions assigned to the centre; • Late registration of learners; • Unreasonable delays in responding to requests and/or communications from the Awarding Organisation • Inaccurate claim for certificates; • Failure to maintain appropriate auditable records, e.g. certification claims; Misuse of the Awarding Organisation’s logo and trademarks or misrepresentation of a centre’s relationship with the Awarding Organisation and/or its recognition and approval status with regard to Awarding Organisation qualifications. • Failure to adhere to, or to circumnavigate, the requirements of the Awarding Organisation’s Reasonable Adjustments and Special Considerations Policy; • Failure to adhere to CSDTA policies, procedures and practices; • Failure to adhere to CSDTA financial payment terms and/or plans (whether infrequent or persistent).