Suitability of Officers

6. Senior officers will be appointed in conjunction with a relevant job description (Condition A1.4). All appointees will be suitably qualified and experienced in their specified role and will be reviewed on an annual basis through appraisal and development discussions. On employment or take up of the role all the items specified in (Condition A1.5) will be checked. Any deficiencies will be resolved before submitting the annual assessment report to Ofqual or reported to Ofqual as a deficiency. Staff of In2assessments will be made aware of what acts of omission must be notified to In2assessments that will or potentially lead to an Adverse Effect upon In2assessments ability to meet its qualification provision requirements.

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Established in the UK

7. In2assessments is part of In2Action, a Limited Company registered and established in the UK. Registered with companies’ house under the following number. In2action 04994617 (Condition A2.1)

​Safeguard on Change of Control

8. Where there is a change of control to In2assessments, In2assessments will ensure that within the process of the change of control, there would be no impact on the delivery of qualifications that would have an Adverse Effect as outlined in the description in Section J. This will include any agreements with third parties and support for qualifications that are within an agreed period that protects learners already committed to qualifications and arranged EPA's. Change of Control policy (Condition A3.1) 

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Mitigation of Risks regarding Governance

9. In2assessments employs a risk management approach to awarding qualifications.

9.1 This procedure sets out guidance of how In2assessments identifies a risk and the procedure it follows.  In2assessments is committed to providing and maintain rigorous quality standards and ensure that it complies with regulatory requirements and best practice. In2assessments manages this commitment through continual risk assessment and takes all reasonable steps to prevent incidents occurring and to prevent any adverse effects. Identification & Management of risks

​9.2 All employees directly associated with the management and direction of the company must disclose any criminal offences that they have committed. This will reduce the potential Adverse Effects of dishonesty and conflicts of interests. (Condition A1.4)

​9.3 At the time of review of an annual review of procedures, all components of Condition A1.2 will be reviewed to check compliance. This will reduce the risk associated with acts or omissions defined in Condition A1.2. Information will be stored under data protection regulations.

​9.4 The In2assessments written Conflict of Interest Policy addresses Condition A4.7. No member of In2assessments employees will be solely and directly responsible for making any award. All assessors and moderators will disclose any potential personal interests in the assessment of any candidates that they have a part in certificating. (Condition A4.5 and A4.6)

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​All employees of In2assessments and third parties acting on behalf of In2assessments will undergo random checks and samples, so there will always be at least two people involved in the assessment and awarding of certificates. Any complaints about potential or perceived conflicts of interests will be investigated with reference to the details provided in conditions A4.1 - A4.3.

​There are several perceived risks in regard to the relationship of In2assessments and with its parent company and the Training Provider owned by the parent company. In2assessments prime aim is to ensure that every assessment remains fit for purpose as outlined in condition D1.2, through managing both organisational risks as well as those at an individual level. The control measures to mitigate these perceived risks are listed within the Conflicts of Interest Policy.

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​Through the process of routine gathering of conflicts of interests and a regular review process of those conflicts of interests raised, the likelihood of the conflicts having an adverse effect on the qualification process, are minimalised. These could include simple changes in personnel involved in the EPA or arranging a different subcontractor for a particular service. (Condition A4.3)

​Where a conflict of interest has had an Adverse Effect, In2assessments will take action as described in the conflict of interest policy and this in turn could lead to action as described within the Malpractice Policy. (Condition A4.4)

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​There are occasions where the personal interests of an individual may have an adverse effect on the outcome of a decision. On these occasions it will be subject to the Governing Committee to ensure that the right personnel are selected to review or to be part of the panel to investigate a suspected or alleged breach of malpractice. (Condition A8.3) Where an individual is being investigated regarding the breach of confidential information or confidentiality of a candidates or employers EPA data; (Condition G4.6) or where an individual’s personal interest could have an adverse effect on the outcome of an appeal decision if they were to sit on the panel. (Condition I1.2)

​All records of Conflicts of Interest will be collected from new starters, and annually from all parties: involving subcontractors and staff. Including any changes in circumstances notified to In2assessments during this annual process. Data from all Conflicts of Interests will be collated in one location and any new or unresolved conflicts of interest will be reviewed at monthly management meetings as part of the regular meeting agenda. (Condition A4.2) 

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​9.5 In2assessments will act swiftly to any request from Ofqual on matters of conflicts of interest. Where the Conflicts of Interest Policy is requested, In2assessments will ensure that the policy is up to date and reflects the true processes of In2assessments and conforms to the requirements of Ofqual. (Condition A4.8)

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​​Availability of adequate resources and arrangements

10. In2assessments will work on a supply and demand principle, drawing on people resources and supporting services as and when required. The aim is to minimise cost and maintain a measured level of service and the reliability of central financial support. Future development depends on the customer base and will not be initiated without specific funds being available to sustain it. This fits with the organisations commitment to deliver qualifications as efficient as possible, considering the financial and reputational risk involved in providing qualifications. Resources and costs associated with these qualifications and their quality assurance should reflect this. (Condition A5.1)

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​10.1 Specific risks associated with financial viability are as follows. (Condition A5.1)

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a. Changes in government policy e.g., in terms of eligibility for funding qualifications and political statements that strengthen monopoly brands from competing qualifications providers are among the greatest risks and largely beyond our control.

b. Committing too many resources to development before revenue is generated to pay running costs

c. Lead-in time for new qualifications to establish themselves and start to generate income

d. Competitors entering the market in such a way that qualifications are dropped or not taken up

 

​The following policies mitigate against these risks

a. Endeavour to fulfil any conditions imposed by government for qualifications funding in target markets

b. Develop incrementally and as far as possible use common methods and technologies.  Strengthen and develop supporting resources and to establish new marketing and sales channels that will result in long term income with very little need for central investment.

c. Reduce development costs by building into existing markets and sectors. Use established marketing channels for new qualifications and ensure that there is demand. Use subcontractors to spread initial costs.

d. Analyse the supply chain and reduce all possible unnecessary costs to make products as unassailable on price as possible. Add value that is identified by customers and low cost for us to implement but expensive for competitors. e.g. On-line evidence management. Low license fees. Use of online moderation and investment in achieving assessor consistency.

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10.2 The entire human resources strategy and business plan are based on the demand from employers. If the number of employers providing apprenticeships increases so will the income to sustain them, if it decreases, there will be time to scale back on staffing. Especially as most staff will be employed on a freelance basis.

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Initially, In2assessments aims to recruit independent Internal Verifiers and EPA’s on a freelance basis, based across England. Due to the irregular flow of work, this would be the most effective and viable way to meet demand. Hybrid & Flexible Working policy. (Condition A5.2) Having a more geographically remote team of assessors, In2assessments will be able to compete and deliver more work throughout England. Where numbers of assessments are outside the capacity of one assessor, In2assessments will contract more assessors or already contracted assessors will travel to various regions to boost numbers and deliver EPA’s. (Condition A5.2a)

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In line with Condition A5.1a all staff will follow the same induction and training system managed through Inspiring Learning and In2assessments. There is also in place regular appraisal and performance meetings schedule within each employee’s online development record.  Staff recruited into roles, either as employees or subcontractors will be suitably qualified for the role as outlined in 1.6. of the recruitment, induction, training, and development procedure.

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Information specific to all roles across the organisation can be accessed via this portal and a record of what data has been read and acted upon can be seen by those with line management access. (Condition A5.2a)

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​10.3 In2assessments will rely upon 3 main IT providers to support its qualification process.​

Internal provision from the Inspiring Learning Group

(a) Hardware provision including Desktop, Laptop computers, tablets, and mobile phones

(b) Server storage and restricted access and security set up

(c) Software ad IT support

​External provision of EPA registration and assessment recording

e.g., Skilltech solutions, Talus - Contract with provider not currently set up at this stage, but demonstrations and conversations have been undertaken.

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​In2assessments files and data will be stored on the Inspiring Learning secure servers based in Brighton. Remote access to data will be via endpoint secure access software. Access to data is restricted to named and authorised personnel. Servers are backed up daily and online IT support is available to those with authorised access. (Condition A5.2c)

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Data on assessors and internal verifiers will be held within secure files and maintained under GDPR Rules.

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Data gathering and retention of learners’ progress through EPA will be held within the external provider software and will be available to those with secure access 24/7. (Condition A5.2b)

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​As part of the Inspiring Learning Group structure, all organisations within the group including In2assessments have access to a range of departments and personnel to support the resource management of the business. Including:

• Human Resources

• Information Technology

• Marketing and Sales

• Finance

• Health & Safety

• Safeguarding

 

Budgets for each area are set and allocated by finance on an annual basis and In2assessments will be set its own budget within each area.  Where these budgets are exceeded, then these will need to be covered through the income generated by In2assessments.

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​​Staff planning and allocation will be coordinated by the EPA Manager (or the Head of In2assessments in their absence) based on skills, knowledge and experience of assessors and verifiers. Taking into consideration conflicts of interest, location, and workload. In2action is a small organisation, and all personnel will have responsibilities appropriate to their skills and qualifications. (Condition A5.2d) The systems for planning and internal control are deliberately simple. Technology will be used where possible to manage control systems and will be mostly automated through other data entry. (Condition A5.2e)

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​The In2assessments strategy for resources management is based on the assessment of current and future demands, working with low levels of resources that are therefore sustainable, even in a downturn of business. This is in keeping with the risk-based strategy supporting compliance with condition A5.1.

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​In keeping with Condition 5.1, resources are reviewed at every meeting of the Governing Committee and the potential for sustainable development within those constraints. In2assessments will not embark on the development of new qualifications without first reviewing the capacity to complete the development and gain sufficient income for managing the subsequent awards.

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​As part of the risk-based strategy for dealing with conditions A5.1, In2assessments engages with companies with expertise in the outdoor learning, hospitality, business, and administration. Qualification development is prioritised with qualifications beyond current capacity put on hold until the resources to support them are secure. (Condition A5.3)

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​In2assessments has no borrowing, and from start-up will have a growing customer base and has sufficient group backing to provide liquid assets that can cover contingencies and cash flow comfortably.

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In2assessments will only undertake delivery of a qualification knowing that it could fulfil that qualification for all learners. Where In2assessments decides to withdraw a qualification, it will continue to support and provide full EPA provision for those learners already registered. (Condition A5.4)

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​Identification and management of risks

11. In2assessments takes all reasonable steps to identify, monitor and mitigate against any risks that could have an adverse effect on In2assessments qualifications our regulatory obligations and good practice. However, In2assessments is aware that incidents could occur on occasions that have not been foreseen and this policy and procedure outlines how In2assessments will identify and manage this potential risk to safeguard In2assessments apprentices and In2assessments qualifications. (Condition A6.1 - A6.2)

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​In2assessments contingency plan will be managed by the Head of In2assessments who will review and update the plan annually (where required) following several tests by the Governing Committee on the plans effectiveness to mitigate against adverse effects. (Condition A6.3) In2assessments have identified and managed risks have a plan in place to mitigate against the possible adverse effects of these various risks within the assessment process and their impact upon the successful awarding of qualifications within the Ofqual guidelines. (Condition A6.4)

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Management of Incidents

12. In the case of an incident arising, for whatsoever reason, that could have an Adverse Effect, the following actions will be taken. (Condition A7)

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a) Identify any policy or procedure formally defined to meet the circumstances of the incident and implement

b) Where the incident lies outside the scope of an existing policy or procedure it will be prioritised on the risk associated with the associated Adverse Effect.

c) Actions will be evaluated to determine the effectiveness of the actions taken

d) In cases where an existing policy or procedure was deemed inadequate or non-existent, a new policy and/or procedure will be devised to minimise the risk of reoccurrence and to deal specifically with any reoccurrence.

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Malpractice and Maladministration

13. Prevention

In2assessments takes seriously the potential risks regarding malpractice and maladministration at whatever level they occur.  It is a priority for In2assessments to prevent malpractice and maladministration from happening in the first place. This is the first stage of any In2assessments risk management policy.

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Through managed on-boarding, training and open discussions learners and assessors will be familiar with the policies and procedures and what's expected of them. This makes it less likely that issues with conflicts of interest, maladministration or malpractice would occur. (Condition A8.1)

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​Investigating and managing the effect

Where suspected malpractice is brought to In2assessments attention, for example through the complaint’s procedure or by day-to-day monitoring, it will be investigated to ascertain the facts around the case.  The person or persons subject to investigation will be given the opportunity to defend themselves in a fair hearing. The main priority would be to reduce any adverse effects at the earliest opportunity. (Condition A8.2)

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Issues of malpractice are covered in In2assessments induction, and all assessors agree to comply with In2assessments procedures as part of this process. Any assessor can ask for more information at any time.

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​Procedure

The following policies and procedures are designed to reduce risk:

• Learners are made aware of the guidance regarding malpractice and maladministration (Condition A8.3a) and its implications upon the assessment process.  All assessors are required to sign an agreement to uphold standards before using the technology that records the assessments and enables the issue of certificates. Issue of certification required the input of two different people, assessor, and verifier. Due to the nature of the assessment plan, only In2assessments assessors will undertake assessments and therefore employers will not need to be required to support or provide any of the assessment process (Condition A8.4)

• As soon as there is a judgement that the issue of malpractice is serious, the Governing Committee will be informed and if the level of concern is confirmed at Committee level the regulators will be informed. The responsible officer will carry out an investigation based on verifiable evidence as to the cause of the incident and report this to the Committee.  If the responsible officer is unavailable or implicated, another qualified person will carry out the work directly reporting to the chair of the Governing Committee. (Condition A8.3b)

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In considering each case there will be two guiding principles:

1. Has someone been given an award for which they are unable to demonstrate that they have met the criteria?​

2. Was an award given negligently with regard to the assessor application of the criteria for the assessment?

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• If a certificate has been awarded to someone who cannot demonstrate competence against the criteria, the award will be revoked, and its record deleted from the database. The facility to verify the certificate will be suspended during any investigation.  Any paper certificates issued will be declared invalid and made impossible to authenticate against the database. Any that exist should be destroyed.  Any corrected results will be actioned in line with (Condition H6.3)

• Where a sanction has been brought against an employer the potential for a candidate having a certificate revoked will be imposed as outlined in the Sanctions Policy. When such sanction is lifted the candidate will be provided with the opportunity of reassessment should they feel they are able to meet the criteria. Where this fits with the individual assessment plan requirements for reassessment and retakes. If an assessor has awarded certificates in good faith but with inappropriate rigour, they will be required to undergo a period of training at their own cost until such time as the awarding body is confident of their capability. 

• If after further training an assessor cannot demonstrate the capability of assessing accurately to the criteria, s/he will have their assessor's rights revoked. In2assessments will provide the assessors for all the assessment process, therefore the employer should not have cause for raising issues of malpractice in the assessment process.  In2assessments will undertake any request from a employer to investigate a proposed incident of malpractice. In2assessments will make a judgement based on the extent of the malpractice as to whether individuals should be involved in any part of the assessment process in the future. (Condition A8.5) Any materials compromised by malpractice will be replaced.

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​Dealing with malpractice and maladministration

• If an assessor is judged to have taken actions to deliberately make invalid awards, they will be de-registered and ineligible to re-register for a period of at least 5 years. (Condition A8.6b) In serious cases, they will be barred for life and the police informed. This would be highly unusual but might be appropriate, for example, where there was evidence of corruption such as the taking of bribes or similar financial reward in return for issuing invalid certificates. In any investigation, In2assessments will deal directly with the apprenticeship employer. (Condition A8.4). The Responsible Officer will review procedures on any instance of malpractice and maladministration with the aim of reducing the chances of reoccurrence. (Condition A8.6a)

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​Student malpractice

• It is the primary responsibility of the assessor to ensure that the candidate meets all the criteria. This means that the assessor should be vigilant in ensuring that any evidence is work originated by the candidate. In many areas the assessment is by direct observation but where candidates have the option to work independently, e.g., in producing a project, the assessors must warn candidates that the work must be their own and that they run the risk of disqualification if this is shown not to be the case. Students must declare that their work is their own and license it for others to use. Where a student submits any work where there is doubt about authenticity, the assessor should require the student to demonstrate capability in line with that of the required work and use this to make a judgement against the criteria. (Condition A8.1)

• Where there is absolute proof of candidates actively cheating, the work should be discounted, the Training Provider informed, and the student banned from participating in the assessment process for 6 months. Such a candidate should subsequently be monitored closely, and should they transgress again, they should be permanently excluded from the certification and their details submitted to In2assessments. (Condition A8.2, A8.6b).

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​In the case of malpractice or maladministration by any direct employees of In2assessments, the normal disciplinary procedures will be invoked. For minor misdemeanours a verbal warning will be deemed sufficient, more serious, or repeated offences a written warning and serious or persistent offending, dismissal. In all cases, a fair investigation based on objective verifiable evidence will take place. In the case of a pending dismissal or in cases where continuing in post could have an Adverse Effect, the offender will be suspended or transferred to low-risk duties. (Condition A8.6b)

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​Where the incident of malpractice has had an adverse effect on the results of learners from one employer and the assessors’ records show that they have been involved in assessments within another employer, this employer should be informed of any serious findings from the investigation and records of previous samplings should be investigated for possible infringements. Where there has been a serious offence of malpractice that has led to dismissal or baring from assessments for In2assessments, then In2assessments will contact those EPAO's where it is known they were also contracted too. (Condition A8.7)

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​Whistleblowing

In2assessments policy on whistleblowing is in line with the published government policy. Anyone can contact In2assessments at any time for a confidential discussion of any incidents that they believe are contrary to good ethical practice. If they are not satisfied, they can contact the Chairman and the Regulators, Ofqual. In2assessments will take no action against anyone that points out any instances of malpractice or unethical behaviour. Actions will be confined to eradicating the risk of malpractice and unethical behaviour as the focus for any investigation and subsequent action.

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Examples of Malpractice

Giving assessor status to people who cannot assess appropriately to the criteria
Failure to adequately monitor the work of assessors
Failure to inform the In2assessments about instances of malpractice
Failure to co-operate with those investigating allegations of malpractice
Failure to co-operate adequately with QA and moderation procedures
Failure to adequately ensure that the candidate fully meets the criteria before awarding a certificate
Failure to attend mandatory training required by the In2assessments
Failure to keep passwords and account access secure
Failure to take the candidate's views of the candidate's competence into account
Failure to notify the In2assessments of significant student malpractice
Failure to co-operate with internal quality assurance procedures
Failure to co-operate with the In2assessments quality assurance procedures
Failure to keep up to date with notices from the In2assessments on the web site
Failure to keep up to date and extend knowledge in the subject matter at a level appropriate to the certification being carried out.
Passing off the work of others as if it is their own
Failure to co-operate appropriately with assessors in quality assurance
Failure to work co-operatively with peers including giving and receiving help (Note that giving and receiving help is not the same as passing off the work of others as if it is your own. If the process of giving and receiving help enables the candidate to match the criteria self-sufficiently then it is to be encouraged.)
Any attempts to break into the In2assessments web site or access restricted areas

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