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The attainment of a qualification involves assessment in the workplace and decisions being made about a learner’s competence in a diverse range of work tasks and activities. At some point during the assessment process the learner may disagree with their assessor’s judgement of competence.

An Appeals Procedure is available for any learner who is not satisfied with the decision or feels it is unfair. This process is designed to deal with appeals in a fair, objective and independent way.  The following information sets out the three stages involved in the Appeals Procedure and will describe the steps each party should take when an appeal is lodged.

Grounds for bringing an appeal

It would be impossible to provide an exhaustive list of grounds for bringing an appeal.  Each situation will be dealt with on its own individual merits.  However, it is likely that disagreements will fall under one or both categories set out below:

Disagreements about assessment decisions

  • The learner believes that the evidence they have produced does not warrant the assessment decision

Disagreement about the conduct of the assessment process

  • The learner feels that the assessment process has been discriminatory in its conduct
  • The assessor demands more evidence that the performance criteria does not require
  • The learner feels that they have had unfair access to assessment, i.e., insufficient time being allocated by the assessor

If the learner feels that they have been unfairly treated and /or disadvantaged by the conduct of the assessment process, they can raise the matter in the following way:

Stage One

When a learner feels that their assessor’s decision is unjustified, the learner should register their comments on their course feedback form.  The learner and the assessor must consider appropriate action to rectify the situation.

If the appeal is against the assessor and the learner does not feel they can discuss this with their assessor, the learner can contact the Centre who will arrange for an Internal Verifier to discuss their concerns and try to resolve the situation.

If the issue cannot be resolved between the assessor and the learner, the learner can instigate Stage Two of the Appeals Procedure. This involves referring the matter to the Centre and appropriate Internal Verifiers.

Stage Two

If the matter cannot be resolved between the assessor and learner, then the learner should lodge their appeal with the Centre, in writing within 7 days, on the Appeals Procedure form. The Office Manager will then appoint an Internal Verifier to this appeal.

The Internal Verifier will then arrange a meeting between both parties to try and find a mutually acceptable solution. The Internal Verifier will re-consider the assessment evidence to ascertain if the decision is valid and appropriate and to give advice and make suggestions about an appropriate course of action to resolve the matter.

If a mutually acceptable agreement cannot be reached, the learner can initiate Stage Three of the Appeals Procedure.

Stage Three

If at this stage the appellant is still unsatisfied with the result of SimTrainer’s decision, the learner can make a direct appeal to SFJ Awards following the SFJ Awards policy found at


SimTrainer UK aims to give learners an excellent experience. We welcome learner feedback on our courses and suggestions about the experience received when contacting us or using any of our products and services.

For any complaints about the service you have received, we refer you in the first instance to our complaints policy as set out below:


A complaint is an expression of dissatisfaction about our products, services or the complaints-handling process itself where it is clear that you expect us to identify the cause of the problem and to take some kind of remedial action.

We aim to ensure that

  • Making a complaint is as easy as possible;
  • We treat a complaint as a clear expression of dissatisfaction with our service which calls for an immediate response;
  • We deal with it promptly, politely and, when appropriate, confidentially;
  • We respond in the right way, for example by giving you an explanation or an apology where we have got things wrong, and letting you know what action we’ve taken;
  • We learn from complaints and we use them to improve our service

It is not possible to provide a definitive list of examples of complaints, but the following are examples of situations that would constitute a complaint:

  • Incorrect invoicing
  • Certificate spelling errors
  • Lack of response to queries
  • Unable to unsubscribe to emails
  • Incorrect products received
  • Delay with receipt of certificates
  • Non-compliance with stated SFJ process e. not adhering to published timescales or processes

However, if there is an allegation of malpractice or maladministration please refer to the Malpractice & Maladministration Policy.

For centres and providers

As part of our application for SFJ approval process we must have this policy in relation to a complaint.  Full details for all SFJ policies are available from the SFJ website,


We will try to ensure that your complaint remains confidential but in some cases the circumstances giving rise to the complaint may make it impossible to maintain confidentiality.  In these situations, we will discuss this with you.

The Investigation

We will acknowledge your complaint within 2 working days and let you know who will be appointed to investigate the matter on your behalf.

We aim to resolve complaints within 10 working days, however, if it is going to take longer than this, then we will keep you fully informed.

Outcome and action

Once we have completed our investigation, we will explain what went wrong and why, apologise when it is appropriate and take action to remedy the situation as soon as possible.

If you are not satisfied, SimTrainer UK will appoint an external independent consultant to review your complaint and agree a resolution. They will review the details of the original complaint, the evidence collected by the person who investigated the matter on your behalf and their initial response and any position on the matter we may hold.

In the first instance with any complaint please raise the issue with the tutor present or contact: John Lord, Managing Director for SimTrainer UK at

Health & Safety (and risk assessments)

Our statement of general policy is:

  • to provide adequate control of the health and safety risks arising from our work activities
  • to consult with our employees on matters affecting their health and safety
  • to provide and maintain safe equipment
  • to provide information, instruction and supervision for staff
  • to ensure all staff are competent to do their tasks, and to give them adequate training
  • to prevent accidents and cases of work-related ill health
  • to maintain safe and healthy working conditions always and to review and revise this policy as necessary at regular intervals

Health and Safety responsibilities

  1. Overall and final responsibility for health and safety is that of:
  • John Lord
  1. Day-to-day responsibility for ensuring this policy is put into practice is delegated to:
  • John Lord qualified Distinction Nebosh General Certificate in Occupational Health and Safety and Fire, Risk Management and IOSH Managing Safely.
  1. To ensure health and safety standards are maintained and improved, the following people have responsibility in the following areas:
  • John Lord: Risk assessment, accident investigation, training

consultation with employees, policy and procedure.

  1. All staff must:
  • Co-operate with supervisors and managers on health and safety matters and not interfere with anything provided to safeguard their health and safety
  • take reasonable care of their own health and safety
  • report all health and safety concerns to an appropriate person (as detailed in this policy statement)

Health and Safety risks arising from our work activities

  1. Risk assessments will be undertaken by:

Individual tutors at the client premises

  1. The findings of the risk assessments will be reported to:

Site management

  1. Action required to remove/control risks will be approved by:

Site management

In addition:

Tutors and site management

  • Will be responsible for ensuring the action required is implemented
  • Will check that the implemented actions have removed/reduced the risks

Safe equipment

John Lord, Owner and Managing Director of SimTrainer UK:

  • Will be responsible for identifying all equipment needing maintenance
  • Will be responsible for ensuring effective maintenance procedures are drawn up
  • Will check that equipment meets health and safety standards before it is purchased
  • Will be responsible for ensuring that all identified maintenance is implemented


  • Any problems found with any equipment should be reported to John Lord.

Information, instruction and supervision

  • Health and safety advice is available from John Lord.
  • Supervision of young workers/trainees will be arranged/undertaken/monitored by John Lord. (None currently and unlikely due to sector competence requirements)

John Lord is responsible for ensuring that our staff working at locations under the  control of other employers are given relevant health and safety information.

Competency for tasks and training

  • Induction training will be provided for all staff
  • Job-specific training will be provided by John Lord
  • Training records are kept by the Office Manager
  • Training will be identified, arranged and monitored by John Lord

Accidents, first aid and work-related ill health

  • The first-aid box is kept at the client’s premises or provided venue for training
  • The appointed person/first aider is provided by the training venue
  • All accidents and cases of work-related ill-health are to be recorded in the accident book. The book is kept by John Lord

In addition;

  • John Lord is responsible for reporting accidents, diseases and dangerous occurrences to the enforcing authority


To check our working conditions and to ensure our safe working practices are followed:

  • We will review all health & safety matters affecting the company
  • John Lord is responsible for investigating accidents, in addition to having responsibility for acting on investigation findings to prevent a recurrence

Emergency procedures – fire and evacuation

The venue provider will ensure that:

  • The fire risk assessment is undertaken and implemented
  • Escape routes are checked
  • Fire extinguishers are maintained and checked
  • Alarms are tested
  • Emergency evacuation is tested

Equal Opportunities/Equality & Diversity

SimTrainer UK is committed to encouraging equality and diversity among our workforce and eliminating unlawful discrimination. The aim is for our workforce to be truly representative of all sections of society and our clients, and for each employee to feel respected and able to give their best.

The organisation – in providing goods, services or facilities – is also committed against unlawful discrimination of clients and the public.

The equality policy is fully supported by senior management and has been agreed with staff.

This policy’s purpose is to:

  • Provide equality, fairness and respect for all in our employment, whether temporary, part-time or full-time
  • Not unlawfully discriminate because of the Equality Act 2010 protected characteristics of age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race (including colour, nationality, and ethnic or national origin), religion or belief, sex (gender) and sexual orientation
  • Oppose and avoid all forms of unlawful discrimination. This includes in pay and benefits, terms and conditions of employment, dealing with grievances and discipline, dismissal, redundancy, leave for parents, requests for flexible working, and selection for employment, promotion, training or other developmental opportunities

SimTrainer UK commits to:

  • Encourage equality and diversity in the workplace as they are good practice and make business sense
  • Create a working environment free of bullying, harassment, victimisation and unlawful discrimination, promoting dignity and respect for all, and where individual differences and the contributions of all staff are recognised and valued
  • This commitment includes training managers and all other employees about their rights and responsibilities under the equality policy. Responsibilities include staff conducting themselves to help the organisation provide equal opportunities in employment, and prevent bullying, harassment, victimisation and unlawful discrimination
  • All staff should understand they, as well as their employer, can be held liable for acts of bullying, harassment, victimisation and unlawful discrimination, in the course of their employment, against fellow employees, customers, suppliers and the public
  • Take seriously complaints of bullying, harassment, victimisation and unlawful discrimination by fellow employees, customers, suppliers, visitors, the public and any others in the course of the organisation’s work activities
  • Such acts will be dealt with as misconduct under the organisation’s grievance and/or disciplinary procedures, and any appropriate action will be taken. Particularly serious complaints could amount to gross misconduct and lead to dismissal without notice
  • Further, sexual harassment may amount to both an employment rights matter and a criminal matter, such as in sexual assault allegations. In addition, harassment under the Protection from Harassment Act 1997 – which is not limited to circumstances where harassment relates to a protected characteristic – is a criminal offence
  • Make opportunities for training, development and progress available to all staff, who will be helped and encouraged to develop their full potential, so their talents and resources can be fully utilised to maximise the efficiency of the organisation
  • Decisions concerning staff being based on merit (apart from in any necessary and limited exemptions and exceptions allowed under the Equality Act)
  • Review employment practices and procedures when necessary to ensure fairness, and also update them and the policy to take account of changes in the law
  • Monitor the make-up of the workforce regarding information such as age, gender, ethnic background, sexual orientation, religion or belief, and disability in encouraging equality and diversity, and in meeting the aims and commitments set out in the equality policy
  • Monitoring will also include assessing how the equality policy, and any supporting action plan, are working in practice, reviewing them annually, and considering and taking action to address any issues

Details on the organisation’s grievance and disciplinary policies and procedures can be found at This includes with whom an employee should raise a grievance. Use of the organisation’s grievance and/or disciplinary procedures does not affect an employee’s right to make a claim to an employment tribunal within three months of the alleged discrimination.

Malpractice & Maladministration

This policy applies to assessments, assignments and their reporting.

Malpractice refers to any deliberate act or practice which compromises or threatens to compromise the process and integrity of assessment, and as a result the validity of the result or certification awarded.

Assessment process and outcomes can also be put at risk through maladministration, and whilst malpractice is a deliberate act, maladministration may be accidental, or a result of incompetence or a simple mistake.

It the responsibility of all SimTrainer staff to be vigilant with regard to any events which may lead to malpractice / maladministration occurring, and report promptly to the Office Manager or Managing Director where they suspect malpractice / maladministration has and /or may occur so that appropriate action can be taken to address this with immediate effect.

The Office Manager is responsible for notifying relevant awarding bodies of cases of suspected or actual malpractice and maladministration to ensure the appropriate action may be taken.


  • To identify and minimise the risk of malpractice by staff or learners
  • To identify and minimise the risk of maladministration by staff and to respond to any incident promptly and objectively
  • To standardise and record any investigation to ensure openness and fairness
  • To impose appropriate penalties and/or sanctions on learners or staff where incidents (or attempted incidents) are proven
  • To protect the integrity of SimTrainer UK and all awarding bodies

In order to do this, SimTrainer UK will:

  • Seek to avoid potential malpractice by using the induction period and the learner handbook to inform learners of the policy on malpractice and the penalties for attempted and actual incidents of malpractice.
  • Conduct any investigations in a form commensurate with the nature of any allegation.
  • Ensure the handling of individual cases takes account of the needs of the learner/staff member.

Examples of Malpractice by Learners:

  • Collusion by working collaboratively with other learners to produce work that is submitted as individual learner work.
  • Copying (including the use of ICT to aid copying).
  • Fabrication of results or evidence.
  • Inappropriate behaviour during an internal assessment that causes disruption to others. This includes shouting and/or aggressive behaviour or language.
  • False declaration of authenticity in relation to the contents of a portfolio or coursework.

Examples of Malpractice by SimTrainer Staff:

  • Improper assistance to candidates.
  • Inventing or changing internally assessed work (coursework or portfolio evidence), where there is insufficient evidence of the candidates’ achievement to justify the assessment decisions made.
  • Failure to keep candidate coursework/portfolios of evidence secure.
  • Fraudulent claims for certificates.
  • Assisting learners in the production of work for assessment, where the support has the potential to influence the outcomes of assessment, for example where the assistance involves staff producing work for the learner.
  • Producing falsified witness statements, for example for evidence the learner has not generated.
  • Allowing evidence, which is known by the staff member not to be the learner’s own, to be included in a learner’s assignment/task/portfolio/coursework.
  • Misusing the condition for special learner requirements e.g. support.
  • Fraudulent certificate claims, that is claiming for a certificate prior to the learner completing all the requirements of assessment.
  • Failure to comply with awarding body procedures for managing and transferring accurate learner data.


Maladministration is any non-deliberate activity, neglect, default or other practice that results in SimTrainer or learner not complying with the specified requirements for delivery of the qualifications as set out in the relevant codes of practice, where applicable.

Actions and Responsibilities

SimTrainer UK will communicate the Malpractice Policy to learners during induction.

Implementing Assessment Practices 

SimTrainer staff have responsibility for implementing assessment practices that reduce the opportunity for malpractice.

Procedure for dealing with allegations of malpractice

All staff have a responsibility for reporting any suspected incidences of staff or learner malpractice through the appropriate channels. Learners will be made aware of the procedure for reporting any allegations of suspected malpractice via the Malpractice Policy. In addition, allegations of suspected malpractice may be made by external verifiers, examiners and reported to SimTrainer UK.

Allegations made by staff: 

Allegations of suspected staff or learner malpractice to be made to the Office Manager.

Allegations made by learners: 

All staff have a responsibility to ensure that any allegations made to them in their professional capacity are taken seriously and reported through the correct channels.

SimTrainer will consider allegations that are made verbally but will request in all cases that allegations are put in writing with any supporting evidence that is available. Course staff will inform the Office Manager regarding any allegations that are made.

Reporting suspected malpractice to Awarding Organisations

SimTrainer accepts the responsibility to report any suspicion of learner or staff assessment malpractice to the appropriate awarding organisation and will submit the fullest details of the case at the earliest opportunity.

Investigation of suspected malpractice:

If assessment malpractice is suspected by staff, there will be a process of investigation; such an investigation will usually be under the terms of the Disciplinary Policy and Procedure given the potential seriousness of the matter.

Possible Actions Taken by SimTrainer:

In cases where it is believed, following an investigation that there is clear evidence of malpractice:

  • The appropriate awarding body will be informed by SimTrainer of the allegation of malpractice and they will be given the supporting evidence.
  • SimTrainer will take disciplinary action commensurate with the seriousness of the malpractice.
  • Incidences of learner assessment malpractice will be investigated in a similar manner by the Office Manager. As with staff malpractice potential conflicts of interest will be avoided by nomination of an investigating officer who is external to the management of the learner.

Investigations will proceed through the following stages: 

  • The learner will be informed about the issues, possible consequences and right of appeal.
  • Collection of evidence related to the alleged malpractice.
  • The review of evidence and production of a report.
  • A formal meeting between the Office Manager and the learner against whom an allegation has been made.

Possible actions taken by SimTrainer in cases where it is believed that there is clear evidence of malpractice:

  • The appropriate awarding body will be informed by the SimTrainer of the allegation of malpractice and they will be given the supporting evidence;
  • SimTrainer will take internal disciplinary action in line with policy and procedures. This action will be commensurate with the seriousness of the malpractice.

Internal Verifiers are expected to:

  • Make malpractice checks when internally verifying work

Assessors are expected to:

  • Minimise the opportunity for malpractice.
  • Report suspected malpractice immediately.

Learners are expected to:

  • Submit work for assessment that is their own original work.
  • Seek advice on assessment practice and procedures from course tutors prior to submitting work.
  • Avoid sharing electronic versions of their work with other learners.


It is understood that in certain cases, awarding bodies may wish to allocate their own staff to join or lead an investigation.

Investigations will adhere to the following principles:

  • Confidentiality – by their very nature investigations usually necessitate access to information that is confidential to SimTrainer or individuals. All material collected as part of an investigation must be kept secure and not normally disclosed to any third parties (other than the regulators or the police, where appropriate).
  • Impartiality – investigations will be undertaken by a senior manager and assessed against the specific facts/evidence of the case in arriving at a decision about intention and culpability.
  • Rights of individuals – where an individual is suspected of malpractice, they should be informed of the allegation made against them (preferably in writing), and the evidence that supports the allegation. They should be provided with the opportunity to consider their response to the allegation and submit a written statement or seek advice, if they wish to. They should also be informed of what the possible consequences could be if the malpractice is proven and of the possibility that other parties may be informed e.g. the regulators, the police, the funding agency and professional bodies. The appeals process should also be communicated to them.
  • Staff Interviews – these interviews should be carried out in line with agreed arrangements, policy and procedures.
  • Retention and storage of evidence and records – all relevant documents and evidence should be retained in line with awarding body and SimTrainer’s policies and procedures.
  • Decisions and action plans – all conclusions should be based on evidence. A course of proposed action should be identified, agreed between the SimTrainer and awarding bodies
  • Proportionality – any decision on the outcome must reflect the weight of evidence and the minor nature of the case – the learner does not have to admit malpractice.
  • Sanctions – any sanctions applied to individuals should be proportionate with the level of non-compliance identified (and evidenced), during the investigation.

Conflict of Interest

Tutors, Assessors and Internal Verifiers

It is the policy of SFJ that tutors and assessors acting on behalf of an SFJ approved centre or SFJ recognised provider must be free from conflicts of interest that could adversely affect their judgement or objectivity to the organisation in conducting business activities and assignments. SFJ recognises that tutors and assessors may take part in legitimate financial, business, charitable and other activities outside of their SFJ approved centre and SFJ recognised provider roles, but any potential conflict of interest raised by those activities must be acknowledged, disclosed, and in relevant cases properly managed.

It is the responsibility of each individual to recognise situations in which they have a conflict of interest, or might reasonably be seen by others to have a conflict; to disclose this conflict and to take such further steps as may be appropriate and set out in more detail under the procedure below.

SimTrainer UK seeks to work at all times to these guidelines.


A conflict of interest may generally be defined as a conflict between the official responsibilities of a tutor, assessor, and internal verifier and any other interests the particular individual may have and as such could compromise or appear to compromise their decisions.

Condition A4 in the Ofqual General Conditions of Recognition 2011 states that a conflict of interest exists in relation to an Awarding Organisation where:

  • The organisations interests in any activity undertaken by it, on its behalf, or by a member of its group have the potential to lead it to act contrary to its interests in the development, delivery and award of qualifications in accordance with its Conditions of Recognition
  • A person who is connected to the development, delivery or award of qualifications by the awarding organisation has interests in any other activity which have the potential to lead that person to act contrary to his or her interests in that development, delivery or award in accordance with the awarding organisations conditions of recognition
  • An informed and reasonable observer would conclude that either of the above situations was the case

Examples of Conflicts of Interests

It is not possible to provide a definitive list of examples of conflicts of interests, but the following are examples of situations that could lead to actual or perceived conflicts of interest:

  • Tutors and assessors working with a business outside of the approved awarding bodies that is in direct competition with them
  • Tutors and assessors participating in the appointment, promotion, supervision or evaluation of a person with whom the person, has close or familial ties
  • Tutors and assessors having a close or familial relationship with an SFJ registered learner, or learners’ family whilst being involved in decisions about the outcome of their qualification
  • Tutors and assessors using non-public SFJ information or SFJ learner data for personal gain or advantage
  • Tutors and assessors involved in the SFJ Centre approval processes, who own business consultancies offering SFJ qualifications or programmes.
  • The existence of such interests as those outlined above, does not necessarily imply conflict, but is likely to give an appearance of conflict and as such should be declare


  • It is the duty of all tutors and assessors working for SimTrainer UK to disclose any actual or potential conflict of interest, and the process for doing this is documented below:
  • All tutors and assessors are issued with a conflict of interest form to complete on commencement with the organisation and it is a requirement of their contract that this is completed and updated on an annual basi
  • The information held on the conflict of interest form is then transferred to a register of interests document which is maintained by a designated person: John Lord
  • If the individual concerned has any changes to their declared circumstances, they must inform their line manager immediately in writing, so that the conflict of interest can be evaluated, and the register updated
  • The form is to be completed even when the individual has no conflict of interest to declare.
  • The information submitted is then evaluated to identify if any further action is required and a written record of the outcome of the evaluation is kept.


Most situations require no further action than the completion of the conflict of interest form. In some instances, however, the information declared on the form will require some follow up action, in order for the conflict of interest to be managed appropriately.

The approach agreed between the line manager and the tutor and assessor, will be documented and held with the conflict of interest forms.

Examples of actions that could be taken

  • Individual not taking part in discussions or decisions of certain matters
  • Referring certain matters for decision to others with no vested interest
  • Agreeing not to be involved in a particular project or with a particular centre
  • Declaring an interest when it is appropriate to do so
  • Referring the matter to SFJ for advice and guidance.

This policy shall be the subject of a three-year review cycle or as necessary.


The aim of this Confidentiality Policy is to ensure that all staff and users understand SimTrainer UK’s requirements in relation to the disclosure of personal data and confidential information.

For the purpose of this policy, confidentiality relates to the transmission of personal, sensitive or identifiable information about individuals (confidential information), which comes into the possession of the Centre through its work.

SimTrainer UK is committed to maintaining high standards of confidentiality in all aspects of its work. This includes records and information pertaining to staff, prospective staff and learners, which will only be used for the purposes for which it was gathered and will not be disclosed to any other individual or centre without the user’s expressed permission.

All personal data will be dealt with sensitively and in the strictest confidence, both internally and externally.

Legislative Framework

The Centre will monitor this policy to ensure it meets statutory and legal requirements of the Data Protection Act.

Information about staff

  • In all but specific circumstances (e.g. disciplinary procedures), the decision as to who should be given of a piece of confidential information is the member of staff to whom it applies.
  • Where such consent is sought it is necessary to tell the member of staff why there is a need to disclose information and to whom. The member of staff should be told of the likely consequences of their agreeing or not agreeing to this.
  • Any consent given should be written, dated and signed specifying exactly what information may be disclosed.
  • Once consent has been obtained, it is the responsibility of the person passing on any information to ensure that this is only done on the terms agreed.
  • Unless previously authorised a request for a member of staff’s address, phone number or email address will always be referred to the individual before any information is disclosed.
  • In some cases there is an automatic right of access to certain parts of staff information e.g. HMRC. The staff member will be notified of any legal requirements whereby SimTrainer UK is obliged to provide such information.
  • A staff member should never divulge another staff member’s personal circumstances or information to anyone without permission of the other person.
  • Do not write anything derogatory about a member of staff, or learners in a file or anywhere else.
  • Make sure any discussion relating to information of another, takes place in an appropriate venue, e.g. not in a place where others, who are not entitled to know, can hear about it.

Record Keeping

  • All personal paper-based and electronic data must be stored in accordance with the Data Protection Act 1998 and must be secured against unauthorised access, accidental disclosure, loss or destruction.
  • All paper based records are kept in locked filing cabinets. This includes notebooks, copies of correspondence and any other sources of information.
  • All computer records are password protected, and computers must be locked when left unattended.
  • Access to personal files of staff will be given only in the circumstances outlined in the previous section. No staff member has the right to view any other parties’ file except as specifically provided for in this policy. All information relating to staff and learners will be stored separately and only accessible through the Office Manager. No personal data of learners is held by SimTrainer UK. Learner’s assessment papers are only required by the External Verifier.
  • Application forms, interview records, medical information and monitoring forms are confidential to SimTrainer UK. Equal opportunity monitoring forms will be detached from application forms on receipt and kept separate from application forms. When seeking references for a new staff member it is made clear to the referees that information is sought in confidence.
  • For those unsuccessful in the hiring process, SimTrainer UK may wish to to keep information about applicants; Only anonymous and the most relevant information will be kept, for equality monitoring purposes, (such as race, sex, etc) and the rest destroyed.
  • Probationary reviews and appraisals of staff will only be available to the Managing Director and Office Manager.
  • Information will be kept for two years once a staff member has left SimTrainer UK. It will then be destroyed or archived.

Statistical Recording 

SimTrainer UK is committed to effective statistical recording of the use of its services in order to monitor usage and performance.

All statistical records given to third parties, such as to support funding applications or monitoring reports for awarding bodies shall be produced in anonymous form, so individuals cannot be recognised.

Partnerships with other organisations

SimTrainer UK may be working in partnership with other organisations. All partnership agencies will be provided with a copy of the confidentiality procedure and the requirements SimTrainer places on the partnership organisations will be explained.

It will be agreed at the outset which staff in the partner organisation will have access to information and in what circumstances. Where specific information-sharing protocols exist that affect a particular organisation all concerned should be aware of this.

Any agreements with other organisations will state that breaches of confidentiality by either party will be treated as a breach of the agreement.

Ensuring the Effectiveness of the Policy

Existing and new staff will be introduced to and receive a copy of the confidentiality policy through induction and training. The implications of the procedure for their work will be explained.

The policy will be reviewed annually and amendments will be proposed and agreed by senior members of staff.

Breaches of Confidentiality

All staff are expected to abide by this policy. Breaches of this policy may give rise to disciplinary action in the case of staff. The nature of any breaches of this procedure will determine the level of action.

Data Protection

This policy sets out SimTrainer UK’s commitment to ensuring that any personal data, including special category personal data, which SimTrainer UK processes, is carried out in compliance with data protection law.

SimTrainer UK processes the personal data of learners from all over the world, and is committed to ensuring that all the personal data that it processes is done in accordance with data protection law. SimTrainer UK ensures that good data protection practice is embedded in the culture of our staff and our centre.

SimTrainer UK’s other data protection policies and procedures are:

  • record of processing activities
  • privacy notices (website, clients, employees)
  • personal data breach reporting process and a breach register
  • data retention policy
  • data subject rights procedure
  • IT security policies

‘Data Protection Law’ includes the General Data Protection Regulation 2016/679; the UK Data Protection Act 2018 and all relevant EU and UK data protection legislation.



This policy applies to all personal data processed by SimTrainer UK and is part of SimTrainer UK’s approach to compliance with data protection law. All SimTrainer UK staff are expected to comply with this policy and failure to comply may lead to disciplinary action for misconduct, including dismissal.


Data protection principles

SimTrainer UK complies with the data protection principles set out below. When processing personal data, it ensures that:

  • it is processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’)
  • it is collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (‘purpose limitation’)
  • it is all adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’)
  • it is all accurate and, where necessary, kept up to date and that reasonable steps will be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’)
  • it is kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed (‘storage limitation’)
  • it is processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’)

SimTrainer UK will facilitate any request from a data subject who wishes to exercise their rights under data protection law as appropriate, always communicating in a concise, transparent, intelligible and easily accessible form and without undue delay.



SimTrainer UK will:

  • ensure that the legal basis for processing personal data is identified in advance and that all processing complies with the law
  • not do anything with your data that you would not expect given the content of this policy and the fair processing or privacy notice
  • ensure that appropriate privacy notices are in place advising staff and others how and why their data is being processed, and, in particular, advising data subjects of their rights
  • only collect and process the personal data that it needs for purposes it has identified in advance
  • ensure that, as far as possible, the personal data it holds is accurate, or a system is in place for ensuring that it is kept up to date as far as possible
  • ensure that appropriate security measures are in place to ensure that personal data can only be accessed by those who need to access it and that it is held and transferred securely

SimTrainer UK will ensure that all staff who handle personal data on its behalf are aware of their responsibilities under this policy and other relevant data protection and information security policies, and that they are adequately trained and supervised.

Breaching this policy may result in disciplinary action for misconduct, including dismissal. Obtaining (including accessing) or disclosing personal data in breach of SimTrainer UK’s data protection policies may also be a criminal offence.


Data retention

SimTrainer UK will only hold onto your personal data for as long as it is needed, after which time it will be securely erased or deleted. Examples of this include:

  • Course registration forms are shredded after submitting to awarding bodies
  • Feedback forms are held for two years for continuous improvement purposes; however, the new version of these forms are anonymous and thus do not pose a data protection issue
  • Assessment papers with learner names and test results are kept for two years for External Quality Verifier inspections


Data Subject Rights

SimTrainer UK has processes in place to ensure that it can facilitate any request made by an individual to exercise their rights under data protection law. All staff have received training and are aware of the rights of data subjects. Staff can identify such a request and know who to send it to.

All requests will be considered without undue delay and within one month of receipt as far as possible.

Subject access: the right to request information about how personal data is being processed, including whether personal data is being processed and the right to be allowed access to that data and to be provided with a copy of that data along with the right to obtain the following information:

  • the purpose of the processing
  • the categories of personal data
  • the recipients to whom data has been disclosed or which will be disclosed
  • the retention period
  • the right to lodge a complaint with the Information Commissioner’s Office
  • the source of the information if not collected direct from the subject, and
  • the existence of any automated decision making

Rectification: the right to allow a data subject to rectify inaccurate personal data concerning them.

Erasure: the right to have data erased and to have confirmation of erasure, but only where:

  • the data is no longer necessary in relation to the purpose for which it was collected, or
  • where consent is withdrawn, or
  • where there is no legal basis for the processing, or
  • there is a legal obligation to delete data

Restriction of processing: the right to ask for certain processing to be restricted in the following circumstances:

  • if the accuracy of the personal data is being contested, or
  • if our processing is unlawful but the data subject does not want it erased, or
  • if the data is no longer needed for the purpose of the processing but it is required by the data subject for the establishment, exercise or defence of legal claims, or
  • if the data subject has objected to the processing, pending verification of that objection

Data portability: the right to receive a copy of personal data which has been provided by the data subject and which is processed by automated means in a format which will allow the individual to transfer the data to another data controller. This would only apply if SimTrainer UK was processing the data using consent or on the basis of a contract.

Object to processing: the right to object to the processing of personal data relying on the legitimate interests processing condition unless SimTrainer UK can demonstrate compelling legitimate grounds for the processing which override the interests of the data subject or for the establishment, exercise or defence of legal claims.


Special category personal data

This includes the following personal data revealing:

  • racial or ethnic origin
  • political opinions
  • religious or philosophical beliefs
  • trade union membership
  • the processing of genetic data, biometric data for the purpose of uniquely identifying a person
  • an individual’s health
  • sexual orientation
  • criminal convictions or offences

SimTrainer UK processes special category data of clients and third parties as is necessary to provide legal services for the establishment, exercise or defence of legal claims.

SimTrainer UK processes special category data of employees as is necessary to comply with employment and social security law. This policy sets out the safeguards we believe are appropriate to ensure that we comply with the data protection principles set out above. SimTrainer UK also has a data retention policy which sets out how long special category data will be held onto.


Responsibility for the processing of personal data

SimTrainer UK take responsibility for data protection.

If you have any concerns or wish to exercise any of your rights under the GDPR, then you can contact the data protection lead in the following ways:

Rebecca Suproniuk

Recognition of Prior Learning

Recognition of Prior Learning (RPL) is a method of assessment (leading to the award of a qualification) that considers whether learners can demonstrate that they can meet the assessment requirements for a unit through knowledge, understanding or skills they already possess and do not need to develop through a course of learning.

This policy applies to some SimTrainer UK qualifications; however, qualifications that require an external or practical assessment will still require the learner to undertake the assessment to verify competency.

RPL enables recognition of achievement from a range of activities using any appropriate assessment methodology. Provided that the assessment requirements of a given unit or qualification have been met, the use of RPL is acceptable for accrediting a unit, however, partial unit completion is not acceptable.

SimTrainer UK when carrying out RPL will ensure that:

  • Identification of any achievement through RPL is prior to learners registering to taking a qualification
  • Records of assessment are maintained, as for any other unit/qualification
  • Certification and claims are made according to normal procedures
  • All relevant evidence is assessed before assessment decisions are confirmed
  • There are designated personnel with the appropriate expertise to support and assure the RPL process.

Evidence of Learning

All evidence must be evaluated using the stipulated learning outcomes and assessment criteria from the qualification or unit being claimed. In assessing a unit using RPL the assessor must be satisfied that the evidence produced by the learner meets the assessment standard established by the learning outcome and its related assessment criteria.

Examples of evidence that may be submitted include:

  • Certificates—copies of previous qualifications
  • Qualification Specifications—in order to map the learning outcomes and assessment methods, the assessor must see qualification units and previous assessment methods


All evidence of learning must be:


  • Addresses the elements and performance criteria
  • Reflects the skills, knowledge and context described in the qualification specification


  • The evidence being submitted is in its original format, can be verified as genuine and confirmed as the work of the learner


  • The assessor must see sufficient evidence to cover all aspects of the unit being claimed
  • The evidence must demonstrate competence over a period of time and can be repeated


  • The evidence must demonstrate the learner’s current skills and knowledge and must comply with current best practice guidance. For example, practical experience must be within the last 5 years


  • Evidence must be from a reliable source and in a reliable format, on organisation headed paper or certification
  • Documents that require translation must be completed by an official translator to ensure authenticity


RPL Procedure

To apply for SimTrainer UK RPL, learners must submit the following to

  • A completed RPL application form
  • Copies of all prior learning evidence including certificates, qualification specifications

Assessment of Evidence

SimTrainer UK will review and evaluate all evidence and map prior learning to qualification units and notify the learner within 14 days.

If the evidence is sufficient, SimTrainer UK will notify the learner on the assessment requirement in order to gain the unit(s).

However, if the RPL evidence is judged not to be sufficient to meet all the requirements of the relevant unit, the learner will be required to complete the normal course of learning.

Access to and Fair Assessment

SimTrainer UK endeavours to ensure that all assessment processes are fair and non- discriminatory. Our assessment policy is based on the concepts of equality, diversity, clarity, consistency and openness.

Our course assessments are a test of the learner’s knowledge, understanding and competence.

All assessments undertaken by learners ensure that the assessment continues to enable a valid, reliable and consistent judgement to be made about the achievement of all learning outcomes against the stated assessment criteria.

We recognise and respect equality and diversity, and therefore use a variety of assessment strategies and language to reflect the needs of individual learners.

Assessments will be standardised and work moderated across all courses to ensure that all learners have been judged against the same standards.

Constructive and focused feedback which is appropriate to the needs of the learner will always be provided by the tutor to enable the learner to improve their performance.

Learners and staff are made aware of the existence of this policy on the website.


Tutors will:

  • Record the outcomes of all assessment activities
  • Provide clear and constructive feedback to learners mapped against achievement of the learning outcomes and assessment criteria where appropriate
  • Ensure that assessment tasks allow for the generation of evidence in diverse ways
  • Ensure that they use appropriate language/communication strategies at a level suitable to the learner.
  • Ensure that the assessment strategy allows for the generation of evidence against all the learning outcomes and assessment criteria.


For students:

  • We aim to ensure that all assessment of work is carried out fairly and in keeping with the awarding body’s requirements
  • All portfolio-based work will be assessed fairly against the qualification standards
  • Internal assessments will be carried out fairly and according to awarding body instructions

Learners can also expect:

  • To be fully inducted onto a new course
  • Learning outcomes, performance criteria and other significant elements of learning and assessment to be made clear at the outset of the course
  • To be given appropriate assessment opportunities during the course with feedback provided on the quality of the work


Cheating and Plagiarism

A fair assessment of learner’s work can only be made if that work is entirely the learner’s own. Therefore, learners can expect an awarding body to be informed if:

  • They are found guilty of copying, giving or sharing information or answers, unless part of a joint project
  • They use an unauthorised aid during a test or examination
  • They copy another learner’s answers during a test or examination

All allegations of cheating and plagiarism will lead to a full investigation which will follow the guidance of the relevant awarding body.

If a learner feels he/she has been wrongly accused of cheating or plagiarism, they should be referred to the Complaints Policy.


Access Arrangements, Reasonable Adjustments and Special Consideration

We are committed to giving all learners equal access and opportunity to demonstrate their achievements.

There may be circumstances whereby, to take account of particular learner’s requirements, arrangements will need to be made, which ensure that this is achieved without conferring any unfair advantage over other learners. We will ensure that access arrangements are considered before an assessment takes place.


Please refer to our policy Reasonable Adjustment & Special Considerations for more information.

Reasonable Adjustments & Special Considerations

This policy is for learners who are undertaking or have completed a SimTrainer UK qualification. We are committed to complying with all current and relevant regulation and legislation to the development and delivery of our courses.

The standard format of assessment may not be suitable for all learners; therefore, we seek to ensure that our assessments and qualifications do not prevent any learners from attaining them. Our aim is to facilitate fair access for all learners who are eligible for reasonable adjustments or special considerations in assessments, whilst ensuring that the assessment of understanding, knowledge, skills and competence is not compromised in any way for all of the protected characteristics within the Equality Act 2010. Please refer to our Equal Opportunities Policy for more information.

This policy will also be used by our staff to ensure they are dealing with all reasonable adjustments and special considerations requests in a fair and consistent manner.

This policy outlines the following:

  • Arrangements for making reasonable adjustments and special considerations in relation to the delivery and assessment of our qualifications
  • How learners qualify for reasonable adjustments and special considerations
  • Reasonable adjustments we will accept and requests that are required prior to them being applied
  • What special considerations can be granted for learners

At SimTrainer UK, we recognise that reasonable adjustments or special considerations may be required at the time of assessment where the following applies:

  • Learners have a permanent disability or specific learning needs
  • Learners have a temporary disability, learning needs or medical condition
  • Learners are not available at the time of assessment

Reasonable adjustments and special consideration arrangements are available to ensure all learners receive recognition of their achievement providing there is evidence that the equity, validity and reliability of the assessments can be assured. These arrangements should not be used to make assessments easier for learners or give learners a head start and should not disadvantage other learners.

All requests for reasonable adjustments and special considerations will be reviewed on an individual basis and all the information received will be considered.

Definition of a Reasonable Adjustment

A reasonable adjustment relates to any actions that help to reduce the effect of a disability or difficulty, which may place the learner at a disadvantage during the delivery of a qualification or an assessment situation. They are applied to an assessment process for a qualification to enable a learner with a disability or difficulty to demonstrate their knowledge, skills and understanding of the levels of attainment required in the qualification specification.

When a reasonable adjustment has been applied, the work produced by the learner will be marked to the same standards and assessment requirements as the work assessed of the other learners.

Definition of a Special Consideration

Special consideration is a post-assessment adjustment to the marks of a learner’s assessment paper or rearrangement of an assessment time and/or date.

A special consideration can be granted after an assessment has taken place if a learner may have been disadvantaged; for example, offering the learner a resit.

Principles of Granting Reasonable Adjustments

SimTrainer UK will make reasonable adjustments by ensuring that the following applies:

  • Reasonable adjustments granted provide learners with the opportunity to demonstrate their attainment
  • The reasonable adjustment compensates for any disadvantage imposed by the disability or difficulty but do not disadvantage others
  • Certificates issued do not mislead anyone regarding the learner’s attainment
  • The assessments were rigorous and fair
  • The assessment activity is valid and is measurable against the assessment criteria
  • Assessment results are reliable

Reasonable adjustments that may be requested are as follows (pre-assessment notice is required):

Visual impairments

  • Use of modified enlarged manuals or assessment papers where enlarged text would allow access to fair delivery and assessment


  • Use of appropriate handouts
  • Use of coloured overlays or handouts printed on coloured paper
  • Sans serif font utilised
  • Font size always 12pt or above
  • Highlighters provided so learners can track where they are up to in the text
  • Multifaceted approach to learning – ie, reading, writing, doing, listening

Assessment extension time

  • An allowance of 25% extra time is permissible for assessment papers if the learner has learning difficulties, supported by an assessment report evidencing the need for the adjustment
  • Extra time is not permitted in practical assessments.


SimTrainer UK may reject requests in situations as follows:

  • Reasonable adjustments must not invalidate the assessment requirements set out in the qualification specification
  • Must not give the learner an unfair advantage compared to other learners for whom a reasonable adjustment has not been granted.

Procedure to Request a Reasonable Adjustment

SimTrainer UK will endeavour to identify learner needs as soon as possible to ensure the appropriate adjustments are reviewed, and implemented upon approval. Joining instructions will ascertain if learners have any learning difficulties so we can prepare accordingly.

The process for requesting access arrangements and the evidence required may vary dependent upon the qualification specification, the learner’s circumstances and any other factors that need to be taken in to consideration.

Reasonable adjustments may cover all of the course content and not just the assessment. We ask that a request is submitted to SimTrainer UK prior to the course starting: if the adjustment is to an assessment paper, a minimum of 14 days’ notice is required. All arrangements for adjustments must be approved by SimTrainer UK before being implemented.

All requests for reasonable adjustments and special considerations will be reviewed on an individual basis and all the information received will be considered.

SimTrainer UK will not approve any adjustments that may compromise the assessment criteria and that may disadvantage other learners.

Regardless of the application for reasonable adjustments, we will endeavour that tutors are provided with a variety of accessible learning resources for cases where learners do not wish to disclose a disability or difficulty.

Principles of Granting Special Considerations

Learners must have attended the course for the appropriate amount of guided learning hours and have been fully prepared by the tutor to take the assessment. If their performance in the assessment is affected by adverse circumstances beyond their control, a special consideration may be granted for a learner if they have temporarily experienced any of the following:

  • Illness or injury
  • An event out of the learners control which has or is likely to have an impact on the learner’s ability to take an assessment or demonstrate their levels of attainment during the assessment.

Any special considerations granted must:

  • Treat all learners fairly
  • Require the learner to fully meet the assessment requirements
  • Maintain the relevance, reliability and comparability of the assessment.

They must not invalidate the assessment requirements set out in the qualification specification.

Special considerations should not give the learner an unfair advantage, neither should it mislead an employer/training provider regarding the learner’s achievements for certification. The learner’s results must reflect the achievement in assessment and not their potential ability.

  • If a special consideration is granted, this will not result in a post-assessment adjustment to the marks of the learner. Our summative assessments require the learner to demonstrate practical competence and the assessment criteria must be fully met.
  • This may be that a resit is granted in class, or remotely through Socrative – ie have to leave due to emergency and can’t complete the test
  • If they have to leave they will receive digital copies of course materials to recap so they are not disadvantaged
  • The minimum passing mark is 70% for all assessments and a resit is automatic if under this threshold.

SimTrainer UK will not approve any special considerations that may compromise the assessment criteria and that may disadvantage other learners.

Failure to comply with this policy may constitute malpractice and the resulting disqualification of the learner.

Centre Responsibility

It is important that all centre personnel involved in the management, assessment and quality assurance of all SimTrainer UK qualifications, are fully aware of the contents within this policy and ensure their learners are made aware of the policy when undertaking or completing any of our qualifications.

Arrangements Not Covered Within This Policy

If any circumstances arise relating to the course or assessment and are not covered within this policy, please contact us to discuss prior to the assessment taking place.


If you wish to appeal against our decision to decline a request for a reasonable adjustment or special consideration please refer to our Appeals Policy, this is available on our website or you can request a copy by contacting us.

Monitoring and Review

This policy and its procedures will be reviewed regularly for improvements as part of our quality assurance requirements. This will ensure it is fit for purpose and reflects the services we deliver which are relevant to the requirements of individual needs.