Student Appeals Procedure

Grounds for appeal

A candidate may challenge the decision of an assessment decision if he / she believes that the decision is unfair or unreasonable, if this is the case then the following procedure must be followed.

Awareness of the Appeals Process

All candidates must be informed of the centre’s appeals process on commencement of their apprenticeship programme within the training plan.

Pre Appeal action

The student should contact the assessor/marker of the work in the first instance to try and discuss and resolve informally, this should be done where practical prior to making a formal appeal. The tutor/assessor should be open-minded to the points raised by the candidate, discuss the matter with his / her internal verifier and a solution sought which makes an appeal unnecessary. If this cannot be achieved the candidate must be advised of his / her right to appeal. Any appeal needs to be submitted in writing within 7 working days by the candidate, Harriet Ellis will then investigate and respond to the appeal within 14 days of receipt of the appeal.

It is vital that the marker/assessor acknowledges the students concerns when received and assists in order resolve the appeal informally where possible, and record its outcome, where the issues raised by the student appear capable of effective and fair resolution by informal discussion with the student.

If it appears to the IV in supporting of the assessor that the appeal appears on the face of it to be unjustified, misconceived or vexatious the Director may write to the student and invite withdrawal of the appeal on such basis with an indication that the appeal only proceed to an investigation if the student responds in writing and requires the appeal to proceed.

The Appeals Process

The candidate must make appeals in writing to the Operations Manager within 14 days of the candidate being notified of the decision against which the appeal is being made.

The written appeal must be copied by the Operations Manager to the tutor/assessor, counter assessor where applicable, who made the decision and to the IQA responsible for the assessor.

Operations Manager must identify a member of his / her programme team to evaluate the evidence and give a judgment (the “Appeals Adjudicator”).

This adjudicator must hold units D32 and D33 or V1/IQA, be technically competent in the skill area being assessed and be knowledgeable of the systems and procedures of the awarding organisation.

The Operations Manager must ensure that the organizational structure of the centre is not a barrier to an objective judgment of the appeal. If necessary, the Centre should access independent resource to achieve this.

In the event of a appeal proceeding formally, the IV / Leader will consider the complaint in consultation with those concerned in the provision of the service e.g. the course tutor, IV other service manager.

If the IV decides that there is a basis for the appeal, they will entitle to the students work to be remarked. Students should be aware that the remarking grade may either be the same as the original grade or possibly lower as well as higher.



The Appeals Adjudicator and where appropriate independent advisor will report back to the Operations Manager who will make the final judgment on the appeal.

The adjudicator’s judgment must be communicated to the candidate by the Operations Manager in writing within 21 days of the written appeal being received.

This communication to be copied to the tutor/assessor against whom the appeal was raised, his / her IQA Apprenticeship Lead must retain full details of the appeal within the Centre File for a period not less than 5 years.

If the appeal is successful, the Operations Manager must identify the specific failure in the centre’s assessment regime and implement corrective actions.

If the candidate is dissatisfied with the result of the appeal and feels that they wish to escalate/proceed with the issue further they can do so by contacting the Awarding Organisation, contact details of which will be supplied by the Operations Manager upon request.

The candidate must be aware that this is not an automatic reversal of original assessment decision/outcome.


The Operations Manager is at liberty to seek guidance from the EQA on any aspect of the appeals process.

A successful appeal is not automatically a reversal of the original assessment outcome: to establish the candidate may need to be re-assessed.

The timescales quoted in these procedures are normal maximums. In extreme cases the timescales may need to be longer.

Version 4 – January 2023

Apprentice Attendance Policy – Weekly Teaching Sessions

 Policy Statement

Harriet Ellis recognises that regular attendance of weekly group teaching sessions is key to success with our apprentices working towards their Apprenticeship Standard.

Attendance and punctuality are the responsibility of all but closely monitored by the Tutor, assisted by the Apprenticeship Delivery Management Team and the Apprenticeship Programme Manager.  Where attendance falls below the expectations of Harriet Ellis, action will be taken by the Delivery Management Team.

Apprentices are required to attend all scheduled classes and to be punctual in doing so.  This covers all sessions identified on the Apprentices Diary of Events but specifically relates to the remote based weekly teaching sessions whereby apprentices join the webinar led by their Tutor via

Harriet Ellis recognises that there may be periods whereby adhering to these expectations is not viable; therefore, absences due to illness, holiday, religious commitments and some personal circumstances will be considered on an individual basis.

NB:  For students who are under 18 or considered vulnerable, parents/guardians will be kept informed.

Monitoring Procedures for Apprentices

  1. Attendance is expected to be 100% and all apprentices are expected to login on time for the start of their weekly teaching session.
  2. It is compulsory for apprentices to have their camera and microphone on throughout the teaching session. If an apprentice does not do so, this will be marked as an absence.
  3. Apprentices must report any absences to the Delivery Management Team via the Head Office telephone number (01708 776 050) or email ( in advance of their teaching session starting
  4. Apprentices who join the session late will be marked as late. Late arrivals are expected to join their teaching session quietly, causing minimal disruption.
  5. A register will be taken for each teaching session. Attendance is monitored every week. If an apprentice’s attendance drops below 70% a written warning will be sent to the apprentice and their employer. Following the first warning, the student will have four weeks to improve their attendance. If the attendance percentage does not reach the required level of 70% a final written warning will be sent and the apprentice’s position on the program will be reviewed by the Operations Team at the next scheduled meeting whereby a decision will be made on potential removal on programme of the apprentice.

Version 3 June 2024


All members of staff and learners are entitled to be treated with dignity and respect in their place of work and / or study. This means freedom from behaviour by colleagues/staff that can be interpreted as bullying or harassment or that causes offense, and access to redress if such behaviour does arise. It also means standards of everyday behaviour that contribute to a working/ studying environment in which mutual respect and individual dignity are maintained.


Behaviour can constitute bullying or harassment where: it violates the dignity of a person on the grounds of their age, disability, gender reassignment, marriage and civil partnership, pregnancy or maternity, race, religion or belief, sex or sexual orientation (the protected characteristics); or where it creates an intimidating, hostile and degrading, humiliating or offensive environment. Individual or accumulative acts can seriously undermine the dignity, confidence, and work satisfaction to such an extent that it has an effect on job performance, and general happiness both inside and outside work.

Conduct becomes harassment if it persists and it has been made clear that it is regarded as offensive by the recipient or a witness to the conduct, although a single offensive act can amount to harassment if it is sufficiently serious.

Bullying and harassment can be further defined in the following ways:


Harassment based on race, colour or ethnic origin that is directed towards an individual by another person or group of people which is racist in nature, and which is regarded as unwelcome or offensive by the recipient or a witness.

  • The following are examples that illustrate such conduct, though this is not an exhaustive list:
  • Jokes about race, colour or ethnic origin
  • Use of offensive names.
  • References to colleagues by offensive racist descriptions.
  • Use of offensive or insensitive stereotypes.
  • Verbal abuse based on race, colour or ethnic origin.
  • Circulation, or display, of offensive material based on race, colour or ethnic origin.
  • Detrimental behaviour because of a colleague’s race, colour or ethnic origin.

Harassment based on pregnancy or maternity that is directed towards an individual by another person or group of people which is regarded as unwelcome or offensive by the recipient or a witness.

The following are examples that illustrate such conduct, though this is not an exhaustive list:

  • Jokes about pregnancy or maternity.
  • Use of offensive names.
  • Use of offensive or insensitive stereotypes.
  • Verbal abuse based on pregnancy or maternity.
  • Circulation, or display, of offensive material based on pregnancy or maternity.
  • Detrimental behaviour because of a colleague’s pregnancy or maternity.

Sexual harassment is conduct that is directed towards an individual by another person or group of people which is regarded as unwelcome or offensive by the recipient or a witness.

  • The following are examples which illustrate such conduct, though this is not an exhaustive list:
  • Unwanted physical contact.
  • Contact which is intimidating, or physically or verbally abusive.
  • Jokes that are based on sexual or gender issues.
  • Non-verbal conduct, such as staring or gestures.
  • Suggestions that sexual favours may further a persons career, or that refusal may hinder it.
  • Sexual advances, propositions, suggestions or pressure for sexual activity at or outside work.

Harassment based on disability is conduct directed towards that is directed towards an individual by another person or group of people which is based on the persons disability or association with someone who has a disability and which is unwelcome to the recipient or a witness.

The following are examples which illustrate such behaviour, though this is not an exhaustive list:

  • Jokes about disability.
  • Use of offensive names.
  • Use of offensive or insensitive stereotypes.
  • Verbal abuse based on disability.
  • Circulation, or display, of offensive material based on disability.
  • Deliberate actions designed to hinder a colleague’s ability to undertake his/her duties because of their disability.

Harassment based on sexual orientation or gender reassignment is conduct that is directed towards an individual by another person or group of people which is regarded as unwelcome or offensive by the recipient or a witness.

The following are examples which illustrate such behaviour, though this is not an exhaustive list:

  • Jokes about sexuality or gender reassignment.
  • Use of offensive names.
  • Use of offensive or insensitive stereotypes.
  • Verbal abuse based on sexuality or gender reassignment.
  • Circulation, or display, of offensive material based on sexuality or gender reassignment.

Harassment based on marriage or civil partnership is conduct that is directed towards an individual by another person or group of people which is regarded as unwelcome or offensive by the recipient or a witness.

The following are examples which illustrate such behaviour, though this is not an exhaustive list:

  • Jokes about marriage or civil partnership.
  • Use of offensive names.
  • Use of offensive or insensitive stereotypes.
  • Verbal abuse based on marriage or civil partnership.
  • Circulation, or display, of offensive material based on marriage or civil partnership.

Harassment based on religion or belief that is directed towards an individual by another person or group of people which is regarded as unwelcome or offensive by the recipient or a witness.

The following are examples which illustrate such behaviour, though this is not an exhaustive list:

  • Jokes about religions or beliefs.
  • Use of offensive names.
  • Use of offensive or insensitive stereotypes.
  • Verbal abuse based on religion or belief.
  • Circulation, or display, of offensive material based on religion or belief.

Harassment based on age is conduct directed towards a person or group of peoples which is based on the age of the person and which is unwelcome by the recipient or a witness.

  • Jokes about age.
  • Use of offensive names.
  • Use of offensive or insensitive stereotypes.
  • Verbal abuse based on age.
  • Circulation, or display, of offensive material based on age.

Bullying and harassment may not be based on the fact that an individual belongs to a particular group, but simply because the individual has been singled out for such treatment or associates with someone of a protected characteristic. For example, this would include claiming someone is gay when they are not or making fun of someone who has a disabled relative. The bullying and harassment may take the following forms, though again this is not intended as an exhaustive list:

  • Limiting or withdrawing verbal communication.
  • Isolating a colleague by unfriendly behaviour.
  • Behaviour designed to belittle or produce anxiety in a colleague.
  • Unreasonable scrutiny of work.
  • Unreasonable criticism of work, and adopting double standards in expectations of work performance.
  • Unreasonable denial of leave and/or special leave requests.
  • Unreasonable denial of requests for flexible working.
  • Work or staff social activities that deliberately exclude a colleague.
  • Jokes or inappropriate humour at the expense of a colleague.
  • Courtesy towards others.
  • Consideration and understanding of the work demands of individuals
  • Maintaining a temperate tone, and temperate language, in all verbal and written communication with all.
  • Avoidance of the use of foul language.
  • Awareness of language and conduct which have the potential to offend someone.
  • Obtaining the express or implied permission of an individual; before adopting familiarity in conduct or language.

The company is committed to ensuring that there is no harassment or bullying in the workplace or in training. Allegations of harassment will be treated as a disciplinary matter, although every situation will be considered on an individual basis and in accordance with the principles of the grievance and disciplinary procedures.

  • Informal Complaint

The first step you are encouraged to take is to raise such issues with a senior colleague of your choice (whether or not that person has a direct supervisory responsibility for you) as a confidential helper. However this person cannot be David Martin, who will be responsible for investigating the matter if it becomes a formal complaint.

If you decide you can deal with the inappropriate behaviour informally, for example, if the act concerned is relatively minor, isolated or clearly unintentional. In these situations it is possible that the matter can be resolved immediately by letting your colleague know that the behaviour in question is unacceptable to you and should be avoided in future. If you feel unable to do this verbally, you should hand a written request to your harasser; this is something your confidential helper can assist you with.

  • Formal Complaint

If you feel uncomfortable about raising the issue directly with your harasser or if you consider the behaviour is more serious because it was deliberate, part of a persistent pattern, or serious in nature, or has been repeated despite having discussed a previous incident informally, then you should bring the matter to the attention of our Safeguarding Lead Siobhan Thomas or our Operations Manager David Martin as a formal written complaint and again this is something that your confidential helper can assist you with.

If possible, you should keep notes of the harassment so that the written complaint can include:

  1. the name of the alleged harasser;
  2. the nature of the alleged harassment;
  3. the dates and times when the alleged harassment occurred;
  4. the names of any witnesses; and
  5. any action already taken by you to stop the alleged harassment.

On receipt of a formal complaint we will take action to separate you from the alleged harasser to enable an uninterrupted investigation to take place.  This may involve a temporary transfer of the alleged harasser to another work area or suspension with contractual pay until the matter has been resolved.

The person dealing with the complaint will invite you to attend a meeting, at a reasonable time and location, to discuss the matter and carry out a thorough investigation. You have the right to be accompanied at such a meeting by your confidential helper or another work colleague of your choice and you must take all reasonable steps to attend. Those involved in the investigation will be expected to act in confidence and any breach of confidence will be a disciplinary matter.

On conclusion of the investigation which will normally be within ten working days of the meeting with you, the decision of the investigator detailing the findings will be sent, in writing, to you.

You have the right to appeal against the findings of the investigator in accordance with the appeal provisions of the complaints procedure.

  1. NOTES
  • If the decision is that the allegation is well founded, the harasser will be liable to disciplinary action in accordance with our disciplinary procedure. An employee who receives a formal warning or who is dismissed for harassment may appeal by using our capability/disciplinary appeal procedure.
  • If you bring a complaint of harassment you will not be victimised for having brought the complaint. However if it is concluded that the complaint is both untrue and has been brought with malicious intent, disciplinary action and /or action will be taken against you.

Version 3 May 2024

Complaints Policy – Apprenticeships

We treat as a complaint any expression of dissatisfaction with our service which calls for a response. We listen to your complaints, treat them seriously, and learn from them so that we can continuously improve our service.

A complaint is an expression of dissatisfaction, whether justified or not.

Our policy covers complaints about:

  • The standard of service we provide
  • The behaviour of our staff
  • Any action or lack of action by staff affecting an individual or group

Our complaints policy does not cover:

  • Matters that have already been fully investigated through the complaints procedure
  • Complaints about examination or End Point Assessment appeals

Step 1 Informal

  • In the first instance speak to a member of Customer service/DMT to raise and discuss your concerns.
  • Your Customer Service / DMT Officer will respond to you and confirm this in writing within two working days.

Step 2 Formal

  • If you are not satisfied with the response provided, you should put your complaint in writing, explaining the nature and ground of your complaint to:

David Martin

Operations Manager

Harriet Ellis Training Solutions

103 North Street



  • On receipt of your complaint we will:
  • Log this on our complaints log
  • Identify a member of staff to investigate the complaint
  • Send you, the complainant acknowledgement of receipt of complaint and a timeline of the investigation and when they can expect a response. A response can be expected within 7 working days.

Step 3 Appeal

  • If you wish to appeal the response you should put this in writing explaining the reasons you are dissatisfied with the response to:

Hadley Silver

Managing Director

Harriet Ellis Training Solutions

103 North Street



  • The managing director will:
  • Log the appeal
  • Instruct the Quality Assurance Manager to investigate the complaint
  • Complainant sent acknowledgement of receipt of complaint and a timeline of the investigation and when you can expect a response. A response can be expected within 7 working days.
  • Investigation carried out
  • The Quality Assurance Manager will report in writing to the Managing Directorand the Managing Director will subsequently respond with the outcome.

Should the complainant fully exhaust this process and still not be satisfied they can consider escalating this directly to the Education Skills Funding Agency, 08000 150 600 or following their published complaints process.

Anonymous Complaints

Complaints received anonymously will be recorded and considered, but action may be limited if further information is required to ensure a full and fair investigation.

The complaints policy can be found on the Harriet Ellis Website under the Terms and Conditions.

Complaints Policy – Private Students

If a student or employer is dissatisfied with either the on-programme delivery or any of the surrounding support services, the following procedure must be followed.

Step 1 Informal

  • In the first instance speak to your Customer Service Officer to raise and discuss your concerns.
  • Your Customer Service Officer will respond to you and confirm this in writing within two working days.

Step 2 Formal

  • If you are not satisfied with the response provided, you should put your complaint in writing, explaining the nature and ground of your complaint to:

David Martin

Operations Manager

Harriet Ellis Training Solutions

103 North Street



  • On receipt of your complaint we will:
  • Log this on our complaints log
  • Identify a member of staff to investigate the complaint
  • Send you, the complainant acknowledgement of receipt of complaint and a timeline of the investigation and when you can expect a response. A response can be expected within 7 working days.

Step 3 Appeal

  • If you wish to appeal the response you should put this in writing explaining the reasons you are dissatisfied with the response to:

Hadley Silver

Managing Director

Harriet Ellis Training Solutions

103 North Street



Anonymous Complaints

Complaints received anonymously will be recorded and considered, but action may be limited if further information is required to ensure a full and fair investigation.

This complaints policy can be found on the Harriet Ellis Website under the Terms and Conditions.

Version 4 – January 2024

Equality & Diversity Policy

The aim of this policy is to communicate the commitment of the Management Team to the promotion of Equality & Diversity opportunities within in Harriet Ellis Training Ltd.

The Managing Director has specific responsibility for the effective implementation of this policy. They have agreed to abide by the policy and help to create the equality environment which is its objective.

In order to implement this policy, we shall:

  • Communicate the policy to all employees by issuing it and providing training as part of their induction.
  • Ensure existing staff are made aware of any revisions to the policy and where appropriate provide refresher training.
  • Communicate to our learners via our website and for apprentices as part of their training plan.
  • Provide Training to all staff and apprentices on importance of policy. Internal staff will receive regular in house training.
  • Engage with staff and apprentices to ensure they are aware of any revisions. Apprentices will be engaged via our website, OneFile and though the training plan.

Harriet Ellis Training Solutions Ltd will endeavour through appropriate training to ensure that it will not consciously or unconsciously discriminate in the selection or recruitment of applicants for employment.

    • We are committed to equality of opportunity and to providing a service and following practices which are free from unfair and unlawful discrimination. The aim of this policy is to ensure that no member of staff or learner / apprentice receives less favourable treatment on the grounds of age, disability, gender reassignment, marriage and civil partnership, pregnancy or maternity, race, religion or belief, sex or sexual orientation, or is disadvantaged by conditions or requirements which cannot be shown to be relevant to performance. It seeks also to ensure that no person is victimised or subjected to any form of bullying or harassment.
  • We value people as individuals with diverse opinions, cultures, lifestyles and circumstances. All employees and apprentices are covered by this policy and it applies to all areas of employment and training including recruitment, selection, training, deployment, career development, and promotion. These areas are monitored and policies and practices are amended if necessary, to ensure that no unfair or unlawful discrimination, intentional, unintentional, direct or indirect, overt or latent exists.
  • The Quality Manager has particular responsibility for overseeing and monitoring the implementation of this Equality and Diversity Policy for apprentices and learners and, as part of this process, all policies and procedures are administered with the objective of promoting equality of opportunity and eliminating unfair or unlawful discrimination. Successful implementation will be monitored through the quality evaluation cycle.
  • All employees, workers or self-employed contractors whether part time, full time or temporary and learners / apprentices – will be treated fairly and with respect. Selection for employment, promotion, training, or any other benefit will be on the basis of aptitude and ability. All employees and learners / apprentices will be helped and encouraged to develop their full potential and the talents and resources of the workforce will be fully utilised to maximise the efficiency of the Company.
  • Equality of opportunity, valuing diversity and compliance with the law is to the benefit of all individuals in our Company as it seeks to develop the skills and abilities of its people. While specific responsibility for eliminating discrimination and providing equality of opportunity lies with managers and supervisors, individuals at all levels have a responsibility to treat others with dignity and respect. The personal commitment of every employee to this policy and application of its principles are essential to eliminate discrimination and provide equality throughout the Company.


  • To create an environment in which individual differences and the contributions of individuals are recognised and valued.
  • Every employee, worker or self-employed contractor and learner is entitled to a working environment that promotes dignity and respect to all. No form of intimidation, bullying or harassment will be tolerated.
  • Training, development and progression opportunities are available to all.
  • Equality in the workplace is good management practice and makes sound business sense.
  • We will review all our employment practices and procedures to ensure fairness.
    • We aim to provide services to which all clients are entitled regardless of age, disability, gender reassignment, marriage and civil partnership, pregnancy or maternity, race, religion or belief, sex or sexual orientation, offending past, caring responsibilities or social class.
  • We will make sure that our services are delivered equally and meet the diverse needs of our service users and clients by assessing and meeting the diverse needs of our clients.
  • This policy is fully supported by senior management and has been agreed with employee representatives.
  • This policy will be monitored and reviewed annually.
  • We have clear procedures that enable our clients, candidates for jobs and employees to raise a grievance or make a complaint if they feel they have been unfairly treated.
  • Breaches of our equality and diversity policy will be regarded as misconduct and could lead to disciplinary proceedings.
  • We will communicate and engage with all employers regularly via phone and email communication to make sure all apprentices are treated fairly.


We will:

  • ensure that people of all ages are treated with respect and dignity;
  • ensure that people of working age are given equal access to our employment, training, development and promotion opportunities; and
  • challenge discriminatory assumptions about younger and older people.


We will:

  • provide any reasonable adjustments to ensure disabled people have access to our services and employment opportunities;
  • challenge discriminatory assumptions about disabled people; and
  • seek to continue to improve access to information by ensuring availability of loop systems, braille facilities, alternative formatting and sign language interpretation.


We will:

  • challenge racism wherever it occurs;
  • respond swiftly and sensitively to racists incidents; and
  • actively promote race equality in the Company.


We will:

  • challenge discriminatory assumptions about women and men;


We will:

  • Challenge discriminatory assumptions about women and men
  • take positive action to redress the negative effects of discrimination against women and men;
  • offer equal access for women and men to representation, services, employment, training and pay and encourage other organisations to do the same


We will:

  • ensure that we take account of the needs of lesbians, gay men and bisexuals; and
  • promote positive images of lesbians, gay men and bisexuals.


We will:

  • ensure that employees’ religion or beliefs and related observances are respected and accommodated wherever possible; and
  • respect people’s beliefs where the expression of those beliefs does not impinge on the legitimate rights of others.


We will:

  • Ensure that people are treated with respect and dignity and that a positive image is promoted regardless of pregnancy or maternity;
  • challenge discriminatory assumptions about the pregnancy or maternity of our employees; and
  • ensure that no individual is disadvantaged and that we take account of the needs of our employees’ pregnancy or maternity.


We will:

  • Ensure that people are treated with respect and dignity and that a positive image is promoted regardless of marriage or civil partnership;
  • challenge discriminatory assumptions about the marriage or civil partnership of our employees; and
  • ensure that no individual is disadvantaged and that we take account the needs of our employees’ marriage or civil partnership.


We will:

  • prevent discrimination against our employees regardless of their offending background (except where there is a known risk to children or vulnerable adults).

EQUAL PAY                                                       

We will:

  • ensure that all employees, male or female, have the right to the same contractual pay and benefits for carrying out the same work, work rated as equivalent work or work of equal value. All staff salaries are reviewed annually in line with the staff annual reviews. A pay rise is not guaranteed however all cases will be reviewed.
  • All Staff have responsibilities to eliminate discrimination on grounds of race, gender, disability or any of the protected characteristics. Staff are responsible for ensuring that they are aware of the statutory duties in relation to legislation.
  • Their schemes of work, lesson content and teaching resources demonstrate sensitivity to issues of equality and diversity.
  • They Challenge inappropriate behaviour by either apprentices, employers or other members of staff.
  • Apprentices also have a role and responsibility to comply with policies
  • Apprentices will be made aware of Harriet Ellis Training ltd policies at induction, through publicity and events, and through embedding of Equality and Diversity in teaching and learning.
  • Apprentices should treat all other staff, colleagues and other apprentices with respect and dignity.
  • Apprentices must show respect for other people’s cultural traditions and religious beliefs
  • Apprentices should report any incidents of discrimination, harassment or bullying using the complaints procedure.


This Policy will be reviewed annually and agreed by the Managing Director

Version 6 February 2024


The purpose of this document is to promote a professional and positive approach from all learners and to assist Harriet Ellis in the decision of whether a student is fit to practise and undertake the relevant qualification. As a Centre, delivering a professional and registerable qualification, Harriet Ellis will support and implement the GDC Fitness to Practise policy. Learners must demonstrate during their education and training that they have the knowledge, skills and attitudes expected of a registered dental care professional. All learners should read the ‘Standards for dental professionals and General Dental Council Fitness to Practise document



Before a qualification may be started there are requirements that must be met to allow a learner to progress and commence a qualification.

The Dental organisation placing a learner onto a training programme must ensure that the learner has met the requirements of a Trainee Dental Nurse and is fully supported by the practice to achieve the qualification route they have selected. In addition a GDC registered mentor is in place within the workplace to support the learner to achieve the qualification aim and that practical elements of training are given alongside the delivery of the qualification by the provider.

The mentor should be available to support the learner and discuss problems/challenges in a supportive and confidential environment. It may be appropriate to offer support to the learner alongside Fitness to Practice procedures and sanctions.

When Fitness to practise concerns are identified anyone supporting the learner i.e. Mentor would be required to inform the appropriate person if there is a reasonable belief that the issue raises, or will raise, Fitness to Practise concerns or poses a risk to colleagues, patients, or the public.

Should a Fitness to practise concern progress to the next stage, (sanction stage 2) the Mentor or person supporting the learner may not be involved in the decision by the organization/ Training Provider to proceed with a Fitness to Practise investigation.


Once a concern has been raised and documented the Internal Management Team at Harriet Ellis will decide if there is a case to answer and whether to proceed to the next stage of a Fitness to Practise procedure.

All discussions, evidence, reports, paperwork and anything relevant to the investigation process will be documented and recorded formally.

The Management Team will at all times keep in mind the balance between patient safety and the interests of the student. Mitigating factors will be considered by the Management Team when deciding on the appropriate outcome. All decisions should be taken in light of any guidance set by the GDC and should be consistent with the regulations and procedures maintained by the Harriet Ellis, Award Bodies and Funding Organisations. Harriet Ellis has a formal Appeals Procedure and Disciplinary procedure.


Possible outcomes of a hearing include

  1. a) learner receives no warning or sanction;
  2. b) learner receives a written warning where there is evidence of misconduct but it is assessed that the learners Fitness to Practice is not impaired and does not require any of the sanctions listed below;
  3. c) The learners Fitness to Practice is judged to be impaired and they receive a sanction.

Beginning with the least severe, the sanctions are;

Conditions or undertakings

Suspension from dental course

Expulsion from dental course

LEARNERS SHOULD BE AWARE that when applying for registration they have a duty and responsibility regarding disclosure when completing the GDC declaration regarding Fitness to Practise and must declare the outcome of any previous formal hearings.

Warnings and sanctions will remain on a learner’s record for the duration of the learner’s qualification.

There is an obligation on providers to ensure that the pre-qualification requirements are met, however it is the responsibility of the Learner to provide honest and truthful information at all times.

ASAT will monitor the principles set out in Standards for Dental Professionals’ and ensure that learners behaviour does not fall beneath the expected standards required. Should a learner behaviour cause concern Harriet Ellis will consider if this amounts to a Fitness to Practise concern and whether these concerns warrant consideration through the formal procedure in place.


During the period that a student/learner is involved in a qualification the Provider has an obligation to ensure that all aspects of the student/learner’s fitness to practise are maintained. In some circumstances it may be necessary to invoke a disciplinary procedure to ensure that students/learners maintain focus and contribute to the quality and integrity of the learning programme.

Some examples of when the procedure may be invoked are below. The list is not exhaustive but illustrative of the types of concerns that could raise a question over fitness to practise.

  1. Students behaviour
  2. Disregard of patients /colleagues professional and clinical responsibilities
  3. Student’s health or impairment may compromise patient safety
  4. Student may have violated patient trust, autonomy or other rights.
  5. Student may have behaved dishonestly, fraudulently or in a way designed to mislead or harm others

The provider must also ensure that other areas of the learner’s attitude to the qualification do not impair the progress or integrity of the qualification. Additional areas of concern are listed below and may invoke the disciplinary procedure.

  1. Criminal conviction
  2. Drug or alcohol misuse
  3. Aggressive, violent or threatening behaviour
  4. Uncommitted to the learning programme
  5. Neglect of admin
  6. Poor time management
  7. Non-attendance of pre-arranged meetings
  8. Cheating or plagiarising work
  9. Not producing set work on time
  10. Forging names or signatures
  11. Dishonesty or fraud
  12. Unprofessional behaviour
  13. Health concerns
  14. Not using revision tools for exams

Should it be necessary to invoke the disciplinary procedure regarding fitness to practise the type of concern would determine the process that would be invoked.

Initially the potential severity of the behaviour would determine the action taken. The remedial action may vary from a written caution, or warning, to suspension, or total expulsion from the learning programme. Records will be kept of all actions imposed by the Provider throughout the learning programme and no action will be taken without consulting with the Practice except in acute, exceptional circumstances.

Any sanction imposed by the Provider will have an appeal process. That process should be received by the Provider IN WRITING ONLY, stating the reasons for the appeal within 5 working days of any sanction being imposed on any student/learner.


STAGE 1: Verbal Warning or Written Warning

STAGE 2: Conditions for Improvement & Expectation

STAGE 3: Undertakings/Restrictions to Clinical Practice

STAGE 4: Suspension

STAGE 5: Dismissal

Version 3 – November 2023

Data Protection Policy


We may have to collect and use information about people with whom we provide training.  This personal information must be handled and dealt with properly, however it is collected, recorded and used, and whether it be on paper, in computer records or recorded by any other means.

We regard the lawful and correct treatment of personal information is very important to our successful operation and to maintaining confidence between us and those with whom we carry out business.  We will ensure that we treat personal information lawfully and correctly.

To this end we fully endorse and adhere to the principles of the General Data Protection Regulation (GDPR).

This policy applies to the processing of personal data in manual and electronic records kept by us in connection with our human resources function as described below. It also covers our response to any data breach and other rights under the GDPR.

This policy applies to the personal data of job applicants, apprentices, volunteers, placement students, workers. These are referred to in this policy as relevant individuals.


“Personal data” is information that relates to an identifiable person who can be directly or indirectly identified from that information, for example, a person’s name, identification number, location, online identifier. It can also include pseudonymised data.

“Special categories of personal data” is data which relates to an individual’s health, sex life, sexual orientation, race, ethnic origin, political opinion, religion, and trade union membership. It also includes genetic and biometric data (where used for ID purposes).

“Criminal offence data” is data which relates to an individual’s criminal convictions and offences.

“Data processing” is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.


Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:

  1. processing will be fair, lawful and transparent
  2. data be collected for specific, explicit, and legitimate purposes
  3. data collected will be adequate, relevant and limited to what is necessary for the purposes of processing
  4. data will be kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay
  5. data is not kept for longer than is necessary for its given purpose
  6. data will be processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures
  7. we will comply with the relevant GDPR procedures for international transferring of personal data

We keep several categories of personal data on our student in order to carry out effective and efficient processes. We keep this data in a file relating to each student and we also hold the data within our computer systems.

Specifically, we hold the following types of data:

  1. personal details such as name, address, phone numbers
  2. information gathered via the recruitment process such as that entered into a CV or included in a CV cover letter, references from former employers, details on your education and employment history etc
  3. medical or health information
  4. information relating to your employment

All of the above information is required for our processing activities


You have the following rights in relation to the personal data we hold on you:

  1. the right to be informed about the data we hold on you and what we do with it;
  2. the right of access to the data we hold on you. More information on this can be found in the section headed “Access to Data” below and in our separate policy on Subject Access Requests”;
  3. the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’;
  4. the right to have data deleted in certain circumstances. This is also known as ‘erasure’;
  5. the right to restrict the processing of the data;
  6. the right to transfer the data we hold on you to another party. This is also known as ‘portability’;
  7. the right to object to the inclusion of any information;
  8. the right to regulate any automated decision-making and profiling of personal data.

More information can be found on each of these rights in our separate policy on employee rights under GDPR.


In order to protect the personal data of relevant individuals, those within our business who must process data as part of their role have been made aware of our policies on data protection.

We have also appointed employees with responsibility for reviewing and auditing our data protection systems.



We acknowledge that processing may be only be carried out where a lawful basis for that processing exists and we have assigned a lawful basis against each processing activity.

Where no other lawful basis applies, we may seek to rely on the students consent in order to process data.

However, we recognise the high standard attached to its use. We understand that consent must be freely given, specific, informed and unambiguous. Where consent is to be sought, we will do so on a specific and individual basis where appropriate. Employees will be given clear instructions on the desired processing activity, informed of the consequences of their consent and of their clear right to withdraw consent at any time.


As stated above, students have a right to access the personal data that we hold on them. To exercise this right, students should make a Subject Access Request. We will comply with the request without delay, and within one month unless, in accordance with legislation, we decide that an extension is required. Those who make a request will be kept fully informed of any decision to extend the time limit.

No charge will be made for complying with a request unless the request is manifestly unfounded, excessive or repetitive, or unless a request is made for duplicate copies to be provided to parties other than the employee making the request. In these circumstances, a reasonable charge will be applied.

Further information on making a subject access request is contained in our Subject Access Request policy.


The Company may be required to disclose certain data/information to any person. The circumstances leading to such disclosures include:

– disabled individuals – whether any reasonable adjustments are required to assist them in relation to their training;

– individuals’ health data – to comply with health and safety or occupational health obligations towards the student;

These kinds of disclosures will only be made when strictly necessary for the purpose.


Hard copy personal information should be kept in a locked filing cabinet, drawer, or safe.

Employees are aware of their roles and responsibilities when their role involves the processing of data.  All employees are instructed to store files or written information of a confidential nature in a secure manner so that are only accessed by people who have a need and a right to access them and to ensure that screen locks are implemented on all PCs, laptops etc when unattended. No files or written information of a confidential nature are to be left where they can be read by unauthorised people.

Where data is computerised, it should be coded, encrypted or password protected both on a local hard drive and on a network drive that is regularly backed up. If a copy is kept on removable storage media, that media must itself be kept in a locked filing cabinet, drawer, or safe.

Students must always use the passwords provided to access the computer system and not abuse them by passing them on to people who should not have them.

Personal data relating to students should not be kept or transported on laptops, USB sticks, or similar devices, unless prior authorisation has been received. Where personal data is recorded on any such device it should be protected by:

  1. ensuring that data is recorded on such devices only where absolutely necessary.
  2. using an encrypted system — a folder should be created to store the files that need extra protection and all files created or moved to this folder should be automatically encrypted.
  3. ensuring that laptops or USB drives are not left where they can be stolen.

Failure to follow the Company’s rules on data security may be dealt with via the Company’s disciplinary procedure. Appropriate sanctions include dismissal with or without notice dependent on the severity of the failure.


Where we engage third parties to process data on our behalf, we will ensure, via a data processing agreement with the third party, that the third party takes such measures in order to maintain the Company’s commitment to protecting data.


The Company does not transfer personal data to any recipients outside of the EEA.


All data breaches will be recorded on our Data Breach Register. Where legally required, we will report a breach to the Information Commissioner within 72 hours of discovery. In addition, where legally required, we will inform the individual whose data was subject to breach.

More information on breach notification is available in our Breach Notification policy.


New employees must read and understand the policies on data protection as part of their induction.

All employees receive training covering basic information about confidentiality, data protection and the actions to take upon identifying a potential data breach.

The nominated data controller/auditors/protection officers for the Company are trained appropriately in their roles under the GDPR.

All employees who need to use the computer system are trained to protect individuals’ private data, to ensure data security, and to understand the consequences to them as individuals and the Company of any potential lapses and breaches of the Company’s policies and procedures.


The Company keeps records of its processing activities including the purpose for the processing and retention periods in its HR Data Record. These records will be kept up to date so that they reflect current processing activities.


Our appointed compliance officer in respect of our data protection activities is:

Hadley Silver

Version 4 – January 2023

Health and Safety Policy and Procedure

  1. General Statement
    • Harriet Ellis fully recognises the duties placed upon it under the Health and Safety at Work Act 1974 and all other relevant legislation. The company is committed to ensuring it at least complies with the minimum requirement and wherever reasonably practicable shall exceed them. It also recognises the obligation it has to others with regard to publicly funded training.
  • The company is committed to working with these partners to ensure a safe and healthy working environment. The company recognises the duties it has to not only its staff, but also to trainees, contractors, apprentices, visitors and any others who may be affected by its activities and shall adopt the principle of zero tolerance with regard to accident prevention. This principle is underpinned by the acceptance of the company that no accident at work is acceptable.
  • Harriet Ellis also recognises the position it holds within the Recruitment and Training Industry and as such is committed to the production of high-quality Health and Safety training materials.
  1. Policy Objectives


  • The company will:
  • Provide and maintain a safe, healthy working environment with safe access and outlets;
  • Ensure the safety of staff who are mobile workers or those who work from work.
  • Ensure that Apprentice employers understand and are committed to their responsibilities for the Health and Safety of their apprentices.
  • Provide all necessary safety devices, protective equipment and supervise their use.
  • Promote our policy to all staff and Apprentices regularly. All policies are stored on the internal system for staff and on the e portfolio system for apprentices.
  • Provide staff training regularly, to update and refresh on health and safety matters to enable the safe performance of work activities. This is also included in the induction process for all new staff.
  • Ensure staff are complying with the policy and procedures.
  • Maintain constant and continuing improvement in all aspects of safety, in particular by introducing and monitoring safety procedures.
  • Consult employees on matters relating to workplace health, safety and welfare, development and review of policy and procedures through safety management established within the company.
  • Communicate relevant Health and Safety information through Notice boards in the workplace and the internal e-mail.
  • Ensure all processes and systems of work are designed to take account of health and safety and are properly supervised at all times.
  • Ensure competent staff are appointed to assist us in meeting our statutory duties including, where appropriate, specialists from outside of the company
  • Ensure adequate facilities and arrangements will be maintained to enable employees to raise issues of health and safety
  • Ensure Apprentices are trained on Health & Safety during their induction / onboarding process.
  • Ensure all arrangements are brought to employees’ attention and are monitored and reviewed to ensure that they are effective.

2.2 Staff, contractors & freelance workers also have a duty to co-operate fully in the operation of this Policy by:

  • Co-operating with management to enable all statutory duties to be complied with
  • Working safely and efficiently, complying with any instruction, information & training in accordance with all procedures and statutory obligations.
  • Taking reasonable care of their own health and safety and the health and safety of others who may be affected by their acts or omissions
  • Familiarising themselves with the health and safety arrangements that apply to them and their work functions.
  • Immediately reporting incidents (including accidents, near misses, which have results in, or may lead to injury) to their line Manager.
  • Immediately reporting any incidents within the Dental Practice directly to the GDC if required.
  • Assisting with the investigation of accidents and aiding the introduction of measures to prevent a recurrence.
  1. Policy Implementation

3.1 The company has appointed David Martin as a responsible for Health & Safety who will ensure continual strategic direction with regard to health, safety and welfare in Harriet Ellis.

3.2 Harriet Ellis shall appoint local advisors competent in Health and Safety who will provide general advice on policy implementation.

3.3 The Health and Safety Officer shall maintain all safety records and ensure policies & processes are in place for its continual improvement.

3.4 Department Managers are responsible for implementation and operation of the safety management system in their departments and will be accountable to the Director responsible for Health and Safety.  Managers will be supported in this function by the Health and Safety Officer.

3.5 The Operational staff handbook which contains health and Safety information will give further guidance on arrangements for putting into effect this policy.

3.6 This policy shall be reviewed whenever circumstances require it such as changes to legislation or activities and at least annually.

3.7 This policy shall be issued to all new members of staff and be made available to all other interested parties.

This policy will be included in the induction of new staff.

  1. Fire and Evacuation Procedures

4.1 Harriet Ellis understands how dangerous a fire can be and will therefore take all reasonable action to ensure that fire is prevented and that in the event of such an event, staff, service users and visitors can be safely evacuated following the Evacuation Policy.

4.2 Harriet Ellis has trained Fire Marshalls throughout the company.

  1. Accidents and First Aid

5.1 Harriet Ellis understands the need of all accidents, incidents and ill health to be reported and adequate records kept to review and resolve any patterns that may be identified.

In the event of an accident or ill health whilst the apprentice is at their normal place of work whether undergoing apprenticeship training at the time or not, we would seek to be notified of such event and where required the details surrounding the accident or ill health. We would fully support the employer and the apprentice where required and or necessary. We would continue regular communication throughout the period of ill health or until the apprentice is recovered from any accident providing any information, advice and guidance along with support for both the apprentice and employer. In the event of a break in learning to cover any period of ill health or as a result of an accident; as and when the leaner and employer are ready for the return, we will assist in preparing both parties for this.

Any incidents that have been reported are logged on the Accident and Incident log on the Company T Drive and the Operations Manager must be informed of these.  A hard copy log is also available.  The Operations Manager will then decide whether any actions are to be taken to prevent further repeat incidents.

5.2 Harriet Ellis has trained First Aider’s within the business.

  1. Welfare and Wellbeing employees and learners

6.1 All staff within the organisation have a strong management team that will support them through their employment. Part of the management team is an experienced HR officer that is in contact with all employees on a regular basis by both phone and email communication.  The senior management team are also constantly communicating with staff both based in the office and those working remotely regarding their welfare and happiness within the role.

6.2 With the programmes being delivered remotely a large focus is on the learners and the contact that is had with them. The customer support teams are in regular contact with learners/employers regarding the programme. All assessors are also required to be contacting their learners on a fortnightly basis by phone for a welfare check. The welfare calls are designed to keep in regular contact with learners to ascertain their progress on the programme. Should a learner be unresponsive to the welfare calls then the employer will be contacted.

6.3 IT measures are put in place for both employees and learners. All staff members are reminded of the IT protocols and regular checks are carried out on their work devices.

Learners have specific teaching sessions for online safety and IT usage due to the remote learning style of the programme.

6.4 Any assessors that are carrying out observations for learners in their workplace are provided with masks, gloves and sanitiser for the safety of both themselves and others.

  1. Process for Identifying Health & Safety Matters

7.1 All Staff will be made aware through their induction and ongoing training of the following Health and Safety Process:

  • Record full details of Health & Safety incident, including dates, times and location of incident.
  • Email full report to David Martin with email headed – Health and Safety Matter.
  • David Martin will then log the incident on Health and Safety log.
  • All Health and Safety issues will be discussed during the Management Meeting for actions to be agreed.
  • David Martin will give advice on action to take.
  • Governing Bodies, such as the GDC will be notified if necessary.

Version 5 – January 2023

Malpractice and Maladministration Policy

(Note: pages 1-3 cover policy, pages 4-5 contain the procedure)

  1. Introduction

Harriet Ellis treats all cases of suspected malpractice very seriously and will investigate all suspected and reported incidents of possible malpractice. The purpose of this Policy and Procedure is to set out how allegations of malpractice in relation to all Harriet Ellis qualifications are dealt with. The scope of the policy is to provide:

  • A definition of malpractice
  • Examples of student and centre malpractice and maladministration;
  • Possible sanctions that may be imposed in cases of malpracti

The term ‘malpractice’ in this policy is used for both malpractice and maladministration.

For the purpose of this document ‘malpractice’ is defined as:

Any act, or failure to act, that threatens or compromises the integrity of the assessment process or the validity of Harriet Ellis qualifications and their certification. This includes maladministration and the failure to maintain appropriate records or systems, the deliberate falsification of records or documents for any reason connected to the award of Harriet Ellis qualifications, acts of plagiarism or other academic misconduct, and/or actions that compromise the reputation or authority of the awarding organisation or of Harriet Ellis, its centres, officers and employees.

Harriet Ellis will report all relevant cases of suspected malpractice to the awarding organisation, accepting that in certain circumstances may take action of its own.

Malpractice by students

Some examples of student malpractice are described below. These examples are not exhaustive and all incidents of suspected malpractice, whether or not described below, will be fully investigated, where there are sufficient grounds to do so.

  • Obtaining examination or assessment material without authorization.
  • Arranging for an individual other than the student to sit an assessment or to submit an assignment not undertaken by the student.
  • Impersonating another student to sit an assessment or to submit an assignment on their behalf.
  • Collaborating with another student or individual, by any means, to complete a coursework assignment or assessment, unless it has been clearly stated that such collaboration is perm
  • Damaging another student’s work.
  • Inclusion of inappropriate or offensive material in coursework assignments or assessment scripts.
  • Failure to comply with published awarding organisation guidance.
  • Disruptive behaviour or unacceptable conduct, including the use of offensive language, at head office, at the centre or assessment venue (including aggressive or offensive language or behaviour).
  • Producing, using or allowing the use of forged or falsified documentation, including but not limited to:
    • personal identification
    • supporting evidence provided for reasonable adjustment or special consideration applications and
  • Falsely obtaining, by any means, a certification.
  • Misrepresentation or plagiarism
  • Fraudulent claims for special consideration while studying.
  • Knowingly studying under a conflict of arrangement situation without notifying Harriet Ellis – such as being assessed by a family member, or studying with a family member

During time constrained assessment:

Possession of any materials not permitted in the assessment room, regardless of whether or not they are relevant to the assessment, or whether or not the student refers to them during the assessment process, for example notes, blank paper, electronic devices including mobile phones, smart watches, personal organisers, books, dictionaries / calculators (when prohibited).


Communicating in any form, for example verbally or electronically, with other students in the assessment room when it is prohibited.

Copying the work of another student or knowingly allowing another student to copy from their own work.

Failure to comply with instructions given by the assessment invigilator, i.e., working beyond the allocated time; refusing to hand in assessment script / paper when requested; not adhering to warnings relating to conduct during the assessment.

Malpractice by centre employees and stakeholders

Examples of malpractice by, teachers, tutors and other officers, invigilators and examination administrators are listed below. These examples are not exhaustive and all incidents of suspected malpractice, whether or not described below, will be fully investigated, where there are sufficient grounds to do so.

  • Failure to adhere to the relevant guidance and procedures, including those relating to centre approval
  • Knowingly allowing an individual to impersonate a student.
  • Allowing a student to copy another student’s assignment work, or allowing a student to let their own work be copied.
  • Allowing students to work collaboratively during an assignment assessment, unless specified in the assignment brief.
  • Completing an assessed assignment for a student or providing them with assistance beyond that ‘normally’ expected.
  • Damaging a student’s work.
  • Disruptive behaviour or unacceptable conduct, including the use of offensive language (including aggressive or offensive language or behaviour).
  • Allowing disruptive behaviour or unacceptable conduct at the centre to go unchallenged, for example, aggressive or offensive language or behaviour.
  • Divulging any information relating to student performance and / or results to anyone other than the student.
  • Producing, using or allowing the use of forged or falsified documentation, including but not limited to:
    • personal identification;
    • supporting evidence provided for reasonable adjustment or special
  • Failure to keep examination/test question papers, examination scripts or other assessment materials secure, before during or after an examination.
  • Allowing a student to possess and / or use material or electronic devices that are not permitted in the examination room
  • Allowing students to communicate by any means during an examination in breach of regulations.
  • Allowing a student to work beyond the allotted examination time.
  • Leaving students unsupervised during an examination.
  • Assisting or prompting candidates with the production of answers.
  • Knowingly teaching under a conflict of arrangement situation without notifying Harriet Ellis – such as assessing a family member.

Possible malpractice sanctions

Following an investigation, if a case of malpractice is upheld, Harriet Ellis may impose sanctions or other penalties on the individual(s) concerned. Where relevant we will report the matter to the awarding organisation. The awarding organisation may impose one or more sanctions upon the individual(s) concerned. Any sanctions imposed will reflect the seriousness of the malpractice that has occurred.

Listed below are examples of sanctions that may be applied to a student, or to a teacher, tutor, invigilator, examination administrators or other officers who have had a case of malpractice upheld against them. Please note that

-this list is not exhaustive and other sanctions may be applied on a case-by-case basis.

-where the malpractice affects examination performance, the awarding organisation may impose sanctions of its own.

Possible study centre sanctions that may be applied to students

  • A written warning about future conduc
  • Notification to an employer, regulator or the polic
  • Removal from the course.

Possible sanctions that may be applied to teachers, tutors invigilators, and other officers

  • A written warning about future conduct.
  • Imposition of special conditions for the future involvement of the individual(s) in the conduct, teaching, supervision or administration of students and/or examinations.
  • Informing any other organisation known to employ the individual in relation to the outcome of the case.


Reporting a suspected case of malpractice

This process applies to, teachers, tutors, invigilators students, examination officers and other centre staff and to any reporting of malpractice by a third party or individual who wishes to remain anonymous.

Any case of suspected malpractice should be reported in the first instance to Hadley Silver, Managing Director.

A written report should then be sent to the Hadley Silver, Managing Director, clearly identifying the factual information, including statements from other individuals involved and / or affected,  any evidence obtained, and the actions that have been taken in relation to the incident.

Suspected malpractice must be reported as soon as possible to the Managing Director and at the latest within two working days from its discovery. Where the suspected malpractice has taken place in a test situation, the incident be reported urgently and the appropriate steps taken as specified by the awarding organisation.

Wherever possible and provided other students are not disrupted by doing so, a student suspected of malpractice should be warned immediately that their actions may constitute malpractice, and that a report will be made to the centre.

In cases of suspected malpractice by centre teachers, tutors invigilators and other officers, and any reporting of malpractice by a third party or individual who wishes to remain anonymous, the report made to the Managing Director should include as much information as possible, including the following:

  • The date time and place the alleged malpractice took place, if known.
  • The name of the centre teacher/tutor, invigilator or other person(s) involved
  • A description of the suspected malpractice; and
  • Any available supporting evidence.

In cases of suspected malpractice reported by a third party, or an individual who wishes to remain anonymous, Harriet Ellis will take all reasonable steps to authenticate the reported information and to investigate the alleged malpractice.

Administering suspected cases of malpractice

Harriet Ellis will investigate each case of suspected or reported malpractice relating to the awarding organisation, to ascertain whether malpractice has occurred. The investigation will aim to establish the full facts and circumstances. We will promptly take all reasonable steps to prevent any adverse effect that may arise as a result of the malpractice, or to mitigate any adverse effect, as far as possible, and to correct it to ensure that any action necessary to maintain the integrity of the qualification and reputation is taken.

Harriet Ellis will acknowledge all reports of suspected malpractice within five working days. All of the parties involved in the case will then be contacted within 10 working days of receipt of the report detailing the suspected malpractice. We may contact other individuals who may be able to provide evidence relevant to the case.

The individual(s) concerned will be informed of the following:

  • That an investigation is going to take place, and the grounds for that investigation;
  • Details of all the relevant timescales, and dates, where known;
  • That they have a right to respond by providing a personal written response relating to the suspected malpractice (within 15 working days of the date of that letter);
  • That, if malpractice is considered proven, sanctions may be imposed either by Harriet Ellis or the awarding organisation, (see section below) reflecting the seriousness of the case;
  • That, if they are found guilty, they have the right to app
  • That Harriet Ellis has a duty to inform the awarding organisation and other relevant authorities / regulators, but only after time for the appeal has passed or the appeal process has been com This may also include informing the police if the law has been broken and to comply with any other appropriate legislation.

Where more than one individual is contacted regarding a case of suspected malpractice, for example in a case involving suspected collusion, we will contact each individual separately and will not reveal personal data to any third party unless necessary for the purpose of the investigation.

The individual has a right to appeal against a malpractice outcome if they believe that the policy or procedure has not been followed properly or has been implemented to their detriment.

Records of all malpractice cases and their outcomes are maintained by Harriet Ellis for a period of at least five years and are subject to regular monitoring and review.

Version 6 January 2023

Online Safety policy

ICT can offer many positive educational and social benefits to young people; however, unfortunately there are some dangers. As in any other area of life, young people and vulnerable adults may expose themselves to danger, whether knowingly or unknowingly, when using the internet and other technologies. Additionally, some young people may find themselves involved in activities, which are inappropriate, or possibly illegal.

Harriet Ellis recognises the benefits and opportunities, which new technologies offer to teaching, learning and work productivity. Our curriculum courses are delivered online as are opportunities for staff professional development training through our CPD courses. However, the accessibility, global nature of the internet and different technologies available mean that we are also aware of potential risks and challenges associated with such use.

Our approach is to implement appropriate safeguards within the organisation while supporting staff and learners to identify and manage risks independently, with confidence. We believe this can be achieved through a combination of security measures, training, guidance and implementation of our policies.

In furtherance of our duty to safeguard learners, and to satisfy our wider duty of care, we will do all we can to make our learners and staff stay safe online. This Online Safety policy should be read alongside other relevant college policies, including:

Safeguarding Policy

Prevent Strategy

Prevent Risk Assessment

Creation, Monitoring and Review

Our staff have contributed to the online safety policy. The designated Lead Safeguarding, Officer Siobhan Thomas, along with the Operations and Quality team oversee the Online Safety policy. It has been developed using national Online Safety guidance.

Scope of the Policy

This policy applies to all learners, staff and members of the College community who have access to IT systems and /or the Internet, both on premises and remotely. Any user of College IT systems must adhere to the ICT Facilities Access Regulations (IFAR) and this Online Safety policy.

This policy applies to all use of the internet and forms of electronic communications such as email, cloud computing, mobile technology, Bring Your Own Device (BYOD), social media sites and instant messaging.

Roles and Responsibilities

There are clear lines of responsibility for Online Safety within the College. All members of the College community are responsible for ensuring the Online Safety of themselves and others in College and on College related activities. Concerns should be reported immediately to our Safeguarding lead. When informed about an incident staff should take care not to guarantee confidentiality towards the individual that reported it or those involved.

Online Safety Coordinator

The Online Safety Coordinators are responsible for keeping up to date with new technologies and their use as well as attending relevant training. They will be expected to lead the Online Safety review process, provide updates to the Online Safety Policy when required, deliver staff/parent development/ training, record incidents, and liaise with the local authority and external agencies to promote Online Safety within the College community. The Online Safety Coordinators role is split between the Safeguarding Lead (Siobhan Thomas) Operations Manager (David Martin) & Quality Team (Halima Ilyas & Kirsty Springer)


Learners must act safely and responsibly at all times when using the internet and/or mobile technologies both in learning and social contexts, in adherence with Harriet Ellis policies. They must follow the reporting procedures where they are worried, concerned or where they believe an Online Safety incident has taken place involving them or another member of the college. Where an e-safety incident is reported to the College this matter will be dealt with very seriously. The College will act immediately to prevent, as far as reasonably possible, any harm or further harm occurring. If a learner wishes to report an incident, they can do so to their Tutor, Dental educationalist, DMT department, Safeguarding and Prevent Officer. Where a member of staff wishes to report an incident, they must contact their line manager as soon as possible. Following any incident, the college will review what has happened and decide on the most appropriate and proportionate course of action. Sanctions may be put in place; external agencies may be involved or the matter may be resolved internally depending on the seriousness of the incident. Serious incidents will be dealt with by senior management, in consultation with relevant parties.

Staff should encourage learners to use the World Wide Web and emerging technologies. However in doing so, care should be taken to judge the digital literacy of the learners and their ability to keep themselves safe.


All staff are expected to be vigilant with regard to Online Safety.

Teaching staff and Dental educationalists are expected to teach, guide and support learners to develop Online Safety skills, providing a model example to learners through embedded good practice with regard to topics including, though not limited to, cyber-bullying, sexting, online grooming, and malicious 3rd party applications.

Digital communication with learners must be professional at all times and in the main restricted to College systems/networks (Microsoft Outlook email, ProMonitor, ProPortal, Google Apps for Education, Txttools, Moodle).

Teaching staff are encouraged to utilise technology to aid their teaching and working practices. They are responsible for ensuring the high standards of professionalism laid out in this policy and its associated acceptable use policies are still maintained through weekly moderation.

External platforms not hosted by the College such as social media sites should not be used for individual friendships with learners.  Any breach by a member of staff of this policy that brings the College into disrepute will be dealt with via by the senior management team.



The College will do all it can to make sure the network is safe and secure. Every effort will be made to keep security software up to date. Appropriate security measures include the use of web and spam filtering, anti-virus/malware scanning, access controls, and firewalling, to prevent accidental or malicious access of college systems and information.

The Internet use for college staff is determined by management. Spot checks are carried out on staff computer history normally around every quarter. Log can be found on internal database. All staff are provided full information of the Email and Internet policies for the business within the employee handbook on the first day of employment. This is explained by a member of the management team during the induction process.


Harriet Ellis will ensure all users of technologies adhere to the standard of behaviour as set out in the ICT Facilities Access Regulations (IFAR) user agreement. The College will not tolerate any abuse of IT systems. Whether offline or online, communications by staff and learners should be courteous and respectful at all times.

Any reported incident of bullying, harassment or other unacceptable conduct will be treated seriously and in line with the college protocols and procedures.

When conduct is found to be unacceptable, the College will deal with the matter internally. Where conduct is considered illegal, the College will report the matter to the Police. Where a designated Safeguarding Officer judge’s abuse has occurred, or there is a potential for significant abuse to occur, actions detailed in the Safeguarding Policy and Procedures will be taken.

Use of Images, Video and personal Information

The use of images or photographs is popular in teaching and learning. This is encouraged where there is no breach copyright or other rights of another person, for example, image rights or rights associated with personal data. This includes images downloaded from the internet and those belonging to staff or learners. Most images and photos are likely to be protected by copyright and this means that a user will need the permission of the copyright owner(s) if they want to copy the image or share it on the internet.

Education and Training

With the current unlimited nature of internet access it is impossible for the College to eliminate all risks for staff and learners. It is our view therefore that the College should support staff and learners to stay safe online through proactive training and education so that individuals develop the necessary skills to be able to identify risks independently and manage them effectively. To this end, online general awareness raising training has been compiled for Online Safety and is mandated to all staff. Topics within this training include: awareness raising on cyber-bullying, cyber- grooming, cyber-stalking and personal online security. Awareness and skills training for learners is delivered through a variety of ways, details of which are in the self- assessment in.

Incidents and Response

When an Online Safety incident is reported to the College this matter will be dealt with very seriously. The College will act immediately to prevent, as far as reasonably possible, any harm or further harm occurring.

If a learner wishes to report an incident, they can do so in confidence via

Where a member of staff wishes to report an incident, they must contact their Line Manager or a senior staff member as soon as possible. Alternatively, they may also use the email address.

Following any incident, the College will review what has happened and decide on the most appropriate and proportionate course of action. Sanctions may be put in place; external agencies may be involved or the matter may be resolved internally depending on the seriousness of the incident. Serious incidents will be dealt with by Senior Management.

Feedback and Further Information

Harriet Ellis welcomes all constructive feedback on this and any other College policy to provide clearer direction and support. We will always consult with staff and learners regarding any major revision of the Online Safety Policy.

If you would like further information on Online Safety or wish to send us your comments on our Online Safety Policy then please contact our office on 01708776050.

Version 2 – October 2022

Plagiarism Policy


“Plagiarism is the process of taking another person’s work, ideas or words and using them as if they were your own” (Macmillan Dictionary)

Consequences Of Plagiarism

As an accredited training centre, Harriet Ellis Training Solutions will treat any act of plagiarism as extremely serious and will not endorse any such work produced by a student on our courses who has been found guilty of the act of copying the ideas, words or work of another student either with or without their prior knowledge.

Plagiarism includes copying or paraphrasing information taken directly from research sources, even if referencing is used. This includes electronic materials.

Should we evidence plagiarism within work submitted, this will be returned to the student for amendments.  No Tutor or Dental Educationalist will mark plagiarised work.

On the first occasion – your work will not be marked; you will receive feedback and you will be asked to rewrite the task and resubmit the work at an acceptable standard.

If your submitted work continues to show plagiarised work, you will receive a formal plagiarism warning. This will be a first and final formal warning. You will also be required to resubmit the work at an acceptable standard

If you continue to submit plagiarised work on or after a formal warning you will be terminated from the course. Any student found guilty of Plagiarism will not be put forward for assessment and will not be successful in completing the award. The Awarding organisation will then be informed of the situation concerning the student.

Version 4 January 2023


In accordance with the General Data Protection Regulation (GDPR), we have implemented this privacy notice to inform you, our Students / Apprentices, of the types of data we process about you. We also include within this notice the reasons for processing your data, the lawful basis that permits us to process it, how long we keep your data for and your rights regarding your data.

This notice applies to current and former Students / Apprentices.


Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:

  1. processing is fair, lawful and transparent
  2. data is collected for specific, explicit, and legitimate purposes
  3. data collected is adequate, relevant and limited to what is necessary for the purposes of processing
  4. data is kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay
  5. data is not kept for longer than is necessary for its given purpose
  6. data is processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures
  7. we comply with the relevant GDPR procedures for international transferring of personal data

We keep several categories of personal data on our Students / Apprentices in order to carry out effective and efficient processes. We keep this data in a personnel file relating to each Student / Apprentice and we also hold the data within our computer systems, for example, our data management system.
Specifically, we hold the following types of data:

  1. personal details such as name, address, phone numbers
  2. name and contact details of your next of kin
  3. your photograph / ID
  4. your gender, marital status, information of any disability you have or other medical information
  5. right to work documentation
  6. information on your race and religion for equality monitoring purposes
  7. information gathered via the recruitment process such as that entered into a CV or included in a CV cover letter
  8. references from former employers
  9. details on your education and employment history etc
  10. National Insurance numbers
  11. bank account details
  12. tax codes
  13. driving licence
  14. criminal convictions
  15. information relating to your employment with us, including:
    1. job title and job descriptions
    2. your salary
    3. your wider terms and conditions of employment
    4. details of formal and informal proceedings involving you such as letters of concern, disciplinary and grievance proceedings, your annual leave records, appraisal and performance information
    5. internal and external training modules undertaken
    6. information on time off from work including sickness absence, family related leave etc
  16. IT equipment use including telephones and internet access.

You provide several pieces of data to us directly during the recruitment period and subsequently upon the start of your course.
In some cases, we will collect data about you from third parties, such as employment agencies, former employers when gathering references or credit reference agencies.
Personal data is kept in files or within the Company’s IT systems.


The law on data protection allows us to process your data for certain reasons only. In the main, we process your data in order to comply with a legal requirement or in order to effectively manage the training agreement we have with you, including ensuring you are paid correctly.
The information below categorises the types of data processing we undertake and the lawful basis we rely on.

Activity requiring your data Lawful basis
Carry out the training agreement that we have entered into with you e.g. using your name, contact details, education history, information on any disciplinary, grievance procedures involving you Performance of the agreement
Carrying out checks in relation to your right to work in the UK Legal obligation
Making reasonable adjustments for disabled students Legal obligation Legal obligation
Making recruitment decisions in relation to both initial and subsequent employment e.g. promotion Our legitimate interests
Ensuring efficient administration of contractual benefits to you Our legitimate interests
Effectively monitoring both your conduct, including timekeeping and attendance, and your performance and to undertake procedures where necessary Our legitimate interests
Maintaining comprehensive up to date personnel records about you to ensure, amongst other things, effective correspondence can be achieved and appropriate contact points in the event of an emergency are maintained Our legitimate interests
Implementing grievance procedures Our legitimate interests
Assessing training needs Our legitimate interests
Implementing an effective sickness absence management system including monitoring the amount of leave and subsequent actions to be taken including the making of reasonable adjustments Our legitimate interests
Gaining expert medical opinion when making decisions about your fitness for study Our legitimate interests
Dealing with legal claims made against us Our legitimate interests
Preventing fraud Our legitimate interests

Special categories of data are data relating to your:

  1. health
  2. sex life
  3. sexual orientation
  4. race
  5. ethnic origin
  6. political opinion
  7. religion
  8. trade union membership
  9. genetic and biometric data

We carry out processing activities using special category data:

  1. for the purposes of equal opportunities monitoring
  2. to determine reasonable adjustments

Most commonly, we will process special categories of data when the following applies:

  1. you have given explicit consent to the processing
  2. we must process the data in order to carry out our legal obligations
  3. we must process data for reasons of substantial public interest
  4. you have already made the data public.

Your failure to provide us with data may mean that we are unable to fulfil our requirements for entering into a training agreement with you. This could include being unable to offer you training.


We will only collect criminal conviction data where it is appropriate given the nature of your role and where the law permits us. This data will usually be collected at the recruitment stage, however, may also be collected during your employment. We use criminal conviction data to determine your suitability, or your continued suitability for the role. We rely on the lawful basis of our legitimate interests to process this data.


Employees within our company who have responsibility for training, collection of payment and agreement benefits and the carrying out performance related procedures will have access to your data which is relevant to their function. All Apprentices / Students with such responsibility have been trained in ensuring data is processing in line with GDPR.

Data is shared with third parties for the following reasons:

  • For collection of payment.
  • For studying purposes & qualification purposes.
  • For employment purposes.

We may also share your data with third parties as part of a Company sale or restructure, or for other reasons to comply with a legal obligation upon us. We have a data processing agreement in place with such third parties to ensure data is not compromised. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.

We do not share your data with bodies outside of the European Economic Area.


We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such.


We only keep your data for as long as we need it for, which will be at least for the duration of your employment with us though in some cases we will keep your data for a period after your employment has ended. Some data retention periods are set by the law. Retention periods can vary depending on why we need your data, as set out below:

Record Recommended Retention Period
Application forms and interview notes Permanently
Assessments under health and safety regulations and records of consultations with safety representatives and committees Permanently
Money purchase details 6 years after transfer or value taken
Personnel files, training records (disciplinary records, working time records) Permanently

Automated decision making means making decision about you using no human involvement e.g. using computerised filtering equipment. No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.


You have the following rights in relation to the personal data we hold on you:

  1. the right to be informed about the data we hold on you and what we do with it;
  2. the right of access to the data we hold on you. More information on this can be found in the section headed “Access to Data” below and in our separate policy on Subject Access Requests”;
  3. the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’;
  4. the right to have data deleted in certain circumstances. This is also known as ‘erasure’;
  5. the right to restrict the processing of the data;
  6. the right to transfer the data we hold on you to another party. This is also known as ‘portability’;
  7. the right to object to the inclusion of any information;
  8. the right to regulate any automated decision-making and profiling of personal data.

More information can be found on each of these rights in our separate policy on employee rights under GDPR.


Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data.


If you think your data rights have been breached, you are able to raise a complaint with the Information Commissioner (ICO). You can contact the ICO at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF or by telephone on 0303 123 1113 (local rate) or 01625 545 745.


Our appointed compliance officer in respect of our data protection activities is:
Karen Purser

Safeguarding, Protection and Prevent Policy


Harriet Ellis Training Solutions makes a positive contribution to a strong and safe community and recognises the right of every individual to stay safe.

Harriet Ellis comes into contact with adults and young adults through their training courses, in the provision of the Level 3 and Level 4 Apprenticeship programmes. This is via distance learning but requires assessor visits.  Contact with apprentices will include email, go to meeting, skype, telephone & face to face contact.  The face-to-face contact will be with the trained Dental Educationalists, Assessors and Exam Invigilators only, who will hold relevant DBS checks.  Apprentices may have remote contact with IQA, EQA and programme lead. Apprentices will also have contact with an IEPA when they undergo End Point Assessment.

The general aim of this policy is to ensure that Harriet Ellis undertakes its responsibilities with regard to protection of its learners and staff and will respond to concerns appropriately. The policy establishes a framework to support staff in their practices and clarifies the organisation’s expectations.

In line with statutory guidance, all staff are required to read Part One of “Keeping Children safe in education”. All staff must confirm that they have been made fully aware of, and understand the contents of, the Safeguarding Policy and Procedures for Harriet Ellis Training Solutions during their induction & ongoing training which is signed & recorded on file.

Safeguarding is about embedding practices throughout the organisation to ensure the protection of our apprentices and adults at risk wherever possible. Harriet Ellis’s protection procedures are about responding to circumstances that arise where abuse may be suspected.

The specific aims of this policy, to include response to our Prevent Duty, therefore are

  • to provide protection for apprentices on programmes managed by Harriet Ellis to ensure their welfare and to ensure the welfare of our staff in the context of their ensuring the safeguarding and the protection of vulnerable groups.
  • to provide apprentices (and, as appropriate, their parents or carers), staff and all working on behalf of Harriet Ellis with the overarching principles that guide our approach to safeguarding and the protection of vulnerable groups.
  • to identify and support apprentices with potential vulnerabilities to all forms of abuse (including that of indoctrination),


The Designated Safeguarding Lead, Siobhan Thomas, is responsible for implementation of this policy as part of her role as Delivery Management Team Leader.

How we promote this policy

All staff receive details of our Safeguarding & Prevent Policy Process through their induction and will receive regular training that is documented as part of our Professional Development Process.  Our Policy and Process details are embedded in our Commitment Statement/Training Plan for all of our Apprentices and promoted throughout the delivery of our programme through reviews. This ensures that staff are wholly committed to this policy and further ensures that all our learners are protected.

Our Policies are available at all times on our website.

All of our Assessors / Dental Educationalists will be placed on Certified CPD training as part of our Process for Personal Development and the certificates will be filed on our HR system.

This policy will be reviewed annually by Siobhan Thomas, Safeguarding Lead Officer and Hadley Silver Managing Director.

This policy takes account of all relevant statutory guidance

  • Keeping Children Safe in Education” and “Working Together to Safeguard Children” (both revised in 2022)
  • the Equality Act (2015)
  • Ofsted’s requirements as detailed in “Inspecting safeguarding in early years, education and skills settings” (August 2022) with particular regard to Annex 4.
  • Counter terrorism and Security Act 2015
  • Prevent duty guidance: for further education institutions in England and Wales

Definitions relevant to this policy

For the purposes of this policy and associated procedures, children and young people are any persons under the age of 18 years. An Adult at Risk is defined by the Care Act 2014 as ’An adult at risk of abuse or neglect is defined as someone who has needs for care and support, who is experiencing or at risk of, abuse or neglect and as a result of their care needs – is unable to protect themselves.

This may include but not exclusive to a person who:

  • Is elderly and frail
  • Has a mental illness including dementia
  • Has a physical or sensory disability
  • Has a learning disability
  • Has a severe physical illness
  • Is a substance misuser
  • Is homeless

Abuse is a selfish act of oppression and injustice, exploitation and manipulation of power by those in a position of authority. Abuse can be caused by those inflicting harm or those who fail to act to prevent harm. Abuse is not restricted to any socio-economic group, gender or culture.

It can take a number of forms, including the following:

  • Physical abuse
  • Sexual abuse
  • Emotional abuse
  • Bullying
  • Neglect
  • Financial (or material) abuse

We include as Appendix B some of the more common indicators of abuse that a young person or adult at risk may show. This clear level of staff understanding further ensures the protection of our learners.

The Prevent Duty

Harriet Ellis is committed to helping & identifying the needs & vulnerabilities of individuals. In accordance with the Counter Terrorism and Security Act, Harriet Ellis Training Ltd has a responsibility to prevent people from being drawn into terrorism and participates fully in such work. Prevent is a strand of the Government counter terrorism strategy -CONTEST. The UK faces a range of terrorist threats. All the terrorist groups who pose a threat seek to radicalise and recruit people to their cause. The Prevent strategy seeks to:

  • Respond to the ideological challenge of terrorism and aspects of extremism, and the threat faced from those that promote these views.
  • Provide practical help to stop people from being drawn into terrorism and ensure they are given appropriate advice and support
  • Work with a wide range of sectors where there are risks of radicalisation which needs to be addressed, including education, criminal justice, faith, charities, the internet, social media and health.

As an organisation we are committed to promoting the welfare of individuals and keeping people safe.  All staff must be vigilant at all times and are trained to be able to recognise and respond to neglect and signs of abuse.  All staff know that they must act quickly if they suspect an individual is suffering or likely to suffer from harm.  We are aware that we have a legal responsibility to fulfil the prevent duty statement.

Standards of Good Practice  

To ensure that we meet our responsibilities to individuals, all staff will:

  • treat all individuals with respect
  • treat young people and adults as individuals
  • put the person’s welfare first
  • set a good example by conducting ourselves appropriately
  • involve people in decisions that affect them
  • encourage positive and safe behaviour among all
  • be a good listener
  • be alert to changes in people’s behaviour
  • recognise that challenging behaviour may be an indicator of abuse
  • maintain appropriate standards of conversation and interaction with and between young people and avoid the use of sexualised or derogatory language
  • be aware and sensitive of different cultures and different communities
  • share concerns immediately with the company Safeguarding Leads, Siobhan Thomas/David Martin in an email format marked “confidential”
  • always act in the best interests of an individual

Abuse of Trust

All staff understand that inappropriate behaviour is completely unacceptable.  In addition, staff must understand that, under the Sexual Offences Act 2003, it is an offence for a person over the age of 18 to have a sexual relationship with a person under the age of 18, where that person is in a position of trust, even if the relationship is consensual. This means that any sexual activity between a member of staff and an apprentice under 18 may be a criminal offence, even if that young person is over the age of consent.


Staff that are concerned about the conduct of a colleague or professional towards an apprentice have a duty to protect the welfare of an individual and report the behaviour immediately.  We appreciate that staff will be placed into an unsettling & difficult position if acting under our whistleblowing policy; however, they must remember their duty to respond and inform.

All concerns of poor practice or possible abuse by colleagues should be reported to the Designated Safeguarding Lead, Siobhan Thomas immediately. All staff, including freelanced staff (paid or unpaid) have a responsibility to follow the guidance laid out in this policy and related policies, and to pass on any welfare concerns using the required procedures.

We expect all staff (paid or unpaid) to promote good practice by being an excellent role model, contribute to discussions about safeguarding and to positively involve people in developing safe practices.

The scope of this Safeguarding Policy is broad ranging and in practice. It will be implemented via a range of policies and procedures and staff handbook within the organisation. These policies include:

  • Health & Safety Policy
  • Equality & Diversity Policy
  • Bullying & Harassment Policy
  • Data Protection Policy

Our Staff handbook includes:

  • Health & Safety
  • Whistleblowing
  • Capability Procedures
  • Personal Harassment and how these allegations will be managed

IT Usage

We believe it is essential for online safety guidance to be given to all staff and learners on a regular and meaningful basis. Online safety is embedded withing the college’s curriculum and we continually look for new opportunities to promote online safety.

As part of the curriculum all the below areas are covered.

  • Educating learners on the dangers of technologies that they will encounter.
  • Learners are aware of the relevant legislation when using the internet such as data protection.
  • Learners are made aware of the impact of online bullying and where they can go to seek help if needed. This includes parents, tutors or a staff member at their employment.
  • Learners are advised to be cautious about the information given to other sites for example users not being who they say they are.
  • Learners are explained the benefits of web filters being added to their software.
  • Every staff member from Harriet Ellis will have their own email account to use. This is to minimise the risk of receiving unsolicited or malicious emails.

Role of Staff and Volunteers

All staff and volunteers working on behalf of the organisation have a duty to promote the welfare and safety of adults at risk. Staff and volunteers may receive disclosures of abuse and observe adults who are at risk. This policy will enable staff/volunteers to make informed and confident responses to specific adult protection issues.

It is important that adults at risk are protected from abuse. All complaints, allegations or suspicions must be taken seriously.  The following procedure must be followed whenever an allegation of abuse is made or when there is a suspicion that an adult at risk has been abused.

Procedure where abuse is suspected

Promises of confidentiality must not be given as this may conflict with the need to ensure the safety and welfare of the individual.

A full record shall be made as soon as possible of the nature of the allegation and any other relevant information.  This must include information in relation to the date, the time, the place where the alleged abuse happened, your name and the names of others present, the name of the complainant and, where different, the name of the adult who it is alleged has been abused, the nature of the alleged abuse, a description of any injuries observed, the account which has been given of the allegation.

Any suspicion, allegation or incident of abuse must be reported to the Designated Safeguarding Lead or Senior Manager on that working day where possible.

The Safeguarding Lead shall telephone and report the matter to the appropriate safeguarding partners which include, but are not limited to The General Dental Council the Police and Social Services. A written record of the date and time of the report shall be made and the report must include the name and position of the person to whom the matter is reported. The telephone report must be confirmed in writing to the relevant local authority adult social services department within 24 hours.

The Role of the Designated Officer

The role of the designated officer is to deal with all instances involving adult and young adult protection that arise within the organisation. They will respond to all adult and young adult at risk protection concerns and enquiries.

The designated Safeguarding Lead for the organisation is Siobhan Thomas. Should you have any suspicions or concerns relating to Adult or Young Adult Protection, contact

Training will be provided, as appropriate, to ensure that staff are aware of these procedures. Specialist training is a requirement for the Safeguarding Lead and Senior Management and provided by Harriet Ellis.

Safe Recruitment

Harriet Ellis ensures safe recruitment through the following processes:

Job or role descriptions for all roles involving contact with children and / or vulnerable adults will contain reference to safeguarding responsibilities.

There are person specifications for roles which contain a statement on core competency with regard to child/ vulnerable adult protection/ safeguarding are included within all contracts offered.

Interviews are conducted according to equality & diversity principles and interview questions are based on the relevant job description and person specification and related to Safeguarding.

Disclosure and barring service (DBS) Management

The organisation commits resources to providing a Disclosure and Barring Service check on all staff whose roles involve regulated activity with children and /or adults at risk. DBS checks will be conducted for specific roles for all staff working with children and vulnerable adults. Portable/ carry over DBS checks from another employer will not be deemed to be sufficient unless the update service is current and can be verified. It is a criminal offence for individuals barred by the DBS to work or apply to work with children or vulnerable adults in a wide range of posts.

Harriet Ellis Training Solutions will ensure that their established staff and roles are regularly reviewed through the following:

A 3-year rolling programme of re-checking DBSs is in place for holders of all identified posts. Existing staff who transfer from a role which does not require a DBS check to one which involves contact with children / vulnerable adults will be subject to a DBS check.

No formal job offers are made until after checks for suitability are completed (including DBS where appropriate)

Harriet Ellis Training Solutions commits resources for induction, training of staff, effective communications and support mechanisms in relation to Safeguarding and Prevent Duty.


Staff receive comprehensive induction which includes familiarisation with this policy, the requirements of “Keeping Children Safe in education” and the Prevent Duty.


All staff who, through their role, are in contact with children and /or adults at risk will have access to safeguarding and Prevent Duty training at an appropriate level. The Designated Safeguarding Lead routinely communicates updates to staff by means of emails and verbal briefings. (See ‘Communications’ below)


We recognise that involvement in situations where there is risk or actual harm can be stressful for staff concerned. The mechanisms in place to support staff include:

Debriefing support for paid and unpaid staff so that they can reflect on the issues they have dealt with. This can be provided by the Lead IQA.

Seeking further support as appropriate e.g. access to counselling.

Staff who have initiated protection concerns will be contacted by line manager or Designated Safeguarding Lead within a timescale of one week.


Harriet Ellis uses the following mechanisms for enabling effective discussion of safeguarding issues between staff:

  • Team/Tutor meetings
  • Operation meetings
  • Board meetings
  • One to one meetings (formal or informal),
  • Clinical supervision


The safeguarding aspects that Harriet Ellis Monitor include:

Safe recruitment practices

  • DBS checks undertaken
  • References applied for new staff
  • Records made and kept of supervision sessions
  • Training – register and record of all staff training
  • Monitoring whether concerns are being reported and acted upon
  • Checking that policies are up to date and relevant
  • Reviewing the current reporting procedure in place
  • Presence and action of Designated Senior Manager responsible for Safeguarding is in post

Safeguarding Apprentices who are vulnerable to Extremism

Since 2010, when the Government published the Prevent Strategy, there has been an awareness of the specific need to safeguard all learners from violent extremism.  There have been several occasions both locally and nationally in which extremist groups have attempted to radicalise vulnerable children and young people to hold extreme views including views justifying political, religious, sexist or racist violence, or to steer them into a rigid and narrow ideology that is intolerant of diversity and leaves them vulnerable to future radicalisation.

We ensure apprentices and employees are resilient to extreme narratives – identify changes in behaviour of apprentices and employees. We do this by providing a curriculum which promotes, knowledge, skills and understanding including:

  • Embedding equality, diversity and inclusion including British Values
  • Promoting wider skills development such as social and emotional aspects of learning
  • Encouraging active citizenship and facilitating apprentices to accept responsibility for their behaviour, show initiative and understand how they can contribute positively to society

Harriet Ellis values freedom of speech and the expression of beliefs / ideology as fundamental rights underpinning our society’s values.  Apprentices and staff have the right to speak freely and voice their opinions.  However, freedom comes with responsibility and free speech that is designed to manipulate the vulnerable or that leads to violence and harm of others goes against the moral principles in which freedom of speech is valued.  Free speech is not an unqualified privilege; it is subject to laws and policies governing equality, human rights, community safety and community cohesion.

The current threat from terrorism in the United Kingdom may include the exploitation of vulnerable people, to involve them in terrorism or in activity in support of terrorism.  The normalisation of extreme views may also make children and young people vulnerable to future manipulation and exploitation. Harriet Ellis is clear that this exploitation and radicalisation should be viewed as a safeguarding concern.

Harriet Ellis seeks to protect its apprentices against the messages of all violent extremism including, but not restricted to, those linked to Islamist ideology, or to Far Right / Neo Nazi / White Supremacist ideology, Irish Nationalist and Loyalist paramilitary groups, and extremist Animal Rights movements.

Definitions of radicalisation and extremism, and indicators of vulnerability to radicalisation are in Appendix A.

Procedure concerns are raised

Harriet Ellis, like all other organisations, is required to identify a Prevent Single Point of Contact (SPOC) who will be the lead within the organisation for safeguarding in relation to protecting individuals from radicalisation and involvement in terrorism: this will normally be the Designated Safeguarding Lead.  The SPOC for Harriet Ellis is Siobhan Thomas.

When any member of staff has concerns that a person may be at risk of radicalisation or involvement in terrorism, they should speak with the Designated Safeguarding Lead. A safeguarding log is held securely on the server, password protected and only the safeguarding lead has access to.

Numerous factors can contribute to and influence the range of behaviours that are defined as violent extremism, but most young people do not become involved in extremist action.  For this reason, the appropriate interventions in any particular case may not have any specific connection to the threat of radicalisation, for example they may address mental health, relationship or drug/alcohol issues.

Safeguarding Apprentices who are vulnerable to Exploitation, Forced Marriage, Female Genital Mutilation or Trafficking

Our safeguarding policy through the organisation’s values, ethos and expectations policies provides the basic platform to ensure children, adults and young adults are given the support to respect themselves and others, stand up for themselves and protect each other.

Our organisation keeps itself up to date on the latest advice and guidance provided to assist in addressing specific vulnerabilities and forms of exploitation. Appendix A outlines the most common

Our staff are supported to recognise warning signs and symptoms in relation to vulnerabilities relating to radicalisation and extremism.

Our Designated Safeguarding Lead knows where to seek and get advice as necessary. She has made productive contacts with the local safeguarding partners, other support agencies, for example, for drug misuse, unplanned pregnancy and homelessness and is familiar with the work of the Child Exploitation and Online Protection service.

Appendix A


  1. Radicalisation refers to the process by which a person comes to support terrorism and forms of extremism leading to terrorism.
  2. Extremism is defined by the Government in the Prevent Strategy as:

Vocal or active opposition to fundamental British values, including democracy, the rule of law, individual liberty and mutual respect and tolerance of different faiths and beliefs.  We also include in our definition of extremism calls for the death of members of our armed forces, whether in this country or overseas.

  1. Extremism is defined by the Crown Prosecution Service as:

The demonstration of unacceptable behaviour by using any means or medium to express views which:

  • Encourage, justify or glorify terrorist violence in furtherance of particular beliefs;
  • Seek to provoke others to terrorist acts;
  • Encourage other serious criminal activity or seek to provoke others to serious criminal acts; or
  • Foster hatred which might lead to inter-community violence in the UK.
  1. There is no such thing as a “typical extremist”: those who become involved in extremist actions come from a range of backgrounds and experiences, and most individuals, even those who hold radical views, do not become involved in violent extremist activity.
  2. Apprentices may become susceptible to radicalisation through a range of social, personal and environmental factors – it is known that violent extremists exploit vulnerabilities in individuals to drive a wedge between them and their families and communities. It is vital that school staff are able to recognise those vulnerabilities.
  3. Indicators of vulnerability include:
  • Identity Crisis – the student / pupil is distanced from their cultural / religious heritage and experiences discomfort about their place in society;
  • Personal Crisis – the student / pupil may be experiencing family tensions; a sense of isolation; and low self-esteem; they may have dissociated from their existing friendship group and become involved with a new and different group of friends; they may be searching for answers to questions about identity, faith and belonging;
  • Personal Circumstances – migration; local community tensions; and events affecting the student / pupil’s country or region of origin may contribute to a sense of grievance that is triggered by personal experience of racism or discrimination or aspects of Government policy;
  • Unmet Aspirations – the student / pupil may have perceptions of injustice; a feeling of failure; rejection of civic life;
  • Experiences of Criminality – which may include involvement with criminal groups, imprisonment, and poor resettlement / reintegration;
  • Special Educational Need – students / pupils may experience difficulties with social interaction, empathy with others, understanding the consequences of their actions and awareness of the motivations of others.
  1. However, this list is not exhaustive, nor does it mean that all young people experiencing the above are at risk of radicalisation for the purposes of violent extremism.
  2. More critical risk factors could include:
  • Being in contact with extremist recruiters;
  • Accessing violent extremist websites, especially those with a social networking element;
  • Possessing or accessing violent extremist literature;
  • Using extremist narratives and a global ideology to explain personal disadvantage;
  • Justifying the use of violence to solve societal issues;
  • Joining or seeking to join extremist organisations; and
  • Significant changes to appearance and / or behaviour;
  • Experiencing a high level of social isolation resulting in issues of identity crisis and / or personal crisis.

Appendix B

Signs of Abuse – physical, psychological and behavioural

Signs of physical abuse might commonly include:

  • Bruises which are in places on the body where accidental bruising is unusual – particularly if symmetrical or in the shape of an object
  • Bites, burns and fractures without an explanation
  • Injuries inconsistent with the explanation given or where the account is inconsistent
  • Injuries which have not received medical attention, particularly repeated or frequent
  • Injury symptoms e.g. difficulty walking, lifting everyday objects, putting on clothing
  • Reluctance to seek medical help, avoidance of questioning or examination by a qualified person.

Non-physical signs

Abuse has psychological and behavioural impacts which might include:

  • Marked change in behaviour or emotional state not explained by a stressful event, such as a bereavement
  • Unexplained depression, denial, aggression or withdrawal, reports of nightmares
  • Reluctance to expose the body in any way – e.g. remove outer clothes in summer
  • Poor personal hygiene, unwashed or damaged clothing, lack of care of own appearance
  • Eating disorders, avoidance of food
  • Body rocking, self-harm

Abuse also has impacts upon relationships, communication and interactions with others which might commonly include:

  • Abnormal behaviour towards others – fear, withdrawal, lack of eye contact, extreme or subdued emotional reactions
  • Under-developed social relationships and lack of interaction with peer group
  • Low self-esteem, need to apologise for self, over-reaction to making mistakes
  • Repeated absence – avoiding events or appointments where personal welfare may be discussed.

Version 4 – September 2022

Whistleblowing policy

This document outlines Harriet Ellis Training & Recruitment Group policy and procedure for how an individual can confidentially and anonymously report concerns regarding the delivery of regulated qualifications and ESFA funded apprenticeships.

The policy will apply to the following:

  • Harriet Ellis staff
  • All staff of employers associated with any Harriet Ellis provision
  • Learners registered on qualifications
  • Apprentices
  • Members of the public who suspect malpractice or maladministration is taking place.

The purpose of this document is to:

  1. Outline in which instances an individual should inform Harriet Ellis of an allegation.
  2. Outline how an individual can confidentially report suspected malpractice to Harriet Ellis.
  3. Outline how Harriet Ellis will protect the interests and confidentiality of whistleblowers, wherever needed.
  4. Inform an individual how Harriet Ellis will respond to a whistleblowing allegation.

This policy is not applicable to individuals who wish to complain about a service provided by Harriet Ellis. Harriet Ellis has a separate policy for complaints that can be found on our website under our policies section.


Whistleblowing is a term used to describe when an individual discloses concerns or information relating to potential malpractice or maladministration. Malpractice or maladministration can be committed by a Centre staff member, a learner, an employer or another third party.

If an individual has concerns regarding the practices of a Harriet Ellis staff member or a Learner, they must first assess whether it would be appropriate to first report the concern to Harriet Ellis itself. If concerns are raised to Harriet Ellis and you are not satisfied that the concerns have been adequately investigated, or, that the issue is still occurring, you may wish to notify the awarding organisations, end point assessment organisations or ESFA directly and provide details of the action already taken.

There are a range of concerns that an individual may wish to be raise under the External Whistleblowing Policy, including, but not limited to:

  1. An individual suspects that Harriet Ellis or a Harriet Ellis staff member or a learner has committed, or is complicit with an instance of malpractice.
  2. An individual suspects that Harriet Ellis is not compliant with the Awarding Organisation, End Point Assessment Organisation or ESFA Approval Criteria.
  3. An individual suspects that Harriet Ellis or a Harriet Ellis staff member or a learner is involved in fraud or other illegal activity regarding qualifications or apprenticeships.
  4. An individual has been asked, or forced, to perform an activity that they believe constitutes as malpractice.

Allegations which do not count as Whistleblowing:

It is important to note that personal grievances (for example bullying, harassment and discrimination) or dissatisfaction with the service received from Harriet Ellis(such as concerns regarding fees or contractual disputes) are not covered by this policy. If an individual has a concern of this type, they should follow the Harriet Ellis complaints policy.

Whistleblowing does not apply to a learner making an appeal against Harriet Ellis or an assessment decision. Harriet Ellis has a full Appeals Policy.

Individuals must refrain from making unwarranted allegations to Harriet Ellis (i.e. if an individual does not believe their allegation to be true). If an allegation was not confirmed following a Harriet Ellis investigation to hold any validity however the individual who has made the allegation had reason to believe it was true no action will be taken against the individual. If, however, allegations are made by staff are deemed malicious or unfounded, Harriet Ellis may apply Sanctions against the individual or take legal action.

Confidentiality :

Harriet Ellis take all whistleblowing allegations seriously and will investigate disclosures in a sensitive and discreet manner.  Individuals who make disclosures can have their identity kept confidential upon request. Harriet Ellis understands the importance of confidentiality for whistleblowers and, where it has been requested, will aim to protect an individual’s anonymity, however this cannot be guaranteed.

It is important to note that Harriet Ellis may not be able to investigate a concern as effectively if an allegation is made to Harriet Ellis anonymously. Harriet Ellis encourages individuals to provide their name and contact details when raising their allegation, as we may need to contact the individual raising the concern for further information, or, to verify details provided throughout an investigation.

There may be instances where Harriet Ellis must reveal an individual’s details, such as, if required to do so by law. Once an investigation into the allegations commences, individuals should also consider that they may be identifiable due to the nature, or content of, their allegations.


Identifying Malpractice:

In the first instance, where an individual suspects malpractice, they must first report it to the Harriet Ellis Operations Manager, where it is appropriate to do so. Harriet Ellis will investigate and respond to all concerns, as well as reporting all cases of suspected malpractice to the relevant external body.

Harriet Ellis understands that it may not always be appropriate for an individual to report a concern directly to us. In these cases, individuals should raise their concerns directly with the external body for their investigation. Examples where this may be applicable include, but may not be limited to:

  1. The individual(s) who handles incidents of malpractice within Harriet Ellis is involved, or may be complicit, with the incident.
  2. The individual raising the concern believes that they may be victimised by raising their concerns to Harriet Ellis or an individual.
  3. The individual raising the concern believes that the Harriet Ellis internal policy for dealing with cases of malpractice or maladministration is not being, or may not be followed.
  4. The individual raising the concern believes that once the incident has been reported it will not be dealt with correctly and/or may be covered up by Harriet Ellis or the individual involved.

Making an Allegation to Harriet Ellis

If an individual wishes to raise an allegation of malpractice to Harriet Ellis, they must contact the Operations Manager by either email, telephone or by letter. The contact details can be found below. Harriet Ellis would encourage an individual to notify them of their concerns as soon as possible, to minimise the loss of information over time and to make it easier for Harriet Ellis to investigate the allegation.

Contact details for reporting Whistleblowing:

Telephone number:01708776050

Contact person: Operations Manager


If an allegation is made by telephone, individuals may be asked to produce a written statement as supporting evidence. The name of the individual will be redacted from statements, upon the individual’s request.

Although whistleblowers are not expected to prove an allegation, they will need to demonstrate that there is sufficient grounds for their concerns in order for Harriet Ellis to investigate. Therefore, whistleblowers should aim to provide as much information as possible regarding their concern. This includes, but is not limited to:

  1. The background and history to the allegation.
  2. Any specific details available including names, dates, times and places.
  3. Details of any evidence which supports the concern.
  4. Full details of the allegations, including the Harriet Ellis provision which is involved.
  5. The individual’s involvement, response and any personal interest they may have in the matter (if applicable).
  6. How they think that things may be put right, if possible.

If, following receipt of an allegation, it is identified that the allegation was against an employer with whom Harriet Ellis works, the allegation will be passed onto the employer, who will follow their own whistleblowing procedure.

How Harriet Ellis Will Respond

Once an allegation is made, the Operations Manager will contact the individual who made the allegation within 7 working days to:

  1. Confirm that the allegation has been received.
  2. Indicate whether or not Harriet Ellis will be investigating the matter or not.
  3. Request any further information which is required from the individual regarding the matter.

Initial enquires will be made to decide whether the allegation requires an investigation, and if so, in what form. If an investigation is required, the Operations Manager will conduct this in line with the Malpractice and Maladministration Policy.  The Harriet Ellis  Managing Director will be notified of all allegations received.

Harriet Ellis is not required to release the outcomes of its investigations to individuals who raise allegations.

In cases of proven malpractice, Harriet Ellis will notify the relevant Awarding Organisation, End Point Assessment Organisation or Funding Bodies of the instigation and outcomes of the investigation.

Version 3 October 2022

Version 3 October 22