Policies & Procedures

Qualifications Scotland

Version 17 April 2026

Contents

Section 1 – Management of a Centre

1.1 Policies and Procedures must be documented and reviewed to ensure full compliance with the QS quality criteria.

The EWA Policies and Procedures will be reviewed annually as a matter of course. If there were to be any amendments / improvements / adaptations due to the nature of a complaint or as a natural progression due to our continuous feedback and development, the Policies and Procedures would be checked and updated if necessary.

Each time an amendment is made on the Policies and Procedures a new version number will be allocated to the Policies and Procedures, which will, demonstrated as a footer. There will be a version control document, which will record all changes and the date of each new version.

All changes, reviews and updated versions will be distributed to all staff who must acknowledge in writing they have received and understood the changes.

It is the responsibility of the EWA Manager, Kirsty McKerrow, to review, update, control and disseminate documents relating to quality assurance of QS qualifications.

Our policies and procedures are designed to apply consistently across all awarding bodies with which we work. Where generic processes are sufficient, these are expressed in broad terms to ensure compliance with the requirements of multiple awarding organisations. Where QS has specific quality assurance requirements, these are identified clearly within the relevant policy or procedure to ensure full compliance. All policies and procedures are subject to regular review to maintain alignment with both QS and other awarding body standards.

1.2 Policies and Procedures must be endorsed by senior management and disseminated to relevant staff

The EWA senior management consists of the manager, Kirsty McKerrow. She fully endorses the Policies and Procedures as well as their continuous review and relevancy.

Kirsty takes responsibility to ensure that all relevant staff are kept informed of any amendments and more recent versions of the P&P. Written confirmation from each staff member confirming they have received and understood the changes will be required and kept on file.

1.3 Notification of changes

The responsibility for notifying the QS of any and all changes relating to the following is the duty of Kirsty McKerrow. She would report directly to her SQA contact, providing detailed information about the relevant changes.

The Edinburgh Whisky Academy recognises that some changes may require further co-operation with the QS in order to ensure the centre’s Quality Assurance Criteria is still being met.

Change of premises;

Change of head of centre/owner/SQA coordinator;

Change of name of centre or business;

Change of contact details;

Outcome of internal/external investigations;

Any change to centre arrangements for safe storage of Assessment papers;

Lack of appropriate assessors or internal verifiers.

Changes to assessors or internal verifiers

Suspected centre malpractice, as well as any confirmed findings of malpractice or maladministration communicated to us by another awarding or industry body.

1.4 Roles and responsibility

QS Co-coordinator - Kirsty McKerrow

All functions of the QS Co-coordinator are to be carried out by Kirsty McKerrow. This involves the following responsibilities:

The first point of contact between the centre, QS and students;

To continually review and maintain that the necessary policies and procedures are in place to support the quality assurance process;

To maintain all documentation is standardised and everyone is using the most current version;

To regularly review and update all policies and procedures in line with current QS guidance and any centre decisions;

To facilitate regular meetings (every 3 months) for internal verifiers and assessors. In doing so this role supports the best practice for sharing between the assessors and internal verifiers;

To be the key liaison between QS Quality Assurance staff and assessors/internal verifiers and to circulate the subsequent quality assurance reports to the appropriate personnel;

Management of QS external quality assurance to ensure the EWA compliance with QS Quality Assurance Criteria;

To ensure that any required actions and development points identified in the quality assurance report are communicated to all staff and implemented accordingly;

To process and submit to the QS, all data passed on by internal verifiers and assessors, in line with the Academy data management policy;

To check the Scottish Candidate Number of new candidates and register those with no number;

To maintain a current and compliant data management policy

To notify the QS of any changes which may affect the Academy’s ability to meet their criteria.

Internal Verifier – Kirsty McKerrow

All responsibilities relating to the role of the Internal Verifier are to be carried out by Kirsty McKerrow. These roles include the following:

To facilitate meetings every 3 months with the assessors and to offer support where necessary;

To sample assessment evidence according to the internal verification policy;

To assist assessors in the standardization of assessment evidence and sharing of best practice;

To countersign evidence as confirmation of verification;

To complete internal verification reports and summary sheets;

To contribute to the review and development of the EWA’s policies, procedures, learning and assessment material and resources;

To participate in any assessment appeal as indicated in the EWA appeals procedure;

To participate in any complaint as indicated in the EWA complaints procedure.

Assessor – Diploma in Single Malt Whisky – Vic Cameron/Joe Cabassa/ Yigit Akdemir/Louis Lee

All responsibilities relating to the role of the Assessor are to be carried out by Vic Cameron, Joe Cabassa, Yigit Akdemir, Louis Lee. These roles include the following:

To undertake candidate induction and ensure that the correct paperwork is completed;

To support the candidate through the qualification;

To provide remediation and re-assessment for candidates where necessary;

To identify and support candidates who require assessment arrangements;

To discuss candidate assessment arrangements with colleagues to ensure a standardised approach;

To attend and participate in standardisation meetings;

To contribute to and help develop the EWA’s review of policies, procedures, learning and assessment material and resources;

To participate in any assessment appeal as indicated in the EWA appeals procedure;

To participate in any complaint as indicated in the EWA complaints procedure;

To attend and participate in any visits by QS quality assurance staff as required;

To be aware of the risk of malpractice and act accordingly to EWA procedure.

Assessor – Diploma in Gin – Geraldine Coates (until further notice this qualification is dormant)

All responsibilities relating to the role of the Assessor are to be carried out by Geraldine Coates. These roles include the following:

To undertake candidate induction and ensure that the correct paperwork is completed;

To support the candidate through the qualification;

To provide remediation and re-assessment for candidates where necessary;

To identify and support candidates who require assessment arrangements;

To discuss candidate assessment arrangements with colleagues to ensure a standardised approach;

To attend and participate in standardisation meetings;

To contribute to and help develop the EWA’s review of policies, procedures, learning and assessment material and resources;

To participate in any assessment appeal as indicated in the EWA appeals procedure;

To participate in any complaint as indicated in the EWA complaints procedure;

To attend and participate in any visits by QS quality assurance staff as required;

To be aware of the risk of malpractice and act accordingly to EWA procedure.

Assessor – Diploma in the Art of Tasting Whisky – Gordon Steele (until further notice this Diploma is dormant)

All responsibilities relating to the role of the Assessor are to be carried out by Gordon Steele. These roles include the following:

To undertake candidate induction and ensure that the correct paperwork is completed;

To support the candidate through the qualification;

To provide remediation and re-assessment for candidates where necessary;

To identify and support candidates who require assessment arrangements;

To discuss candidate assessment arrangements with colleagues to ensure a standardised approach;

To attend and participate in standardisation meetings;

To contribute to and help develop the EWA’s review of policies, procedures, learning and assessment material and resources;

To participate in any assessment appeal as indicated in the EWA appeals procedure;

To participate in any complaint as indicated in the EWA complaints procedure;

To attend and participate in any visits by QS quality assurance staff as required;

To be aware of the risk of malpractice and act accordingly to EWA procedure.

3rd party partners

The Certificate in Scotch Whisky is delivered via a Learning Management System. It can also be taught face to face with certain providers. In this instance all material, both teacher transcript and candidate PP/workbook will be provided by the EWA. No changes to the material can be made without the authority of Kirsty McKerrow, thus ensuring the quality assurance of the material. This course is assessed online and procedures are in line with upholding the QS Code of Practice to ensure quality assurance.

The responsibility of these education providers are as follows:

To undertake candidate induction and ensure that the correct paperwork is completed;

To support the candidate through the qualification;

To provide remediation and re-assessment for candidates where necessary;

To identify and support candidates who require assessment arrangements;

To use learning material provided by EWA.

Course content and material is not to be altered or edited and modules should be taught in order.

Any teacher filling this role will be required to fill in the Staff Supporting Document and keep on file for the EV visit.

All teachers must have completed the Diploma in Single Malt Whisky and the Education Providers course.

1.5 Malpractice policy and procedures

Our centre will fully cooperate with any investigation conducted by QS, and promptly implement any corrective actions determined necessary by QS, unless such actions are successfully appealed. Additionally, we recognise the potential role of artificial intelligence-related activities in malpractice risks. Our malpractice policy explicitly addresses the misuse or inappropriate use of AI tools by staff or candidates, defining safeguards, detection measures, and response protocols to uphold the integrity of assessments.

Candidate malpractice

QS definition

Malpractice means any act, default or practice (whether deliberate or resulting from neglect or default) which is a breach of QS requirements including any act, default or practice which:

compromises, attempts to compromise or may compromise, the process of assessment, the integrity of any QS qualification, or the validity of a result or certificate; and/or

damages the authority, reputation or credibility of QS or any officer, employee or agent of QS.

Malpractice can arise for a variety of reasons:

Some incidents are intentional and aim to give an unfair advantage or disadvantage in an examination or assessment (deliberate non-compliance). Examples might include:

failure to carry out adequate/published internal quality assurance arrangements;

completing assessment work on behalf of learners; or

falsification of information leading to certification.

We define maladministration as including incidents that arise due to ignorance of QS requirements, carelessness or neglect in applying the requirements. Examples might include:

seeking approval to offer a new qualification after the deadline for new approval applications has passed; or

requesting late certification of learners after a regulated qualification’s certification end date.

Malpractice can include both maladministration in the assessment and delivery of QS qualifications and deliberate non-compliance with SQA requirements.

Whether intentional or not, it is necessary to investigate any suspected instances of malpractice, to protect the integrity of the qualification and to identify any wider lessons to be learned.

Where QS becomes aware of concerns of possible malpractice, its approach will be fair, robust and proportionate to the nature of the concern. These procedures will be applied where QS’s view is that there is a risk to the integrity of certification, which is not being successfully managed through our regular processes.

Procedures must include:

Reporting

Investigation

Sanctions

Actions

Appeals

Record-keeping

Retention of records of all investigations of malpractice to be provided to the SQA on request

Any suspected cases of centre malpractice must be reported to QS as soon as we have carried out an initial screening exercise to establish the nature of the concern. This includes any concerns where we take the view that no further action is necessary. ‘We must inform QS of any investigation carried out by an awarding body, industry body, funding agency or regulator which may or may not affect our delivery of SQA qualifications. We must also promptly bring to QS’s attention any findings of centre malpractice or maladministration communicated to us by another awarding or industry body. We must notify QS promptly if another awarding body removes approval from our centre, regardless of the reason given for this withdrawal. ‘QS expects us to bring candidate malpractice concerns for internal assessments to their attention only if:

the concern came to our centre’s attention after submission of internal assessment marks
the concern relates to candidate malpractice for a qualification regulated by QS Accreditation, Ofqual or Qualifications Wales
a candidate affected by a malpractice decision, who has exhausted their right of appeal within our centre, wishes to exercise their right of appeal to QS; or
there are other exceptional circumstances, eg we believe that the malpractice case involves a criminal act (if the malpractice involves a criminal act the matter must also be reported to the police)

Candidate Malpractice relates to any students who collude with others during an individual assessment, copy answers from another candidate, personate, display inappropriate behaviour – abusive, disruptive or aggressive behaviour, use unauthorised aids (mobile phone, notes, iPads etc.) during the internal assessment or include inappropriate material (obscenities, discriminatory, offensive or obscene) with their assessment paper. Please note that candidates are allowed to use their translation tool on their phone during the assessment.

Any student suspecting malpractice from another student can report their concerns in confidence to Vic Cameron, Gordon Steele, Joe Cabassa, Yigit Akdemir, Louis Lee.

Any member of staff suspecting malpractice from a student can report their concerns in confidence to Vic Cameron, Gordon Steele, Joe Cabassa, Yigit Akdemir, Louis Lee or Kirsty McKerrow.

Any candidates suspected of committing one or more of the offences above will have their paper confiscated and will be interviewed regarding the alleged offence. A further meeting will be held with the assessor and in liaison with the QS a decision will be made as to the offence. Kirsty McKerrow (EWA) and the QS liaison officer will hear any appeal from the candidate.

If the appeal is upheld the candidate will be invited to attend the next available course and re-take the exam.

If the candidate is found guilty of malpractice their paper will be destroyed and they will forfeit the right to any refund for the course. Their attendance on any future course would be welcomed within the guidelines of the Edinburgh Whisky Academy Policies and Procedures.

Centre malpractice

This includes maladministration and non-compliance in breach of the QS requirements. Any act which comprises or attempts to comprise the integrity of any QS qualification or the validity of the certificate status and/or damages the reputation, authority or credibility of the QS or any employee of the QS.

Examples of the above include:

Misuse of assessments;

Insecure storage of assessment instruments and marking guidance;

Failure to comply with requirements for accurate and safe retention of candidate evidence, assessment or internal verification records;

Failure to comply with the QSs procedures for managing and transferring accurate candidate data;

Excessive direction from assessors to candidates on how to meet the national standards;

Deliberate falsification of records in order to claim certificates.

Any student suspecting malpractice from an EWA member of staff can report their concerns in confidence to Vic Cameron, Joe Cabassa, Yigit Akdemir, Louis Lee or Gordon Steele or Kirsty McKerrow.

Any member of staff suspecting malpractice from another member of staff can report their concerns in confidence to Vic Cameron, Gordon Steele, Joe Cabassa, Yigit Akdemir, Louis Lee or Kirsty McKerrow.

With regards to alleged student malpractice Kirsty McKerrow will head the investigations in liaison with the QS.

With regards to alleged staff or centre malpractice an independent manager, Henrietta Dundas, will head the investigations.

All suspected cases of centre malpractice would be reported immediately to the QS.

All suspected malpractice situations will be conducted through a combination of reviewing assessment evidence, checking records, interviewing other students, interviewing the assessor or interviewing other staff as appropriate to the offence.

Written confirmation of the investigation outcome will be communicated within 28 days of the suspected malpractice being reported. In some cases this may not be possible in which case all parties will be kept fully up to date with the developments with the outcome being decided as soon as possible.

Confidential letters will be sent to the parties involved as well as sending a detailed report to the QS.

Actions and sanctions if malpractice is proven

Staff - The staff member involved will either be given further training in this area and will be shadowed on every course they teach for the next 6months. Or if this is not appropriate the staff member will have their contract with the EWA terminated.

Students - Dependent on the severity of the malpractice the student will be permitted to resit the written assessment within 28 days of the malpractice decision. Or if this is not appropriate they will be excluded from the course and future courses for a period of 6 months.

The EWA will then undertake a review of their Policies and Procedures to ensure that this does not happen again.

Appeals

Any appeals should be submitted in writing to Kirsty McKerrow. The document must state the reason for an appeal including all evidence relating to the malpractice. This document must be received no longer than 14 days after the date that the malpractice decision was made. Any appeals received after this time will not be valid.

Kirsty McKerrow, from the EWA and an independent manager, Henrietta Dundas, will review all appeals submitted within the accepted time frame. All evidence will be reviewed and relevant parties will be re-interviewed where necessary. A final decision will be made and written communication sent to all parties within 4 weeks of first receiving the appeal document.

Where malpractice is investigated by the QS, the EWA has the right to appeal a decision where a case of reported malpractice by the EWA has been confirmed through investigation by the QS. The EWA also has the right to appeal a decision in the case of suspected malpractice by a candidate reported by the EWA to the QS.

Where an investigation of suspected malpractice is carried out, the EWA will retain related records and documentation for 3 years. Records will include any work of the candidate and assessment or verification records relevant to the investigation.

In an investigation involving a criminal prosecution or civil claim, records and documentation will be retaining for 6 years after the case has been heard.

In the case of an appeal to the QS against the outcome of malpractice investigation assessment records must be retained for 6 years.

The QS will be kept fully informed or all cases of suspected malpractice of appeals.

1.6 Procedure for dealing with conflict of interest for assessors, internal verifiers or invigilators

Any personal interest in the outcome of an assessment constitutes a conflict of interest as this could in turn pose a risk to the integrity of assessment.

Staff (including assessors, internal verifiers and invigilators) have a responsibility to report any personal interest that the Academy can then address, this includes any close professional relationships including line management of or by a candidate. Staff will be required to sign a Policies and Procedures and induction document before starting work at the Academy, in which the conflict of interest information will be covered. All signed documents will be kept by the Academy for the duration of their time with the Academy. All conflicts of interest should be reported to Kirsty McKerrow on the form overleaf.

Declaring conflicts of interest

Staff should declare a conflict of interest if they are related to, or have a personal relationship with a candidate and where they role is one or more of the following:

Set assessments which this candidate will undertake;

Make assessment judgments on this candidate’s evidence;

Internally verify assessment decisions on this candidate’s work;

Invigilate an assessment which this candidate is sitting;

Conflict of interest also applies where an individual stands to make a personal financial gain from the outcome of the assessment, as opposed to payment to the centre through normal business practices.

Centre staff are also required to make a declaration of conflict of interest if they have a close or familial relationship with each other. For example, where the assessment decisions of an assessor are to be internally verified by a relative. Conflict of interest also applies where an individual stands to make a personal financial gain from the outcome of the assessment, as opposed to payment to the centre through normal business practices.

This policy also includes any conflict of interest of language of assessment translators.

Addressing conflicts of interest

Dependent on the situation, actions will be implemented including – moving the candidate to another course, change the assessor/IV/invigilator, include the candidate in samples for verification and have their assessment marking supervised or re-marked. The decision and action will be documented and recorded.

All copies of documentation will be retained for 1 year after completion of the assessments in question, including details of the action taken.

1.7 Process for communicating with Staff, Candidates and QS

Candidates

We use Shopify as our cloud-based e-commerce platform. Upon purchasing a course, they will be automatically enrolled onto thinkific (learning portal) and invited to set a password for their account. The pre-reading material will be delivered via this portal. At the start of the course, there is a downloadable version of our Ps and Ps along with the QS Privacy Policy for candidates to read/download if they want.

Staff

Kirsty is the liaison for all teaching staff and is in regular contact with them via phone, email or face to face. It is the responsibility of the teachers to inform Kirsty of any changes to their contact details.

Kirsty is the QS co-ordinator and has a designated Account Manager who she is in regular contact with. The QS conduct a course EV every year and a Centre EV every 3 years. If Kirsty’s contact details change, she will inform her co-ordinator immediately to ensure communication channels are transparent.

1.8 Candidate feedback

Candidate feedback is essential in the development of the Academy. There is a member of EWA management on each course where candidates are free to discuss any suggested improvements or problems they may have. Any comments are then discussed at the weekly EWA staff meeting where improvements might be actioned. If there is a complaint of a serious nature, please see section 3.6 for our Complaints Procedure. Candidates are automatically sent a typeform for feedback on completion of their course.

Prior to a new course starting, a Pilot Day is held to ensure the effectiveness of the material, assessor and assessment questions in line with the Learning Outcomes and expectations.

1.9 Compliance with requests for access to records for EV activities

The QS is welcome to view any records in line with EV activities.

Our centre will comply with all requests from QS to undertake quality assurance activities, including systems verification, within the timescales specified by QS. This requirement is clearly documented in our roles and responsibilities framework and reflected in our quality assurance procedures. We understand that non-compliance with a systems verification request within the required timeframe will result in this criterion being rated Red, which may lead to sanctions.

1.10 Dissemination of EV visits

Outcomes of EV visits will be disseminated to the appropriate staff via e-mail and recorded in their course folder. If there are any actions to be taken, timescales will be agreed and adhered to.

Section 2 - Resources

2.1 Policies and Procedures must be documented and reviewed to ensure full compliance with the QS quality criteria. Assessors and internal verifiers must be competent to assess and internally verify, in line with the requirements of the qualification

Assessors

The EWA currently has 4 assessors, Vic Cameron, who will run all the english language Diploma in Single Malt courses, Joe Cabassa who will run the spanish and portuguese Diploma in Single Malt Whisky courses in the following countries;

Puerto Rico, Mexio, Brazil, Panama, Argentina, Peru, Chile, Equador, Dominican Republic and Spain, Yigit Akdemir who will run the Diploma in Single Whisky courses in Turkey and Louis Lee who will run the Diploma in Single Malt Whisky in Hong Kong .

Vic has worked in the whisky industry for 28 years specializing in operations and laboratory management, process support and cereal procurement. During his time as a Malting Manager (1996 -2000) Vic was an QS Assessor for a Maltings Vocation.

He is currently a part-time lecturer of whisky at the University of Highlands and Islands, a committee member of the Spirit of Speyside Whisky School, Technical Manager for the UK NIR Grain Network and founder of Discerning Spirits. He has taught at a variety of events including the Orkney Science Festival and Holland’s first ever whisky school.

Joe Cabassa has worked in the whisky industry for over 25 years in a variety of different consumer facing roles including Regional Brand Ambassador and Head of Education. A passionate spirits educator, in 2023 Joe founded Academia De Whisky which teaches trade and consumers about spirits and whisky.

Louis Lee has been working in the wine and spirits industry for most of his career. A key educator for the Hong Kong Wine Academy for over 10 years and one of the first EWA educators.

Yigit Akedmir is the founder of Yeme Icme Isleri and a key educator in Turkey for wine and spirits.

Dr Gordon Steele has spent over 25 years in the mainly in his previous role as Director of the Scotch Whisky Research Institute. His work has encompassed all parts of whisky distilling from grain development, processing and mashing through to distilling, maturation, blending and bottling. For the previous 5 years he has been working as a consultant creating the whiskies for distilleries such as Harris, Annandale and Royal Oak amongst others.

Throughout his career Gordon has regularly delivered training courses around different areas of whisky production as well as holding sensory workshops for the industry.

The criteria for any additional assessors would include the following:

Experience of teaching/public speaking;

Experience of working in the industry from a production side;

Keen interest and enthusiasm for the whisky industry and teaching.

Internal Verifiers

The EWA currently has 1 internal verifier, Kirsty McKerrow, who will internally verify all courses.

Kirsty worked as a TEFL teacher for 3 years at state schools in Poland as well as language schools in England before qualifying as a Paramedic. She worked as a Paramedic for 8 years before setting up her own whisky consultancy in Sweden. Alongside her whisky consultancy she worked as the Nordic Brand Manager for Möet Hennessey's whisky portfolio. Her roles for Möet included hosting whisky masterclasses, whisky education to on and off trade as well as organising and participating in whisky fairs and events.

Kirsty has very good knowledge of the whisky industry and has held jobs which demanded attention to detail and an organized, pragmatic approach.

The criteria for any additional internal verifiers would include the following:

Proven record of holding a position which carries a high degree of responsibility;

Experience of being organized and showing attention to detail.

Ongoing staff development

The EWA will keep staff updated with developments in the whisky industry. Units maybe need to be adapted accordingly in line with developments which will be conducted in liaison with the SQA in accordance with their criteria.

2.2 Induction training for assessors and internal verifiers

A signed record of the induction process will be kept for each staff member. The induction will include a discussion about the Policies and Procedures highlighting the following areas: what information the candidate is told (assessment process, internal appeals etc – please see candidate induction checklist 3.1), malpractice, internal verification procedures, conflict of interest, secure storage and transport of assessment materials and retention policy for candidate assessment evidence and records.

A copy of the EWA Policies and Procedures will be given to each staff member. Once the staff member is happy they understand all areas and have had all questions answered they will sign the induction sheet confirming this.

Any amendments to the Policies and Procedures will be distributed to all staff members who then must sign a sheet saying they have read and understood the changes – these signatures will be kept alongside a version control sheet.

2.3 A documented system for initial and ongoing reviews of assessment environments, equipment and reference, learning and assessment materials

A review meeting will be held after each Diploma course. At this meeting all staff will discuss the resources used and whether they remain relevant, current and with appropriate quantities for the qualification requirements and candidate numbers. Any relevant candidate feedback will also be included.

It is the responsibility of Kirsty to ensure that all teaching and assessment materials are updated and to change any whiskies/gins/samples required and that all material is updated on an annual basis if necessary.

It is the responsibility of Kirsty McKerrow to source and order any additional resources required in time for the next Diploma course.

For the Diploma courses that are delivered in a different language to English, all material will be translated by an expert, which is then reviewed by a native speaker before being available for use by a candidate.

The assessment is also translated and reviewed with any changes noted and signed off when amended.

2.4 Please refer to Part B of the Qualification Approval

2.5 Site Selection Checklist

Please contact kirsty@edinburghwhiskyacademy.com for a hard copy of these.

Our centre recognises that some assessment sites may not be physically accessible to QS staff. In such instances, we can document alternative measures to ensure transparency and verification, including remote oversight, virtual site tours, or documented declarations confirming that the site meets QS’s requirements.

Section 3 – Candidate Support

3.1 Candidate induction

Upon purchasing a course, candidates will be sent an email inviting them to create their profile on our online portal. It is on this platform where the pre-course reading and information will be displayed, they can ask questions directly and they also have downloadable copies of our Ps and Ps and the QS privacy policy.

3.2. Please refer to Part B of the Qualification Approval

3.3 Equal opportunities for assessment

The Edinburgh Whisky Academy is committed to providing equal opportunities to all the candidates. No individual will be discriminated against on any unjustifiable factor within the constraints of available resources and current legislation including age, disability, gender, gender re-assignment, marriage and civil partnership, pregnancy or maternity, race and ethnicity, religion and belief or sexual orientation.

Any barriers to assessment will be discussed and the EWA staff will do everything possible to remove this barrier. If translation of the teaching material and exam questions is required then the candidate must raise this issue before the course begins.

A candidate may have a translator present during the assessment. Normal assessment procedures will be in place and the translator and candidate will be seated in a private room. In order for this to happen, the candidate must contact Kirsty prior to the course beginning and receive confirmation that their translator will be permitted and arrangements for an alternative room have been organized. The translator cannot attend the course being assessed. The EWA retains the right to withdraw this if they believe the integrity of the assessment is being compromised.

Any changes made must not compromise the integrity of the assessment or give an unfair advantage over other students.

3.4 Please refer to Part B of the Qualification Approval

3.5 Individual candidates’ requirements for assessment arrangements must be discussed, identified, implemented and recorded

All candidates will be informed in their induction information of the availability of assessment arrangements to address additional support needs.

Any additional needs requiring assistance must be raised in advance in order that the EWA has sufficient time to provide the necessary support.

Procedures for the following assessment needs are covered by the EWA – detailed below each point:

Identification and evidence of needs;

How needs are met across different subject/units;

How recommendations for assessment arrangements are independently confirmed;

Recording and communication of assessment arrangements put in place Review of needs and support over time.

The key areas we are anticipating are language barriers. In this instance the candidate will be offered a 1-hour tutorial with Vic at the end of Day 1 or before class on Day 2 to ensure the student has absorbed and understood the content. With respect to the 1-day courses, candidates will be offered a tutorial in the lunch break pre-assessment.

Through starting to offer the Diploma in a couple of other languages we are working towards making this level of technical knowledge accessible to all by removing the language barriers that might limit the learning opportunities of some candidates.

The assessment can be conducted verbally in a closed room with the assessor if the candidate has issues with writing in English. Foreign candidates are allowed dictionaries during the assessment.

Any additional assessment arrangements will be logged in pre-delivery template and if appropriate the EWA Policies and Procedures record and will be relayed to all assessors.

The EWA will continually monitor the support they offer to candidates in line with any additional needs as they arise.

3.6 Handling of candidate complaints in line with the QS requirements

The EWA values all feedback– both positive and negative. Feedback from candidates allows us to continually evaluate our performance and helps to inform quality improvements.

All candidates will automatically be sent a request for feedback upon completion of the course.

All candidates will be able to email Kirsty at any point, before, during or after the course, to mention any feedback they feel relevant or wish to discuss.

As a small Academy, feedback is paramount to our success to ensure that we reach the highest standards with candidate satisfaction with the organization, quality and professionalism of the course.

This complaints procedure is not to be used for challenging assessment decisions, please refer to the Centre Appeals procedure - section 1.5 in the EWA Policies and Procedure Handbook.

Stage 1 - Informal Complaint

Candidates are able to complain to Kirsty McKerrow, IV, Vic Cameron, Joe Cabassa, Yigit Akdemir, Louis Lee, Gordon Steele or Henrietta Dundas, Independent Manager.

The timescale for an informal complaint is within 14 days of the event happening. We would encourage candidates to report their complaint as soon as possible after the event. However, there is a 14-day deadline for complaints to be issued. Complaints can be made in person, via email or via phone.

The complaint will be recorded and logged and an internal process will begin in trying to fix the complaint dependent on the nature of it. If the complaint relates to the assessor, a meeting will immediately be called with the assessor and Kirsty to ensure the validity of the complaint and steps will be taken to ensure another complaint of a similar nature will not happen again.

The complainant will receive a written letter detailing what action has been taken, if any, from the EWA within 21 days of their complaint being received.

Stage 2 - Formal Complaint

Candidates wishing to make a formal complaint must do so in writing to the EWA to kirsty@edinburghwhiskyacademy.com.

A formal complaint must be received within 21 days of the event. Candidates are able to initiate a formal complaint at any time, there does not need to be an informal complaint logged first.

All formal complaints will be handled by Henrietta Dundas, an independent manager. Kirsty will forward the complaint to Henrietta who will then begin an investigation.

Kirsty will act as a liaison officer ensuring that Henrietta has all the relevant details as well as keeping the candidate informed of any developments or any clarification needed.

The EWA has no complaint form. Once the complaint has been received Kirsty will email an acknowledgement of the complaint within 24 hours of receiving and the formal complaint process will begin.

The EWA aims to resolve all formal complaints within 21 days of receiving the complaint.

Each complaint will be logged and recorded and the SQA will be consulted (where needed) and informed on each case.

Appeals

The EWA does not have a detailed appeals process. However, we will work very closely with the complainant and the investigating officer, Henrietta Dundas, to ensure that a satisfactory resolution is found and that steps are taken to ensure no repeat of a complaint of a similar nature.

If required another independent manager could be called in to review the case. In this case their decision would be final and the matter would be closed.

Recording of complaints

All complaints both informal and formal will be recorded and logged in a complaints folder. These will be reviewed quarterly and any similar trends will be identified early on. A quarterly newsletter will be distributed to all staff detailing this information and explaining any steps taken to improve the EWA service in response to these complaints.

Complaints to the QS

Candidates of QS Qualifications also have the right to complain to QS awarding body. The QS will only consider their complaint if they have already gone through all stages of the EWA’s complaints procedure and remain dissatisfied with the outcome, or the way in which their complaint was handled.

The QS will deal with complaints about:

Assessment – including the conduct of, preparation for and the environment for the assessment

Dissatisfaction with the way in which the EWA handled with complaint

The QS will not deal with complaints about:

Assessment decisions (see section 1.5)

The wider experience of being a candidate (support services, facilities)

Section 4 – Internal Assessment and Verification

Internal assessment and verification procedures must be documented, implemented and monitored to meet qualification and QS requirements. The EWA is required to provide evidence of their systems, policies and procedures to ensure all assessment decisions are consistent with the qualification standards and to show how the EWA will maintain records of the internal verification process.

4.1 Internal assessment and verification procedures must be documented and monitored to meet the QS requirements

Internal verification is a crucial element of the QS’s quality assurance. It ensures that all candidates entered for the same qualification are assessed fairly and consistently to the specified standard.

The EWA is responsible for operating an effective and documented internal quality assurance system which is a requirement of being an QS- approved centre.

In order to ensure effective assessment and internal verification the EWA will regularly review the effectiveness of their procedures and make any necessary improvements whilst ensuring that any changes by the QS are adopted.

The internal verification procedure for all Diplomas includes 3 stages – pre-assessment, during assessment and post assessment.

Stage 1 - Pre-assessment

The strategy of the EWA follows one where a named member of staff carries out the internal verification for all units in the award. This allows the IV a view of all assessment activities relating to the award they are responsible for quality assuring. This role is carried out by Kirsty McKerrow.

The pre-delivery tasks break down into the following roles:

Role of the Assessor

Understand roles and assessor and internal verifier – Section 1.4

Be familiar with Unit/Awards standards and conditions.

Propose assessment approach. All assessment exemplars and materials will be agreed prior to course beginning in collaboration with the independent experts.

Prepare candidates for assessment.

Role of the Internal Verifier

Ensure assessor and internal verifier roles and responsibilities are clear – Section 1.4.

Define approach to internal verification including sampling.

Collaborate with assessor(s) and other internal verifiers to ensure

shared understanding of Unit/Awards standards and conditions.

Collaborate to ensure that assessment approach is valid, reliable, practicable, equitable and fair.

Internally verify centre-devised assessment before submitting to the QS for prior verification, if applicable.

Confirm that agreed assessment guidance for specific Units/Awards is implemented for candidates including those requiring special assessment arrangements.

The recorded pre/during/post assessment sheets are contained in each course folder. Available on request by the QS to view at any point.

Stage 2 - During assessment

Diploma in Single Malt Whisky

Candidates will be assessed in a 2-hour exam which will take the shape of a practical assessment where candidates must nose/taste a whisky and answer questions on it as well as a multi-choice paper. The assessment is now completed online via Brillium, removing the problem of human error in marking.

All Diploma courses that are conducted in another language than english must use the online assessment. This negates the concern over printed assessments being used in different environments, thus increasing the chances of a breach of security.

The sensory assessment will be set up in the adjoining room and candidates can choose the order in which they complete the assessment. There are 2 assessment papers which will be rotated by course. Questions for resits will come from the next paper due.

Due to the nature of the course and the assessment, plagiarism is not expected. However, candidates will be seated apart from one another and the assessor will maintain vigilance throughout the practical and written assessments to ensure no candidate is looking at another’s paper/device.In July 2021 we launched an online version of this course. The course material is exactly the same as the face to face course with knowledge checks throughout the material for self-learning checks.

The online assessment is undertaken via proctoring software, ProctorExam. Candidates must fulfil the system requirements and once successfully completed them they are sent the assessment link. It is a record and review service so the candidate can take the assessment any time that suits them. Their assessment is recorded via webcam and reviewed by a proctor within 48 hours. Any discrepancies are noted down along with the time code and available for EWA to review. The recordings are kept for 3 weeks. Candidates displaying any evidence of cheating will either be disqualified or asked to resit the entire assessment.

The pass rate is the same with candidates having to achieve 60% or more in each of the 7 modules. The assessment is 2 hours long.

Candidates are allowed a dictionary and must display an ID card for the recording at the start.

Diploma in the Art of Tasting Whisky

Candidates will be assessed in a 45-minute exam, there is no practical element. There are 2 assessment papers which will be rotated by course. Questions for resits will come from the next paper due. Due to the nature of the course and the assessment, plagiarism is not expected. However, candidates will be seated apart from one another and the assessor will maintain vigilance throughout the practical and written assessments to ensure no candidate is looking at another’s paper.

The assessment is now marked using an automatic marking tool, Zipgrade, removing the problem of human error in marking.

Assessors and IV will meet every 3 months to ensure the standardisation, quality and fairness of the assessments. After each course both the assessor and the IV must complete a sign-off sheet confirming that all the necessary criteria have been met and that the candidate’s papers are eligible for marking.

Certificate in Scotch Whisky

This is an online course (8-12hours) with an online assessment which is undertaken via Proctor (if remote) and Brillum. There are 2 assessment papers (1 for assessing and 1 for resit) and we feel this is enough to mitigate the risk of plagiarism. Each paper is randomly selected for candidates and the pass rate is 70% overall rather than for each module. The assessment will be conducted via ProctorExam as above. The assessment is 1 hour long.

With select 3rd party partners, this course can be taught face to face. In this instance the assessment will be conducted online via brillium with the assessors invigilating in real time.

Sampling strategy

On new or revised qualifications, a Pilot Day/course will be held to gain feedback on the effectiveness of the assessor and material

This will also take place to ensure the material and resources are in line with the candidates’ development and understanding and the assessment methods are appropriate to the course content.

Based on the feedback, if the IV feels these methods need to be amended, they will raise it at the post-course meeting with the assessor and the material will be developed further. A pre-verification form will be completed by the IV detailing what areas need amended.

Stage 3 - Post-assessment

As stated above, a discussion between the Assessor and the IV will take place after each course. Any action points resulting from this discussion will be recorded on the Post-delivery template and it will give staff the opportunity to reflect on the Internal Verification Policy of the EWA to voice any concerns or suggest any possible improvements to safe-guard the integrity of the Diploma going forward.

Trustpilot has been adopted as the feedback system – visible on online.

IV Self-assessment is in each course folder and available to view at any time by the QS.

Due to the new automated marking scheme adopted, internal verification is no longer required on assessment papers from a marking side. However, regular verification activities will continue (ensure standardization between any changes in the papers, assessment is closed-book, no cheating etc.) as does the processes detailed above with the pre/during/post assessment, evidenced in each course folder. The online Certificate in Scotch Whisky and the online Diploma in Single Malt Whisky is assessed via ProctorExam on a record and review function.

The recordings on ProctorExam are checked for any red or yellow lights after the reviewer has checked them. Any areas for concern will result in either the candidate being asked to explain the incident, or their paper being disqualified.

4.2 Please refer to Part B of the Qualification Approval

4.3 Please refer to Part B of the Qualification Approval

4.4 Please refer to Part B of the Qualification Approval

4.5 Assessment materials and candidate evidence must be stored and transported securely

This relates primarily to assessments where candidates would gain an unfair advantage by seeing the assessment in advance when the assessment is carried out under controlled conditions.

The EWA assessments are produced within the centre. Our procedure for management of these assessments is as follows:

All EWA staff must take sufficient steps to protect the integrity of the QS – this includes adhering to the security steps laid out below.

The responsibility for management of the security of assessments is down to Kirsty McKerrow;

The assessment question bank will be held on a memory stick of which only Kirsty has a copy with another one locked in the filing cabinet at the office. The memory sticks are password protected;

During the course, hard copies of the assessment questions will be

locked in the Arniston House Manager’s office or at another office onsite for other venues.

After the papers will be kept in a locked filing cabinet in Kirsty McKerrow’s office. Only Kirsty and an independent manager will have keys to this cabinet;

This process will be fully explained during staff induction and will be reviewed regularly to ensure the secure methods used are the most effective.

Transport

Kirsty will have full responsibility of the secure transport of the assessment papers until her arrival at the venue where they will be placed in a locked cabinet.

On completion of the course, Kirsty will have full responsibility for the secure transport of the assessment papers until her arrival at her office where they will be placed in a locked filing cabinet.

After marking the papers, they will be kept in a locked filing cabinet in Kirsty’s office until the candidate is certified.

All EWA staff will be made aware of the following:

The assessments must not be left lying around in classrooms or work rooms;

Assessments handed out to candidates to use must be collected back in and either shredded, put into confidential waste or stored securely again;

All candidates must be made aware that taking away assessments, copies or images of assessments is malpractice and could result in a disciplinary process;

Staff who give assessments, copies of images of assessments to candidates out with the assessment process, without good reason or permission, are committing malpractice which could result in a disciplinary process;

Any breaches of security of assessment must be reported immediately to Kirsty McKerrow.

Remote Assessment Security and Procedures

In cases where assessments are delivered remotely, our centre complies with QS guidance for supporting technology-based assessment, covering the secure distribution of assessment materials, candidate identity authentication, and environmental controls to uphold the integrity of assessment conditions. We reference and apply practices outlined in Using Technology to Support Assessment Remotely: Questions and Answers and QS’s guidance on remote invigilation in our internal training and procedural documentation.

Candidate assessment evidence

All assessment evidence produced by candidates must be held and moved securely. As detailed above, the assessment evidence will be in hard copy and will be handed over to Kirsty in a sealed envelope ensuring it cannot be altered by others.

The papers will be kept until candidate certification in a secure environment. The SQA will have access at any point to the papers.

4.6 Please refer to Part B of the Qualification Approval

4.7 Candidate evidence must be retained in line with QS requirements

The EWA will keep all papers until 3 weeks after the end date that was notified on the QS system.

However, if the EWA is selected for external verification, the candidate assessment evidence for the selected Units will be retained for the qualification verification visit or central verification event. This may be physical evidence or records of the evidence.

In the case of an appeal to QS against an internal assessment result in a regulated qualification, centres must retain records, including all materials and candidate evidence, until the appeal has been resolved.

Where an investigation of suspected malpractice is carried out, centres must retain related records and documentation for three years. Records should include any work of the candidate and assessment or verification records relevant to the investigation.

In an investigation involving a criminal prosecution or civil claim, records and documentation will be retained for six years after the case has been heard. In the case of an appeal to QS against the outcome of a malpractice investigation, assessment records must be retained for six years.

4.8 Internal assessment appeals must be handled in line with a documented procedure which meets the QS requirements

Candidates have the right to appeal against the result of internal assessments if they feel they have been treated unfairly or if they feel the course content was not reflected in the level of assessment.

This message will be conveyed to the students on their pre-course induction sheet as well as being highlighted verbally at the beginning of each course.

All candidates will be able to email Kirsty at any point, before, during or after the course, to mention any feedback they feel relevant or wish to discuss.

Stage 1 - Informal

Candidates are able to complain informally to their assessor. The candidate has 14 days from the date of receiving their assessment result, to lodge their appeal.

The candidate will receive confirmation of receipt of their appeal within 24 hours of its arrival.

The appeal will be logged and recorded and a decision made and communicated to the candidate within 21 days of receipt of the appeal.

Any action required will be communicated to all staff by the assessor and will be discussed at the next meeting.

Stage 2 - Informal

If the candidate is dissatisfied with the outcome from the Informal stage or they feel uncomfortable contacting Vic Cameron, they can email Kirsty McKerrow, in her role as the IV.

Candidates will have 21 days from the date of receiving their assessment result, to lodge their appeal.

The candidate will receive acknowledgement of receipt of their appeal within 24 hours of its arrival.

Their appeal will be logged and recorded and a decision will be made and communicated to the candidate within 21 days from receipt of the appeal. Any actions to be implemented as a result of the appeal, will be communicated to all staff by Kirsty McKerrow in order to ensure the same situation does not arise again.

Stage 3 - Formal

All formal appeals must be made in writing to an independent third party, Henrietta Dundas, who has not been involved at any earlier stage of the process. Candidates can write to her at hd@arniston-house.co.uk Candidates will have 21 days from the date of receiving their assessment result, to lodge their appeal. Or if their appeal has already been dismissed through the informal stage, they will have 21 days in which to lodge a formal appeal from the date of the decision of the informal stage.

The candidate will receive acknowledgement of receipt of their appeal within 24 hours of its arrival.

Their appeal will be logged and recorded and a decision will be made and written notification of this will be communicated to the candidate within 21 days from receipt of the appeal.

Any actions to be implemented as a result of the appeal, will be communicated to all staff by Kirsty McKerrow in order to ensure the same situation does not arise again.

The EWA has no appeals form.

The EWA aims to resolve all formal complaints within 21 days of receiving the complaint.

Each complaint will be logged and recorded and the QS will be consulted (where needed) and informed on each case.

The EWA assessments are non-regulated qualifications, therefore the candidate has no further right of appeal against the internal assessment decisions. The final decision rests with your centre. The SQA will not accept internal assessment appeals.

Recording of appeals

All appeals both informal and formal will be recorded and logged in an appeals folder. These will be reviewed quarterly and any similar trends will be identified early on.

A newsletter will be distributed to all staff detailing any appeals information and explaining any steps taken to improve the EWA service in response to these appeals.

Records will be kept for up to 6 years after the appeal has been settled.

Section 5 – Assessment and Quality Assurance

For our Customised Awards, Edinburgh Whisky Academy applies assessment and internal verification procedures that fully align with QS’s quality assurance requirements. All assessments are designed to validly and reliably measure the published learning outcomes, with clear marking guidelines to support consistency. Candidate evidence is securely stored for the required retention period, and all assessment decisions are subject to internal verification before certification. Procedures are in place to ensure the security of assessment instruments, the accurate recording and retention of results, and the provision of constructive feedback to learners. Where remote or technology-supported assessment is used, additional safeguards are applied in line with QS guidance to maintain integrity and security.

Section 6 – Data Management

The EWA procedures for supplying complete, current and accurate information to the QS for purposes of registration, entries and certification must be documented, implemented and monitored to meet QS requirements.

6.1 Assessment evidence must be the candidate’s own work, generated under QS’s required conditions

Obtaining personal information from candidates

Personal information from the candidate will be collected online when the candidate enrols on the course. The information gathered will include the following:

Full name;

Date of birth;

Home address;

E-mail address;

Contact telephone number;

2 weeks prior to the course starting the candidates will be emailed asking for any food allergies or disabilities and to bring their previous SQA number, if they have previously held one.

It is the responsibility of the candidate to inform the Edinburgh Whisky Academy immediately of any changes to their personal details.

With the framing option now very popular, many candidates’ certificates are being sent to the office for us to forward on for framing. The procedure for this is that Kirsty will register the candidates under their home address and include an email or UK mobile in place of updating their address details as their home address.

Please refer to the EWA Data Management Policy for further information on the collection and security of data.

All candidates will be made aware of the dissemination of their data to the SQA and will be signposted to the SQA Privacy Policy in our Privacy Policy and in their induction.

The responsibility for organizing all the above is down to Kirsty McKerrow. The information will be stored securely in hard copy as per the EWA Data Management Policy and disposed of securely as soon as is possible. This information will only be shared with the QS and any other required 3rd party or in circumstances of a criminal nature.

6.2 Data on candidate entries submitted by centres to the QS must accurately reflect the current status of the candidate and the qualification

It is the responsibility of Kirsty McKerrow to notify the QS of registered candidates undertaking its Awards within 2 weeks of the course starting.

Checking Scottish Candidate Numbers

It is the responsibility of Kirsty McKerrow to check SCNs and allocate new SCNs via QS Connect. This will be completed within 5 days of the course starting.

Or for online candidates, within 5 days of them registering for the assessment.

Kirsty McKerrow will also check that the EWA is approved to offer the Awards she is registering the candidates for. She will send all candidate information to the QS using QS Connect.

Data cleansing

Kirsty McKerrow is responsible for cleansing candidate information on the QS system. This includes any changes to candidates’ personal details and withdrawal of award entries when past their completion date and not resulted as a pass or fail. It is the policy of the EWA that students have 12 months after enrolment to attend the Award course and take the assessment. Kirsty will then change the status of candidates who have not completed their Certificate within the 12 months to Withdrawn.

No extension will be granted for the assessment. However, a resit assessment is allowed for up to 12 months after the Award course.

Data Cleansing will take place monthly with any necessary changes being communicated to the QS via QS connect.

6.3 Data on candidate results submitted by centres to QS must accurately reflect the current status of the candidate and the qualification

The EWA only offers 3 customised group awards.

Kirsty McKerrow has the responsibility for recording candidates results. This will be done electronically but with paper copies kept on file until candidates’ certification.

Kirsty McKerrow is the data management staff so she will update records and maintain secure treatment of all paper copies of the candidate’s papers.

She will also submit successful results to the QS on Connect within 7 days of the completion of the course.

6.4 There must be an effective and documented system for the accurate recording, storage and retention of assessment records, internal verification records and candidate records of achievement in line with the QS requirements

The EWA will retain the following records for 1 year after completion of the course:

A list of candidates registered with the QS for each qualification offered in the centre;

Details of candidate assessment, including the name of the assessor

Internal verification activity;

Certificates claimed.

All records both paper and electronic will be kept securely as per the EWA data management policy and will be made available for EV.

In the case of an appeal to the QS against an internal assessment, the EWA will retain all records including all materials and evidence until the appeal has been resolved. Thereafter, assessment and internal verification records for appeals cases should be retained for six years, unless there is a legitimate reason to retain records for a further period.

Where an investigation of suspected malpractice is carried out, the centre must retain related records and documentation for three years. In an investigation involving a criminal prosecution of civil claim, records and documentation will be retained for six years after the case has been heard.

Kirsty McKerrow will take responsibility for ensuring that the appropriate assessment records are retained for the required periods and for destroying them when they are no longer required.

All records will be stored securely as per the EWA data management policy.

Appendix – Data Management Policy

Policy prepared by: Kirsty McKerrow
Next review date: December 2026 (or sooner if legislation changes)

1. Purpose of this Policy

Edinburgh Whisky Academy (EWA) collects, stores, and processes certain personal information about customers and learners. This policy sets out how EWA manages personal data in order to:

Comply with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Protect the rights and freedoms of individuals whose data we hold.

Ensure transparency, accountability, and security in all data management activities.

Protect the organisation from risks such as data breaches, reputational damage, and unlawful processing.

2. Scope

This policy applies to:

Edinburgh Whisky Academy Ltd.

All staff, contractors and third parties working on behalf of EWA.

All personal data held by EWA, in any form (electronic, paper, or other media).

Personal data includes, but is not limited to:

Names, addresses, email addresses, telephone numbers.

Employment or learner records.

Any other information that could directly or indirectly identify an individual.

3. Data Protection Principles

In line with UK GDPR, EWA ensures that personal data is:

Processed lawfully, fairly, and transparently.

Collected for specified, explicit, and legitimate purposes only.

Adequate, relevant, and limited to what is necessary.

Accurate and kept up to date.

Retained only for as long as necessary.

Processed securely, protecting against unauthorised or unlawful access, loss, destruction, or damage.

Managed under the principle of accountability, with EWA able to demonstrate compliance.

4. Responsibilities

Owners/Directors – hold overall responsibility for compliance.

Data Protection Lead (currently Kirsty McKerrow) – responsible for:

Reviewing policies and procedures.

Coordinating staff training.

Responding to data protection queries and Subject Access Requests.

Managing data protection contracts with third parties.

Overseeing security measures and audits.

Acting as the main point of contact with the Information Commissioner’s Office (ICO).

All Staff and Contractors – must handle data responsibly, follow this policy, and report any issues immediately.

5. Rights of Individuals

EWA recognises the rights of data subjects under UK GDPR, including the rights to:

Access their personal data.

Rectification of inaccurate or incomplete data.

Erasure (“right to be forgotten”).

Restrict or object to processing.

Data portability.

Not be subject to decisions based solely on automated processing.

Requests will be handled by the Data Protection Lead and responded to within statutory timescales.

6. Data Breach Procedure

All staff must report suspected personal data breaches immediately to the Data Protection Lead.

EWA will investigate, document, and assess the risk of all breaches.

Where a breach poses a risk to individuals’ rights and freedoms, the ICO will be notified within 72 hours.

Where required, affected individuals will also be informed promptly.

7. Data Storage and Security

Personal data in paper form must be kept in locked storage when not in use.

Electronic data must be stored on approved servers or cloud services, protected by strong passwords, encryption, firewalls, and antivirus software.

Two-step authentication is enabled on company email accounts.

Data must not be stored on personal laptops, phones, or removable devices unless encrypted and approved.

Regular backups are maintained.

Access is restricted only to those who need it for their work.

8. Data Use

Data must only be accessed for legitimate business purposes.

Employees must always use the central, most up-to-date version of data rather than saving local copies.

Data should never be shared informally or disclosed to unauthorised individuals.

9. Data Accuracy

Staff are responsible for ensuring data they handle is accurate and updated.

Outdated or unnecessary data should be securely deleted.

Learners, customers, and staff will be provided with clear ways to update their personal information.

10. Data Retention and Disposal

Data will only be kept for as long as necessary for the purpose it was collected.

EWA maintains retention schedules, reviewed annually.

Secure disposal methods are used: shredding, digital wiping, or anonymisation.

11. International Data Transfers

Where personal data is transferred outside the UK (e.g. via cloud providers), EWA ensures that:

Transfers are lawful under UK GDPR.

Adequate safeguards (such as Standard Contractual Clauses) are in place.

12. Training and Awareness

All staff handling personal data will receive training on data protection and information security.

Refresher training will be provided periodically, or when legislation or policies change.

13. Review

This policy will be reviewed at least annually, or sooner if required by changes in legislation, guidance from the ICO, or business operations.