Introduction

We have both a grievance procedure and a bullying and harassment procedure in place to enable you to lodge a grievance relating to your own employment. The whistle-blowing policy is intended to cover other serious concerns which fall with the Public Interest Disclosure Act 1998. We are committed to running our business with honesty and integrity and within the restraints of the law. As such whilst legislation protects you from suffering a detriment at work if you take a matter to a relevant outside body, we would hope that you would feel able to bring any concerns you may have to the attention of the Directors with confidence that any such concern would be dealt with appropriately and swiftly and without any fear of reprisal, even if your belief of wrongdoing turns out to be unfounded as the result of a thorough investigation.

Whistle Blowing is the everyday term used to describe a disclosure made to someone in authority alleging corruption, malpractice or wrongdoing on the part of another person. In employment whistle blowing refers to an employee (“whistle blower”) making a disclosure about a colleagues conduct in the course of employment, or about employer’s practices The Legal Position Employees and workers who make a ‘protected disclosure’ are protected from being treated badly or being dismissed as a result of making the disclosure.

The Act offers protection to any person who makes a disclosure relating to the following serious offences:-

• Criminal offences
• Risks to health and safety
• Failure to comply with a legal obligation
• A miscarriage of justice
• Environmental damage
• Abuse of a service user

For a disclosure to be protected it must be made to an appropriate body. For example, disclosing a health and safety issue to the Health and Safety Executive is likely to be protected, but not if the concern was disclosed to the media. The raising of a concern will be covered by this policy provided you have a reasonable belief that the disclosure is made in the public interest.

Scope

This policy applies to:

• Everyone who works for the organisation, on a paid or unpaid basis, including any temporary

staff or contractors who may provide services to ASA Training

• Employers, witnesses and supporting mentors to any learners
• Learners enrolled with ASA Training

Individuals can raise an issue with ASA Training under the arrangements outlined in this policy if they have a reasonable belief that malpractice and/or a wrongdoing is occurring or is likely to occur and they should have a reasonable belief that the disclosure is in the public interest.

Why

We have a duty under the GDC standards of professionalism.

Duty of candour states that health and care professionals must “tell the person (or, where appropriate, their advocate, carer or family) when something has gone wrong.

The GDC’s Standards for the Dental Team already require dentists and dental care professionals to:

• Put patients’ interests first (principle one);
• Be honest and act with integrity (standard 1.3)

However, candour means being open and honest with all patients, whether they have made a

complaint or not.

Procedure

We are committed to the highest possible standards of operation. In line with that commitment we encourage you to consider raising the matter with the Head of Quality & Apprenticeships or the Senior Business Manager before taking the matter to an outside body. We will take all such concerns seriously and any individual raising legitimate concerns under this policy will not be subjected to any detriment either during or after employment. All such concerns raised will be thoroughly investigated and appropriate action taken accordingly.

Steps:

1. Initial concern reported in writing to Head of Quality & Apprenticeships or Senior Business Manager
2. Concern to be investigated within 14 working days
3. Meeting with whistleblower to disseminate findings/outcome
4. Report of investigation
5. If concern is mitigated, case is closed
6. If concern is upheld, we will adhere to relevant governing body policy/procedure and escalate

Safeguarding Complaints

We recognise that the decision to report a concern can be a difficult one to make and we will support you during the process. We will not tolerate any harassment or victimisation (including informal pressures) and will take appropriate action to protect you when you raise a concern to us in good faith. Every effort will be made to keep the identity of the whistle blower who makes a disclosure under this policy confidential, at least until a formal investigation is under way. In order to ensure that a fair investigation can take place the whistle blower will also be expected to keep the fact that they have raised a concern, the nature of the concern and the identity of those involved confidential.

It may be that during an investigation, disciplinary or legal proceedings that the company no longer maintains the whistle blowers confidentiality. If that does occur then the company will endeavour to notify the whistle blower in advance.

Employee Handbook Issue 1 ٠ (September 2021) Page 25 Produced & supported by Avensure Ltd:

Untrue Allegations If you make an allegation, but it is not confirmed by the investigation, no action will be taken against you. If, however, you make an allegation maliciously, vexatious, or for personal gain, disciplinary action may be taken against you and, dependent upon the circumstances, this may be treated as Gross Misconduct.

Point of contact for all whistleblowing reports:

Claire Lamb – Head of Quality & Apprenticeships – claire@asatraining.co.uk

John Turner – Senior Business Manager – john@asatraining.co.uk

Copy of Whistleblowing log:

Progression Concerns – Process – Learners/Employers

Initial problem/concern identified by Educational Practitioner/Employer/FS’s Tutor/Operational Team

Green Warning Issued.

At this stage the Progression Concerns Process will be reiterated, you & your Employer will be made aware of consequences this could lead to.

Your Employer will be made aware of the Green warning issued and why.

Learner made aware of Green warning issued and why, improvements will be clearly set which must be met to prevent further warnings.

If a learner is 10% – 15% behind their progress target, or 50hrs or more behind target with their Off The Job (OTJ), a green warning will be issued without fail.

Details will be completed on your OneFile portfolio and at the Progress Reviews with your Employer.

At your next appointment, if no improvements have been identified/there are further concerns arising/improvements not met from Green warning:

Amber Warning issued.

Your Employer will be made aware of Amber warning issued and why.

Learner made aware of Amber warning issued and why, improvements will be clearly set which must be met to prevent further warnings.

If a learner is 16% – 25% behind their progress target, or 80hrs or more behind target with their Off The Job (OTJ), an Amber warning will be issued without fail.

Details will be completed on your OneFile portfolio and at the Progress Reviews with your Employer.

At your next appointment, if no improvements have been identified/there are further concerns arising/improvements not met from Amber warning:

Red Warning issued.

Your Employer will be made aware of Red warning issued and why.

Learner made aware of Red warning issued and why – what has not improved despite RAG warnings being issued.

If a learner is 26% – 35% behind their progress target, or 120hrs or more behind target with their Off The Job (OTJ), a Red warning must be issued without fail.

Process will now escalate to the next level – Head of Quality & Apprenticeships (HOQA).

Details will be completed on your OneFile portfolio and at the Progress Reviews with your Employer.

Head of Quality & Apprenticeships (HOQA) to conduct a full qualification continuation review (QCR) and risk assess, decide on appropriate action to take.

HOQA to contact learner and employer, in writing, regarding issues raised and issue a written report and action plan (if appropriate) to support the learner back on target.

If an action plan is appropriate, weekly deadlines will be put in place and the learner must meet these deadlines in order to stay on the apprenticeship programme. If the learner fails to meet the actions set out in the QCR action plan, they will be at risk of removal from the apprenticeship.

In line with the Apprenticeship funding guidance, any learner that does not complete within the specified time frame, may require an extension of delivery. This will be costed at the agreed funding band amount.

If the learner does not complete within the specified learning period, the employer will be charged at a rate of £266.00* per month**

*This may vary depending on the funding amount agreed at the start of the apprenticeship

**Subject to change

The above process needs to be followed as closely as possible. However, this is also based on risk.  Risk to patients, colleagues, and team members.

It may be that the risk is too great, and the HOQA needs to intervene immediately.  If this is the case it will be evidenced as to why the RAG warnings have not been issued prior to this happening, we can substantiate the need to escalate issues more swiftly than the process allows.  There is an allocated box on OneFile to complete the details of this process.

Purpose

The purpose of this document is to define how prior learning, both accredited (APL) and recognised (RPL), is assessed and accounted for as part of a student’s Apprenticeship programme.

Scope

This policy should be implemented at the start of each student’s Apprenticeship, ensuring the student, Employer and tutor are cognisant of the programme length, content (including Off-the-Job (OTJ) content/ hours requirement) and total price, prior to commencement. The policy is also applicable where a student ‘restarts’ their Apprenticeship, for example in the case of a change of employer after a ‘gap’ in learning, but not where a student returns from a Break in Learning.

Policy Statement

To satisfy the requirements of both the Education & Skills Funding Agency (ESFA) and Ofsted, it is essential that a skills gap analysis is undertaken with every apprentice to identify existing knowledge, skills and behaviours. This sets the starting point for the student’s learning, allowing the tutor to tailor the programme to best suit the needs and requirements of the individual to ensure they achieve.

The process of recognising prior learning as part of an Apprenticeship preceded the reforms. However, the requirement to agree a price with the employer (comprising delivery and EPA), the introduction of the minimum 20% OTJ requirement and the 365-day minimum programme duration rule (and extension for those below 30 hours) were new and must be considered when establishing a student’s eligibility/ suitability.

When a student is identified as having prior learning in the form of carry over accreditation or being ‘qualified by experience’, their length of programme will be reduced proportionately to reflect the level of knowledge, skills and behaviours previously obtained. Where the student’s programme length is reduced resulting in them not being able to fulfil their minimum duration, the student will be deemed ineligible for the Apprenticeship. This is to ensure students are not learning what they already know and continue to develop throughout the duration of their programme.

The ESFA has stated they will not fund any existing knowledge development, therefore, where prior learning is identified, the price of the programme must also be reduced to reflect this.

Process

Accredited Prior Learning

The Apprenticeship enrolment forms (including signatures), are captured digitally using a PICS’ ‘Form Capture Application’ (FCA) tool. They include a section focussing on the student’s prior learning and comprise the below points:

• A Skills Scan is sent to the applicant prior to completion of the PICS form.

The applicant will score themselves 0-10 (10 being top score) on each one of the areas of knowledge, Skills and behaviours in the desired qualification. If an applicant’s skills scan indicates a medium to high score we will ask for supporting evidence (certificates) or supporting comments. If the applicant is already employed then the employer will need to review and agree to the scoring the applicant has given themselves.

• An occupational competency multiple choice test is also sent to the applicant prior to enrolment as a further measure of the learners knowledge. This is not done for every qualification currently however / or where a skills scan will suffice.

Is the student currently undertaking any other Government funded programme? – If the student declares ‘Yes’, this is raised with the employer as an eligibility issue. Other eligibility checks related to funding are also carried out prior to enrolment for a funded qualification.

• Prior qualifications obtained, including level, grade and place of learning (Inc. Apprenticeships & Traineeships). – If the student has undertaken programmes at the same level or in the same industry, a unit mapping exercise should be conducted to confirm eligibility.

• English, Maths and ICT – All students undertake a mandatory initial assessment for Maths and English using an industry acknowledged assessment tool, the result determines the level of functional skill applied.

If a student declares prior attainment, certificates will be sought for confirmation. If these are not obtained within 3 months, functional skills delivery should commence to ensure the student completes the required level of functional skill in time for Gateway.

• Employment/work experience within the related industry & existing vocational skills and experience – Evidence to supports the mandatory Skills Assessment as part of the assessment of recognised prior learning.

• Progression and employment ambitions – Allows the tutor to provide suitable IAG. At the enrolment stage this is provided to ensure the chosen Apprenticeship is relevant to their job role & aspirations. At completion, IAG is provided to advise the student of suitable progression routes.

Once the student has had sight of the ESFA’s Privacy Policy and signed to confirm they have done, ASA will access the student’s Personal Learning Record (PLR) on the Learning Records Service (LRS) and will either:

1. Confirm the information declared is correct.
2. Identify accredited learning not declared on the enrolment form.
3. Investigate accredited learning declared but not present on the PLR – this will be achieved through requesting copies of certificates from the student and employer.

Where a student has previously studied towards another programme in a similar industry or at the same level, a mapping exercise will be conducted to establish knowledge carry over. The price and length of programme will be subsequently reduced to reflect this.

Recognised Prior learning

RPL is determined by way of a sector specific skills assessment which is undertaken with each student at the start of their programme. The skills assessment requires the student to specify their level of ‘Developmental Need’, by selecting one of four options, these being ‘Substantial’, ‘High’, ‘Moderate’ and ‘Limited’.

Where a student assesses their own developmental need as ‘Substantial’ for a topic, there is no effect to the programme length or price as the student requires full knowledge development. If the student chooses any of the three remaining options, the price and length of programme are reduced to accommodate the reduction in content to be delivered.

Establishing the student’s knowledge gaps allows the tutor to focus on developing those areas in advance of Gateway. Tutors should challenge and probe where students claim they have a reduced development need to ensure the student is aware of the full requirements of that subject area to achieve EPA. All areas of the programme should still be covered but the extent of which will be determined by the assessment scan.

 NEBDN Apprenticeships

If a learner enrols on the NEBDN Dental Nurse Apprenticeship, then the NEBDN Recognition of Prior Learning must also be followed. The NEBDN policy states outright that no prior learning is recognised for their qualifications. This is justified as a means to maintain the validity and reliability of their qualifications, particularly in safeguarding patient safety in dental practices.

All training providers have a duty to Safeguard their Apprentices.

Prevent is about safeguarding our Apprentices to keep them both safe and within the law.

The Prevent Duty is not about preventing Apprentices from having political and religious views and concerns, but about supporting them to use those concerns or act on them in non-extremist ways.

1. Our Commitment

The government Counter-Terrorism and Security Act 2015, places a duty upon all education providers to have regard to the need to prevent people from being drawn into terrorism. This Prevent Duty forms part of the wider governments CONTEST counter terrorism strategy:

• Prevent terrorism – stop people becoming terrorists
• Pursue terrorism – disrupt and stop terror attacks
• Protect against terrorism – strengthen UK protection
• Prepare to deal with terrorism – mitigate impact of attacks that can’t be stopped.

The Prevent duty seeks to:

• Respond to the ideological challenge of terrorism and the threat we face from those who promote these views
• Prevent people from being drawn into terrorism and ensure that they are given appropriate advice and support.
• Work with a wider range of sectors where there are risks of radicalisation which needs to be addressed, including education, criminal justice, faith, charities, the internet and health.

2. Our Key Objectives

As a training provider ASA Training Ltd have a responsibility to ensure:

We promote and reinforce shared values

We listen and support our learners

We ensure our learners and team members are aware of their roles and responsibilities

We have ensured our team members have undertaken the relevant training in the Prevent Duty

Learners and Team members are aware of how to raise a concern

To embed and promote democracy, the rule of law, individual liberty and mutual respect and tolerance for those with different faiths and beliefs.

3. Scope

This policy relates to all team members and learners.

4. Leadership and Values

Prevent forms part of the Safeguarding agenda.  ASA Training Ltd’s Safeguarding agenda features throughout company meetings and the Safeguarding team are responsible for leading the Prevent initiative within our Safeguarding agenda and policy.

We provide an ethos which upholds core values of shared responsibility and wellbeing for all staff members, learners and visitors, promoting respect, equality, diversity and understanding.

We promote the companies mission statement and core British Values including respect, equality, diversity, democratic society, religious tolerance, learner voice and participation.

We promote team member and learner understanding of related issues which allows them confidence to deal with these effectively.

To comply with the Prevent Duty, we as providers are expected to show British Values in our management, teaching practice & general behaviours. British Values are defined as –

• Rule of Law, Individual Liberty, Mutual respect & tolerance of those from other backgrounds, religions, beliefs, Democracy, Compliance with the Equality Act & those protected by it

The protected characteristics in the Equality Act are –

• Age, Gender reassignment, Disability, Marriage & civil partnership, Pregnancy & maternity, Race, Religion or belief, Sex, Sexual orientation

Tutors / assessors understand  and embed British Values into the apprenticeship delivery journey to ensure learners are aware of them and understand what it means to be a successful learner and take part in life and Britain today.

Learners will also be required to understand how to keep themselves protected from risks associated with radicalisation, extremism, forms of abuse, grooming, bullying & staying safe online.

We also to work with employers to ensure learners are not exposed to risks associated with any of the above and adequate awareness of Prevent & British Values has taken place with workplace mentors, line managers or HR.

We have an open culture which allows freedom of speech and exploration of issues that affect learners locally, nationally & internationally. Providers are to operate a safe place for learners to communicate, but provide challenge where views or discussions become offensive, extreme or upsetting to others.

5. Teaching and Learning

Our team members undertake regular training to ensure they are up to date and current regarding Prevent.

Prevent awareness is embedded into our curriculums ensuring learners are made aware of the risks and are clear on the reporting process should they have any concerns.

Both allowing us to promote the Prevent strategy and British Values.

Understanding is monitored and evaluated through regular surveys.

Risks and concerns are discussed at regular reviews with learners so we can identify any concerns swiftly and take appropriate action.

6. How to raise a concern

If a team member, Employer or learner has concerns, they should ref to ASA Training Ltd’s Safeguarding Policy and Reporting Procedure.

If they feel they are in immediate danger they should contact the policy immediately.

Once a concern has been reported via the safeguarding process the designated officer (DO) will make a decision on escalating this to the local police.

The DO will support the Channel process.

It should be considered that a learner displaying indicators does not mean they will necessarily be at risk of radicalisation, but it may do so.

In all instances that concern a team member, employer or learner, they should be reported following the process, any concern will be risk assessed looking at the learners level of engagement, intent and capability.

7. Indicators

There is no single way of identifying who is likely to be vulnerable to being drawn into terrorism.

Factors that may have a bearing on someone becoming vulnerable may include:

• Loneliness or isolation leading to negative influence from other people or via the internet
• Drugs, gangs, violence and crime against them or their involvement in crime, e.g. race/hate crime, anti-social behaviour etc.
• Family tensions and breakdown, poverty, homelessness and lack of self-esteem
• Personal or political grievances or recent political or religious conversion
• Sexual exploitation, physical or mental abuse

8. Signs

• Have low self-esteem.
• Be confused about their faith, sense of belonging, or identity.
• Be victims of bullying or discrimination.
• Feel isolated or lonely.
• Be experiencing stress or depression.
• Be going through a transitional period in their life.
• Be angry at other people or the government.

APPENDIX A.

13a. If a learner raises a concern with a member of ASA Training ltd.

APPENDIX B.

13b. If a member of ASA Training Ltd has a concern regarding a learner

APPENDIX C.

13c. If a learner/parent/employer has a concern regarding a team member of ASA Training Ltd.

APPENDIX D.  13d.  If an Employer or Parent has a concern regarding a Learner/their child.

APPENDIX E 

13e. If a member of ASA Training Ltd observes a concern in the learners workplace.

APPENDIX F

13f. If a learner raises a concern in their working environment.

APPENDIX G 

Safeguarding/Prevent Recording Form

Please complete the form below if you have been notified of a safeguarding concern.

Please provide as much detail as possible.

Name of learner: _____________________________________________________________________________________

Workplace: __________________________________________________________________________________________

Name of person taking initial query: _______________________________________ Date of Record: _____________                                                 

APPENDIX H

Other relevant/associated documents and policies

Safeguarding Policy

Company Values and Mission Statement

Health and Safety Policy Statement

Equality and Diversity Policy and Statement

Social Media, Online Safety and Cyberbullying policies

Learner Wellbeing Policy

Harassment and Bullying Policy

Plagiarism Policy/Procedure – Staff and Learners

This policy is available for staff, learners, employers, witnesses and supporting mentors.

Identifying Plagiarism

The expertise of individual Assessors is the best safeguard against plagiarism, supported by appropriate technology where available. Check learner work for:

• the use of unfamiliar words
• grammar and syntax of a standard far higher than that demonstrated previously
• a discontinuous rise in the quality and accuracy of the learner’s work
• the use of texts familiar to the Assessor, but without appropriate referencing
• the use of American spellings and unfamiliar product names.

You might also:

• build an oral element into the assessment process, wherever appropriate, to check on understanding
• ask learners to elaborate on suspect passages within their work
• type a few selected phrases into a search engine such as Google
• pay particular attention to those learners who perform well in coursework but much less well in examinations and tests
• share concerns with colleagues: if everyone has the same suspicions about a particular learner, it would seem appropriate to apply rigorous checks to all of his or her work.

What can you do to help minimise the risk of plagiarism?

The most important thing you can do is contribute to a culture in which learners do not consider plagiarism an option.

You should:

• explain at induction what is meant by ‘plagiarism’ and how it will be monitored and policed
• explain, at an early stage of the course, the concepts of individual ownership of ideas and words, the ownership of electronic material and the difference between ‘intellectual property’ and ‘common knowledge’
• provide instruction in study skills, research skills, writing skills, time management skills and the use of a suitable referencing system to record and cite sources correctly
• use of referencing bibliographies
• provide learners with opportunities to discuss any problems they may encounter, support them at each step and provide them with the resources they need to do the work properly

Links to GDC Fitness to Practice

According to the updated “Student Professionalism and Fitness to Practice” 2024 document, all learners are required to adhere to the GDC standards of professionalism. This covers “Dishonesty or fraud which might include dishonesty in relation to your training, such as cheating and plagiarism”.

Please ensure that you are fully aware of the requirements under the “Student Professionalism and Fitness to Practice”, link below;

https://www.gdc-uk.org/docs/default-source/education-and-cpd/students-and-trainees/guidance-for-students/student-professionalism-and-fitness-to-practise-an-introduction-for-students.pdf?

Sanctions for non-compliance include:

• Verbal Warning or Written Warning
• Conditions for Improvement & Expectation
• Undertakings/Restrictions to Clinical Practice
• Suspension
• Dismissal

The use of Artificial Intelligence (AI), is strictly prohibited, as per our separate AI policy.

This policy is available for staff, learners, employers, witnesses and supporting mentors. It is the responsibility of anyone involved in the training of all learners to report any instance of plagiarism or use of AI. Please follow the procedure below if you believe a learner is cheating or plagiarising within the evidence that they are submitting towards their qualification.

For any enquiries relating to this policy/procedure, please contact our Head of Quality & Apprenticeships on; claire@asatraining.co.uk

All dental professionals have a professional responsibility to report any treatment or behaviour which might pose a risk to patients or colleagues.

A key part of this is ensuring that there is a culture of openness and honesty. Raising a concern should be input that is welcomed rather than tolerated. It is vital that staff raising a concern are listened to and that the information is acted upon. This type of environment benefits patients, colleagues, and the wider health service.

This policy should be used in line with the Safeguarding and Whistleblowing policies.

If a learner feels that a patient is at risk, then they should follow the guidelines outlined below:

1. Is the patient at risk? If so, why? Learner records the reasons why they feel a patient is at risk.
2. Learner reports (in writing) that a patient is at risk to their Educational Practitioner.
3. Educational practitioner reports the concerns to the Head of Quality & Apprenticeships.
4. Head of Quality & Apprenticeships investigates the concerns of the learner. If the issue is deemed “patient at risk” then the whistleblowing policy will be followed.

Clinical/Technical

If a learner feels that they are at risk from clinical or technical issues, we have a duty of care to record this.

Process:

1. Educational Practitioner to discuss with learner, at every appointment, if there have been any accidents or incidents that have been logged since their last appointment.
2. Educational Practitioner records the details of accident/incident, before emailing the details to Head of Quality & Apprenticeships.
3. Head of Quality & Apprenticeships adds the accident/incident to ASA Training log.

Log below.

Accident/Incident Log

This policy is available for staff, learners, employers, witnesses and supporting mentors.

Purpose of the policy

The purpose of this policy is to set out the steps you, your learners or other personnel, follow when reporting suspected or actual cases of malpractice and our responsibilities in dealing with such cases. It is also in place to review those processes which led to the suspected or actual case of malpractice and to support you in any investigations. We will act upon any reports of suspected or actual cases of malpractice we receive about your activities, your personnel or your learners which may affect the integrity of the training programme(s) and quality assurance systems.

We also have a professional responsibility to report non-adherence to the General Dental Council.

Definitions

Malpractice is essentially any activity or practice that deliberately contravenes regulations and compromises the integrity of the assessment process and/or the validity of certificates. For the purpose of this policy this term also covers professional misconduct.

The categories listed below are examples of centre and candidate malpractice. Please note that these examples are not exhaustive and are guidance on our definition of malpractice:

• Forgery of evidence
• Plagiarism of any nature by learners
• Submission of false information to gain a qualification
• Discriminatory, bullying or harassing behaviour
• Unprofessional conduct
• Behaviour likely to endanger the health or safety of the public
• Breach of confidentiality of patients, learners or organisation
• Failure to meet the awarding body or regulator’s requirements
• Falsifying assessment records

Reporting procedure

Anybody identifying cases of malpractice should report them to the Head of Quality & Apprenticeships immediately. We have to investigate all cases of malpractice in liaison with the parties concerned. If an investigation finds evidence of maladministration, we will have to take the necessary steps to ensure that the learners’ interests are protected as far as is reasonably possible. This may include making arrangements for re-assessment. If the investigation reveals that certification is inappropriate we will have to take the necessary steps to revoke the certification in order to protect the health and safety of the public.

Following contact by telephone, you should submit your own report accompanied by supporting evidence. Reports must include:

• The learner’s name
• Staff details (name, job role) if they are involved in the case
• The title of the programme affected or nature of the service affected
• The date(s) suspected or actual malpractice occurred
• The full nature of the suspected or actual malpractice

Post, email or fax your completed report to our Centre Management Team as soon as possible.

• We will acknowledge your report within 5 working days of receipt
• We will arrange for appropriate personnel to review the report and commence the investigation
• We will aim to action and resolve all investigations within 14 working days of receipt of the report
• We will advise you of the outcome of our investigation within 5 working days of making our decision

When we receive your report, we will allocate a panel comprising ASAT Ltd senior personnel and, where appropriate, external advisors such as external verifiers. The panel will review the report and supporting evidence and carry out the investigation.

The investigation process

During the investigation the panel’s review may involve:

• A request for further information
• Interviews (face to face or by telephone) with personnel involved in the investigation
• Arranging for ASAT Ltd staff to carry out a workplace visit
• Informing the Regulatory/Awarding body. Where applicable, we’ll inform the appropriate regulatory authorities of any investigation into suspected or actual cases of serious malpractice and will agree the appropriate course of remedial action with them.

We will make informed decisions based on the evidence.

We will protect the identity of the ‘informant’ as required.

We will also share information with other external parties, as required.

Learner malpractice

If the investigation confirms that learner malpractice has taken place, we may have no alternative but to impose one or more of the following sanctions on the candidate. In cases of Training Dental Nurses this will then be sign posted to the Fitness to Practice process.

Please note that this list is not exhaustive:

• Disallowing all or part of the candidate’s assessment evidence
• Disallowing all or part of the candidate’s external assessment marks
• Not issuing the candidate’s certificate(s)
• Not accepting any further registrations for the candidate
• Disqualification from the programme

In cases of malpractice by learners, final results may be void if the case is proven and any certificates which have already been issued may be deemed to be invalid and will need to be returned to the awarding body.

Plagiarism and Identification of Learners

Plagiarism is defined as submitting as one’s own work, irrespective of intent to deceive, that which derives in part or in its entirety from the work of others without due acknowledgement.

Examples of plagiarism include Copying (using another person’s language and/or ideas as if they are a candidate’s own), by:

• Quoting verbatim another person’s work without due acknowledgement of the source;
• Paraphrasing another person’s work by changing some of the words, or the order of the words, without due acknowledgement of the source;
• Using ideas taken from someone else without reference to the originator;
• Cutting and pasting from the Internet to make a pastiche of online sources;
• Submitting someone else’s work as part of a candidate’s own without identifying clearly who did the work. For example, buying or commissioning work via professional agencies such as ‘essay banks’, or not attributing research contributed by others to a joint project.

Plagiarism might also arise from colluding with another person, including another candidate, other than as permitted for joint project work (i.e. where collaboration is concealed or has been forbidden). A candidate should include a general acknowledgement where he or she has received substantial help, for example with the language and style of a piece of written work.

Plagiarism can occur in respect to all types of sources and media:

• Text, illustrations
• Material downloaded from websites or drawn from manuscripts or other media
• Published and unpublished material, including handouts and other students’ work.

Acceptable means of acknowledging the work of others (by referencing, in footnotes, or otherwise) vary according to the subject matter and mode of assessment.

Failure to conform to the expected standards (e.g. by not referencing sources) in examinations may affect the mark given to the candidate’s work. In addition, suspected cases of the use of unfair means (of which plagiarism is one form) will be investigated and may be brought to the attention of the awarding body and any other professional bodies deemed necessary.

All learners undertaking exams either written or online will be asked to produce a valid form of Identification. This can either be your passport or driving licence. Failure to produce this identification will mean that you will be turned away from the exam and asked to attend on another day with the required documentation.

Links to GDC Fitness to Practice

According to the updated “Student Professionalism and Fitness to Practice” 2024 document, all learners are required to adhere to the GDC standards of professionalism. This covers “Dishonesty or fraud which might include dishonesty in relation to your training, such as cheating and plagiarism”.

Please ensure that you are fully aware of the requirements under the “Student Professionalism and Fitness to Practice”, link below;

https://www.gdc-uk.org/docs/default-source/education-and-cpd/students-and-trainees/guidance-for-students/student-professionalism-and-fitness-to-practise-an-introduction-for-students.pdf?

Sanctions for non-compliance include:

• Verbal Warning or Written Warning
• Conditions for Improvement & Expectation
• Undertakings/Restrictions to Clinical Practice
• Suspension
• Dismissal

The use of Artificial Intelligence (AI), is strictly prohibited, as per our separate AI policy.

This policy is available for staff, learners, employers, witnesses and supporting mentors. It is the responsibility of anyone involved in the training of all learners to report any instance of plagiarism or use of AI. Please follow the procedure below if you believe a learner is cheating or plagiarising within the evidence that they are submitting towards their qualification.

For any enquiries relating to this policy/procedure, please contact our Head of Quality & Apprenticeships on; claire@asatraining.co.uk

In line with the  GDC “Standards for Education” document, it is a requirement that all trainee dental nurses are identified as this appropriately.

Requirement:

“Providers must have systems in place to inform patients that they may be treated by students and the possible implications of this. Patient agreement to treatment by a student must be obtained and recorded prior to treatment commencing”.

To ensure that this requirement is met, ASA expect one of the following options be available for all trainee dental nurses undertaking their qualification with us;

1. Learner must wear a name badge clearly stating that they are a “Trainee Dental Nurse”.
2. Clear signage within the reception area and clinical areas, that trainee dental nurses are working within the practice.

Under GDC requirements, consent must be gained by each patient, to be treated by a trainee dental nurse and this consent must be recorded to their individual patient records.

Under Standard 1 – Protecting patients, all patients that are treated by a trainee dental nurse, must be aware of this and have consented to this.

Monitoring Procedure:

As a training provider, we have a responsibility to ensure that this requirement is being met. Regular monitoring will take place to ensure this using one or all of the procedures below;

1. At every scheduled appointment with the lead educational practitioner, the learner will be asked to show their name badge.
2. If a name badge is not the preferred option, the learner will be asked to show the educational practitioner the appropriate signage around the practice whilst on their scheduled remote video meetings.
3. Spot checks will also be conducted by the Internal Quality team to ensure that this requirement is met.

Non-compliance:

If the dental practice fails to meet this requirement, ultimately this overall risk to the learner is removal from the training course. A resolution process will be followed to support and guide the practice, where appropriate, before we remove a learner from the training course.

All employers must sign the Training Plan, to agree that they will adhere and uphold this requirement. The training plan is in place for every new learner and will be signed before any new learner begins their training course.

Copy of recording document:

ASA is committed to providing a high-quality Information, Advice and Guidance service. This policy provides details of our service and the standards of delivery.

We aim to provide an independent Information, Advice and Guidance (IAG) service to individuals wishing to consider accessing the company’s training programmes, those already in learning with the company, and those who work for the company.

A high-quality Information, Advice and Guidance service is key to the success of the organisation; it ensures we have students on programmes suited to their needs and contributes to our retention and success rates. It also ensures that we have well informed employees who are able to offer effective (IAG) and contributes to our employee retention rates. The quality of the service is monitored through performance data and feedback from users.

The company supports the concept of lifelong learning and we will endeavour to help individuals make informed choices about training, their career and development opportunities in the context of their working lives and leisure activities.

Our Information, Advice and Guidance will be:

• Timely and in a form that is easily understood
• Independent, confidential and focussed on the needs of the individual
• Undertaken by employees trained to offer appropriate Information, Advice and Guidance
• Able to provide access to a range of agencies for specialist support
• Free from stereotyping in accordance with our Equality & Diversity Policy
• Easily accessible and clearly defined
• Free of charge to the users
• Subject to evaluation and continuous improvement encouraging individuals to get the most from the process

The service offer to students:

• Open access to information on education, training and career advice/opportunities in a range of formats
• An initial assessment to help identify students’ skills and aptitudes
• A trained ASA Employee to discuss student needs and aspirations and to plan for the achievement of goals
• Provision of the services of a trained employee of ASA
• Signposting to other agencies who may be able to help students in achieving their goals
• The opportunity for students to spend time with an employee of ASA to review and revisit their goals and discuss progress and next steps
• Access to a trained ASA employee to answer queries and provide advice by phone/email

The service offer to employers:

• Information and advice on the courses and qualifications we offer
• Information and advice on our bespoke training packages and how we can tailor these specifically to meet employer needs
• Advice on unit content and selection where qualifications are delivered
• Information on the cost of training and any funding which may be available to support the costs
• Information on their students’ progress whilst on their learning programme
• Information and advice on progression opportunities
• Signposting to other agencies who may be able to help employers in achieving their goals
• Opportunity to feedback on services received via regular employer surveys, in line with our Quality Assurance Policy

The service offer to employees:

• Information and advice about job roles and responsibilities during the recruitment process
• Structured information about the business during induction activities
• Regular information and advice through internal employee development
• Regular information and advice on business and personal performance and expectations through team meetings, one to one meetings and appraisals with line manager
• Regular business updates in a range of formats
• Opportunity to feedback on services received via our annual employee survey
• Completion of IAG qualifications

All service users can expect:

• A service delivered to recognised national standards
• A clear explanation of the Information, Advice and Guidance services we offer
• Trained and experienced employees who will treat all with respect and dignity
• A timely response to requests for information
• Up to date information on education, training and career opportunities/career advice in a range of formats
• Information on the cost of training and any funding which may be available to support the costs
• All information will be treated as strictly confidential in line with the General Data Protection Regulations (GDPR); see Data Protection Policy

Contents

1. Purpose
2. Objectives
3. Scope
4. Potential Health and Safety Risks
5. Our Responsibilities
6. Promoting Health and Safety and Our Policy
7. Key Contact and Individual Responsibilities
8. Training
9. Reporting a Concern
10. Other relevant/associated documents and policies

1. Purpose

This policy sets out ASA Training Ltd.’s Health and Safety Policy, who this applies to and the measures in place to ensure learners and team members are aware of Health and Safety risks and how to remain safe.

All ASA Training Ltd team members have a responsibility to safeguard its learners and have an important role in identifying any Health and Safety concerns that may arise during their time in training with us.

This policy has been designed to ensure all team members and learners are aware of how to identify a Health and Safety concern, and how to report these, it is also in place to reduce risk to its team members and learners.

2. Objectives

To ensure team members and learners of ASA Training Ltd are aware of and understand Health and Safety.

To ensure all parties are aware of their responsibilities regarding Health and Safety and raising/reporting a concern.

To ensure all parties are able to identify a Health and Safety concern.

3. Scope

This policy applies to safeguarding all our learners and team members.

4. Potential Health and Safety Risks

Slips, Trips and Falls

Fire

Hazardous Substances

Electrical Dangers

Noise Hazards

Lack of PPE

5. Our Responsibilities

As an employer and a training provider we carry a responsibility to ensure that all our team members, learners, children, young people and adults at risk are protected from harm, informed and educated about any potential risk to their wellbeing and welfare, they understand how to seek help and who to contact and who they can talk to.

We must ensure concerns are dealt with in a timely manner and in an appropriate manner.

We must ensure all our team members have a good knowledge and understanding of what a potential Health and Safety concern is and how to identify them, provide support and guidance and how to escalate a concern.

We must also ensure we are educating our learners to identify potential Health and Safety concerns they may be at risk of.

We must ensure our learners and team members feel safe in the workplace and online.

We must ensure learners and team members have confidence in us to address concerns raised.

We must ensure we have suitable arrangements in place for raising a concern.

6. Promoting Health and Safety and Our Policy

It is the policy of ASA Training ltd to comply with the terms of the Health and Safety at Work Act 1794 and subsequent legislation and to provide and maintain a healthy and safe working environment for it team members and learners.

ASA Training Ltd are committed to ensuring that its training activities and the actions of its team members and learners, whilst maintaining occupational realism, do not hazard the health, safety and welfare at work of other colleagues, learners or any other persons who may be affected as is reasonable practical.

As an employer we promote our Health and Safety policy to all ASA Training Ltd team members, ensuring that regular training is undertaken to be able to understand and identify risks, the steps to take when raising a concern and who to contact, Health and Safety s monitored regularly in the workplace and team members undertake training to ensure regular development and knowledge is maintained.  All team members are issued with a copy of this policy to refer to and use when dealing with a concern.

As a training provider we embed safeguarding subjects and training modules into our curriculums, raising awareness to our learners of Safeguarding risks and providing a better understanding of why these are relevant to them, this includes Health and Safety in the Workplace.  Within these modules is clear guidance on who they should contact if they have a concern and a link to our Safeguarding Policy.  This training enables learners to be further educated in Health and Safety areas and also allows them to be educated to identify the signs themselves in their everyday work settings and personal lives, which equips them with the skills and understanding of safeguarding other people.  Welfare of our learners is monitored at each appointment through the delivery team, and also discussed at regular Progress Reviews with the Employer as well.  A copy of our Health and Safety Policy, plus other relevant associated policies are issued to all learners and are stored on each learners e-portfolio system, for them to access at any time.

7. Key Contact and Individual Responsibilities

Work Place Health & Safety designated officer :

John Turner

01604 871340

07494 984858

john@asatraining.co.uk

Mental Health First Aider and Learner Welfare designated officer:

Kirsty Gibbs & Claire Lamb

01604 871340

kirsty@asatraining.co.uk

claire@asatraining.co.uk

Other Safeguarding Designated Officers:

DSL

Kirsty Gibbs

01604 871340

kirsty@asatraining.co.uk

DDSL

Claire Lamb

07494 984683

claire@asatraining.co.yk

8. Training

ASA Training Ltd will provide employees with the training necessary to carry out their tasks safely.  However, if an employee is unsure how to perform a tasks or feels it would be dangerous to perform a specific job, then it is the employees duty to report this to their line manager and/or health and safety officer.

An effective Health and Safety Programme requires continuous communication between workers at all levels, it is therefore every team members responsibility to report any situation immediately, which could jeopardise the well-being of themselves or any other person.

ASA Training Ltd provide all learners with basic training and understanding of Health and Safety in the workplace.  As a training provider we also ensure learners have had a robust induction within their workplace and their employer has carried out mandatory Health and Safety requirements to ensure learners are safe in the work setting.

We risk assess each learners workplace, check that all workplaces have a Covid-19 risk assessment in place and we carry out a pre attendance check to ensure minimum risk to any team members when visiting, team members must familiarise themselves with each workplace procedure and requirements.

9. Reporting a Concern

Should any member of ASA Training Ltd at any time feel at risk or observe a Health and Safety concern in the workplace they must report this to the designated Health and Safety officer and/or their line manager.

Learners can use the Safeguarding reporting process if they wish to report a concern to us regarding their work setting.

ASA team members can use the Safeguarding process to report a concern regarding learner welfare in their work setting.

Each learner provides an emergency contact at induction, so we can inform this person of any accident a learner may have had, whilst with a member of ASA training Ltd.

10. Other relevant/associated documents and policies 

Safeguarding Policy

Company Values and Mission Statement

Prevent Policy

Social Media, Online Safety and Cyberbullying policies

Equality and Diversity Policy

Learner Wellbeing Policy