Terms and Conditions

We operate under a comprehensive set of terms and conditions designed to ensure a transparent and positive experience for everyone

TERMS AND CONDITIONS OF ENROLMENT AND WEBSITE USE

Index

1. Terms and Conditions
2. Equal Opportunities Learner’s Charter
3. Our Commitment to Equal Opportunities
4. Standards of Service
5. Customer Expectations
6. Malpractice Policy and Procedure
7. Reasonable Adjustments Policy
8. Safeguarding Learner Policy
9. Areas for Appeal for CPD Courses
10. Data Protection Act 2018 Policy
11. Disclaimer

The next few pages outline the terms and conditions of our agreement, covering: (a) how you use our website; and (b) how we deliver our learning programs to you.

Whilst the full terms and conditions of this contract are set out further below, we have summarised the key terms of the contract as follows. Please note that this summary does not form part of our contract and if there is any conflict then you will need to rely on the contract itself.

1. DEFINITIONS

“Academy”, “LIA”, “we”, “us”, “our” means Alsaihati Intercultural Center Ltd trading as London Intercultural Academy.

“Learner”, “you”, “your” means any individual enrolling in or accessing our courses.

“Course” means any training programme, CPD course, online module, or learning material provided.

“Website” means www.liacademy.co.uk and associated domains.

“Partner Institution” means any third-party organisation delivering course content.

2. CONTRACT FORMATION

2.1 A legally binding contract is formed when:

• You complete enrolment; and
• Payment (if applicable) is confirmed; and
• We issue written confirmation.

2.2 You must be at least 18 years old to enrol. Individuals aged 16–17 may enrol only with verified parental or guardian consent.

2.3 These Terms constitute the entire agreement between you and the Academy and supersede prior communications.

3. CONSUMER RIGHTS

3.1 Nothing in these Terms excludes or limits rights under:

• Consumer Rights Act 2015
• Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013
• Consumer Protection from Unfair Trading Regulations 2008

3.2 If you are a consumer, statutory rights cannot be excluded or restricted.

       4. COURSE DELIVERY 

4.2 We may make reasonable changes to a Course where necessary to:

• improve quality;
• reflect legal or regulatory changes;
• address operational requirements beyond our control.

4.3 Any changes will:

• not materially reduce the overall learning outcomes;
• not significantly alter the nature of the Course purchased.

4.4 Where a change materially impacts the Course, you will be entitled to:

• • a transfer to an alternative course; or
  • a pro-rata refund.

      5. CERTIFICATION AND OUTCOMES

5.1 Upon successful completion, learners will receive a certificate issued by the Academy.

5.2 Unless expressly stated otherwise:

• the certificate is not a regulated qualification;
• it is not accredited by a UK awarding body;
• it does not confer any professional licence or statutory status.

5.3 Any reference to “certification” refers solely to:

• confirmation of course completion; and
• internal verification of authenticity.

5.4 We do not guarantee:

• employment outcomes;
• professional advancement;
• recognition by third-party organisations.

5.5 Learners are responsible for verifying whether a Course meets their professional or regulatory requirements.

      6. FEES AND PAYMENT

6.1 Fees are displayed at enrolment and include VAT where applicable.

6.2 Payment must be made using approved methods.

6.3 We reserve the right to suspend access for non-payment.

      7. REFUNDS

7.1 Cooling-Off Period (Consumers)
You have the right to cancel your purchase within 14 days of the contract being formed.

7.2 Digital Content
Where you request immediate access to digital content, you expressly consent to performance beginning within the cooling-off period and acknowledge that your right to cancel will be lost once access begins.

7.3 Refund Entitlement (Post-Cooling-Off Period)

Refunds shall be issued strictly as follows:

• 100% refund:
  Where no course content has been accessed and cancellation is requested within 14 days.
• 50% refund:
  Where cancellation occurs after 14 days but before 25% of course content has been accessed.
• No refund:
  Where more than 25% of course content has been accessed, or where assessments have been submitted.

7.4 Academy Cancellation
Where we cancel a course, you will receive a full refund or the option to transfer.

7.5 Statutory Rights
Nothing in this clause affects your statutory rights.

8. LEARNER OBLIGATIONS

You agree to:

• Provide accurate registration information.
• Maintain account confidentiality.
• Not share login credentials.
• Not reproduce, distribute, or commercially exploit materials.
• Comply with assessment regulations.
• Behave respectfully toward staff and learners.

Academic misconduct may result in suspension or removal.

9. INTELLECTUAL PROPERTY

9.1 All materials are owned by the Academy or licensed to it.

9.2 You receive a limited, non-transferable, non-exclusive licence for personal, non-commercial use.

9.3 You may not:

• Copy;
• Record;
• Redistribute;
• Sell;
• Modify materials without written consent.

10. WEBSITE USE

You must not:

• Access accounts without authorisation;
• Circumvent security features;
• Use automated scraping tools;
• Upload malicious software;
• Engage in unlawful or fraudulent conduct.

We may suspend access for breach.

11. DATA PROTECTION

11.1 We process personal data in accordance with:

• Data Protection Act 2018
• UK GDPR

11.2 Full details are contained in our Privacy Policy.

11.3 International transfers occur only where lawful safeguards (e.g., UK IDTA or adequacy decisions) are in place.

12. SAFEGUARDING

12.1 We comply with:

• Care Act 2014
• Children Act 1989 & 2004
• Safeguarding Vulnerable Groups Act 2006
• Working Together to Safeguard Children (Statutory Guidance)

12.2 All safeguarding concerns must be reported immediately to the Designated Safeguarding Lead.

13. REASONABLE ADJUSTMENTS

13.1 We comply with Equality Act 2010.

13.2 Learners may request reasonable adjustments.

13.3 Adjustments must:

• Be proportionate;
• Not compromise learning outcomes;
• Not provide unfair advantage.

Requests should be made at least 28 days before assessment where possible.

14. LIMITATION OF LIABILITY

14.1 Nothing excludes liability for:

• Death or personal injury caused by negligence;
• Fraud or fraudulent misrepresentation;
• Any liability that cannot be excluded by law.

14.2 Subject to 14.1:

We are not liable for:

• Indirect or consequential losses;
• Loss of business or opportunity.

14.3 Our total liability shall not exceed the total fees paid for the relevant Course.

14.4 We do not guarantee uninterrupted access to digital content.

15. INDEMNITY

You agree to indemnify us for losses arising from:

• Your breach of these Terms;
• Your unlawful conduct;
• Your misuse of materials.

This does not apply where loss arises from our negligence.

16. TERMINATION

16.1 We may suspend or terminate access where:

• There is breach of these Terms;
• Fraudulent behaviour occurs;
• Payment is not received.

16.2 Upon termination:

• Access ceases immediately;
• No refund is due unless required by law.

17. COMPLAINTS

17.1 Complaints must first be raised with the Course Administrator.

17.2 If unresolved, complaints may be escalated to the Director.

17.3 If you remain dissatisfied, you may pursue Alternative Dispute Resolution (ADR). Details are available on request.

Nothing restricts your right to pursue claims through UK courts.

18. DISPUTE RESOLUTION

18.1 These Terms are governed by the laws of England and Wales.

18.2 If you are a consumer, disputes may be brought in the courts of your place of residence within the UK.

18.3 Where both parties agree, disputes may be referred to arbitration seated in London under the Arbitration Act 1996.

This clause does not restrict statutory consumer rights.

19. FORCE MAJEURE

We are not liable for failure or delay caused by events beyond reasonable control including:

• Acts of God;
• Pandemic;
• Government restrictions;
• Internet outages.

20. SEVERABILITY

If any provision is deemed unenforceable, remaining provisions remain in effect.

21. ASSIGNMENT

We may assign rights and obligations to a successor entity.

You may not assign rights without written consent.

22. VARIATION

We may amend these Terms. Material changes will be notified.

Continued use constitutes acceptance.

(a) Website Use

 

1. Content Ownership and Use
   1. We are licensed to use all the content on our website. Generally, the content is owned by our Partner Institutions, but we control access to it. We ask that you please respect the content.
   1.2. You are not allowed to commercialise our website or the content on it (i.e., you are not allowed to make money or attract advertising to another business by using our website).
   1.3. You can share our Homepage URL with others, but if you link to part of our website or copy and paste parts of it, you must acknowledge where the content comes from.
   1.4. We are not responsible for the content or any viruses on sites that we may link to.
   1.5. You are not allowed to develop, support, or use software, devices, or scripts to scrape the content on the website.
2. Privacy and Data Protection
   We comply with all relevant laws on Privacy and Data Protection. This means we will only collect or process personal information for specific and lawful purposes, won’t collect more than necessary, won’t keep it longer than necessary, will keep it as accurate as possible, and will protect it as best as we can.

(b) Using Our Website

1. Acceptance and Restrictions
   1. By using this Website and the Online Content and Courses, you confirm that you have read, agree to, and are in compliance with these Terms and the Policies (each as amended from time to time). Use of the Website and access to the Online Content and Courses by anyone under the age of 16 is strictly prohibited.

1.2. Your use of and access to this Website and the Online Content and Courses are subject to the following conditions (“Acceptable Use Conditions”). Failure to comply with any one of these conditions constitutes a breach of these Terms. The Acceptable Use Conditions are as follows:

1.2.1. You agree to use the Website and access the Online Content and Courses only for lawful purposes, and your use is in no way unlawful or fraudulent and does not damage us or our Institutional Partners either reputationally or financially.
1.2.2. You agree not to use or access the Website or Online Content and Courses to contact, harm, or attempt to harm minors in any way.
1.2.3. You agree not to distribute all or any part of the Website or Online Content and Courses in any medium without our prior written consent, unless such distribution is offered through the functionality of the Website and permitted by these Terms.
1.2.4. You agree not to alter or modify any part of the Website or the Online Content and Courses.
1.2.5. You agree not to access the Website or Online Content and Courses through any technology other than the software provided by us or enabled via APIs or other generally available third-party web browsers such as Chrome, Firefox, or Safari.
1.2.6. You agree not to (and will not attempt to) circumvent, disable, or interfere with any security features of the Website or features that: (i) prevent or restrict use or copying of content; or (ii) enforce limitations on you, the use of the Website or access to the Online Content and Courses.
1.2.7. You agree not to knowingly transmit any data or submit any content containing viruses, Trojan horses, worms, time-bombs, key-stroke loggers, spyware, adware, or any other harmful programs or similar computer code designed to adversely affect the operation of any computer software or hardware.
1.2.8. You agree not to use or access the Website or Online Content and Courses for any commercial purposes or for the benefit of any third party, including but not limited to:
1.2.8.1. The sale of access to the Online Content and Courses or any associated content.
1.2.8.2. The solicitation of business in the course of trade or in connection with a commercial enterprise.
1.2.8.3. The solicitation of any Visitors or Learners of the Website with respect to their content for commercial purposes.
1.2.9. You agree to use the Website and access the Online Content and Courses in a way that does not infringe the rights of third parties or restrict or prevent others’ use and enjoyment of the Website, Online Content, and Courses.
1.2.10. You agree not to ask for, collect, or harvest any personal data of any Visitor or Learner of the Website or Online Content and Courses.
1.2.11. You agree not to post, upload, email, or otherwise transmit chain letters, surveys, calls to action, junk mail, pyramid schemes, incentives (monetary or click-based), spamming, or bulk communications of any kind, whether for commercial or non-commercial purposes.
1.2.12. You will not copy, reproduce, create derivative works of, distribute, transmit, broadcast, display, sell, license, or otherwise exploit any content on the Website (including the Online Content and Courses) for any purpose other than as permitted by these Terms without our prior written consent.
1.2.13. You agree not to use the Website or Online Content and Courses in any manner intended to damage, disable, overburden, or impair any of our servers or the network(s) connected to our servers, or to infringe any requirements, procedures, policies, or regulations of any servers or networks connected to our website.
1.2.14. You agree not to use any high volume, automated, or electronic means to access the Website or Online Content and Courses (including robots, spiders, or scripts).
1.2.15. You agree not to frame the Website or Online Content and Courses, place pop-up windows over its pages, or otherwise affect the display of its pages.
1.2.16. You agree not to access or attempt to access any other Visitor or Learner’s account or falsely state, impersonate, or otherwise misrepresent your identity, including misrepresenting your affiliations with a person or entity.
1.2.17. You agree not to force headers or otherwise manipulate identifiers to disguise the origin of any communication transmitted through the Website.
1.2.18. You agree not to send, knowingly receive, submit, download, use, or re-use any material that does not comply with these Terms and the Policies.

1.3. We grant the operators of public search engines permission to use spiders to copy materials from the site solely for creating publicly available searchable indices of the materials, but not caches or archives. We reserve the right to revoke these exceptions at any time.

1.4. You acknowledge and agree that the form and nature of the Website and Online Content and Courses may change from time to time without prior notice to you.

1.5. While we strive to ensure the Online Content and Courses are of high quality, you understand and acknowledge that you may be exposed to content from our Partner Institutions that could be factually inaccurate, offensive if taken out of context, indecent to certain people, or otherwise objectionable. We are not responsible (legally or otherwise) for any claims related to this type of content.

1.6. You acknowledge and agree that we may stop providing the Website, Online Content, and Courses (or any part thereof) to you or to Learners generally, either permanently or temporarily, at our sole discretion, without prior notice.

1.7. You agree that you are solely responsible for any breach of your obligations under these Terms and for the consequences of that breach, including any loss or damage that we or any third party may suffer.

(c) Registration and Accounts

1. Creating and Maintaining Accounts
   1. Any visitor can browse the Website. However, to fully engage with all activities, including Online Content and Courses, you must create a personal Learner Account by providing a name, email address, and password. You agree to keep your access details confidential and not share them with others.
   1.2. During account setup, you might need to provide additional details such as your date of birth and location. This information helps personalize your experience and connect with other Learners.
   1.3. You commit to ensuring that all information related to your Learner Account is accurate, up-to-date, and complete. You are responsible for keeping your account details secure and updated.
   1.4. By registering for a Learner Account, you agree to:
   1.4.1. Maintain a single Learner Account and not create multiple accounts.
   1.4.2. Not allow others to use your Learner Account.
   1.4.3. Refrain from cheating or sharing solutions for assignments and exams.
   1.4.4. Report any observed cheating or breaches of these Terms to the Course Administrator immediately.
   1.5. If you violate any of these terms, we may restrict or revoke your access to the Online Content and Courses.

(d) Course Providers

1. Access and Terms
   1. We may offer Online Content and Courses through Partner Institutions and other organizations (collectively, “Course Providers”).
   1.2. Access to these resources may be through your Learner Account. Courses provided by Course Providers may have additional terms and conditions which you must comply with.

(e) Payment and Fees

1. Payment Terms
   1. Some Online Content and Courses may require payment or enrollment fees. Details of any applicable fees will be provided at the time of enrollment or purchase.
   1.2. You agree to pay all fees associated with your use of the Website and access to the Online Content and Courses. Payments must be made through the methods we specify, and you are responsible for providing accurate and complete payment information.
2. Refunds and Cancellations
   1. Refunds, if applicable, will be processed in accordance with our refund policy, which is provided separately and may vary based on the Course Provider or type of content.
   2.2. You may cancel your enrollment or subscription according to the terms specified at the time of purchase. Some fees may be non-refundable, and details will be clearly communicated to you.
3. Billing Disputes
   1. If you believe there is a discrepancy or error in your billing, you must notify us within thirty (30) days of the date of the charge. Failure to notify us within this period will result in waiver of any disputes related to the charge.

(f) Intellectual Property

1. Ownership and Licensing
   1. All intellectual property rights in the Website, Online Content, and Courses, including but not limited to copyrights, trademarks, and patents, are owned by us or our licensors.
   1.2. You are granted a limited, non-exclusive, non-transferable, revocable license to access the Website and Online Content and Courses for personal, non-commercial use only. Any other use is prohibited without our prior written consent.
2. Content Submission
   1. By submitting content to the Website or any Course (e.g., assignments, comments, feedback), you grant us a perpetual, irrevocable, non-exclusive, royalty-free license to use, reproduce, modify, publish, and distribute such content.
   2.2. You represent and warrant that you own or have the necessary rights to the content you submit and that it does not infringe any third-party rights.

(h) Disclaimers and Limitation of Liability

1. Disclaimers
   1. The Website and Online Content and Courses are provided on an “as-is” and “as-available” basis. We make no representations or warranties of any kind, express or implied, regarding the availability, accuracy, or reliability of the Website or Online Content and Courses.
   1.2. We do not guarantee that the Website will be uninterrupted or error-free, nor do we guarantee that any defects will be corrected.
2. Limitation of Liability
   1. To the fullest extent permitted by law, we will not be liable for any indirect, incidental, consequential, or punitive damages arising out of or related to your use of the Website or Online Content and Courses.
   2.2. Our total liability for any claims arising out of or related to these Terms or your use of the Website will be limited to the amount you paid for access to the Online Content and Courses, if applicable.

(i) Indemnification

1. Your Responsibilities
   1. You agree to indemnify and hold us, our affiliates, and their respective officers, directors, employees, and agents harmless from and against any claims, liabilities, damages, losses, and expenses, including reasonable attorneys’ fees, arising out of or related to:
   1.1.1. Your use of the Website or Online Content and Courses.
   1.1.2. Your violation of these Terms or any applicable law.
   1.1.3. Any content you submit or post on the Website.

(j) Changes to Terms

1. Modifications
   1. We may update or modify these Terms from time to time. Any changes will be effective upon posting the revised Terms on the Website.
   1.2. Your continued use of the Website and Online Content and Courses after such changes constitutes your acceptance of the modified Terms.
2. Notification
   1. We will make reasonable efforts to notify you of significant changes to these Terms. It is your responsibility to review the Terms periodically for any updates.

(k) Governing Law and Dispute Resolution

1. Governing Law
   1. These Terms and any disputes arising out of or related to these Terms will be governed by and construed in accordance with the laws of the jurisdiction in which we are based, without regard to its conflict of law principles.
2. Dispute Resolution
   1. Any disputes arising out of or related to these Terms will be resolved through binding arbitration in accordance with the rules of the United Kingdom.
3. (l) Miscellaneous
4. Severability
   1. If any provision of these Terms is found to be invalid or unenforceable, the remaining provisions will continue to apply.
5. Entire Agreement
   1. These Terms constitute the entire agreement between you and us regarding your use of the Website and Online Content and Courses and supersede any prior agreements or understandings.
6. Assignment
   1. We may assign or transfer our rights and obligations under these Terms without restriction. You may not assign or transfer your rights or obligations under these Terms without our prior written consent.
7. Waiver
   1. Our failure to enforce any provision of these Terms will not constitute a waiver of that provision or any other provision.

 

Equal Opportunities Learner’s Charter

“Everyone has a part to play in ensuring we achieve equality of opportunity. We believe

that a positive attitude towards equality and diversity is right for our people, our clients and our business suppliers. This means that we must encourage all our people to welcome diversity and respect each person’s individuality”.

 

Alsaihati Intercultural Center is committed to ensuring that the admissions process will be open and transparent, and that no individual or group receives less favourable treatment by virtue of age, disability, economic status, faith, gender, marital status, sexuality, race, colour, and nationality, ethnic or national origin.

The following Learner Charter has been drawn up stating the standards of service you can expect to receive as a learner of Alsaihati Intercultural Center

Using the Alsaihati Intercultural Center you can expect…

• to receive a highly quality learning experience
• to be given equal opportunities and treated fairly
• to be treated with courtesy
• to have access to advice, guidance and support to ensure your choices are informed ones and that your learning needs are met
• to learn in a healthy and safe environment
• to be provided with timely and appropriate information on your progress
• to have staff listen to any issues, suggestions or concerns you may have, and to respond in a relevant manner

In turn as a customer of Alsaihati Intercultural Center we would like you to:

• be fully committed to your course
• treat our staff with courtesy
• provide us with appropriate information to help us meet your learning and assessment needs
• ensure that your behaviour contributes to a healthy and safe environment
• abide by any rules specifically relating to online assessment
• communicate issues, suggestions or concerns using the procedures outlined in your Student Handbook.

If for any reason you wish to make a formal complaint, then please access our formal complaints procedure on the website or email

Malpractice Policy

Alsaihati Intercultural Center treats all cases of suspected malpractice* very seriously and will investigate all suspected and reported incidents of possible malpractice.

The purpose of this Policy and Procedure is to set out how allegations of malpractice in relation to all Alsaihati Intercultural Center’s training assessments and training events are dealt with.

The scope of the policy is to provide:

• a definition of malpractice
• examples of learner and centre malpractice and maladministration;
• possible sanctions that may be imposed in cases of malpractice.

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

Introduction

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

Any act, or failure to act, that threatens or compromises the integrity of the assessment processor and the validity of Alsaihati Intercultural Center training events and their certification.

This includes:

• maladministration and the failure to maintain appropriate records or systems;
• the deliberate falsification of records or documents for any reason connected to the award of training events certification;
• acts of plagiarism or other academic misconduct;
• and/or actions that compromise the reputation or authority of its employees or associates. Alsaihati Intercultural Center will report all relevant cases of suspected malpractice to the relevant authority, accepting that in certain circumstances they may take action of its own, including imposing sanctions.

Malpractice by learners

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

• Obtaining examination or assessment material without authorisation.
  • Arranging for an individual other than the learner to sit an assessment or to submit an assignment not undertaken by the learner.
  • Impersonating another learner to sit an assessment or to submit an assignment on their behalf.
  • Collaborating with another learner or individual, by any means, to complete a coursework assignment or assessment, unless it has been clearly stated that such collaboration is permitted.
  • Damaging another learner’s work.
  • Inclusion of inappropriate or offensive material in coursework assignments or assessment scripts.
  • Failure to comply with published examination regulations.
  • Disruptive behaviour or unacceptable conduct, including the use of offensive language, at training centre or assessment venue (including aggressive or offensive language or behaviour).
  • Producing, using or allowing the use of forged or falsified documentation, including but not limited to:
    • personal identification;
    • supporting evidence provided for reasonable adjustment or special consideration applications; and
    • competency documents
    • results documentation, including certificates.
  • Misrepresentation or plagiarism of a Alsaihati Intercultural Center certificate.
  • Fraudulent claims for special consideration while studying.
  • Falsely obtaining by any means a certificate

Malpractice by Alsaihati Intercultural Center employees and associates

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

• Failure to adhere to the relevant regulations and procedures, including those relating to Alsaihati Intercultural Center approval, security undertaking and monitoring requirements as set out by these regulations.
  • Knowingly allowing an individual to impersonate a learner.
  • Allowing a learner to copy another learner’s assignment work or allowing a learner to let their own work be copied.
  • Allowing learners to work collaboratively during an assignment assessment, unless specified in the assignment brief.
  • Completing an assessed assignment for a learner or providing them with assistance beyond that ‘normally’ expected.
  • Damaging a learner’s work.
  • Disruptive behaviour or unacceptable conduct, including the use of offensive language (including aggressive or offensive language or behaviour).
  • Allowing disruptive behaviour or unacceptable conduct at Alsaihati Intercultural Center to go unchallenged, for example, aggressive or offensive language or behaviour.
  • Divulging any information relating to learner performance and / or results to anyone other than the learner.
  • Producing, using or allowing the use of forged or falsified documentation, including but not limited to:
    • personal identification;
    • supporting evidence provided for reasonable adjustment or special consideration applications; and
    • competency documents
    • results documentation, including certificates
  • Falsely obtaining by any means a certificate.
  • Failing to report a suspected case of learner malpractice, including plagiarism, to your Line Manager.

Possible malpractice sanctions

Following an investigation, if a case of malpractice is upheld, Alsaihati Intercultural Center may impose

sanctions or other penalties on the individual(s) concerned. Where relevant we will report the matter and may impose one or more sanctions upon the individual(s) concerned. Any sanctions imposed will reflect the seriousness of the malpractice that has occurred.

Listed below are examples of sanctions that may be applied to a learner, tutor or other associates who has had a case of malpractice upheld against them. Please note that this list is not exhaustive and other sanctions may be applied on a case-by-case basis.

Possible sanctions that may be applied to learners

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

Possible sanctions that may be applied to employees, tutors and other associates

• A written warning about future conduct.
  • Imposition of special conditions for the future involvement of the individual(s) in the conduct, teaching, supervision or administration of learners and/or examinations.
  • Informing any other organisation known to employ the individual in relation to courses or examinations of the outcome of the case. Alsaihati Intercultural Center may carry out unannounced monitoring of the working practices of the individual(s) concerned.

Procedure

Reporting a suspected case of malpractice

This process applies to, employees, tutors, learners and other associates to Alsaihati Intercultural Center

and to any reporting of malpractice by a third party or individual who wishes to remain anonymous.

Any case of suspected malpractice must be reported as soon as possible and at the latest within two working days from its discovery to the Training & Development Manager (Quality Nominee).

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

Wherever possible, and provided other learners are not disrupted by doing so, a learner suspected of malpractice should be warned immediately that their actions may

constitute malpractice, and that a report will be made to the Training & Development Manager.

In cases of suspected malpractice by Alsaihati Intercultural Center employees, tutors and other

associates, and any reporting of malpractice by a third party or individual who wishes to remain anonymous, the report made to the Training & Development Manager should include as much information as possible, including the following:

• the date time and place the alleged malpractice took place, if known.
  • the name of the employee, tutor or other third party involved
  • a description of the suspected malpractice; and
  • any available supporting evidence.

In cases of suspected malpractice reported by a third party, or an individual who wishes to

remain anonymous, Alsaihati Intercultural Center will take all reasonable steps to authenticate the

reported information and to investigate the alleged malpractice.

Administering suspected cases of malpractice

Alsaihati Intercultural Center will investigate each case of suspected or reported malpractice, to ascertain whether malpractice has occurred. The investigation will aim to establish the full facts and circumstances. Alsaihati Intercultural Center will promptly take all reasonable steps to prevent any adverse effect that may arise as a result of the malpractice, or to mitigate any adverse effect, as far as possible, and to correct it to make sure that any action necessary to maintain the integrity of our training and reputation is taken. Alsaihati Intercultural Center will acknowledge all reports of suspected malpractice within five working days. All of the parties involved in the case will then be contacted within 10 working days of receipt of the report detailing the suspected malpractice. We may also contact other individuals who may be able to provide evidence relevant to the case.

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

• that an investigation is going to take place, and the grounds for that investigation;
  • details of all the relevant timescales, and dates, where known;
  • that they have a right to respond by providing a personal written response relating to the suspected malpractice (within 15 working days of the date of that letter);
  • that, if malpractice is considered proven, sanctions may be imposed by reflecting the seriousness of the case;
  • that, if they are found guilty, they have the right to appeal.
  • that Alsaihati Intercultural Center has a duty to inform the relevant authorities / regulators, but only

after time for the appeal has passed or the appeal process has been completed. This may also include informing the police if the law has been broken and to comply with any other appropriate legislation.

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

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

Records of all malpractice cases and their outcomes are maintained by Alsaihati Intercultural Center for

a period of at least five years and are subject to regular monitoring and review.

Reasonable Adjustments Policy

Aims and Objectives of the Policy

Alsaihati Intercultural Center has a duty under the Equality Act 2010 to make any reasonable

adjustments that can be made for our learners to ensure they are not discriminated against.

We aim to facilitate open and fair access to our training for learners who are eligible for reasonable adjustments and / or special considerations without compromising the assessment of skills, knowledge, understanding or competence being measured , Alsaihati Intercultural Center achieve this through:

Reasonable Adjustments

Alsaihati Intercultural Center will consider requests for Reasonable Adjustments and Special Considerations.

This is agreed at point of booking/registration. The learner must request within a reasonable timeframe any adjustments that may be needed to reduce the effect of a disability or difficulty, which places the learner at a substantial disadvantage. Any requests for reasonable adjustments must not affect the quality and reliability of the learning outcomes nor must they give the learner an advantage over other learners undertaking the same or similar training.

Reasonable Adjustments may not be applied to training that will provide a “licence to practice” or where the learner needs to demonstrate a practical competence.

Special Considerations

A special consideration request can be made during or after a training event to reflect temporary illness, injury or indisposition that occurred at the time of the event. Any special considerations granted cannot remove the difficulty the learner faced at the time of the event and can only be a relatively small adjustment to ensure that the integrity of the training is not compromised. Special consideration may not be applied to training that will provide a “licence to practice” or where the learner needs to demonstrate a practical competence.

Alsaihati Intercultural Center will only consider requests for Reasonable Adjustments and Special

Considerations submitted within a timely manner and have completed the appropriate paperwork for these requests.

Reasonable Adjustments

A reasonable adjustment helps to reduce the effect of a disability or a difficulty that places the learner at a substantial disadvantage.

Reasonable adjustments must not affect the quality and reliability of the learning outcomes, but may include;

• Ensuring any online learning is more accessible (such as ability to adjust display settings and providing advice/guidance on speech technology)
• Providing assistance during an assessment of learning
• Adapting materials or providing it on coloured paper
• Re-organising the physical assessment/learning environment
• Use of mechanical and electronic aids
• Use of assistive software
• Use of low vision aids
• British Sign Language

Reasonable adjustments must be approved and set in place prior to any assessment or learning is carried out.

Any assessment of work following a reasonable adjustment has been made must be carried out in the same way of work from other learners.

Reasonable adjustments must never give a learner and advantage to other learners and must never affect the quality or reliability of the learning.

It is important to note that not all requests for reasonable adjustments may be granted if they are not deemed reasonable, permissible or practical in certain situations. The learner may not need, nor be allowed, the same adjustments for all learning.

Requests for reasonable adjustments are approved by Alsaihati Intercultural Center prior to any

bookings/registrations are taken. They are intended to allow access to training / assessment but can only be approved if the adjustment does not;

• Affect the quality and reliability of the learning
• Provide an unfair advantage to other learners
• Influence or compromise the final outcome of the assessment of learning

Any requests for reasonable adjustments must be made to Alsaihati Intercultural Center within 7 days of registration / booking or at least 28 working days before an assessment / classroom event using the appropriate paperwork.  If you are unsure if a learner requires a reasonable adjustment, please speak with Alsaihati Intercultural Center who will provide the relevant guidance.

Special Considerations

A special consideration is consideration given to a learner who was prepared and present at an assessment but may have been disadvantaged by temporary illness, injury or adverse circumstances outside of their control.

It is important to note that special consideration may not be possible where assessment requires the demonstration of practical competence, or the training provides a “licence to practice”.

Where an assessment of learning is carried out and marked by a computer, the learner will have the ability to take it at a later date however this must be completed prior to any practical assessments or other learning is carried out.

A special consideration cannot give a learner an unfair advantage to other learners and must not mislead the learners’ achievement. The learner’s results must reflect their true achievement and not potential ability. Alsaihati Intercultural Center’s decision on requests for special considerations will vary from learner to learner and one subject to another. The factors may include the severity of the consideration, date of assessment and the nature of the assessment such as practical or oral presentation.

The learner may be eligible for special considerations if;

• The performance in an assessment is affected by circumstances out of their control, such as recent personal illness, accident or bereavement
• Alternative arrangements which were agreed in advance proved to be inappropriate or inadequate
• Part of an assessment / event was missed due to circumstances beyond the control of the learner

The learner will not be eligible for special consideration if;

• The leaner has not been affected at the time of an assessment by a particular condition
  • Part of an assessment / event is missed due to personal arrangements including holidays or unauthorised absence
  • The event / assessment is affected by difficulties such as disturbances through building work, lack of proper facilities, changes in or shortages of staff or industrial disputes

Examples of circumstances where special consideration may be given are;

• Terminal illness of the learner
  • Recent bereavement of a member of the immediate family
  • Serious of disruptive domestic crises leading to acute anxiety about the family
  • Incapacitating illness or injury of the learner
  • Severe car accident
  • Outbreak of infection where learners are in isolation
  • Lost or damaged work beyond the control of the learner

Special consideration will not be granted for minor illness or a minor disturbance.

Requests for special considerations are approved by Alsaihati Intercultural Center Applications for special

considerations must be made on case-by-case basis and thus separate applications must be made for each learner. Any requests for special considerations will only be approved if they do not;

• Affect the quality and reliability of the learning
  • Provide an unfair advantage to other learners
  • Influence or compromise the final outcome of the assessment of learning

Any requests for special considerations must be made to Alsaihati Intercultural Center within 7 days of the

event or assessment using the appropriate paperwork.  If you are unsure if a learner requires a

special consideration please speak with Alsaihati Intercultural Center who will provide the relevant guidance.

It is important to note that special consideration will not be granted if / where learner achievement has been acknowledged and certified.

Safeguarding Learner Policy

Introduction

All staff working with children and vulnerable adults have a legal duty to work together

to protect them from harm or abuse. Alsaihati Intercultural Center Safeguarding lead has overall responsibility for the safeguarding of learners, and is responsible for ensuring the effectiveness of all work done to safeguard and promote the welfare of children and young people on programme. Alsaihati Intercultural Center Policy covers:

• The recruitment and employment of staff working with vulnerable adults and the provision of a safe learning environment under the requirements of this act
• Training & Development Manager & HR department are responsible for ensuring that Alsaihati Intercultural Center follows safer recruitment procedures. This includes carrying out Disclosure and Baring checks on all staff working with vulnerable learners every three years. This also applies where staffs have already been checked by a previous employer.

Statement of Intent:

Alsaihati Intercultural Center’s first priority is to ensure the safety and protection of all learners

taking part in learning. In order to protect young people and vulnerable adults from harm we

will act in accordance with the following legislation and guidance: ‘No Secrets’ DH 2000

Scope

This policy statement applies to all learning provided by Alsaihati Intercultural Center, and includes:

• All learning provision for adults delivered directly by employed staff
• All learning provision for adults commissioned through partnership arrangements
•  

Definitions

Safeguarding The term “safeguarding” describes the broader preventative and precautionary approach to planning and procedures that are necessary to protect children, young people and vulnerable adults from any potential harm or damage.

Safeguarding means:

• Protection from abuse and neglect
• Promotion of health and development
• Ensuring safety and care relating to the environment and activity
• Ensuring optimum life chances
•  

‘Child’ or ‘Young Adult’ An individual is considered to be a child or young person up to their 18th birthday

‘Vulnerable Adult’ A Vulnerable adult is any person aged 18 or over ‘who is, or may be in need of, community care services by reason of mental or other disability, age or illness and who is, or may be, unable to take care of him or herself or protect him or herself against significant harm or exploitation’ (‘No Secrets’ DH 2000).

The list below is not exhaustive but a vulnerable adult may be someone

• who: is elderly and frail
• has a mental disorder
• has a physical or sensory disability has a severe physical illness
• is a substance misuser is homeless
• has a learning disability
•  

‘Abuse’ is

“a violation of an individual’s human and civil rights by any other person or persons” (‘No Secrets’ DH 2000). Abuse may consist of a single act or repeated acts, abuse may happen intentionally or unintentionally and can take place in any relationship or setting. Examples of abuse that could occur in a learning environment include:

Physical abuse – shoving, hitting, slapping

Sexual abuse – involvement in any direct or indirect (e.g. innuendo, pornography) activity against the learner’s will or knowledge

Emotional/psychological abuse e.g. intimidation, bullying or humiliation Discriminatory abuse e.g. racial, sexual or religious harassment Financial or material exploitation e.g. coercing money or goods

Institutional abuse e.g. failure to ensure privacy, dignity or uphold individual human and civil rights.

Neglect or acts of omission e.g. ignoring physical or medical needs, failure to access appropriate health, social care or educational services, withholding medication.

An abuser: may be anyone including relatives, friends, professional staff, other learners and service-users, neighbours, care workers, volunteers, and strangers.

Policy Statement

Alsaihati Intercultural Center is committed to promoting safeguarding through the provision  of an

inclusive, supportive and safe environment for its learners, staff and others closely associated with its work and affirms the rights of individuals to be treated fairly and with respect.

Alsaihati Intercultural Center intends to pursue this commitment by

1.  Promoting a culture of value and respect for all within a supportive and safe learning environment

• Ensure that all internal tutoring staff, and learning and personal support staff in contact with learners have a current Disclosure and Barring check for working with adults and/or children
  • Provide accessible information for learners, tutoring staff and subcontracting providers on equality, diversity, bullying, harassment, dignity and respect in the learning environment
  • We will provide opportunities for adults and young people to voice any concerns they may have regarding inappropriate behaviour, abuse, harassment or misconduct and providing strong sanctions to deter victimisation or cover up of malpractice

• Supply information to learners on Alsaihati Intercultural Center procedures for following up complaints relating to the conduct of tutoring staff and/or other learners
• Require all tutoring staff and others associated with the delivery of our provision to carry and produce appropriate identification on request
  • Ensure that premises used to deliver learning activities are risk assessed by appropriately trained staff
  • Ensure that learning activities are risk assessed by appropriately trained staff
  • Ensure that care and safety issues and concerns are reported

2.  Providing Information, training and briefings on safeguarding vulnerable adults and children that includes:

• Include information on Safeguarding as part of learner induction
  • Provide information to tutoring staff and learners about the standards we expect with regard to confidentiality and disclosure
• Provide appropriate training for tutoring staff on safeguarding, disclosure and diversity matters
  • Distribute information to all internal on the signs of abuse and the action to take if/when abuse is reported.
  • Provide accessible information for learners, and tutoring staff on the complaint’s procedure
  • Provide headline information for learners on safeguarding, e-safety, bullying and harassment equality of opportunity and diversity.
  • Provide learners with the name of the designated safeguarding contact and the procedure to be followed in the case of any alleged case of bullying or harassment

3.  Gathering and analysing information from learners on matters related to feeling safe in the learning environment

• Generate questions on the feedback form to elicit how safe learners feel in the learning environment
• Analyse the information obtained and acting on the results

Monitoring the effectiveness of this Safeguarding Policy and reviewing it annually

• Monitor the safeguarding practices within provision
• Identify and sharing good practice in safeguarding with subcontracted providers
• Review the Alsaihati Intercultural Center safeguarding policy on an annual basis
• Link with learning networks and the local authority safeguarding unit to ensure that information on safeguarding is current and up to date

All enquiries relating to safeguarding issues should be addressed in the first instance to the

designated safeguarding officer for Alsaihati Intercultural Center Assessment Centre.

Appeals Procedure for students enrolled on CPD courses

We at the Alsaihati Intercultural Center through our portal (London Intercultural Academy) provide a formal route for our learners wishing to appeal against an assessment decision. All learners are assessed against the relevant learning outcomes for the course and regulating organisation criteria, where applicable. Assessment decisions are made by internal Assessors.

Areas for Appeal

Our Appeals Policy enables learners in certain situations to make a formal appeal against a recommendation or assessment decision relating to:

1. the Assessor’s decision on any element of assessment that differs to that of our Internal Quality Assurer’s decision (for example, if an internal assessment has been marked by the Assessor as achieved but the Internal Quality Assurer disagrees with this decision).

• an application for a reasonable adjustment or special consideration

submitted to the regulating organisation for approval.

• our final, overall assessment decision for a CPD Course.

Grounds for Appeal

The following is a list of examples and is not exhaustive:

• A reasonable adjustment was refused without reason, or a decision to limit a requested for a reasonable adjustment proved to be inappropriate or insufficient.
• The learner requested special consideration, but this does not seem to have been applied.
• There was inappropriate or irregular conduct on the part of the Assessor.

Appeals Process

Stage 1

The learner should discuss on the day they receive the assessment decision their intention to appeal that decision directly with the Assessor responsible for informing the learner of that decision. If the learner is dissatisfied with the outcome of this discussion, the learner should request a ‘Learners Appeals Application’ form which can be posted or email to you. The learner must submit this form within five days of the date of the assessment and include with it any supporting evidence (see additional notes below). Appeals received after this time will not be heard.

Stage 2

Once received by us, our designated Internal Quality Assurer (“IQA”) will investigate the appeal and respond in writing to the learner with a decision within 20 working days of receipt of the form. If the learner is dissatisfied with the IQA’s decision, the learner should make a complaint directly to the Owner of the company.

Additional Notes

1. It is extremely difficult to investigate appeals without impartial evidence. Therefore, appeals against referrals in practical teaching based solely on the learner’s disagreement with the Assessor’s decision will only be considered when accompanied by a video recording of the learner’s practical assessment.

• The learner has the right to video any aspect of their practical assessment using their own video recording equipment provided it does not interfere with the assessment process, other learners, or the Assessor’s ability to carry out their role(s).
• It is the responsibility of the learner to arrange a video operator.
• Prior to the assessment date and so that a decision can be made for deferral, it is the responsibility of the learner to notify us of any medical problem which may affect the learner’s performance adversely in the assessment process.

Complaint – a grievance, problem, difficulty or concern

POLICY STATEMENT

Alsaihati Intercultural Center recognises the importance of learner complaints and welcomes complaints

as a valuable form of feedback about its services. We are committed to using the information we receive to help drive forward improvements.

This procedure outlines the aims of Alsaihati Intercultural Center in dealing with complaints and sets

out what you as the customer can expect when making a complaint regarding a service.

A complaint is a way of letting us know that you are not happy with a particular service. We welcome your feedback. A complaint may be about delay, lack of response, discourtesy, failure to consult or about the standard of service you have received.

So please let us know if:

• you think we have done something wrong
• we have not done something that we said we would do
• you are not satisfied with a particular service or set of services that we provide
•  

ANONYMOUS COMPLAINTS

We understand that it might be difficult for you to complain because you are worried that your complaint could result in a poorer service.  Please be assured that we treat all complaints in the strictest confidence, and that it is your right to complain. If you do not provide us with a contact name or address, it will not be possible for us to get back to you with the outcome of the investigation

PROCEDURE

In the first instance, the complaint should be discussed with the team member concerned and resolution sought within 48 hours of the incident occurring.  If this is successful and a resolution is reached, the complaint should be documented on the attached Appendix (1) and sent to the Company Administrator for filing. This should be received by the Company Administrator by the end of the next working day. There will be no further action taken.

In the case of an individual wishing to make the complaint, who feels unable to discuss the complaint with the team member concerned, the matter should be referred to the Training Manager within 48 hours of the incident occurring. The Training Manager should then contact the Company Owner within the next 7 days to make them aware of the complaint. The nature of the complaint will be documented as per Appendix (2) and sent to the Training Manager.

On receipt of the complaint, the nature of the complaint will be brought to the attention of the team member concerned and discussed within 48 hours of receiving the complaint. The Training Manager will then contact the individual making the complaint with a view to resolve.

If resolution cannot be found, the Training Manager will arrange a meeting with all relevant parties and agree a resolution. This will take place within 30 days. This will be final.

The Company Administrator will maintain a record of all complaints and make these available on request. All complaints must be regarded as confidential and discussed only with those parties involved.

In the instance where the complaint is around an assessment / verification decision, then the stages outlined in the Appeals Procedure must be followed.

Course Content Review Policy

Alsaihati Intercultural Center takes the standard of its courses very seriously. For this reason, the below policy sets out how we ensure the standards of our service is maintained.

Course reviews are an integral part of Alsaihati Intercultural Center’s quality assurance process.

The focus of course reviews is on:

• The appropriateness of the content and assessment method in order to achieve the learning outcomes,
• The course content being up to date and accurate.

Responsibility

Responsibility for course review and recommendations being addressed rests with the Training & Development Manager. The responsibility for the Review process lies with the company Directors.

Frequency

Each course is reviewed on an annual basis. The courses are reviewed by a Subject Matter Specialist to ensure their accuracy.

All legal elements of the learning materials will be reviewed by the companies Legal Representatives to ensure the most up to date version of any legal references are used and are correct as of the time of the review.

Timing

At the review date, each subject area specialist will have a 30-day period to complete the review of the given subject and all findings reported back to the Training & Development Manager.

The Training & Development Manager will then action any appropriate changes to course materials with an additional 30-day period.

Any legal advice/review related to legal references within the learning materials will be form part of the 30-day review period by the Subject Matter Specialist.

Reporting

Following learning materials & legal review, a detailed report will be provided to the Training & Development Manager, outlining all elements that require addressing and updating.

Data Protection Act 2018 Policy

Introduction

This Policy sets out the obligations of Alsaihati Intercultural Center,(“the Company”) regarding data protection and the rights of customers and business contacts (“data subjects”) in respect of their personal data under Data Protection Act 2018 (Formally EU Regulation 2016/679 General Data Protection Regulation (“GDPR”)).

The Data Protection Act 2018 defines “personal data” as any information relating to an identified or identifiable natural person (a “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

This Policy sets the Company’s obligations regarding the collection, processing, transfer, storage, and disposal of personal data. The procedures and principles set out herein must be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company.

The Company is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all personal data, respecting the legal rights, privacy, and trust of all individuals with whom it deals.

The Data Protection Principles

This Policy aims to ensure compliance with the Data Protection Act 2018. The Data Protection Act 2018 sets out the following principles with which any party handling personal data must comply. All personal data must be:

• Processed lawfully, fairly, and in a transparent manner in relation to the data subject.
• Collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes. Further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes.
• Adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.
• Accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased, or rectified without delay.
• Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. Personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, subject to implementation of the appropriate technical and organisational measures required by the Data Protection Act 2018 in order to safeguard the rights and freedoms of the data subject.
• Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organisational measures.

The Rights of Data Subjects

• The Data Protection Act 2018 sets out the following rights applicable to data subjects
• The right to be informed’
• The right of access,
• The right to rectification,
• The right to erasure (also known as the ‘right to be forgotten’),
• The right to restrict processing,
• The right to data portability,
• The right to object; and
• Rights with respect to automated decision-making and profiling.

Lawful, Fair, and Transparent Data Processing

The Data Protection Act 2018 seeks to ensure that personal data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the data subject. The Data Protection Act 2018 states that processing of personal data shall be lawful if at least one of the following applies:

• The data subject has given consent to the processing of their personal data for one or more specific purposes;
• The processing is necessary for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract with them;
• The processing is necessary for compliance with a legal obligation to which the data controller is subject;
• The processing is necessary to protect the vital interests of the data subject or of another natural person;
• The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller; or
• The processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
• If the personal data in question is “special category data” (also known as “sensitive personal data”) (for example, data concerning the data subject’s health), at least one of the following conditions must be met:
• The data subject has given their explicit consent to the processing of such data for one or more specified purposes (unless EU or EU Member State law prohibits them from doing so);
• The processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent;
• The processing relates to personal data which is clearly made public by the data subject;
• The processing is necessary for the conduct of legal claims or whenever courts are acting in their judicial capacity;

Specified, Explicit, and Legitimate Purposes

The Company collects and processes the personal data set out in this Policy.

This includes:

• Personal data collected directly from data subjects OR
• Personal data obtained from third parties.
• The Company only collects, processes, and holds personal data for the specific purposes set out in this Policy (or for other purposes expressly permitted by the Data Protection Act 2018).
• Data subjects are kept informed at all times of the purpose or purposes for which the Company uses their personal data.

Adequate, Relevant, and Limited Data Processing

The Company will only collect and process personal data for and to the extent necessary for the specific purpose or purposes of which data subjects have been informed (or will be

informed).

Accuracy of Data and Keeping Data Up-to-Date

• The Company shall ensure that all personal data collected, processed, and held by it is kept accurate and up-to-date. This includes, but is not limited to, the rectification of personal data at the request of a data subject.
• The accuracy of personal data shall be checked when it is collected and at regular intervals thereafter. If any personal data is found to be inaccurate or out-of-date, all reasonable steps will be taken without delay to amend or erase that data, as appropriate.

Data Retention

• The Company shall not keep personal data for any longer than is necessary in light of the purpose or purposes for which that personal data was originally collected, held, and processed.
• When personal data is no longer required, all reasonable steps will be taken to erase or otherwise dispose of it without delay.
• For full details of the Company’s approach to data retention, including retention periods for specific personal data types held by the Company, please refer to our Data Retention Policy.

Secure Processing

The Company shall ensure that all personal data collected, held, and processed is kept secure and protected against unauthorised or unlawful processing and against accidental loss, destruction, or damage. Further details of the technical and organisational measures which shall be taken are provided later in this Policy.

Accountability and Record-Keeping

The Company’s Data Protection Officer is Hadi Brenjekjy

E-Mail: h.bren@londoninterculturalcenter.co.uk

The Data Protection Officer shall be responsible for overseeing the implementation of this Policy and for monitoring compliance with this Policy, the Company’s other data protection-related policies, and with the Data Protection Act 2018 and other applicable data protection legislation.

• The Company shall keep written internal records of all personal data collection, holding, and processing, which shall incorporate the following information:
• The name and details of the Company, its Data Protection Officer, and any applicable third-party data processors;
• The purposes for which the Company collects, holds, and processes personal data;
• Details of the categories of personal data collected, held, and processed by the Company, and the categories of data subject to which that personal data relates;
• Details of any transfers of personal data to non-EEA countries including all mechanisms and security safeguards;
• Details of how long personal data will be retained by the Company; and
• Detailed descriptions of all technical and organisational measures taken by the Company to ensure the security of personal data.

Data Protection Impact Assessments

• The Company shall carry out Data Protection Impact Assessments for any and all new projects and/or new uses of personal data.
• Data Protection Impact Assessments shall be overseen by the Data Protection Officer and shall address the following:
• The type(s) of personal data that will be collected, held, and processed;
• The purpose(s) for which personal data is to be used;
• The Company’s objectives;
• How personal data is to be used;
• The parties (internal and/or external) who are to be consulted;
• The necessity and proportionality of the data processing with respect to the
• purpose(s) for which it is being processed;
• Risks posed to data subjects;
• Risks posed both within and to the Company; and
• Proposed measures to minimize and handle identified risks.

Keeping Data Subjects Informed

The Company shall provide the information set out in section (i) below to every data subject:

Where personal data is collected directly from data subjects, those data subjects will be informed of its purpose at the time of collection; and where personal data is obtained from a third party, the relevant data subjects will be informed of its purpose:

1. a) if the personal data is used to communicate with the data subject, when the first communication is made; or
2. b) if the personal data is to be transferred to another party, before that transfer is

made; or

1. c) as soon as reasonably possible and in any event not more than one month after

the personal data is obtained.

• The following information shall be provided:
• Details of the Company including, but not limited to, the identity of its Data Protection Officer;
• The purpose(s) for which the personal data is being collected and will be processed (as detailed in this Policy) and the legal basis justifying that collection and processing;
• Where applicable, the legitimate interests upon which the Company is justifying its collection and processing of the personal data;
• Where the personal data is not obtained directly from the data subject, the categories of personal data collected and processed;
• Where the personal data is to be transferred to one or more third parties, details of those parties;
• Where the personal data is to be transferred to a third party that is located outside of the European Economic Area (the “EEA”), details of that transfer, including but not limited to the safeguards in place,
• Details of data retention;
• Details of the data subject’s rights under the Data Protection Act 2018;
• Details of the data subject’s right to withdraw their consent to the Company’s processing of their personal data at any time;
• Details of the data subject’s right to complain to the Information Commissioner’s Office (the “supervisory authority” under the Data Protection Act 2018);
• Where applicable, details of any legal or contractual requirement or obligation necessitating the collection and processing of the personal data and details of any consequences of failing to provide it; and
• Details of any automated decision-making or profiling that will take place using the personal data, including information on how decisions will be made, the significance of those decisions, and any consequences.

Data Subject Access

• Data subjects may make subject access requests (“SARs”) at any time to find out more about the personal data which the Company holds about them, what it is doing with that personal data, and why.
• Data subjects wishing to make a SAR may do so in writing, using the Company’s Subject Access Request Form, or other written communication. SARs should be addressed to the Company’s Data Protection Officer at Alsaihati Intercultural Center [167-169 Great Portland Street, London-UK W1W 5PF] Tel: [020383 494 68] Email: info@londoninterculturalcenter.co.uk
• Responses to SARs shall normally be made within one month of receipt, however this may be extended by up to two months if the SAR is complex and/or numerous requests are made. If such additional time is required, the data subject shall be informed.
• All SARs received shall be handled by the Company’s Data Protection Officer.
• The Company does not charge a fee for the handling of normal SARs. The Company reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.

Rectification of Personal Data

• Data subjects have the right to require the Company to rectify any of their personal data that is inaccurate or incomplete.
• The Company shall rectify the personal data in question, and inform the data subject of that rectification, within one month of the data subject informing the Company of the issue. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed.
• In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of any rectification that must be made to that personal data.

Erasure of Personal Data

Data subjects have the right to request that the Company erases the personal data it holds about them in the following circumstances:

1. a) It is no longer necessary for the Company to hold that personal data with respect to the purpose(s) for which it was originally collected or processed;
2. b) The data subject wishes to withdraw their consent to the Company holding and processing their personal data;
3. c) The data subject objects to the Company holding and processing their personal data (and there is no overriding legitimate interest to allow the Company to continue doing so),
4. d) The personal data has been processed unlawfully;
5. e) The personal data needs to be erased in order for the Company to comply with

a particular legal obligation.

Unless the Company has reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied with, and the data subject informed of the erasure, within one month of receipt of the data subject’s request. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed.

In the event that any personal data that is to be erased in response to a data subject’s request has been disclosed to third parties, those parties shall be informed of the erasure (unless it is impossible or would require disproportionate effort to do so).

Restriction of Personal Data Processing

Data subjects may request that the Company ceases processing the personal data it holds about them. If a data subject makes such a request, the Company shall retain only the amount of personal data concerning that data subject (if any) that is necessary to ensure that the personal data in question is not processed further.

In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of the applicable restrictions on processing it (unless it is impossible or would require disproportionate effort to do so).

Objections to Personal Data Processing

Data subjects have the right to object to the Company processing their personal data based on legitimate interests, direct marketing (including profiling) and processing for scientific and/or historical research and statistics purposes.

Where a data subject objects to the Company processing their personal data based on its legitimate interests, the Company shall cease such processing immediately, unless it can be demonstrated that the Company’s legitimate grounds for such processing override the data subject’s interests, rights, and freedoms, or that the processing is necessary for the conduct of legal claims.

Where a data subject objects to the Company processing their personal data for direct marketing purposes, the Company shall cease such processing immediately.

Where a data subject objects to the Company processing their personal data for scientific and/or historical research and statistics purposes, the data subject must, under the Data Protection Act 2018, “demonstrate grounds relating to his or her particular situation”. The Company is not required to comply if the research is necessary for the performance of a task carried out for reasons of public interest.

Personal Data Collected, Held, and Processed

The following personal data is collected, held, and processed by the Company:

Data Ref. Type of Data Purpose of Data Electronic and hard copy Learner records

Name-Email-Phone Number (if applicable)

Data Security – Transferring Personal Data and Communications

The Company shall ensure that the following measures are taken with respect to all

communications and other transfers involving personal data:

• All emails containing personal data must be encrypted using Encryption software;
• All emails containing personal data must be marked “confidential”;
• Personal data may be transmitted over secure networks only; transmission over unsecured networks is not permitted in any circumstances;
• Personal data may not be transmitted over a wireless network if there is a wired alternative that is reasonably practicable;
• Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself should be deleted. All temporary files associated therewith should also be deleted using deletion software;
• Where personal data is to be sent by facsimile transmission the recipient should be informed in advance of the transmission and should be waiting by the fax machine to receive the data;
• Where personal data is to be transferred in hardcopy form it should be passed directly to the recipient or sent using Royal Mail Registered or 1st or 2nd Class Signed For post; and
• All personal data to be transferred physically, whether in hardcopy form or on removable electronic media shall be transferred in a suitable container marked “confidential”.

Data Security – Storage

The Company shall ensure that the following measures are taken with respect to the storage of personal data:

• All electronic copies of personal data should be stored securely using passwords and data encryption;
• All hardcopies of personal data, along with any electronic copies stored on physical, removable media should be stored securely in a locked box, drawer, cabinet, or similar;
• All personal data stored electronically should be backed up at least daily with backups stored onsite. All backups should be encrypted using data encryption’
• No personal data should be stored on any mobile device (including, but not limited to, laptops, tablets, and smartphones), whether such device belongs to the Company or otherwise without the formal written approval of the Data Protection Officer and, in the event of such approval, strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary; and
• No personal data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the letter and spirit of this Policy and of the Data Protection Act 2018 (which may include demonstrating to the Company that all suitable technical and organisational measures have been taken).

Data Security – Disposal

When any personal data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it should be securely deleted and disposed of.

Data Security – Use of Personal Data

The Company shall ensure that the following measures are taken with respect to the use of

personal data:

• No personal data may be shared informally and if an employee, agent, sub-contractor, or other party working on behalf of the Company requires access to any personal data that they do not already have access to, such access should be formally requested from The Data Protection Officer,
• No personal data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of the Company or not, without the authorisation of The Data Protection Officer,
• Personal data must be handled with care at all times and should not be left unattended or on view to unauthorised employees, agents, sub-contractors, or other parties at any time;
• If personal data is being viewed on a computer screen and the computer in question is to be left unattended for any period of time, the user must lock the computer and screen before leaving it; and
• Where personal data held by the Company is used for marketing purposes, it shall be the responsibility of Hadi Brenjekjy to ensure that the appropriate consent is obtained and that no data subjects have opted out, whether directly or via a third-party service such as the TPS.
•  

Data Security – IT Security

The Company shall ensure that the following measures are taken with respect to IT and information security:

• All passwords used to protect personal data should be changed regularly and should not use words or phrases that can be easily guessed or otherwise compromised. All passwords must contain a combination of uppercase and lowercase letters, numbers, and symbols;
• Under no circumstances should any passwords be written down or shared between any employees, agents, contractors, or other parties working on behalf of the Company, irrespective of seniority or department. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords;
• All software (including, but not limited to, applications and operating systems) shall be kept up-to-date. The Company’s IT staff shall be responsible for installing any and all security-related updates after the updates are made available by the publisher or manufacturer, unless there are valid technical reasons not to do so; and
• No software may be installed on any Company-owned computer or device without the prior approval of the Company.

Organisational Measures

The Company shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:

• All employees, agents, contractors, or other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the Data Protection Act 2018 and under this Policy, and shall be provided with a copy of this Policy;
• Only employees, agents, sub-contractors, or other parties working on behalf of the Company that need access to, and use of, personal data in order to carry out their assigned duties correctly shall have access to personal data held by the Company;
• All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately trained to do so;
• All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately supervised;
• All employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be required and encouraged to exercise care, caution, and discretion when discussing work-related matters that relate to personal data, whether in the workplace or otherwise;
• Methods of collecting, holding, and processing personal data shall be regularly evaluated and reviewed;
• All personal data held by the Company shall be reviewed periodically, as set out in the Company’s Data Retention Policy;
• The performance of those employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed;
• All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be bound to do so in accordance with the principles of the Data Protection Act 2018 and this Policy by contract;
• All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of the Company arising out of this Policy and the Data Protection Act 2018; and
• Where any agent, contractor or other party working on behalf of the Company handling personal data fails in their obligations under this Policy that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.

Transferring Personal Data to a Country Outside the EEA

The Company may from time to time transfer (‘transfer’ includes making available remotely) personal data to countries outside of the EEA.

The transfer of personal data to a country outside of the EEA shall take place only if one or more of the following applies:

• The transfer is to a country, territory, or one or more specific sectors in that country (or an international organisation), that the European Commission has determined ensures an adequate level of protection for personal data;
• The transfer is to a country (or international organisation) which provides appropriate safeguards in the form of a legally binding agreement between public authorities or bodies; binding corporate rules; standard data protection clauses adopted by the European Commission; compliance with an approved code of conduct approved by a supervisory authority (e.g. the Information Commissioner’s Office); certification under an approved certification mechanism (as provided for in the Data Protection Act 2018); contractual clauses agreed and authorised by the competent supervisory authority; or provisions inserted into administrative arrangements between public authorities or bodies authorised by the competent supervisory authority;
• The transfer is made with the informed consent of the relevant data subject(s);
• The transfer is necessary for the performance of a contract between the data subject and the Company (or for pre-contractual steps taken at the request of the data subject);
• The transfer is necessary for important public interest reasons;
• The transfer is necessary for the conduct of legal claims;
• The transfer is necessary to protect the vital interests of the data subject or other individuals where the data subject is physically or legally unable to give their consent; or
• The transfer is made from a register that, under UK or EU law, is intended to provide information to the public and which is open for access by the public in general or otherwise to those who are able to show a legitimate interest in accessing the register.

Data Breach Notification

• All personal data breaches must be reported immediately to the Company’s Data Protection Officer.
• If a personal data breach occurs and that breach is likely to result in a risk to the rights and freedoms of data subjects (e.g. financial loss, breach of confidentiality, discrimination, reputational damage, or other significant social or economic damage), the Data Protection Officer must ensure that the Information Commissioner’s Office is informed of the breach without delay, and in any event, within 72 hours after having become aware of it.
• In the event that a personal data breach is likely to result in a high risk (that is, a higher risk than that described under Part 29.2) to the rights and freedoms of data subjects, the Data Protection Officer must ensure that all affected data subjects are informed of the breach directly and without undue delay.
• Data breach notifications shall include the following information:
• The categories and approximate number of data subjects concerned;
• The categories and approximate number of personal data records concerned;
• The name and contact details of the Company’s data protection officer (or other contact point where more information can be obtained);
• The likely consequences of the breach;
• Details of the measures taken, or proposed to be taken, by the Company to address the breach including, where appropriate, measures to mitigate its possible adverse effects.

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Registered Company Name: Alsaihati Intercultural Center Ltd
Registered in England and Wales
Registered Office: 167–169 Great Portland Street, London, W1W 5PF
Company Registration Number: 14163851
Contact Email: info@londoninterculturalcenter.co.uk

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info@londoninterculturalcenter.co.uk