01 Feb 2023
As centres undertake the process of submitting exam entries to awarding bodies, in recent weeks, we have received numerous emails from exams officers asking for clarity over Conflicts of Interest (COI) and when these should be declared to the awarding bodies.
The significance of identifying and managing a COI is summarised by AQA who explain that ‘the conflict of interest process is designed to protect the integrity of the exams system and also helps to ensure that staff members at schools and colleges are protected if there is an allegation of malpractice due to a perceived, or real, conflict.’
In this article, we consider instances of COI which must be declared to the awarding bodies, and those which must be recorded at centre level only, and the records which must be maintained highlighting the measures taken, or protocols put in place, to mitigate any potential risk to the integrity of the qualifications affected.
Please note that all instances of COI – those reported to the awarding bodies and those requiring internal recording – must include the measures taken to mitigate/manage the risk represented by the conflict to the integrity of the qualification(s) affected.
What is a Conflict of Interest (COI)?
A Conflict of Interest occurs where any member of staff who has access to privileged information, or is responsible for making decisions about assessment outcomes, could, potentially, use that information, or their position, to give an unfair advantage to students with whom they have a relationship and who are entered for an examination/assessment at the centre itself or any other centre.
Such a relationship may exist with members of their family (which includes stepfamily, foster family and similar close relationships), or close friends and their immediate family (e.g. son/daughter).
A COI also occurs if any member of centre staff is entered for an examination/assessment.
JCQ regulations
The regulations concerning COI are detailed within JCQ’s General Regulations for Approved Centres (section 5.3i) publication.
When to inform the awarding bodies
Firstly, it must be noted that any potential COI must be declared to the awarding bodies before the published deadline for entries for each examination series. Therefore, ideally this is a task which should be undertaken at the beginning of the academic year if examinations are to be taken throughout the academic year, and the declaration will remain in place for all affected examination series.
Centres should follow this four-step process at the beginning of each academic year to identify any COI amongst members of staff:
Step 1: Identifying staff
Identify members of staff who will be required to declare any COI. This will include teachers and exams office staff (which could include invigilators) but is unlikely to include any other staff unless they have access to confidential assessment materials or are entered for an examination/assessment.
Step 2: Acquire staff declarations
Ask these staff members to complete – and sign – a form which confirms whether they have a COI. This should include a clear and accurate explanation of what constitutes a COI, and a definition of a ‘close relationship’.
It is suggested good practice for centres to collect declarations from all staff and to maintain a record confirming no potential COI has been identified. Staff should be reminded that a failure to declare a COI will result in further action being taken by the relevant awarding body/bodies.
Step 3: Record the conflicts (and any mitigations of the risk)
Where these staff declare an interest, centres must detail the measures taken to mitigate/manage the risk represented by any COI and any potential risk to the integrity of the qualifications affected. These may include ensuring that an individual does not have unaccompanied access to confidential examination material, or even removing their access to the centre’s secure storage facility.
Centre records must identify the relevant member of staff, the name, relationship and the nature of any potential conflict.
The records must also include the details of any staff entered for an examination/assessment
and the steps the centre is taking to manage this COI. These arrangements must include ensuring they have no access to confidential material.
These records must be retained until the deadline for reviews of marking has passed or until any appeal, malpractice or other results enquiry has been completed, whichever is later. They may also be inspected by a JCQ Centre Inspector and/or awarding body staff or requested by an awarding body if they have received a particular concern.
Note: The Exams Office has produced a Declaration of Interest Form template and Conflicts of Interest Log template to support centres in collecting declarations and recording COI and the measures taken/protocols put in place to mitigate any potential risk to the integrity of the qualifications affected.
Step 4: Informing the awarding bodies
Centres must inform the awarding body/bodies where, for one or more of their specifications:
- any members of centre staff who are taking qualifications at their own centre which include internally assessed components/units
- any members of centre staff who are teaching and preparing members of their family (which includes stepfamily, foster family and similar close relationships) or close friends and their immediate family (e.g. son/daughter) for qualifications which include internally assessed components/units
The awarding body/bodies have established processes for collecting this information. If further clarity about how the information should be submitted is needed, then the relevant awarding body/bodies should be contacted.
Informing the awarding bodies or maintaining a centre record?
The table below highlights the general principles which are applied when deciding if a COI should be declared to the awarding bodies or recorded internally.
Please note that in both instances, centres are required to detail the measures which have been/are being taken, or protocols put in place, to mitigate any potential risk to the integrity of qualification affected.
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Inform awarding bodies
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Maintain a centre record
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If a member of centre staff is taking a qualification at their own centre which includes internally assessed components/units
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If a member of centre staff is taking a qualification at their own centre which does not include internally assessed components/units
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If a member of centre staff is taking a qualification at another centre
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If a member of centre staff who is teaching and preparing members of their family (which includes stepfamily, foster family and similar close relationships) or close friends and their immediate family (e.g. son/daughter) for qualifications which include internally assessed components/units
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If exams office staff have members of their family (which includes stepfamily, foster family and similar close relationships) or close friends and their immediate family (e.g. son/daughter) being entered for examinations and assessments either at the centre itself or other centres
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Examples of mitigation
Below is a list of some of the measures which a centre may take in the event of a COI to mitigate against any potential risk(s) to the integrity of the qualifications affected:
Conflict of Interest
As a last resort where the member of staff is unable to find another centre, a member of centre staff is taking a qualification at the centre itself which includes internally assessed components/units.
Note: This must be declared to the relevant awarding body/bodies before the published deadline for entries (for each affected examination series).
Mitigation
- Prevent the member of centre staff having access to confidential examination/assessment materials prior to exam(s)/assessment(s)
- Brief other relevant centre staff on maintaining the integrity and confidentiality of exam/assessment materials
- Ensure the member of centre staff is treated in the same way as any other candidate entered for that qualification, does not have access to examination materials and does not receive any preferential treatment
Protocols
- Record/evidence the specific measures taken/protocols in place to achieve the above
Conflict of Interest
A member of centre staff is teaching and preparing a member of family (which includes step-family, foster family and similar close relationships) or close friends and their immediate family (e.g. son/daughter) for a qualification(s) which includes an internally assessed component/unit
Note: This must be declared to the relevant awarding body/bodies before the published deadline for entries (for each affected examination series)
Mitigation
- Make every effort to avoid situations where a candidate is assessed by a person who has a close personal relationship with the candidate
- Ensure the member of centre staff is not solely involved in making assessment decisions for the affected candidate for any internally assessed component/unit
- Ensure the marked work will be submitted for moderation whether or not it is part of the moderation sample
Protocols
- Record/evidence the specific measures taken/protocols in place to achieve the above
Conflict of Interest
A member of exams office staff has a member of family (which includes stepfamily, foster family and similar close relationships) or close friends and their immediate family (e.g. son/daughter) being entered for examinations and assessments at the centre itself or another centre
Note: A centre record must be maintained but this does not need to be declared to the relevant awarding body/bodies
Mitigation
- Ensure that the member of exams office staff does not have unaccompanied access to confidential examination materials (for example, question papers, pre-release materials, answer scripts, etc.)
- Ensure that another person is present for particular administrative arrangements relating to the candidate’s exams/assessments
Protocols
- Record/evidence the specific measures taken/protocols in place to achieve the above – this could include but is not limited to, as example: No unaccompanied access to confidential materials during the receipt, checking, secure storage and removal from secure storage process
- Having logs in place or extending existing logs to confirm all activity in relation to confidential materials is supported/witnessed by another member of staff
- Extending the ‘second pair of eyes check’ record to allow confirmation that question paper packets are still intact when they are removed from secure storage at the time of the examination
- Nominating another member of staff to undertake tasks such as:
- opening question paper packets in the secure room where there is a need to split question paper packets for different examination rooms or facilitate access arrangements
- handling any secure electronic materials
- checking and packing affected scripts for dispatch
- dealing with post-exam reporting where the related person may be involved, for example special consideration, very late arrival, malpractice
Conflict of Interest
A member of centre staff is taking a qualification at the centre itself which does not include internally assessed components/units.
Note: A centre record must be maintained but this does not need to be declared to the relevant awarding body/bodies.
Mitigation
- Prevent the member of centre staff having access to confidential examination materials prior to exam(s)
- Brief other relevant centre staff on maintaining the integrity and confidentiality of examination materials
- Ensure the member of centre staff is treated in the same way as any other candidate entered for that qualification, does not have access to examination materials and does not receive any preferential treatment
Protocols
- Record/evidence the specific measures taken/protocols in place to achieve the above
Conflict of Interest
A member of centre staff is taking a qualification at another centre.
Note: A centre record must be maintained but this does not need to be declared to the relevant awarding body/bodies.
Mitigation
- Ensure the member of centre staff does not have access to confidential examination materials for the same awarding body qualification if this is delivered in the centre itself
Protocols
- Record/evidence the specific measures taken/protocols in place to achieve the above
Appendix
Awarding body information
To make declarations, follow the individual awarding body’s procedures, as explained on their website:
AQA https://www.aqa.org.uk/exams-administration/exams/conflict-of-interest-declarations
CCEA www.ccea.org.uk
OCR https://www.ocr.org.uk/administration/centre-staff-declaration-form/
Pearson https://support.pearson.com/uk/s/article/Conflict-of-Interest
WJEC https://www.wjec.co.uk/home/administration/centre-information/#tab_1