Conflict of Interest Policy
As AOW Co.,Ltd is required to identify to WSET and assist in managing or monitoring actual, potential and perceived conflicts of interest (‘Conflicts of Interest’) involving both APP staff and students. This policy complements WSET’s conflicts of interest policy and works to safeguard the integrity of WSET qualifications and promote confidence in WSET and AOW Co.,Ltd processes and procedures.
This policy applies to all AOW Co.,Ltd staff and students and to any individual acting on behalf of AOW Co.,Ltd
A Conflict of Interest exists where an individual has interests or loyalties that could adversely influence their judgement, objectivity or loyalty to WSET or AOW Co.,Ltd when conducting activities associated with WSET qualifications.
• The assessment of candidates by an individual who has a personal interest in the result of the assessment for any or all individuals concerned;
• The moderation of assessment of candidates by an individual who has a personal interest in the result of the assessment for any or all individuals concerned;
• The undertaking of a WSET qualification by any individual employed by an APP;
• The invigilation of a WSET assessment by any individual involved in the delivery of training leading to the assessment;
• The coaching of candidates by any individual involved in the assessment of candidate scripts;
• The investigation of a non-compliance incident by someone who is unable to act impartially.
Some of these Conflicts of Interest are manageable and therefore acceptable. For example, if family member of one of AOW Co.,Ltd’s educators or APP staff takes a qualification and exam through AOW Co.,Ltd., or when an employee of AOW Co.,Ltd, or of the WSET, takes a WSET qualification through AOW Co.,Ltd, we can notify WSET in advance and work with them to put in place measures to maintain the integrity of the exam.
Some Conflicts of Interest are not manageable and are not acceptable. For example, no mitigation efforts overcome the conflict created when an individual when a single individual serves as the educator and exam officer of an exam for a family member where an external invigilator is not available.
Any staff member or student of AOW Co.,Ltd who becomes aware of a Conflict of Interest must inform AOW Co.,Ltd as soon as possible. AOW Co.,Ltd will inform the WSET of the possible conflict of interest and will work with WSET to put any protective or mitigating measures in place to manage the conflict on a case-by-case basis. If WSET and AOW Co.,Ltd determine the conflict is not manageable, AOW Co.,Ltd will inform any impacted APP staff or students.
Please note that the failure to declare a conflict of interest may have consequences for the student or AOW Co.,Ltd because we are required to report conflicts to WSET.
•If the candidate is not satisfied with the response and solution from (APP name), they may wish to file a complaint with WSET about the issue by contacting WSET’s Quality Assurance Team firstname.lastname@example.org.
•Conflict of Interest declarations will be recorded by WSET on the Conflicts of Interest Register.
諮詢時間: 周一至周五, 9:00~18:00
Reasonable Adjustments Policy
Both WSET and AOW Co.,Ltd want to make WSET assessments accessible for all students, so none are at an advantage or disadvantage based on a disability or differing ability. This policy and the reasonable adjustment process allows us AOW Co.,Ltd to work with you, our student, before an assessment to gather the information we need to submit a request to WSET and work with them to make arrangements that give students access to WSET qualifications.
A reasonable adjustment is any accommodation or arrangement that helps to reduce the effect of a known disability or difficulty that substantially disadvantages a student’s assessment. Using a reasonable adjustment does not impact how WSET grades your exam, or your result, but WSET cannot agree to reasonable adjustments where your particular difficulty directly affects performance necessary to complete the assessment outcomes (e.g. inability to smell or taste for a Level 3 Exam). The goal of a reasonable adjustment is to give you equal access to a WSET qualification, not to give unfair advantages over other students who take an assessment without the same adjustment, or to affect the overall reliability of the assessment outcomes that are explained in the course Specification.
AOW Co.,Ltd will gather the information we need from you to submit a Reasonable Adjustment Application form to WSET. WSET must approve and arrange reasonable adjustments before the assessment activity takes place. Before completing enrolment with AOW Co.,Ltd, we will give all students access to this policy and the chance to identify any special needs that could require a reasonable adjustment. If a student identifies a special need, AOW Co.,Ltd will give the student the Reasonable Adjustment Application form as soon as possible and work with the student to gather the necessary information.
For any student seeking a reasonable adjustment, please contact AOW with:
• Your full name;
• contact information;
• description of the special need, disability or differing ability that requires an adjustment; and
• supporting documentation.
You must submit this information at least 30 working days before the exam date for Levels 1-3 qualifications. The information you submit will be shared with WSET and will be handled under WSET’s Privacy and Data Protection Policy.
AOW Co.,Ltd will keep records of all reasonable adjustment
諮詢時間: 周一至周五, 9:00~18:00
Special Consideration Policy
Special consideration is any adjustment given to a student who has temporarily experienced an illness or injury, or other event outside of their control at the time of the exam that significantly affects their ability to take the exam or their ability to show their knowledge and understanding in the assessment. Special consideration is only for things that happen immediately before or during an exam that have a material impact on your, the student’s, ability to take the exam or on your performance. To be eligible for special consideration, you must have completed the whole course and would have been fully prepared if not for the temporary illness, injury or other uncontrollable event. A special consideration may be for an individual (e.g. a student becomes ill the day of the exam) or a group of students (e.g. an exam is interrupted by a natural disaster).
You may be eligible for special consideration if:
• Your performance on the exam is adversely affected by an event outside of your control. This may include temporary illness, temporary injury, bereavement or exam room conditions;
• Reasonable adjustments which were agreed in advance of the exam proved inappropriate or inadequate;
• The application of special consideration would not make a passing result and certificate misleading about the student’s ability to satisfy the qualification’s assessment criteria.
Applying for special consideration
If you have taken an exam, or your exam is immediately approaching, and you feel that you have a temporary injury or illness, or other uncontrollable event that has interfered with your ability to complete your exam, please contact AOW Co.,Ltd as soon as possible. AOW Co.,Ltd will provide you with a Special Consideration Application Form, which must be completed and returned with supporting documentation within 3 working days after the effected exam. The information you submit will be shared with WSET and will be handled under WSET’s Privacy and Data Protection Policy.
If there has been serious disruption during an exam affecting a group of students, AOW Co.,Ltd will submit a detailed report of the circumstances and candidates affected to WSET to request a special consideration.
AOW Co.,Ltd will keep records of all applications for special consideration.
諮詢時間: 周一至周五, 9:00~18:00
Malpractice and Maladministration Policy
Both AOW Co.,Ltd and WSET have policies and procedures in place to protect WSET students and safeguard the integrity of WSET qualifications. AOW Co.,Ltd ensures compliance with AOW Co.,Ltd and WSET’s policies through this Malpractice and Maladministration Policy, which gives a framework for both us and you to identify, report and manage potential malpractice or maladministration.
Non-compliance with AOW Co.,Ltd or WSET Policies and Procedures can fall into two distinct, but related, categories:
1. Maladministration, where the non-compliance is generally unintentional, or the result of mistakes, carelessness, inexperience or poor processes; and
2. Malpractice where the non-compliance is intentional or the result of a negligent or reckless action without consideration of the consequences of the action.
Context is important and the line between maladministration or malpractice is not always clear: for example, maladministration incidents may become malpractice (e.g. if you fail to implement corrective measures, repeat the same or similar incident, or attempt to misrepresent or hide information during an investigation); or there may be mitigating factors that turn potential malpractice into maladministration. Though malpractice and maladministration are distinct concepts, they can shade into one another. Malpractice and maladministration are always case, context and fact specific. Both APPs and students can commit malpractice and maladministration.
This document sets out our data processing practices and your rights and options regarding the ways in which your personal information is used and collected. If you have any queries, please contact WSET’s data protection contact by emailing email@example.com.
1. Who we are and how to contact us
If you have any questions about how we use your personal information or how we comply with our responsibilities, please contact us as follows:
Call: +44 (0)20 7089 3800
Write: 39-45 Bermondsey Street, London SE1 3XF
2. How we collect your personal information
We collect your personal information in a number of different ways, depending on how you engage with us. We have set out these methods below.
When you directly provide it to us directly
For example, when you subscribe to a WSET newsletter, respond to a WSET survey, or register for a WSET-hosted course or event.
From your chosen course provider
When you register for an exam with WSET, your chosen course provider (known as your Approved Programme Provider or ‘APP’) must provide WSET with some of your personal information for the purpose of identification and managing your qualifications and results.
When our systems collect information or personal information indirectly
For example, whenever you use a website or mobile application. The most common type of information our systems collect is in the form of cookies (cookies are small text files sent by your computer each time you visit our website) but can also include personal information transferred by the device you are using to access our website. The manufacturer of your device or the provider will have the details about what information your device shares. Please see our Cookies Policy for more information.
3. What personal information we collect
The type of information we collect depends upon your engagement with us. We may collect the following information about you:
(a) Your name, date of birth, gender and contact details (this could include your postal address, telephone numbers and email address);
(b) Purchases and orders made by you or on your behalf by your chosen course provider;
(c) Your payment card details (which are encrypted) when you purchase any products or services (should you pay for one of our products or services over the telephone or using one of our payment forms, your card details will not be retained and will be securely destroyed);
(d) When you set up any account with us, your login credentials;
(e) Your marketing preferences;
(f) Your correspondence with us;
(g) In certain situations, information relating to health which may be required to support applications for reasonable adjustment and/or special consideration in the context of exams for WSET qualifications;
(h) Your ethnicity and/or racial origin and such other information as may be required by our regulator in connection with the delivery of WSET qualifications.
4. Why we collect your personal information
We use your personal information for a number of different reasons:
(a) To register you as a candidate with WSET and enable you to sit exams for WSET qualifications.
(b) To administer and conduct your exam, including making arrangements for reasonable adjustments and/or special considerations.
(c) To communicate with your course provider and issue your exam results and qualification certificate as appropriate.
(d) To provide you with post-results services such as enquiries against results and appeals and solicit feedback from you on WSET qualifications.
(e) To process your registration for any WSET-hosted courses or events so that we can deliver these services to you.
(f) To send you information regarding the course or event for which you are registered (or which you have registered interest in).
(g) To process sales of products or services you have purchased from us.
(h) To manage any account(s) for providing our online services including but not restricted to our Online Classroom and Global Campus where you have registered with us so that:
(i) We can provide you with the relevant products and services;
(ii) You can access relevant course materials;
(iii) We can fulfil our services and communicate with you about them.
(i) To verify your identity.
(j) To carry out research to better understand your requirements on the relevant products and services.
(k) To personalise, report on and improve the services and products we provide to you, and to provide you with a best-in-class customer service experience.
(l) To send you marketing communications including information about our qualifications, upcoming events and links to our blogs.
(m) To investigate any potential maladministration, malpractice, or other non-compliance in connection with the delivery of WSET qualifications.
5. Lawful processing
We are required to rely on one or more lawful grounds to collect and use the personal information we have outlined above. We consider the grounds listed below to be relevant:
Where applicable law allows us to collect and use personal information for our or another person’s legitimate interests, and the use of your personal information is fair, balanced and does not unduly impact your rights. We rely on this ground to process your personal information when we believe that it is more practical or appropriate than asking for your consent. For example, when we use your personal information to register you for and process your exams, that is a key component of our legitimate
business interest in providing you with a WSET qualification. Additionally, where you provide information on the Online Classroom and Global Campus, we will rely on the legitimate interest ground to communicate with you in most instances.
Where we ask for your consent for our use of your personal information for a specific purpose. For
example, we will ask for your consent to send you marketing materials via email. You always have the
right to withdraw your consent.
Where it is necessary to use your personal information to fulfil a contract with you or to take steps at your request prior to entering into one. For example, when you sign up to the Online Campus and Global Classroom, you are asked to agree to our terms and conditions. This creates a contract between you and WSET. It may be necessary to use your information to update you about access to the Online Campus, or other such administrative matters.
Where the processing of your personal information is necessary for us to comply with a legal obligation to which we are subject. For example, we may need to report matters from time to time to our regulators, including the Charity Commission and Ofqual.
6. Special Categories of personal information
Data protection law recognises certain categories of personal information as sensitive and therefore requiring more protection. These categories of data include information about health, ethnicity, and political opinions.
We may collect and/or use special categories of data in connection with the provision of our services, for example in order to make adjustments for any disabilities or dietary requirements you may have. We will only process these special categories of data if there is a valid reason for doing so and where the data protection laws allow us to do so.
7. Marketing communications - Opt-in and Opt-out
In general, WSET will not send you any marketing information unless you have requested to receive email/ text/social media message updates from us. However, if you have made a purchase from us in the past or contacted us in relation to one of our qualifications, we may contact you in the future about similar items or qualifications. We will always provide you with an opportunity to opt out of any further communication, as discussed more below.
For legal entities, such as companies, limited liability partnerships and other incorporated organisations, WSET operates, in compliance with the relevant data protection laws, an ‘opt-out’ policy. This means that we will continue to contact such businesses with news and information of our goods and services until we are informed that this communication is no longer required.
If you (whether an individual or a legal entity) wish to be removed from our direct marketing list and do not wish to receive any further information from us (opt-out) you can inform us of this by clicking on the link at the bottom of each email communication you receive from us, or by our Contact Us page. Once this information is received, we will remove you from our direct marketing database.
8. Sharing your personal information with third parties
For us to provide you with products and services, we on occasion share some of your personal information with certain approved third parties. These include course providers, examiners, suppliers (for example, our IT services provider) and regulatory bodies (for example, Ofqual, the Charity Commission or Information Commissioner’s Office).
We reserve the right to disclose your personal information to third parties:
(a) in the event that we buy or sell any business or assets, in which case we may disclose your personal information to the prospective buyer or seller of such business or assets;
(b) if substantially all of our assets are acquired by a third party, personal information held by us may be one of the transferred assets;
(c) with our professional advisors e.g., lawyers, where necessary to protect our interests;
(d) if we are under any legal or regulatory obligation to do so; and
(e) in connection with any legal proceedings or prospective legal proceedings, in order to establish, exercise or defend our legal rights.
If we share your information with any other third party, we will let you know in advance.
9. How do we keep your personal information secure?
We are committed to maintaining the security of your personal information. We conduct a data security review of any third party we are required to share your personal information with to ensure that they meet our high security standards.
Every company we work with is required to have a contract with us that clearly describes how your personal information is kept secure. We will only ever share data specific to its intended use. Specific details of what data we have shared are available to you on request.
10. International Data Transfers
While WSET is based in the UK, our reach is international with candidates and course providers based around the world. This means that it is possible that personal information we collect from you will be transferred to and stored in a location outside the UK or the EEA.
Please note that certain countries outside of the UK or EEA have a lower standard of protection for personal information, including lower security protections. Where your personal information is transferred, stored, and/ or otherwise processed outside the UK or EEA in a country which does not offer an equivalent standard of protection to the UK or EEA, we will take all reasonable steps necessary to ensure that the recipient implements appropriate safeguards designed to protect your personal information. For instance, we may use cloud providers to store personal information who have servers in the US and are signed up to the Privacy Shield. If you have any questions about the transfer of your personal information, please contact us using the details above.
11. Data retention – how long do we hold your personal information
We will not hold your personal information for longer than is necessary for the purposes described in this policy. If, however, you have completed one of our qualifications we will retain your information for a longer period, in order to comply with our regulatory obligations. For full details about our retention policy, please contact firstname.lastname@example.org
12. Your rights
You have several rights under data protection law, these are summarised below.
The right to be informed
You have the right to total transparency on how we are using your personal information, we will endeavour to make this clear by ensuring that this document is regularly reviewed and updated, but if you have any concerns or questions please send them to our data protection contact at email@example.com
Your right of access
You have the right to know what information we hold about you and how it is processed. If you wish to access your personal information, contact firstname.lastname@example.org. If we are satisfied that you have a right to see this personal information and we are able to confirm your identity, we will, except in very limited circumstances provide you with this personal information.
The right to rectification
If you think that the information we hold about you is inaccurate or incomplete, or if your contact details change, please ask us to amend it by contacting email@example.com.
The right to erasure
You reserve the right to ask us to delete your personal information; however, this is not an absolute right. We can refuse to erase personal information which we need to keep in order to comply with legal obligations. For example, we are required by HMRC to keep personal information for up to 6 years for VAT reporting purposes, and in relation to investigations by law enforcement agencies or the Information
When you ask us to delete your personal information, we may clarify with you as to whether instead you no longer wish to hear from us again. If this is the case, we may retain limited information about you to make sure you are removed from all future marketing lists.
The right to transfer your personal information (known as data portability)
You have the right to move, copy or transfer your personal information from one organisation to another. If you wish to transfer your personal information, we would be happy to help. If you ask for a data transfer, we will give you a copy of your personal information in a structured, commonly used and machinereadable form (for instance, in a CSV file format). We can provide the personal information to you directly. When making a transfer request, it would be helpful if you can identify exactly what personal information you wish us to transfer. We will comply with your request within one month or, if the request is complex or
there are several requests from you, within two months.
The right to object
If you would like us to stop processing your personal information:
(a) for marketing purposes;
(b) on the basis of legitimate interests; and/or
(c) for research purposes
simply let us know by contacting firstname.lastname@example.org
If you would like to exercise any of the above rights, or if you have any questions or complaints, please contact email@example.com You also have the right to contact and raise an issue with the Information Commissioner’s Office. You can find the relevant details on their website: https://ico.org.uk/
13. Policy Update
We may update this policy from time to time to take account of any new business activity or to reflect any changes in law or best practice in relation to data protection. We will seek to make you aware of any significant changes to this policy by placing an update notice on our website.
Diversity and Equality Policy
WSET is committed to upholding the principles of diversity and equality in all areas of its work, seeking to ensure that all APPs, candidates and other stakeholders are treated fairly and equally at all times. This policy applies to all WSET staff and to any individual acting on behalf of WSET. As an APP, you must have your own diversity and equality policy which complements the provisions set out below.
WSET assures equality of opportunity for candidates by:
• Promoting open access to WSET qualifications (having regard to the legal minimum age for the retail purchase of alcohol and assessment competence standards);
• Ensuring that the format and content of all specifications, exams and other WSET materials do not discriminate unlawfully against anyone on the grounds of disability, age, marriage and civil partnership, gender reassignment, pregnancy and maternity, race, religion or belief, sex and sexual orientation (having regard to the legal minimum age for the retail purchase of alcohol and assessment competence standards);
• Allowing candidates with special educational needs, disabilities, or temporary injuries to access WSET exams without changing the demands of the assessment in line with our Reasonable Adjustment and Special Consideration policies;
• Ensuring that WSET employees consider this policy when developing new qualifications andother WSET projects;
• Requiring all APPs to have a diversity and equality policy in place which promotes open access to WSET qualifications;
• Collating and monitoring data on candidate age, gender, ethnicity and access arrangements and reporting in a non-attributable format;
• Inviting feedback on diversity issues from APPs, candidates, and other stakeholders;
• Working with relevant organisations as appropriate to develop measures to identify and prevent inequality of opportunity; and
• Reviewing this policy regularly to ensure it continues to meet legislative and organizational requirements and goals.
WSET assures equal opportunities for APPs by considering applications from any organisation or individual who demonstrates that they meet our approval criteria. We do not give any one provider exclusivity to offer our qualifications in a defined territory or region. Candidates who believe they may have been unfairly discriminated against by an APP initially should raise their concern with their APP.
Any APP, candidate or stakeholder who has a concern that actions of an individual connected to the delivery of WSET qualifications is against the WSET code of conduct can report their concern to QA@wsetglobal.com. This policy must be made available to candidates upon request.