Centre Policies and procedures
Simms Counselling & Training – Centre Policies & Procedures
Level 2 to Level 5 courses
Prepared 11 October 2026 | Version 1.0 | Policy owner Denise Duncan
Purpose and scope
These policies explain how Simms Counselling & Training supports learners, assesses work, handles concerns and manages fees and personal information. They apply to ICSK-L2, CSK-L2, ELSK-L2, CST-L3, CST-L4 and CBT-L5, including online learning.
The shared procedures apply to these courses. Course handbooks and assignment briefs set out the qualification-specific learning outcomes, teaching dates, evidence requirements and professional practice obligations. Those requirements remain separate; Level 3 does not qualify a learner to practise as a professional counsellor.
Contact and independence
Course Director and Co-ordinator: Denise Duncan, denise@simmscandt.co.uk. General enquiries, complaints, assessment appeals, disciplinary appeals and privacy requests: enquiries@simmscandt.co.uk. Fee and payment questions only: Lianna Walker, lianna@simmscandt.co.uk. Proposed complaints and appeals reviewer: Camilla Akehurst, camilla@simmscandt.co.uk. Website: https://simmscandt.co.uk.
Put the relevant procedure in the email subject. The centre will route it to the responsible person. If your concern involves your tutor, administrator or a senior manager, say so and request an independent handler. Nobody will decide an appeal against their own decision or a case in which they have a conflict of interest. An external reviewer will be appointed where necessary.
Camilla Akehurst, camilla@simmscandt.co.uk, is the proposed complaints and appeals reviewer, subject to suitable expertise and no prior involvement or conflict of interest. You may contact her directly or use enquiries@simmscandt.co.uk for routing. Lianna Walker deals only with fee-related matters. If Camilla considers an original complaint, another independent reviewer must consider any appeal against her decision. A further assessment appeal will be considered by a separate panel with no prior involvement.
Using these policies
Working days mean Monday to Friday, excluding public holidays and notified centre closure dates. Help with submitting concerns, reasonable adjustments and a supporter at meetings are available on request. Extensions may be agreed for good reason. If a response will be delayed, the centre will explain why and provide a revised date. Good-faith complaints and appeals will not attract a penalty.
Contents
1 Equality inclusion and learner support
2 Complaints
3 Internal assessment appeals
4 Discipline and disciplinary appeals
5 Bullying safeguarding and safe learning
6 Internal quality assurance
7 Privacy and learner information
8 Recording and confidential learning material
9 Fees withdrawal and centre cancellation
10 Academic integrity and achieving the qualification
1 Equality inclusion and learner support
We oppose unlawful discrimination, harassment and victimisation and expect staff and learners to treat everyone with dignity and respect. The Equality Act 2010 identifies nine protected characteristics: age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation. We also value diversity in language, background, socio-economic circumstances, appearance, health and political opinions.
Concerns about discrimination may be raised directly through the formal complaints route. Alleged misconduct will be addressed through a fair disciplinary process. Serious safety concerns may require immediate protective action, but this does not remove the right to respond or appeal.
Support and reasonable adjustments
Speak with your tutor before or during the course if you need accessible materials, note-taking support, dyslexia support or another adjustment. Explain the barrier without sharing more medical detail than necessary. The centre will consider the request against current CPCAB requirements, record agreed arrangements and explain a refusal in writing. Adjustments support access while preserving the competencies required for the qualification.
If you disagree with an adjustment decision, email enquiries@simmscandt.co.uk and request an independent review. Assessment-related decisions may be challenged under section 3. Tutorial arrangements, assignment deadlines and any special consideration requirements are explained in the relevant course handbook and current briefs.
Attendance and punctuality
Aim for full attendance and punctuality. Notify your tutor promptly, preferably before the session, if you will be absent or late. Discuss repeated absence and how missed learning may be addressed. Attendance alone does not establish proficiency: all required outcomes and evidence must be achieved.
| Course | Centre minimum attendance |
| ICSK-L2 | 80% |
| CSK-L2 | 80% |
| ELSK-L2 | 80% |
| CST-L3 | 80% |
| CST-L4 | 85% |
| CBT-L5 | 90% |
Teaching hours, dates, breaks and course-specific requirements remain in the course handbook and scheme of work. Catch-up arrangements must preserve required guided learning and assessment standards. Concerns about attendance barriers should be discussed promptly so that support can be considered.
2 Complaints
A complaint concerns the learning experience, administration, fees, facilities or staff conduct. Assessment decisions follow section 3; disciplinary decisions follow section 4. If a concern overlaps procedures, the centre will explain the route and contact for each issue.
Stage 1 Informal resolution
Where safe and appropriate, discuss the concern with the person involved, verbally or by email. You may go straight to the formal stage for bullying, harassment, discrimination, safeguarding, a power imbalance or fear of retaliation. If informal discussion does not resolve the concern, escalate within 10 working days of the response; extensions may be agreed for good reason.
Stage 2 Formal complaint
Send a complaints form or a written account to Camilla Akehurst at camilla@simmscandt.co.uk or enquiries@simmscandt.co.uk, marked “Formal complaint”. Explain what happened, relevant dates, supporting evidence and the outcome you seek. A form is available from the same address. If a staff member is implicated, request an independent handler.
The centre will review eligibility and respond within 21 working days of receipt. If the complaint will not proceed, it will give written reasons. Where investigation is required, an independent complaints officer will consider relevant evidence and give those involved an opportunity to respond. Meetings may be online or in person, with a supporter and documented notes.
A written decision will normally be issued within 30 working days of receipt of the formal complaint. It will explain whether the complaint is upheld, partly upheld or dismissed, the reasons, any action and deadlines, and the appeal route. Delays will be explained with a revised date.
Stage 3 Complaint appeal
Appeal within 10 working days of receiving the decision if material evidence has emerged that was not reasonably available earlier, or the complaints procedure was not followed. Email camilla@simmscandt.co.uk or enquiries@simmscandt.co.uk, marked “Complaint appeal”, identifying the decision, grounds and supporting evidence.
Camilla Akehurst will review the appeal if suitably qualified and free of prior involvement or conflict. Otherwise another independent reviewer will be appointed. A final written response will normally be issued within 21 working days of receiving the appeal. After the internal process, unresolved concerns may be raised with CPCAB where they fall within its remit: https://www.cpcab.co.uk/making-a-complaint/.
Complaint records are confidential and shared only as necessary to investigate, act on findings or meet legal and quality assurance obligations. Persistence or disagreement alone does not make a complaint vexatious. Any contact restriction will be proportionate, explained in writing and independently reviewable; relevant new evidence will still be considered.
3 Internal assessment appeals
You may challenge an internal assessment decision, an overall proficiency decision, or the application of assessment requirements or reasonable adjustments. Grounds include relevant evidence being overlooked, criteria applied incorrectly, procedural error, bias or an agreed adjustment not being provided. Disagreement alone does not establish an assessment error.
Stage 1 Clarification
Contact your tutor within 10 working days of receiving the decision. Ask which criteria have not been met and how your evidence was assessed. The tutor will explain the decision and check for errors. If the concern involves the tutor or you do not feel able to approach them, email enquiries@simmscandt.co.uk directly.
Stage 2 Formal appeal and independent review
If unresolved, email camilla@simmscandt.co.uk or enquiries@simmscandt.co.uk, marked “Assessment appeal”, within 10 working days of the tutor’s response. If you bypass clarification, submit within 10 working days of the assessment decision. Identify the assessment and decision, explain your grounds, attach relevant evidence and state the outcome sought.
The centre will acknowledge receipt within five working days. Camilla Akehurst will review the appeal if she has suitable assessment expertise and no prior involvement or conflict. Otherwise an independent, suitably qualified reviewer will be appointed. The reviewer will examine the evidence, criteria and assessment procedure and normally provide a written outcome with reasons within 20 working days of receipt.
The outcome may confirm or correct the decision, or refer it for reassessment or further evidence as appropriate. An appeal does not guarantee proficiency. Keep the originally assessed work unchanged; identify any additional material separately and explain its relevance. New assessed evidence is accepted only through an authorised reassessment or further-evidence process, rather than by altering the original submission.
Stage 3 Final centre review
If relevant evidence was overlooked or the appeal procedure was not followed, request a final review within 10 working days of receiving the outcome. Email enquiries@simmscandt.co.uk, marked “Final assessment review”, with your grounds. A separate panel with suitable expertise and no prior involvement or conflict will consider the case. External members will be used where necessary.
The centre will normally provide the final written outcome within 20 working days of receiving the request, explaining reasons, any required action and the further route available. Each stage is dated and recorded. After the internal process, an unresolved concern may be raised with CPCAB under its current complaints policy where within its remit; this does not automatically provide a fresh assessment or change the result.
4 Discipline and disciplinary appeals
This procedure addresses alleged breaches of the Learner Agreement, conduct, equality, confidentiality or academic integrity requirements. It is separate from a complaint about services and an appeal against an assessment decision. Action must be proportionate and based on relevant evidence.
Step 1 Written notification and response
You will receive written notice of the allegation, available evidence, possible outcomes and how to respond. Normally you will have at least five working days to provide an account or request a meeting. You may bring a friend or supporter. Relevant evidence and your response will be considered impartially before a final decision; meetings will be documented.
Step 2 Immediate safety measures
Where there is a serious safety or safeguarding concern, the centre may require you to leave a session or temporarily suspend attendance while it investigates. This is a precaution and does not establish misconduct. Written reasons, attendance arrangements and a review date will be provided promptly. Immediate removal does not remove your opportunity to respond, request a meeting or appeal a final dismissal.
Step 3 Written decision
A decision will normally be issued within 20 working days of the written notice. It will explain findings, evidence, reasons, any action, deadline and appeal route. If more time is needed, you will receive an explanation and a revised response date. Outcomes may include no action, a written warning with improvement requirements, or dismissal where justified by serious or repeated conduct. Relevant circumstances will be considered.
Step 4 Independent disciplinary appeal
Appeal within 10 working days of receiving the decision on grounds of procedural unfairness, relevant new evidence not reasonably available earlier, or a disproportionate sanction. Email enquiries@simmscandt.co.uk, marked “Disciplinary appeal”, identifying the decision, grounds and outcome sought.
The centre will acknowledge receipt within five working days and appoint a reviewer with no prior involvement or conflict; an external reviewer will be used where necessary. A final written outcome will normally be issued within 20 working days of receipt, explaining whether the decision is upheld, amended or referred for reconsideration and any further route available. Attendance during an appeal will be addressed separately in writing, with safety considerations explained.
Examples of conduct concerns include discrimination, harassment, bullying, deliberate property damage, attending under the influence of illicit substances or alcohol, theft, confidentiality breaches, fighting or assault, and academic misconduct. Further incidents after a warning may lead to additional action under this procedure. Fee liability is addressed under section 9 and the Learner Agreement, subject to statutory rights.
5 Bullying safeguarding and safe learning
Staff and learners have a right to a safe, respectful learning environment. Bullying, intimidation, harassment and hate-related abuse are taken seriously. Examples include threats, malicious gossip, name-calling, coercion, social exclusion, theft or damage to property, physical assault and abusive online communications. A complaint or critical review made in good faith is not itself bullying.
Bullying related to protected characteristics may involve unlawful discrimination or harassment. A hate-related incident may involve hostility or prejudice relating to race, religion, sexual orientation, disability or transgender identity, including perceived characteristics. Some conduct may also be a criminal offence. Report concerns to your tutor or enquiries@simmscandt.co.uk; you may use the formal complaints route directly. Alleged misconduct is considered under section 4.
Safeguarding and urgent concerns
Tell your tutor promptly about a safeguarding or serious safety concern, or email enquiries@simmscandt.co.uk, marked “Safeguarding concern”. If the concern involves the tutor or another member of staff, use the alternative route and request an independent responsible person. The Course Director will arrange an appropriate response and referral where necessary.
In immediate danger call 999. Centre emails and course messages are not emergency services. Do not delay contacting emergency services while waiting for a centre response. Staff will record concerns and act promptly, sharing relevant information with appropriate services where necessary and lawful.
Confidentiality and personal material
Respect the group contract and the confidentiality of peers, clients and others. Do not disclose identifying client material in learning groups or coursework. Staff may need to share relevant information for safeguarding, serious safety concerns, assessment, quality assurance or legal obligations. They will normally explain proposed sharing and involve you where safe; urgent action may be necessary without prior discussion.
Learning can have a personal or emotional impact. Choose material suitable for a training setting; you are not required to disclose traumatic experiences or highly sensitive information. You may pause a distressing exercise and seek support or an appropriate adjustment. Journals and reflective work should focus on learning without unnecessary disclosure.
6 Internal quality assurance
Internal quality assurance (IQA) checks that teaching, assessment and learner support are fair, consistent and aligned with current CPCAB requirements for each qualification covered by this policy. Internal moderation reviews assessment decisions; internal verification reviews course design, delivery and assessment systems. All tutors and assessors take part.
Responsibilities and independence
Denise Duncan approves the annual IQA plan, arranges suitable staffing and ensures actions are completed. Tutor-assessors assess work, provide developmental feedback and maintain records. Moderators must have appropriate teaching and assessment qualifications or equivalent, subject expertise, and experience teaching and assessing at the relevant level or above. They must not moderate their own assessment decisions; a separate moderator is arranged where needed.
The internal verifier oversees the wider IQA process and will have a recognised IQA qualification, equivalent qualifications or relevant IQA experience, with further training supported where needed. Roles and conflicts of interest are recorded before sampling begins.
Planning frequency and sampling
Each academic year, the internal verifier prepares a dated plan naming activities, responsible staff and completion dates. For ICSK-L2 and ELSK-L2, internal moderation takes place for every candidate group before internal assessment results are uploaded; for ELSK-L2, evidence of moderation also accompanies samples submitted to CPCAB for independent verification. For CSK-L2, CST-L3, the Level 4 course and CBT-L5, moderation takes place at least annually for each qualification and covers every registered tutor assessing that qualification. The centre checks current CPCAB requirements for the registered qualification code. Internal verification also takes place annually for each qualification. Moderation is scheduled early enough to correct problems, with follow-up before final results.
For the group selected for moderation, the sample covers at least 30% of portfolios or four portfolios, whichever is greater, rounded up. All portfolios are sampled if fewer than four learners are in the group. A sampling grid identifies the group, assessor, candidates, evidence and dates. The sample includes stronger, middle-range and weaker work and different evidence types. Sampling is extended for concerns, new assessors, borderline outcomes or appeals, with reasons recorded.
Findings improvement and final checks
The moderator checks evidence, decisions and the usefulness of feedback. A written report records findings, disagreements and actions with owners and deadlines. The assessor responds and the moderator verifies completion. Unresolved disagreements go to the Course Director for independent, suitably qualified review.
Team standardisation and the annual course review consider planning, delivery, support, attendance, assessment tracking, adjustments, tutor development, feedback, complaints and appeals. An IQA record holds plans, role allocations, sampling grids, moderation and verification reports, meeting records and closed actions.
Before results are submitted, the centre checks evidence and Completion Statements, completion of IQA actions and qualification requirements. Your portfolio is confidential, but it is not private to your tutor alone. Authorised assessors, moderators and CPCAB verifiers may review it for assessment and quality assurance. Access is limited to people with an authorised need, and material must not be shared publicly. Client material must be anonymised. External verification findings are logged and followed through; certification must not proceed where CPCAB has placed a hold. IQA does not replace the assessment appeal procedure. This policy is reviewed annually and after significant CPCAB changes, findings or appeals.
7 Privacy and learner information
Simms Counselling & Training Ltd is the data controller. Send privacy questions, access or deletion requests, or reports of suspected loss or disclosure to enquiries@simmscandt.co.uk, marked “Privacy request”. The centre will provide the applicable detailed privacy information for each collection or processing activity.
Information purposes and lawful use
Information may include enrolment and contact details, emergency contacts, attendance, payments, assessment evidence, journals, recordings, tutorials, support needs and concern records. It is used for administration, support, assessment, quality assurance, financial administration and handling concerns. Only information necessary for an identified purpose is collected; avoid unnecessary identifying details about clients and other people.
The centre identifies and documents an appropriate lawful basis for each processing purpose. Necessary course administration may use contract; other purposes may use legal obligation or legitimate interests where appropriate. Contract is not a blanket basis for every use. Health and other special-category information requires an additional lawful condition. Consent is not assumed merely because a learner enrols.
Access security and retention
Access is restricted to authorised people with a defined need, including relevant tutors, administrators, assessors, moderators and CPCAB staff or verifiers. Approved technology providers may process information for the centre. Relevant information may be shared with safeguarding services or authorities where necessary and lawful. Learner work is confidential but is not private to the tutor alone.
Submitted written work, portfolios and learning journals are retained for three years from the course end date, subject to lawful early deletion or a documented reason for longer retention, such as an active dispute or legal requirement. Learner access to Google Classroom is separate from the centre’s retention obligations; the tutor will communicate the access end date. Recordings have a separate retention arrangement communicated before recording.
Other records, including applications, emergency contacts, support, finance, safeguarding, complaints and discipline, are retained only as long as needed for their purpose, legal duties, quality assurance or relevant claims. The centre documents the retention period or criteria and reviews continued need. You may ask for the period or criteria applicable to your records. Secure deletion covers centre copies, authorised local copies and the provider’s backup lifecycle.
The centre uses approved accounts, role-based access and secure transfers, reviews permissions and removes unnecessary access. Report suspected loss, unauthorised access or accidental sharing promptly. Third-party provider and overseas-transfer information, where applicable, will be supplied in the detailed privacy information.
Your rights
You may request access, correction and, where applicable, erasure, restriction, objection or portability. Where consent is relied on, you may withdraw it without affecting earlier lawful processing. You may request deletion at any time; there is no three-month waiting period. The centre will explain any information it must retain and why, and respond within applicable statutory timescales. You may raise a concern with the Information Commissioner’s Office: https://ico.org.uk/make-a-complaint/.
8 Recording and confidential learning material
Before recording
All participants must be told the purpose of a skills recording, who may access it, how it will be submitted and retained, and the arrangements for withdrawal or objections. Their informed agreement must be obtained and recorded before recording starts. Permission to record is separate from identifying a lawful basis and any required special-category condition.
Where recording is required for assessment, the brief will explain it. Discuss concerns and reasonable adjustments before the activity. The centre will consider arrangements against CPCAB requirements. Do not secretly record. Tutor demonstrations, online classes and other activities require separate authorisation; permission for one activity does not authorise other recording.
Personal material and submission
Unless the tutor directs an activity otherwise, skills practice uses real material chosen by the peer in the client or helpee role. Role play may be used when directed. Choose material you feel comfortable exploring; avoid unnecessary sensitive disclosures and information identifying clients or other people. Peer agreement does not authorise recording identifiable information about someone else.
Use only the approved Google Classroom assignment or another secure route expressly confirmed by the tutor. Do not use public links, social media, personal messaging or public AI services. Do not share or reuse recordings outside the authorised learning and assessment process.
Use a personal recording device only where the tutor has approved the method and security arrangements. Disable automatic uploads to personal cloud accounts where applicable. Protect files and devices, use neutral filenames and delete local, synced and deleted-item copies after the tutor confirms successful receipt and that no further learner copy is required. Report loss or sharing promptly.
Access deletion and reuse
Authorised tutors, assessors, moderators and CPCAB verifiers may access recordings where required. Before recording, the centre will communicate a deletion date or clear retention criteria covering assessment, verification and appeals. Recordings are not included in the three-year written-work retention period. They must not be reused for publicity or future teaching without a separate approved arrangement.
Journals and reflections may be seen by authorised assessment and quality assurance staff. Anonymise other people and submit only through approved systems. Discuss especially sensitive material with your tutor before submission. A safeguarding concern may require limited sharing under section 5.
9 Fees withdrawal and centre cancellation
Payment arrangements
Course fees are payable before the course starts unless instalments have been agreed with the centre. Discuss payment difficulties promptly with Lianna Walker at lianna@simmscandt.co.uk. Certificates will not be released until fees properly due have been paid. Outstanding sums may be referred for collection after attempts to resolve the matter with the learner.
Learner withdrawal and deposits
Deposits are non-refundable if a learner withdraws, as stated in the published terms and Learner Agreement. Deposits contribute towards initial course costs and commitments. The Learner Agreement states that students remain liable for the full course fee even if they leave before completion. Agreed instalments remain payable under that agreement. Statutory cancellation, refund and other consumer rights remain unaffected; these terms apply only to the extent permitted by law.
Centre cancellation before teaching begins
If the centre cancels before teaching begins, all course fees paid, including the deposit, will be refunded. Learners may choose an agreed replacement course or later cohort instead, but will not be required to accept it.
Centre closure or incomplete delivery
If the centre cannot complete delivery after the course starts, it will notify learners and CPCAB promptly and seek a suitable completion plan using appropriately approved tutor cover or other agreed arrangements. Business reserves support contingency costs. Candidate records and completed assessment evidence will be protected.
No formal alternative-provider agreement is currently in place. Where needed, the centre will work with CPCAB to explore suitable transfer options without guaranteeing a placement. Continuation or transfer arrangements will be explained in writing and agreed with affected learners.
Where no suitable continuation is agreed with the learner, fees paid for the undelivered portion will be refunded and related unpaid instalments cancelled. Learners will receive a written explanation of the calculation and refund arrangements. The non-refundable deposit provision does not prevent a refund where the centre cancels or cannot provide the contracted service.
Temporary interruptions and requests
For technical interruption to online delivery, the tutor will pause the session, contact learners and arrange a secure alternative connection or replacement live teaching. Lost guided learning time will be rescheduled. This does not remove refund or other statutory rights if contracted provision cannot be delivered.
Send refund requests or fee questions to Lianna Walker at lianna@simmscandt.co.uk. Applicable cooling-off and other statutory rights remain available. An unresolved concern may be raised under section 2. No signature or agreement removes statutory rights.
10 Academic integrity and achieving the qualification
Your own work and permitted assistance
Assessed work must be your own. Acknowledge sources. Plagiarism includes submitting another person’s work as yours, having work written for you or allowing others to copy it. Basic spelling checks and proofreading may identify errors but must preserve your meaning and authorship. Declare substantive assistance and ask your tutor before using a tool if its effect on authorship is unclear. Agreed accessibility support remains available.
Collaborate only where the brief permits it. Individual evaluations, journals and self-reviews must reflect your own learning. Do not use generative AI to produce, rewrite or invent assessed content, personal reflections, references or skills evidence, or submit generated text as your own. Any assessment-related AI use must follow current CPCAB requirements. Do not upload confidential learning, client or peer information to public AI services.
Responding to concerns
The centre will explain concerns and evidence and invite your response before deciding on action. An AI-detection score alone is not conclusive evidence. Assessment errors use section 3; alleged misconduct uses section 4, including written reasons and a disciplinary appeal. Sanctions must follow published policy and must not be imposed retrospectively. Suspected malpractice or maladministration will be recorded and referred to CPCAB where required by its current policy.
Achievement and deadlines
To achieve a qualification, learners must be internally assessed as proficient against all required outcomes and criteria and satisfy the relevant qualification requirements. Attendance or completing written assignments alone is not enough. Tutors provide feedback and may set an action plan with evidence requirements and deadlines. Repeating a course is not automatic.
Follow the handbook, scheme of work and current brief for deadlines. Request an extension in writing as early as possible, explaining the circumstances. The tutor will record any agreed revised deadline and evidence requirements. Completion extensions, deferral and qualification-specific client or supervision requirements are handled under the relevant course arrangements and current CPCAB rules.
Policy review and resources
The Course Director reviews these policies annually and after significant regulatory changes, verification findings, complaints or appeals. Changes will be dated and communicated. Material changes to existing learner terms require appropriate notice and agreement where necessary and do not operate retrospectively to remove rights.
CPCAB complaints: https://www.cpcab.co.uk/making-a-complaint/
CPCAB IQA policy: https://www.cpcab.co.uk/public_docs/cpcab-iqa-policy
CPCAB assessment appeals guidance: https://www.cpcab.co.uk/public_docs/appeals-and-complaints-guidance-for-centres
BACP ethical framework: https://www.bacp.co.uk/ethical-framework/
ICO concerns: https://ico.org.uk/make-a-complaint/
To request a complaints form or a copy of centre policies, email enquiries@simmscandt.co.uk.