Item 11 Appendix A

West Dunbartonshire Council · 18 March 2026
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Appendix A
Malpractice Policy
August 2025

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1. Purpose and Scope
This policy sets out the procedures and principles that West Dunbartonshire Council will
follow when investigating and responding to concerns of potential malpractice in the
assessment and certification of Qualifications Scotland (QS) qualifications. It aligns with
the standards outlined by Qualifications Scotland (QS) and ensures fair, robust, and
proportionate management of malpractice concerns.
This policy applies to all QS approved centres managed by the Local Authority and staff
and candidates involved in the delivery or assessment of QS qualifications. The aim is to
protect the integrity of QS assessments and certifications by ensuring all concerns are
handled promptly, fairly and thoroughly. Investigations will be evidence-based, impartial
and proportionate. All parties must assist investigations fully and preserve confidentiality;
any failure to comply may result in suspension of certification or other actions by QS.
2. Definitions
 Malpractice: Any act, default or practice (whether deliberate or unintentional) that
breaches QS requirements and “compromises, attempts to compromise, or may
compromise, the process of assessment, the integrity of any QS qualification, or the
validity of a result or certificate”, or that damages QS’s authority or credibility.
Malpractice includes both deliberate attempt to circumvent a process and
unintentional errors (“maladministration”).
 Candidate Malpractice: Any type of malpractice by a candidate that threatens the
integrity of an assessment or examination. Examples include plagiarism,
unauthorised use of AI or generative tool, collusion, bringing prohibited material into
an exam, or falsifying work.
 Centre Malpractice: Any type of malpractice by the centre or anyone acting on its
behalf (e.g. a teacher or assessor) that threatens the integrity of assessments. This
can be intentional or unintentional (maladministration). Examples include falsifying
records, inappropriate direction of candidates, such as overhelping or supplying
answers, failure to apply assessment regulations, or non-compliance with QS
procedures.
 Lead Investigator: A senior, impartial individual (e.g. an experienced Depute Head
or Senior Leader) appointed to conduct a given investigation. The lead investigator
coordinates evidence-gathering, interviews, analysis and reporting, with authority
and no conflict of interest regarding the case.
3. Roles and Responsibilities
 West Dunbartonshire Council (Local Authority): Maintains this policy and
ensures its adoption by all schools. They will oversee investigations, appoint Lead

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Investigators, where one cannot be appointed from the centre, and provide advice to
schools. The local authority will also monitor centres’ compliance and report
concerns of centre malpractice to QS.
 Headteachers (Head of Centres): Each head of centre or their designated
representative (normally the QS Coordinator) must implement and publicise this
policy, ensuring all staff and candidates are aware of it and of their responsibilities.
Heads of centre must establish or maintain detailed centre-level malpractice
procedures (in line with this policy and QS guidance), ensure no candidate results
are submitted during an ongoing investigation, and conduct an initial screening of
any malpractice concern to determine its nature. The Head Teacher must inform the
Senior Education Officer of any suspected malpractice (candidate or centre) and,
where centre malpractice is suspected, promptly notify QS by email
(malpractice@sqa.org.uk) or phone. The Head Teacher also ensures that candidates
and staff are fully aware of the malpractice policy and the process for appealing.
 Lead Investigators: Lead Investigators manage the investigation process, from
planning through to reporting, under QS’s Standards for Devolved Investigations.
They must be a senior member of staff with no personal involvement in the case.
This will usually be, but not always, the QS coordinator in the school. They define the
scope and terms of reference, gather evidence, conduct interviews, and compile
findings. They must act impartially, thoroughly and discreetly, contacting QS and
informing the Head of Centre immediately if new evidence emerges that heightens
risk.
 Q Co-ordinator: The QS Co-ordinator is responsible for overseeing all QS exams
within the school, disseminating updates from QS, maintaining secure assessment
conditions and training staff annually on malpractice and procedural changes, and
informing pupils of malpractice processes and procedures. They are responsible for
overseeing procedures for quality assurance of assessments are in place and
followed. They will normally lead investigations and ensure that these are
documented and reported correctly.
 Centre Staff (Teachers, Invigilators, Assessors, Admin): All staff must follow QS
requirements for assessment and exams and take all reasonable steps to prevent
malpractice (e.g. securely store materials, fair marking and internal verification).
They must report any suspicions of malpractice to the head of centre at once. Staff
involved in the investigation (e.g. as witnesses) must cooperate fully. Staff should
maintain confidentiality of all investigation information. Internal Verifiers and Quality
Assurance personnel should actively monitor for irregularities and ensure
compliance with procedures.
 Internal Verifiers: Are responsible for ensuring that assessment practices meet QS
requirements. They should actively monitor for assessment irregularities and report
any concerns about potential malpractice to the Head of Centre or QS Coordinator.

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 Quality Assurance staff: Oversee the effectiveness of assessment and verification
systems across the centre. They are responsible for ensuring compliance with QS
and internal procedures, identifying risks that may lead to malpractice, and advising
on appropriate actions. They will also contribute to preventative practices by
identifying areas for improvement in assessment and verification procedures. They
also support policy implementation, contribute to staff training.
 Candidates: Candidates must adhere to the rules of assessment. They must not
engage in cheating or fraudulent practices. Candidates will be informed about
malpractice and reminded of sanctions for offences. During an investigation, a
candidate is entitled to clear information about the allegation and evidence against
them, the right to be accompanied by a supporter in meetings, the chance to give a
statement, and information on appeals.
4. Preventing Malpractice
 All parties must take proactive steps to minimise malpractice risk: designing robust
assessments, storing materials securely, and maintaining rigorous internal quality
assurance. This should include training on use of AI, generative tools, academic
integrity, data handling, and exam regulations, as well as clear procedures for
internal and external assessments. West Dunbartonshire Council will support centres
with training where required (e.g. on QS rules and assessment design) and will
periodically review centres’ internal verification and tracking of assessment data.
 QS’s Guide to Assessment can help centres to minimise the risk of malpractice by
suggesting ways of designing assessments or assessing and authenticating
candidate evidence. Centres must ensure that all staff and candidates are familiar
with this policy and their responsibilities in relation to malpractice.
5. Reporting Suspected Malpractice
 Candidate Malpractice: If a teacher or invigilator suspects a candidate of
malpractice, they must immediately inform the Head Teacher. The Head Teacher , or
their designated representative, will ensure no results or marks are submitted for that
assessment during the investigation and will conduct an initial screening to check the
validity and urgency of the concern. If Malpractice is identified after assessment
materials have been submitted to QS the Head Teacher should promptly notify the
QS by writing (investigation.enquiries@sqa.org.uk) or by telephone. In all cases the
Head Teacher will coordinate with their nominated Lead Investigator to carry out the
investigation.
 Centre Malpractice: If there is evidence of malpractice by staff or systemic
problems (e.g. widespread assessment irregularities, tampering with certificates,
falsified records), the Head Teacher must report this immediately to the Senior
Education Officer and conduct an initial screening. After screening, the Head
Teacher will inform QS in writing (malpractice@sqa.org.uk) or by telephone. The
Head Teacher will appoint a lead investigator to conduct a full investigation. Any

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concerns raised by external bodies (e.g. another awarding organisation) must also
be referred to QS promptly.
 Initial Notification to QS: Concerns of centre malpractice must be reported to QS
as soon as possible after initial screening. For candidate malpractice QS must also
be informed immediately, using the candidate malpractice report form. All reports to
QS should include basic information (centre name, qualification, date, individuals
involved, nature of concern) to allow timely risk assessment.
6. Investigation Procedure
The investigation will follow a structured, step-by-step process as follows:
1. Initial Screening: Determine the scope and risk. The Head teacher will identify the
alleged breach and relevant rules and define what is to be investigated. They will
collect basic evidence (e.g. original assessment task,) and decide if immediate
actions are needed (e.g. voiding an exam sitting, withdrawing submitted marks). No
certificate for the affected assessment will be produced until the investigation
concludes.
2. Appoint Lead Investigator: A Lead Investigator is formally assigned. This person
must be senior, impartial and experienced in QS matters. This will normally be the
QS Coordinator within the school. The Lead Investigator manages the investigation
timeline, liaises with QS as needed, and ensures the process adheres to regulatory
requirements.
3. Planning the Investigation: The Lead Investigator will plan how to gather evidence
and whom to interview. They will identify all sources of information (documents, logs,
electronic data); list all potential witnesses (teachers, invigilators, candidates,
verifiers); determine if technical or expert input is needed; and fix a target timetable.
Investigations should normally be completed within 20 working days of the
appointment of a Lead Investigator. In complex cases, an interim update should be
provided to the Senior Education Officer and QS. Special care is taken if sensitive
data (e.g. medical or child protection) is involved with appropriate confidentiality
measures are put in place.
4. Gathering Evidence: The Lead Investigator will collect all relevant evidence, which
may include copies of candidates’ work, question papers, marking records,
attendance sheets, assessment plans, emails, system logs, etc. All items are logged
with date/receipt. Documentary evidence is preserved securely; for example, exam
scripts are kept intact. The investigator may also arrange technical analysis (e.g.
plagiarism and AI detection, IT data) or seek expert opinions on assessment
standards. In sum, investigations must be evidence-based.

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5. Witness Interviews: Witness testimony is critical. The Lead Investigator will
interview staff or candidates with knowledge of the case. Interviews must be carefully
prepared and conducted. Best practice steps include:
 Conduct a face-to-face interview with the investigator and a note-taker present.
 Inform the interviewee (and parent/guardian) of the purpose of the meeting,
what it concerns, and their rights (for instance, that they may have a supporter
present and are not obliged to answer).
 Explain confidentiality (the witness should not discuss the interview with others)
and how information will be used (including possible sharing with QS or
regulators).
 If a witness is suspected of malpractice, they should be given fair notice of the
specific allegations and evidence beforehand, to allow them to respond.
 Use clear, focused questions prepared in advance and adapt your approach for
staff and candidates.
 After each interview, the note-taker (or investigator) drafts a written statement
summarising exactly what the witness said, in clear language, using the
witness’s own words where possible. The statement should include dates, be
logically structured, and omit irrelevant personal details. The witness reviews
the draft, signs or amends it to confirm accuracy. If the witness changes
something against the interviewer’s recollection, that is noted. Each statement
is dated and securely filed.
 If significant new information arises or if evidence gathering is hindered (e.g. a
key document is missing), the Lead Investigator should notify QS immediately.
6. Evaluation of Evidence: Once gathering is complete, the Lead Investigator will
carefully analyse all evidence. They assess each piece for relevance, reliability and
credibility. The investigator compares “what should have happened” (e.g. correct
procedure) with “what did happen” to identify any deviations. If evidence conflicts,
the investigator decides the most likely interpretation and records their reasoning.
The aim is to form an objective conclusion: either malpractice occurred (with
specifics) or it did not. Any mitigating factors (circumstances that influenced actions
but do not excuse breach of rules) are identified separately.
7. Reporting Findings: The Lead Investigator prepares a detailed report. It should be
clear, factual and well-structured, using plain language. The report will typically
include:
 Background and Context: What was being assessed, who was involved, and
why the investigation was initiated.

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 Scope and Methodology: The defined scope of the investigation and how it was
conducted (documents reviewed, people interviewed).
 Evidence Summary: A factual account of all relevant evidence (written and
verbal). This includes witness statements (appended) and key documents. Any
contradictions or gaps should be highlighted.
 Findings: The investigator’s analysis of facts – specifically, whether and where
procedures or rules were breached. If malpractice is identified, its nature and
implications are detailed. (For example, “Candidate X was found to have copied
segments of answers from an unauthorised source, as evidenced by ….”)
 Mitigating Factors: Any relevant context that affected the situation (without
excusing the malpractice). For example, misinterpretation of instructions may be
noted.
 Conclusion: A clear statement of whether malpractice is confirmed and who is
responsible (candidate or centre), based on the evidence.
 Actions Taken or Recommended: For candidate malpractice, the
recommended penalty (e.g. zero-mark, re-assessment) and any discipline
measures. For centre malpractice, corrective actions (e.g. retraining staff,
revising procedures) and any immediate safeguards. Also note any urgent
actions already implemented (e.g. exam retake, re-verification). The report
should conclude with assurance that all records have been retained and with any
necessary notifications sent (to QS, parents, etc.).
QS advises that investigation reports “include a statement of the facts and a detailed
account of the circumstances”, plus details of the centre’s own investigation and relevant
witness statements. For external exam malpractice, reports should also list seat
numbers, unauthorised materials found, and any candidate work reviewed. The report
and attachments should be submitted to the Senior Education Officer and to QS (if QS
requested the investigation).
8. Review and Decision: The Head Teacher in consultation with the Senior Education
Officer will review the report and determines the outcome.
For Candidates:
Following review, the outcome may be that there is no case to answer, or, where
malpractice is confirmed, the candidate may be subject to sanctions including
withdrawal from the course or qualification. The Head Teacher will inform the
candidate and their parent/carer of the decision and any sanctions applied, and will
advise them of their right to appeal.
For the Centre:
Where the investigation relates to potential centre malpractice, the outcome may

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range from no case to answer to formal disciplinary action, depending on the severity
of the breach.
If the investigation was initiated at the request of QS or a malpractice panel is
involved, the final report will be submitted to QS for their consideration and
determination.
7. Appeals against decisions
 Candidate Appeals: A candidate who is found responsible for malpractice may
appeal the decision. The candidate must first use the school’s internal appeals
process. Once this is exhausted, they have the right to appeal to QS. A candidate (or
their representative) can appeal if they disagree with the outcome of a centre-led
investigation or QS’s decision. The school will explain the appeals process (internal
and QS’s) to the candidate, as required by QS guidelines.
 Centre Appeals: If the Head Teacher disagrees with a finding of centre malpractice,
the Head teacher may submit an appeal to QS. This is done after the centre’s own
review process and in accordance with QS’s published appeals procedure. Individual
staff cannot appeal a centre malpractice finding (only the centre as a whole can).
All appeals must follow the official Appeals Process specified by QS. Details of grounds
and timelines are available in QS’s Appeals Process: Information for Centres. The
Council will support candidates or staff in understanding and exercising their appeal
rights when applicable.
7.1 Appeals for Candidate disagreement with Malpractice
investigation outcome
Where a candidate disagrees with the outcome of a malpractice investigation conducted
by the centre, the following procedure must be followed:
Step 1: Centre-Level Internal Appeal
 The candidate (or their representative) must submit a written appeal to the Head
Teacher within 15 working days of being informed of the outcome of the
malpractice investigation.
 The appeal should outline clearly the reasons why the candidate believes the
decision is incorrect, and may include any supporting evidence not previously
considered.
 The Head Teacher in consultation with the Senior Education Officer will review the
full investigation report, all evidence, and the grounds for appeal.

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 A decision will be issued in writing within 15 working days of receipt of the appeal,
unless exceptional circumstances require more time (in which case the candidate will
be informed).
 The candidate will be advised in writing of the outcome and whether the original
decision has been upheld, overturned, or amended.
If the candidate is not satisfied with the outcome of the internal appeal, they may
proceed to the next step.
Step 2: Appeal to QS
Once the centre’s internal appeals process is exhausted, the candidate has the right to
submit a formal appeal to the QS. This can be done if:
 The centre has conducted its own malpractice investigation, and the candidate
disagrees with the outcome and has exhausted the centre’s internal appeals
process;
 QS asked the centre to conduct an investigation, and the candidate disagrees with
the outcome;
 Or QS itself conducted the investigation and the candidate disputes the decision.
How to Appeal to QS:
 The appeal must be submitted in writing within 15 working days of the centre’s final
decision.
 The appeal must include:
o A clear statement of why the decision is considered incorrect;
o Reference to any relevant procedural irregularities or unreasonable
judgements;
o Supporting evidence where applicable.
 Appeals should be emailed to: investigation.enquiries@sqa.org.uk
 QS will respond within 15 working days of receiving all relevant information.
 If the appeal is not upheld, the candidate has the right to escalate the case to the QS
Appeals Sub-committee, as detailed in the published QS Appeals Process.
Centre Responsibilities:
 The Head Teacher must ensure that candidates are aware of their rights to appeal
both internally and to QS.

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 Centres must retain all investigation records securely until any potential appeal is
fully resolved.
 The Senior Education Officer should be informed of all escalated appeals.
8. Record Keeping and Confidentiality
Throughout the investigation, records must be kept secure and confidential. All
documentation (electronic and paper) is subject to data protection regulations. Sensitive
information should be accessible only to those directly involved. The following records
must be retained:
 The investigation report (with findings and conclusions);
 Signed witness statements and interview notes;
 Copies of all relevant assessment work; and
 Details of any actions or sanctions taken.
In general, these records should be kept for at least 3 years after the conclusion of the
case, or 6 years for any qualifications regulated by QS Accreditation. If the case
involves criminal or civil proceedings, records must be kept for 6 years after final
resolution. The local authority may be required to provide these records to QS on
request during quality assurance or appeals processes.
Confidentiality is paramount and details of the case should only be shared on a need-to-
know basis. Investigators and staff must observe professional confidentiality. If any
safeguarding concerns arise during the investigation (for example, if a child’s welfare is
at risk), these must be escalated immediately under the Child Protection Policy and the
school’s safeguarding procedures.
All investigations conducted under this policy should be fair, impartial and proportionate,
conducted confidentially, focused on the integrity of qualifications and learner’s rights,
align with the QS’s Standards for devolved investigations. All investigations should
include initial screening, appointing a lead investigator, evidence collection, interviews,
evaluation, reporting, and outcomes.
9. Safeguarding and support for participants
Investigations will be conducted with sensitivity, especially when children or vulnerable
individuals are involved. Candidates under investigation must be treated fairly and
provided support. They may bring a parent/carer or advisor to meetings, and any special
needs or reasonable adjustments should be accommodated. Investigators must ensure
the welfare of any minors or protected individuals is safeguarded throughout the
process. Equally, staff involved are entitled to support (for example, union
representation) and a fair hearing.

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10. Reporting template and structure
To ensure consistency, a standard report template will be used. An investigation report
should generally include the following sections (for example):
 Case Reference & Dates: Unique ID, dates of incident and of report.
 Incident Summary: Brief description of the alleged malpractice (who, what, when,
where).
 Investigation Team: Names and roles of the Lead Investigator and any assistants.
 Scope and Terms: What was investigated and under what authority (e.g. QS
guidelines).
 Evidence Collected: List of key evidence reviewed (documents, logs, exam scripts,
emails, etc.).
 Interviews Conducted: Names/roles of interviewees (anonymised if required) and
summaries of their statements.
 Findings: Factual account of what the evidence shows (including any contradictions
and how they were resolved).
 Conclusion: Determination of malpractice or no malpractice, specifying who is at
fault and on what basis.
 Mitigating Factors: Any relevant circumstances identified.
 Action Taken/Recommenda tions: Penalties or sanctions applied (or proposed) for
candidates or staff, and recommendations for corrective action (e.g. retraining, policy
changes).
 Signature and Date: Report signed by Lead Investigator (and countersigned by
Head Teacher or nominee).
All appendices (e.g. signed witness statements, documentary evidence) should be
clearly indexed. (For guidance, QS suggests reports include “a statement of the facts
and a detailed account of the circumstances” of the case, details of the investigation,
relevant witness statements, any mitigating factors, candidate seat numbers and
unauthorised materials found.) The report should be factual, unbiased and structured
under clear headings, so that any reader (including QS panel members) can follow the
reasoning.
11. Policy Review and Communication
This policy will be reviewed regularly or after any major change in QS guidance. It will be
communicated to all schools, and training on malpractice awareness will be provided for

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staff by centres. All schools must publish their own aligned malpractice procedures and
ensure candidates understand their responsibilities under the policy.
Compliance with this policy is mandatory. Any deviation from QS requirements or the
procedures above should be reported to the Senior Education Officer. Maintaining exam
integrity is a shared responsibility. By following this policy, West Dunbartonshire Council
and its schools will protect fair and valid assessment for all learners.

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Appendix 1: Centre-Level Malpractice Procedures Proforma
To be completed by the Head of Centre or their delegated representative (normally the
QS Coordinator)
1. Centre Details
Name of School / Centre:
Centre Number:
Head of Centre (Headteacher):
QS Coordinator:
Date of Completion / Review of this
Proforma:
2. Policy Implementation and Communication
Date malpractice policy was last shared
with all staff:
Method of communication to staff:
Date malpractice policy was last shared
with candidates:
Method of communication to candidates:
3. Centre-Level Malpractice Procedures
Please summarise below how your centre meets the requirement to establish or
maintain detailed malpractice procedures, including actions taken to ensure alignment
with QS guidance and this local authority policy:
• Procedures in place for identifying and responding to suspected malpractice:
• Steps taken to ensure investigations are fair, proportionate and evidence-based:
• Internal reporting/escalation processes:
• Record keeping and storage of evidence relating to malpractice investigations:

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• Process for ensuring candidate results are not submitted during an ongoing
investigation:
4. Appeals and Support
• How candidates are informed of their right to appeal a malpractice decision:
• Support mechanisms in place for candidates/staff involved in a malpractice
investigation:
5. Review and Quality Assurance
Date when malpractice procedures were
last reviewed:
Name and role of person responsible for
the review:
Any planned improvements to current
procedures:
6. Confirmation and Sign-Off
Signed (Head of Centre): Date:
Signed (QS Coordinator, if
applicable):
Date:

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Appendix 2: Malpractice Investigation Report Template
1. Case Reference & Dates
Case Reference Number:
Date of Alleged Incident:
Date of Report:
2. Incident Summary
Brief description of the alleged malpractice, including who was involved, what occurred,
when and where it happened.
3. Investigation Team
Lead Investigator:
Other Staff Involved in the Investigation:
4. Scope and Terms of Investigation
Outline what was investigated and under what authority (e.g., QS guidelines, centre
policy).
5. Evidence Collected
List all key evidence reviewed (e.g., documents, logs, exam scripts, emails).
6. Interviews Conducted
List interviewees (anonymised if required), their roles, and provide a brief summary of
their statements.
7. Findings
Provide a factual account of what the evidence shows, including any contradictions and
how they were resolved.
8. Conclusion
State whether malpractice has been determined. Specify who is at fault and the
evidence supporting this conclusion.

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9. Mitigating Factors
Note any relevant personal or contextual factors that should be considered in
determining outcomes.
10. Action Taken / Recommendations
List penalties or sanctions applied (or proposed), and any recommendations for future
corrective action (e.g., staff training, procedural changes).
11. Signature and Date
Signature of Lead Investigator: Date:
Countersignature (Head Teacher or
Nominee):
Date:
12. Appendices (if applicable)
Include any signed witness statements, documentary evidence, or other relevant
documents. Each appendix should be clearly indexed.

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Appendix 3 Process for Malpractice investigation
Allegation of Malpractice arise
Head Teacher screens concern
Are concerns
well founded?
Head Teacher informs SEO & QS
& appoints Lead Investigator
Case closed
Lead Investigator conducts
Investigation
Malpractice found? Investigation report closed QS
& SEO informed of decision
Actions determined
Investigation reported to SEO & QS
YES
H
NO
NO
YES

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