Chinese Walls Policy

This policy covers the steps taken by the Chartered Institute for Securities & Investment and its subsidiary companies to manage potential conflicts of interest arising from its examining and training operations. The aim of the Policy is to protect the integrity of the Institute’s examinations.

  1. The Institute has implemented a number of structural and procedural measures to establish proper division of duties between examinations and training activities.

     

  2. Barriers to the flow of confidential examination information have been established between all relevant department functions.  Information technology security has been enhanced to ensure data security and integrity.

     

  3. Procedures and working practices are communicated to new staff and Invigilators during induction. Procedures are communicated in the form of written guidance notes and line management/Executive Director supervision.

     

  4. Confidentiality agreements have been established for all staff, Invigilators and exam practitioner working groups.

     

  5. Exam question papers are transmitted to the printer/distributor by secure means. Exam question papers are delivered from the printers in sealed packages either direct to exam venues or to the Institute. The printer/distributor contracted to undertake this work has signed a confidentiality agreement.

     

  6. The exam delivery and course delivery functions are managed and directed under the control of separate Executive Directors.

     

  7. Secure areas have been designated for authorised Exams dept. staff under restricted card-key access.

     

  8. No information regarding exam paper content is communicated to unauthorised personnel. No examination paper is sent by external e-mail, with the exception of password-restricted e-mails, which are sent to the printer/distributor.  Any examination paper sent to a Senior or Chief Examiner is sent by secure means

     

  9. A physically separate secure storage area has been assigned for all confidential exam documentation.

     

  10. Information technology systems have restricted access controls to prevent unauthorised access to exam data. Passwords are changed frequently.

     

  11. Exam question papers that are returned from venues in sealed packages are received directly by the Exams dept. staff and are either immediately shredded in confidential waste bins or locked in the secure exams area, pending secure disposal.

     

  12. Exams dept. staff are not permitted to access all exam question banks. Exams department managers have access to only part of the question bank that they compile the exam for.  

     

  13. The procedures within this policy and their effectiveness are reviewed by the Executive Directors.