This interpretation addresses implementation of continuity planning: applicability, materiality, decision records and corrective-action verification.
Reporting on the control should distinguish established fact, analytical judgement and planned action.
Application to implementation of continuity planning
The conditions described by the pandemic-related operational disruption create an exceptional operating context for continuity planning.
Records concerning the conclusion should remain traceable from source evidence to decision and follow-up. For continuity planning, superseded conclusions should be retained where they informed a material outcome.
- Review the validity of assessment.
- Define the conditions for restoration or further adaptation.
- Monitor participation and welfare.
- Maintain secure communication and records.
- Identify essential education and protection functions.
Controls for implementation of continuity planning
The criteria applied to continuity planning should be settled and recorded before the evidence is assessed. For the control, a reliable record should identify what occurred, when it occurred, who was responsible, the authority for the action and any later correction.
A narrow control over the conclusion may create false assurance. In the present context, loss or corruption of learner records, uncontrolled changes to assessment and loss of contact with learners may produce acceptable aggregate reporting while individual learners remain exposed to material disadvantage. Across the defined scope, the test should deliberately include exceptions and cases in which the expected outcome was not achieved.
Relevant evidence for the applicable expectation will normally include a current continuity plan with decision thresholds, welfare referral and safeguarding records, data backup and recovery tests, alternative delivery and accessibility arrangements, and review of temporary measures and return criteria. For continuity planning, contradictory evidence should be investigated and resolved, not omitted from the record.
- Are partner records subject to equivalent controls?
- Are access rights proportionate?
- Can an amendment be distinguished from the original?
- Is the record attributable?
- Can records be retrieved throughout the required period?
Review of implementation of continuity planning
Authorities and providers reviewing continuity planning should proceed in a defined sequence. The method for the applicable expectation is to specify mandatory fields, source ownership, access rights, retention and correction procedures. Test a sample from creation through use, amendment, reporting and disposal, including records created during disruption or by a delivery partner.
Assurance concerning continuity planning should be expressed at the level established by the evidence.
The principal risks associated with the matter should be assessed as connected conditions. In the context of continuity planning, continuity should not be measured only by whether teaching activity continues. For the matter, interpretive guidance should not create an obligation that is absent from the governing instrument or applicable law.
When examining continuity planning, decisions concerning the applicable requirement should remain traceable to the information available for the stated reference period.
Accountability for the conclusion should follow decision-making authority. For decisions concerning continuity planning, where work is delegated, the record should continue to identify who is accountable for material consequences to learners.