Explains implementation records in relation to continuity planning, covering scope, evidence, decision authority, material exceptions and continuing assurance.
In 2020, consideration of continuity planning must take account of the pandemic-related operational disruption and the responsibilities it places before education systems. A standard is effective only when its terms lead to consistent decisions without displacing professional judgement or applicable law.
For continuity planning, the applicable expectation should be capable of consistent application. Reporting on the control should distinguish established fact, analytical judgement and planned action. Material revisions should retain their reason and effective date. Criteria affecting learners should not permit materially different interpretation without an evidenced reason.
Meaning in practice
The conditions described by the pandemic-related operational disruption create an exceptional operating context for continuity planning. Evidence may be incomplete and normal controls may be unavailable, but uncertainty should be stated rather than converted into unsupported assurance. Authorities and providers should record the basis, duration and affected scope of temporary decisions and should reassess them when access, public-health, security or delivery conditions change.
Records concerning the assurance 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 For continuity planning, superseded conclusions should be retained where they informed a material outcome. Assurance should follow the learner journey and test more than a single access point or aggregate result.
- 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.
Responsibilities and material risks
The analysis of continuity planning should make its decision rule explicit. 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. Records should remain protected against unauthorised alteration while legitimate amendments remain visible. The method should prevent an unfavourable result from being dismissed through an unrecorded change in interpretation.
A narrow control over the assurance 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. Within the scope under review, 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?
Basis for a reliable conclusion
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 assurance 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.
In work concerning continuity planning, progress should not be assessed by the amount of policy or documentation produced.