Candidate records and retention

This policy sets out the records CBA holds about you as a candidate, how long each is kept, and the reason each period follows from what the record is for. It is separate from the privacy policy, which describes how CBA handles the personal data of a website visitor or an enquirer. Where a record concerns your registration, your assessment or your credential, this policy governs it.

Status of this policy

This policy applies to every candidate record from the day it is created. Where a category or a period changes, the change is stated and dated on this page.

Registration and identity

The registration record is your name, your email address, your country, your sign-in credentials, and, where you gave marketing consent, the record of that consent and the page on which you gave it.

If you register and never enrol, the registration record is deleted two years after your last activity on the account. If you enrol, it is kept for as long as the longest-lived record it identifies. An examination record that cannot be attached to a person evidences nothing, so identity is kept alongside the assessment rather than deleted ahead of it.

CBA does not currently ask candidates for identity documents. If a programme comes to require documentary identity evidence, or supervision that produces a recording, the retention period for that material will be published here before the requirement applies, and before anybody pays for a programme that carries it. The intention is to keep the fact that a check was carried out and the date of it, rather than the document itself; that decision has not been finally taken, and this policy will state it plainly when it is.

Reasonable adjustment records

Where an adjustment to examination conditions is agreed with you, CBA keeps the adjustment agreed, the date, and the programmes it applies to. That record is kept for as long as your account is open, so that an adjustment agreed once does not have to be arranged from the beginning at the next sitting.

Whether evidence is needed depends on the adjustment, and the reasonable adjustments policy governs that question rather than this page. Where you do provide evidence, it is special category data under UK GDPR: CBA asks for your explicit consent to hold it, keeps it for twelve months after the last sitting at which the adjustment was applied, and then deletes it. What remains on file after that is the adjustment itself and the date it was agreed, so you do not have to make the case a second time.

Enrolment and payment

The enrolment record is the programme, the date, the order reference, the issue and redemption of any examination voucher, the amount paid and the invoice.

It is kept for six years from the end of the accounting period in which the transaction falls. That period follows UK company and VAT record-keeping requirements rather than a choice of CBA’s, and it cannot be shortened on request.

CBA does not hold card numbers. Card details are handled by the payment processor, and the payment record CBA keeps is the transaction reference, the amount, the date and what was bought. An enrolment that lapses without a sitting is kept on the same basis where money changed hands, and is deleted with your registration record where it did not.

Examination records

The examination record is the sitting itself: the date, the programme, the paper served to you, meaning which items were drawn and from which domains, the response you gave to each, the time taken, your score, the pass mark in force at your sitting, the breakdown by domain and the result. Attempts that did not pass are kept on the same terms as attempts that did.

Examination records are kept for ten years from the date of the sitting. The reasoning is cumulative:

• A credential is valid for three years and then requires recertification, so the record has to outlive more than one cycle of the thing it produced.
• An appeal may be brought within 30 days of a result, and the paper served is the only evidence an appeal can be decided on.
• Where an appeal or an audit shows an item to be defective, every paper that item appeared in is re-marked, including papers that passed. That is only possible while the papers still exist.
• A register entry can be checked long after the credential has expired, and CBA has to be able to show what the award rested on when it is asked.

How an item performs is also recorded as counts across everyone who saw it: how often each option was chosen, and how the item behaved against the rest of its domain. Those counts are what the answer-cueing audit and the standard-setting panel work from, and they are kept for as long as the item remains in the bank. They carry no candidate identity.

Assessed workbook submissions

At Practitioner tier the credential also rests on applied workbooks completed in a spreadsheet and marked to a stated tolerance. The workbook is generated on request rather than stored, so the record is the figures you submitted, the outcome of each check against its tolerance, the date and the attempt.

Workbook submissions are kept for ten years from submission, on the same basis as the examination record for the same programme. A Practitioner credential rests on the paper and the workbook together, and a record of one without the other does not show what was awarded.

Experience declarations and referee correspondence

At Professional tier the credential also rests on professional experience confirmed by a named referee. The record is your declaration, meaning your role, your organisation, the years claimed and your description of the work; the referee’s name, role, organisation, email address and stated relationship to you; the confirmation the referee gave and the date of it; your ethics undertaking and its date; and the review, recorded against the role that carried it out.

Where the declaration results in a Professional credential, the record is kept for as long as that credential remains on the register. A Professional credential asserts verified experience, the register entry carries that assertion for as long as it is published, and CBA has to be able to show what the assertion rests on for the same period.

Where no credential results, because the declaration is withdrawn, the verification is refused or the examination is not passed, the record is kept for two years from that decision, so that a refusal can be reviewed or appealed, and is then deleted.

A referee is told, at the point of being asked to confirm, what CBA will keep and for how long. A referee may ask for a copy of their own confirmation and may ask for it to be corrected.

Conduct and appeals records

This category covers complaints, appeals against a result or a decision, and investigations into malpractice. The record is what you submitted, the evidence considered, any representations you made, the decision, the reasons for it and the role that made it.

Conduct and appeals records are kept for six years from the conclusion of the matter, whatever the outcome. A report that was investigated and not upheld is kept for the same six years as one that was: the person cleared by it has the strongest interest in CBA being able to show that it investigated and cleared them, and a body that deletes the file the moment it decides in your favour cannot prove it ever did. A decision that can be challenged has to be evidenced by the body that made it, and a pattern of conduct across separate sittings is only visible if the earlier sitting is still on file. Six years matches the ordinary limitation period in England and Wales.

Where the outcome is the withdrawal of a credential, the record is kept for as long as the register entry that shows the withdrawal, because that entry states a fact CBA has to be able to stand behind.

The public register entry

Every award has a unique credential ID that resolves to a public register entry. The entry shows the credential ID, the holder’s name, the programme, the credential tier, the version of the scheme the holder was assessed against, the issue and expiry dates and the current status, including whether the credential has been withdrawn and when. It shows no email address, no contact detail, no score and nothing from the examination record. The register cannot be browsed or searched: an entry resolves only for somebody who already holds the ID.

The register entry is permanent by design. A credential nobody can verify after the body has forgotten it is not verifiable at all, and the point of a credential ID is that it still answers years after issue. An entry is not deleted when a credential expires, when it is withdrawn, or when an account is closed. Its status changes and the entry remains.

What you may ask for, and how

You may ask CBA to:

• give you a copy of the records it holds about you;
• give you a copy of your own examination record, on the terms set out below;
• correct anything inaccurate in your registration, enrolment or declaration;
• close your account and delete what can be deleted;
• restrict or object to a particular use of your data;
• withdraw marketing consent, at any time and without affecting anything else.

Ask through the contact page, using the email address on your account. Where a request arrives from a different address, CBA will ask you to confirm it from the account address before releasing anything: releasing a candidate’s record to the wrong person cannot be undone.

CBA acknowledges a request within five working days and responds within one month of receiving it, which is the period UK data protection law allows. Where a request is complex enough to need longer, CBA will tell you inside that month and give you the date it will respond by. There is no charge.

A copy of your own examination record

A copy of your examination record contains the date and the programme, your score, the pass mark in force at your sitting, the result, the breakdown by domain, how many items you were served in each domain, whether each of your responses was correct, and the time taken.

It does not contain the text of any item, the options offered, the correct answer, or the reference by which an item is identified in the bank.

What CBA will not disclose

• Live examination items. Item text, the options, the answer key and the identity of the items served are withheld from every candidate, including from a candidate asking about their own paper. Papers are assembled automatically from a shared bank to published domain weightings, so an item disclosed to one candidate is an item compromised for everyone who sits afterwards, and for everyone already holding the credential it helped award. The item text is CBA’s own assessment material rather than personal data about you, and a request for your own records does not reach it.
• Another candidate’s records, in any form, including in the course of an appeal that concerns more than one person.
• The names of individuals. Reviewers, markers, panel members and staff are identified by role and not by name. A decision is attributed to the role that took it, such as the Head of Assessment.
• Material that would disclose a third party’s personal data without their agreement, which includes referee correspondence in full. You may ask what your referee was asked to confirm and whether the verification was accepted. Where something is withheld on this ground, CBA will tell you that it has been withheld and why.

When a credential is withdrawn

Where a credential is withdrawn, the register entry stays and shows the withdrawal and its date. Deleting the entry would erase the very fact somebody might need to check: an employer who verified the credential last year has to be able to discover that it no longer stands.

The examination record, the workbook submissions, the experience verification and the conduct record supporting the decision are kept as set out above. You may still ask for a copy of your own examination record after a withdrawal, and you may appeal the decision on the same terms as any other.

Expiry is not withdrawal. A credential that reaches the end of its three-year term without recertification shows as expired, which is a statement that the term ended and not a statement about your conduct.

A request under data protection law cannot remove a register entry or reverse a recorded withdrawal. Where CBA refuses a deletion request on that ground it will say so in writing and give the reason.

Deleting an account

You may close your account at any time. Closing it deletes your sign-in credentials, your marketing preferences and the registration record, subject to the periods above.

It does not delete the payment records that UK law requires CBA to keep, the examination records within their stated period, the conduct records within theirs, or the register entry, which is permanent. Data protection law does not require erasure where records are kept to comply with a legal obligation or for the establishment, exercise or defence of legal claims. Where a request cannot be met in full, CBA will tell you what has been deleted and what has been kept.

Where records are held

Candidate records sit in CBA’s database and application hosting. The locations and the processors involved are set out in the privacy policy, which is updated whenever a processor changes.

If you are not satisfied

If you are unhappy with how a request under this policy was handled, raise it through the complaints and appeals policy. Complaints about the handling of personal data may also be made to the Information Commissioner’s Office at ico.org.uk.

Changes to this policy

Where a retention period changes, the change is dated on this page and applies to records held at that date. The permanence of the register is not something a change to this policy will be used to undo: entries already published stay published.