GHCA-IMP-01
Impartiality Policy
GHCA authorizes the providers who deliver training toward its qualifications, and independently certifies the candidates those same providers train. That is the single most common source of bias in a certification body. This is what GHCA does about it.
The conflict, stated plainly
A training provider's commercial success depends on its candidates passing. GHCA's revenue depends in part on provider fees and candidate volume. Put those two facts together and the risk is obvious: a certification body has a financial reason to be generous with the standard it certifies against.
This is normal for a certification body and it is not a reason for suspicion in itself — but it only stays harmless if the body names the conflict and constrains itself against it. That is what this policy does.
The risks GHCA tracks
A staff member, examiner or item writer also holding a financial or employment interest in a training provider. An examiner marking, or a proctor supervising, a candidate they personally trained in the last 12 months.
Commercial pressure — explicit or implicit — to pass fee-paying candidates, particularly from high-volume or strategically important providers or corporate partners.
A Board or Certification Committee member with a personal, family or financial relationship to a candidate, provider or vendor under consideration. Sponsorship or investment arrangements that could create an expectation of favourable treatment.
Concentration risk — relying on too few providers or partners for revenue, which could make GHCA reluctant to sanction one of them.
The structural safeguards
Certification decisions — pass and fail determinations, malpractice findings, and appeal outcomes — are made exclusively by the Certification Committee and its delegated assessment staff, none of whom hold a revenue or sales target tied to registration or pass volume.
No individual may hold both a commercial or sales role and a certification-decision role for the same qualification.
The Ethics and Compliance Committee, a majority of whose members are independent of GHCA's commercial operations, has standing authority to review any certification decision, policy or commercial arrangement for impartiality risk, and reports directly to the Board.
Item banks, marking keys and moderation records are access-controlled separately from the marketing, sales and provider account-management systems.
Declarations, recusal and cooling-off
Every Board member, Certification Committee member, examiner, item writer and proctor completes an annual declaration of interests — employment, directorships, and financial interests in any training provider, corporate partner or competing certification body.
Anyone with a declared or discovered interest in a specific candidate, provider or decision must recuse themselves from it, and the recusal is recorded in the case file.
An examiner or proctor may not mark or supervise a candidate they personally trained, tutored or directly supervised within the preceding 12 months.
Assessment decisions are not for sale
Pass marks, grading and malpractice sanctions are never adjusted, directly or indirectly, in response to provider revenue, candidate volume or partnership status.
Any instruction or pressure to do so — from any source, including GHCA's own Board — is itself an impartiality breach, and is reportable to the Ethics and Compliance Committee.
A failure to disclose a conflict, or a proven instance of commercial interest influencing a certification decision, is handled as malpractice for assessment-facing personnel, with mandatory notification to that committee.