1. Purpose

The Institute for Advanced Learning and Metacognition (“IALM” or “the Institute”) is committed to carrying out its activities in a manner consistent with its charitable purposes, its obligations to provide public benefit and the responsibilities of its trustees.

As IALM develops relationships with schools, colleges, education settings, professionals, parents, carers, pupils and other organisations, it may occasionally identify circumstances in which an institutional or individual relationship presents legal, governance, safeguarding, operational, integrity, reputational or other material risks to the Institute.

The purpose of this policy is to establish a consistent framework through which the Board of Trustees may:

• undertake appropriate due diligence;
• identify and assess relevant risks;
• designate particular organisations as Restricted Organisations;
• determine the extent to which a restriction should apply to individuals connected with those organisations;
• prevent circumvention of restrictions;
• protect IALM’s services, resources, intellectual property and charitable activities;
• provide for individual exceptions where appropriate; and
• periodically review restrictions to ensure that they remain necessary and proportionate.

A restriction imposed under this policy is a governance and risk-management measure. It does not, by itself, constitute a finding or allegation of criminal, civil, regulatory, professional or other wrongdoing against any organisation or individual.

2. Scope

This policy applies to all IALM activities, including:

• membership;
• use of the IALM website;
• online accounts and restricted areas;
• workshops;
• webinars;
• conferences and events;
• training;
• educational programmes;
• consultancy;
• assessment services;
• publications;
• downloadable materials;
• digital resources;
• research or collaborative activities;
• professional relationships;
• institutional partnerships; and
• any other service, provision, resource or activity provided by or through IALM.

The policy applies to trustees, employees, consultants, contractors, volunteers and other persons acting on behalf of IALM.

3. Policy Principles

Decisions under this policy shall be taken in the interests of IALM and in accordance with the Institute’s governing document and applicable law.

When exercising their powers under this policy, trustees should, where relevant:

• act within the powers available to them;
• act in good faith and in the interests of IALM;
• ensure that they are sufficiently informed;
• consider relevant information and disregard irrelevant considerations;
• identify and appropriately manage conflicts of interest and conflicts of loyalty;
• consider the charitable purposes and public benefit obligations of IALM;
• consider whether a proposed restriction is necessary and proportionate;
• consider whether a less restrictive measure could adequately address the identified risk;
• consider equality, safeguarding and data-protection implications; and
• maintain an appropriate record of significant decisions.

4. Definitions

For the purposes of this policy, the following definitions apply.

4.1 Restricted Organisation

A Restricted Organisation means an organisation which has been formally designated as restricted by resolution of the Board of Trustees.

The designation may apply to an education setting itself and, where appropriate, its governing body, proprietor, academy trust, company or other legal entity responsible for its operation.

Restricted Organisations are recorded in IALM’s internal governance records.

4.2 Relevant Staff Member

A Relevant Staff Member means:

(a) any person currently employed or engaged by a Restricted Organisation, including an employee, worker, officer, consultant, contractor, agency worker or person serving in a professional, management or leadership capacity; or

(b) any person who was employed or engaged in any such capacity by the Restricted Organisation at any time during the five years immediately preceding the relevant decision, application, booking, registration, access request or proposed engagement with IALM.

The five-year period operates on a rolling basis.

4.3 Connected Parent or Carer

A Connected Parent or Carer means a parent, guardian or carer associated with a Restricted Organisation who has a Material Connection with a Relevant Staff Member.

A person shall not become a Connected Parent or Carer solely because their child currently attends or previously attended a Restricted Organisation.

4.4 Material Connection

A Material Connection means a relationship or association between a parent, guardian or carer and a Relevant Staff Member which is more than merely incidental, remote or insignificant.

A Material Connection may include, but is not limited to:

• marriage, civil partnership or an intimate or domestic partnership;
• a family relationship, whether by blood, marriage, civil partnership or equivalent relationship;
• residing together or having previously shared a household;
• a close personal relationship;
• a close social relationship;
• an employment relationship;
• a professional relationship;
• a business or commercial relationship;
• a financial relationship;
• a consultancy or contractual relationship;
• acting as an agent, representative or intermediary for the Relevant Staff Member;
• regularly assisting or acting on behalf of the Relevant Staff Member; or
• another relationship which the Board reasonably considers sufficiently substantial and relevant to justify application of the restriction.

A connection shall not ordinarily be treated as material merely because two people:

• know one another casually;
• have attended the same event;
• belong to the same large organisation or professional body;
• are connected through social media;
• have had isolated professional contact; or
• have another remote or incidental association.

4.5 Restricted Person

A Restricted Person means an individual to whom a restriction under this policy has been determined to apply.

This may include a Relevant Staff Member, Connected Parent or Carer, or another person acting for or on behalf of a Restricted Organisation.

4.6 IALM Content

IALM Content means materials owned by, licensed to, commissioned by or produced for IALM, including:

• presentations;
• slides;
• training materials;
• publications;
• reports;
• research materials;
• videos and recordings;
• webinar materials;
• worksheets;
• assessment materials;
• methodologies;
• educational programmes;
• course materials;
• member resources;
• downloadable resources;
• digital content;
• documents; and
• other copyright, confidential or proprietary material.

5. Authority to Designate a Restricted Organisation

The authority to designate an organisation as a Restricted Organisation rests with the Board of Trustees.

The Board may delegate the administration and implementation of a restriction, but the initial designation of a Restricted Organisation should normally be made through a recorded Board decision.

Before making a designation, the Board should consider such information as it reasonably considers relevant, which may include:

• information obtained through organisational due diligence;
• publicly available information;
• regulatory information;
• safeguarding considerations;
• evidence supplied to the Institute;
• previous dealings with the organisation;
• identified risks to IALM, its beneficiaries or charitable purposes;
• legal advice where appropriate; and
• any other relevant evidence.

The Board does not need to determine whether criminal, civil, employment, professional or regulatory liability has arisen in order to make a risk-management decision under this policy.

6. Due Diligence

IALM may undertake proportionate due diligence before entering into significant relationships with education settings or other organisations.

Due diligence may include consideration of:

• publicly available information;
• regulatory reports and findings;
• inspection information;
• published governance information;
• relevant media reporting;
• information concerning educational or assessment practices where relevant to IALM’s proposed involvement;
• information provided directly to IALM; and
• other information reasonably relevant to the proposed relationship.

Due diligence should ordinarily focus upon the organisation rather than compiling unnecessary information about individual members of staff.

Where concerns about identifiable individuals are relevant, IALM shall ensure that any personal information collected is necessary, proportionate and processed in accordance with applicable data-protection legislation.

7. Conflicts of Interest and Loyalty

A trustee who has or has previously had a personal, professional, employment, financial, contractual or other material relationship with an organisation being considered under this policy must declare that connection before the matter is considered.

The Board shall determine how the conflict or potential conflict should be managed in accordance with IALM’s governing document and conflicts of interest arrangements.

Where appropriate, this may include requiring the affected trustee to:

• withdraw from discussion of the matter;
• refrain from receiving particular confidential information;
• leave the meeting while the matter is considered;
• abstain from voting; and
• refrain from attempting to influence the decision outside the meeting.

The declaration and the way in which the conflict was managed shall be appropriately recorded.

8. Effect of Designation as a Restricted Organisation

Unless the Board determines otherwise, IALM shall not:

• establish an institutional partnership with a Restricted Organisation;
• provide consultancy to it;
• undertake training or workshops commissioned by it;
• provide institutional membership;
• provide services specifically for its benefit;
• enter into collaborative arrangements with it; or
• knowingly provide IALM Content or restricted resources for its institutional use.

A Restricted Organisation must not circumvent a restriction by attempting to procure IALM services or resources through another organisation or individual.

9. Relevant Staff Members

Unless an exception has been expressly authorised, persons who are currently employed or engaged by a Restricted Organisation may be prohibited from accessing IALM membership, services, activities, resources or restricted content.

The Board may determine that the same restriction applies to former Relevant Staff Members whose employment or engagement with the Restricted Organisation ended within the preceding five years.

This includes persons working for the Restricted Organisation on:

• an employed basis;
• a consultancy basis;
• a contractual basis;
• an agency basis; or
• another professional or service arrangement.

The existence of the five-year rule does not prevent the Board from considering individual circumstances or granting an exception where appropriate.

10. Five-Year Rule

Where the restriction applies to former staff, contractors or consultants, the five-year period shall normally commence on the date upon which the individual’s employment, consultancy, contract or other relevant engagement with the Restricted Organisation ended.

The period shall operate on a rolling basis.

Once more than five years have elapsed, the individual shall ordinarily cease to fall within the definition of Relevant Staff Member solely by reason of their former employment or engagement.

Nothing in this section prevents a restriction continuing where:

• the individual separately falls within another category covered by this policy;
• the individual is acting for or on behalf of the Restricted Organisation;
• there is evidence of attempted circumvention; or
• the Board has made a separate individual decision based upon other relevant circumstances.

11. Connected Parents and Carers

The Board may extend a restriction to a Connected Parent or Carer who has a Material Connection with a Relevant Staff Member.

The purpose of this provision is to prevent restrictions imposed upon a Restricted Organisation or Relevant Staff Member from being circumvented through persons closely connected with them.

A parent, guardian or carer shall not be restricted merely because their child attends or previously attended the Restricted Organisation.

Before treating a parent or carer as a Restricted Person, IALM should have reasonable grounds for concluding that a Material Connection exists.

The Board or an authorised decision-maker should consider:

• the nature of the relationship;
• its closeness;
• whether it is current or historic;
• whether there is evidence that the parent or carer is acting for or assisting the Relevant Staff Member;
• whether IALM services or materials may be obtained indirectly for a Restricted Person or Restricted Organisation;
• the proportionality of imposing the restriction; and
• whether an individual exception would be appropriate.

A merely incidental, remote or insignificant relationship should not ordinarily result in restriction.

12. Pupils and Students

A pupil or student shall not ordinarily be restricted merely because they attend, or previously attended, a Restricted Organisation.

IALM recognises that its charitable purposes may include providing educational or other benefits to children and young people independently of the education setting which they attend.

A restriction may nevertheless be applied in an individual case where there are reasonable grounds to believe that access is being sought:

• on behalf of a Restricted Organisation;
• on behalf of a Restricted Person;
• for the purpose of obtaining resources for a Restricted Organisation or Restricted Person;
• as part of an attempt to circumvent an existing restriction; or
• in circumstances where another legitimate and proportionate reason justifies the restriction.

Any decision involving a child or young person should have appropriate regard to IALM’s charitable purposes, safeguarding responsibilities and public benefit obligations.

13. Prohibited Circumvention

A Restricted Organisation or Restricted Person must not knowingly attempt to circumvent a restriction imposed under this policy.

Circumvention may include:

• asking another person to register for an event on their behalf;
• using another person’s account;
• registering through another organisation;
• asking a parent, carer, pupil, colleague or intermediary to obtain materials;
• using alternative email addresses to conceal an association;
• arranging for another person to purchase or download resources;
• using a third party to commission IALM services;
• obtaining recordings or materials indirectly; or
• otherwise attempting to achieve indirectly what the restriction prevents directly.

IALM may suspend or terminate access where it reasonably believes that a restriction is being circumvented.

14. IALM Content and Unauthorised Possession

IALM does not grant Restricted Organisations or Restricted Persons any permission to obtain or use IALM Content except where prior express written permission has been given.

Where a Restricted Person knowingly obtains, receives or otherwise comes into possession of IALM Content without authorisation, they should not knowingly:

• retain it unnecessarily;
• use it;
• reproduce it;
• copy it;
• distribute it;
• disclose it;
• transmit it;
• publish it;
• adapt it; or
• provide it to another Restricted Person or Restricted Organisation.

Where appropriate, IALM may request that unauthorised material be returned, permanently deleted or securely destroyed.

IALM may take reasonable steps to investigate unauthorised access, copying, use or distribution and may exercise any contractual, intellectual-property or other legal rights available to it.

Any provision concerning charges, recovery of losses, reasonable enforcement expenses, licence fees or other financial consequences shall be governed by the applicable IALM Terms and Conditions and applicable law.

Accidental or unsolicited receipt of IALM Content shall not, by itself, be treated as a breach of this policy where the recipient did not knowingly request or procure the material and takes reasonable action once becoming aware that they are not authorised to possess or use it.

15. Access to the IALM Website

Where technically and legally appropriate, IALM may take reasonable measures to restrict access to its website or digital services by a Restricted Organisation or Restricted Person.

Such measures may include:

• blocking accounts;
• declining registrations;
• cancelling membership access;
• blocking known institutional email domains;
• restricting access credentials; and
• using reasonable technical measures to prevent repeated unauthorised access.

IALM recognises that publicly accessible internet content cannot always be technically prevented from being viewed by a particular individual.

The existence of a restriction nevertheless establishes IALM’s position regarding authorised access and use.

16. Refusal, Suspension and Termination of Services

Where permitted by IALM’s governing document, applicable contractual terms and law, IALM may:

• refuse an application;
• decline a booking;
• refuse or terminate membership;
• suspend an account;
• cancel attendance;
• terminate access to resources;
• decline an institutional relationship;
• refuse consultancy or training; or
• take other reasonable action necessary to implement a restriction.

Where money has already been paid, any refund or other financial entitlement shall be determined in accordance with the relevant contractual terms and applicable law.

17. Individual Exceptions

The Board recognises that a blanket application of a restriction may not be appropriate in every circumstance.

An exception may therefore be granted where the Board or an authorised decision-maker considers that:

• the connection is sufficiently remote;
• circumstances have materially changed;
• there is no reasonable risk of circumvention;
• refusing access would be disproportionate;
• granting access would further IALM’s charitable purposes;
• public benefit considerations favour granting access;
• safeguarding considerations favour an exception; or
• there is another compelling reason to permit access.

An exception may be unconditional or subject to reasonable conditions.

An exception granted to one individual does not automatically alter the designation of the Restricted Organisation or create an entitlement for another person.

18. Evidence and Decision-Making

IALM should maintain sufficient records to demonstrate the basis upon which significant decisions under this policy were made.

Records should ordinarily focus upon:

• the nature of the risk identified;
• the information considered;
• the trustees’ assessment;
• relevant legal or governance considerations;
• conflicts of interest and how they were managed;
• proportionality;
• the decision reached; and
• any review date.

IALM should avoid recording unnecessary allegations or conclusions concerning identifiable individuals where recording those details is not necessary to support the governance decision.

19. Confidentiality

Information underlying the designation of a Restricted Organisation or Restricted Person shall normally be treated as confidential governance information.

Access should be limited to trustees and other persons who have a genuine need to know.

Employees, consultants or volunteers responsible for implementing the restriction should ordinarily be informed only of the information necessary to perform their role.

IALM shall not ordinarily publish confidential evidence underlying a designation.

Nothing in this policy prevents disclosure where:

• required by law;
• required by a regulator or competent authority;
• necessary for safeguarding;
• authorised by the Board following appropriate consideration; or
• otherwise lawfully required or permitted.

20. Data Protection

Personal information processed under this policy shall be handled in accordance with applicable data-protection legislation and IALM’s data-protection and privacy policies.

IALM shall take particular care where information concerns:

• allegations of criminal conduct;
• convictions;
• regulatory proceedings;
• safeguarding matters;
• special category personal data; or
• other particularly sensitive information.

IALM shall collect and retain only information reasonably necessary for its legitimate governance purposes.

Where information constitutes criminal offence data, IALM must establish the appropriate lawful basis and any additional legal condition required before processing it.

Where required by law, IALM shall maintain an Appropriate Policy Document and undertake a Data Protection Impact Assessment.

Access to sensitive information shall be appropriately restricted and secured.

21. Communications About Restrictions

IALM is not required to provide a Restricted Organisation or Restricted Person with confidential evidence underlying a restriction where disclosure would be unlawful, inappropriate or contrary to legitimate confidentiality, safeguarding or legal considerations.

Where an individual is informed that a restriction applies, communications should ordinarily be neutral and should not contain unnecessary allegations concerning the organisation or other individuals.

A suitable explanation may state that:

“IALM is currently unable to provide access to the requested service or resource pursuant to its Restricted Engagement and Access Policy.”

Where appropriate, the individual may be informed that they may request a review.

22. Requests for Review

A Restricted Organisation or Restricted Person may request that the Board reconsider a designation or individual restriction.

The Board may take into account:

• the passage of time;
• changes in circumstances;
• new information;
• changes in personnel;
• the nature of the proposed engagement;
• the likelihood of circumvention;
• safeguarding and public benefit considerations;
• legal or regulatory developments; and
• any other information reasonably considered relevant.

A review does not require IALM to disclose confidential, legally privileged, safeguarding or protected personal information.

23. Periodic Review

Restricted Organisation designations should be reviewed periodically and whenever there has been a material change in circumstances.

The Board may:

• maintain the designation;
• amend its scope;
• impose additional safeguards;
• narrow the restriction;
• grant specified exceptions; or
• remove the designation.

A review should be appropriately recorded.

24. Responsibilities

Board of Trustees

The Board is responsible for:

• approving this policy;
• designating Restricted Organisations;
• determining significant restrictions;
• managing trustee conflicts;
• reviewing significant decisions;
• ensuring that restrictions remain compatible with IALM’s charitable purposes; and
• reviewing this policy.

Director and Authorised Officers

The Director or other authorised officer may be responsible for:

• undertaking or coordinating due diligence;
• implementing Board decisions;
• administering access restrictions;
• referring uncertain cases to the Board;
• maintaining appropriate records; and
• ensuring that confidential information is appropriately protected.

Operational staff should not independently make findings of misconduct or wrongdoing against organisations or individuals.

25. Relationship with Other IALM Documents

This policy should be read alongside:

• IALM’s governing document;
• Website Terms and Conditions;
• Membership Rules;
• workshop, webinar and event Terms and Conditions;
• Data Protection Policy;
• Privacy Policy;
• Safeguarding Policy;
• Conflicts of Interest Policy;
• Intellectual Property provisions; and
• any other relevant governance policies.

Where IALM’s public Terms and Conditions impose contractual restrictions or financial consequences, those provisions shall operate in addition to this internal governance policy.

The Board of Trustees adopted this policy on 24th August 2026.