LSHTM Teaching Policies PLAGIARISM & ASSESSMENT IRREGULARITIES POLICY

LSHTM Teaching Policies PLAGIARISM & ASSESSMENT IRREGULARITIES POLICY

LSHTM Teaching Policies PLAGIARISM & ASSESSMENT IRREGULARITIES POLICY

1 of 62 LSHTM Teaching Policies PLAGIARISM & ASSESSMENT IRREGULARITIES POLICY  This document is available electronically, along with copies of relevant forms, at www.lshtm.ac.uk/edu/taughtcourses/exams_assmt_staff/assessmentirregularityr esources INTRODUCTION Scope of this policy  This document sets out School policy, procedures and guidance for detecting and dealing with plagiarism, cheating and other forms of irregularity in assessed student work.  This is intended to be applicable across all LSHTM provision, including taught courses in face- to-face (F2F) and distance learning (DL) modes, as well as for research degrees (RD). Audience for this policy  This document is aimed primarily at staff, and all staff should be aware of the „plagiarism detection guidance‟ given in Annex 1. Comprehensive further guidance and documentation is included in further Annexes, as listed below.

 Formal definitions, procedures and penalties for dealing with assessment irregularities are set out in Procedures at Annex 4 (for taught courses) and Annex 5 (for research degrees). Staff such as Faculty Taught Course Directors and Research Degrees Directors should be closely familiar with these. Any students against whom a case is raised should also be referred to Annex 4 or Annex 5 as appropriate. Contents Annex 1: Detecting student plagiarism – guidance for staff . 2 Annex 2: Plagiarism declaration form for students . 13 Annex 3: Procedures for the use of Turnitin at LSHTM . 15 Annex 4: Formal Assessment Irregularities procedure for taught courses 19 Annex 5: Formal Assessment Irregularities procedure for research degrees 40 Annex 6: Standard notification to students about suspected assessment irregularities 60 Annex 7: Assessment Irregularity record form . 61 Related documentation  Students are provided with guidance in this area via course handbooks, which give definitions of plagiarism and other assessment irregularities and provide outline guidance on good referencing practice. Before first submitting any coursework for assessment, all students are required to sign and submit a form, as at Annex 2, to declare they have read, understood and will follow the School‟s definitions and guidance.

 The School‟s Academic Writing handbook provides a further key resource for students.  Staff should also be aware of other relevant LSHTM Codes of Practice, policies and procedures – particularly as included in the Assessment handbook and the Re-sits policy. © London School of Hygiene & Tropical Medicine, 2013 Approved by the Associate Dean of Studies – minor revisions to ensure currency made Feb 2013.

2 of 62 Annex 1: Detecting student plagiarism – guidance for staff Executive Summary This guidance is aimed at all staff involved in marking student work. It describes how to look out for plagiarism or related assessment irregularities, and what to do if you identify something suspicious. The key principle is that staff should not take unilateral action (e.g. marking down) if you encounter or suspect such issues. Rather, you should refer them on for investigation. Identifying plagiarism  Careful scrutiny by markers is the School‟s primary method of detecting plagiarism or any other irregularities in assessed student work. Markers are expected to use their own professional expertise and experience to evaluate whether a piece of work appears bona fide or not.

 Section 4 of this guidance gives a bullet-point list of items to look out for which may raise suspicion or warrant further investigation.  The School also makes use of the Turnitin plagiarism detection tool. MSc projects and Research Degree upgrading/review documents are all checked in Turnitin as standard. Certain MSc modules are also piloting use of Turnitin for their assessments. However, Turnitin should not be relied on as the only check for plagiarism. Following up suspicions  Markers should always report any suspicions about student work (e.g. if you suspect plagiarism, collusion, exam misconduct or other assessment irregularities) to the Module Organiser, Course Director or Research Degrees Coordinator with responsibility for the assessment.

 It can be helpful to investigate slightly further yourself before reporting a suspicion, e.g. checking suspicious phrases in a search engine or a likely source textbook. However, even if this turns up no further evidence, if your suspicion remains then you should report it.  The relevant Taught Course Director or Research Degrees Director will then investigate whether there is a case to answer. Students will be presumed innocent until such time as proceedings establish otherwise.  You should provisionally grade the work under suspicion, acting on the assumption that it is genuine. However, marks will be withheld from the involved students until investigations have concluded.

If you have any queries on any of these matters, then please speak in the first instance to your Taught Course Director or Research Degrees Director. Contents of this Annex Executive Summary . 1 Identifying plagiarism . 2 Following up suspicions . 2 1. Scope of this guidance . 3 2. Context – „prevention is better than cure . 3 3. The School‟s definition of plagiarism, and related procedures . 4 4. Looking out for plagiarism in student work . 5 5. Use of the Turnitin tool . 6 6. Current procedures for different types of work . 7 6.1 For taught modules (both face-to-face and distance learning . 7 6.2 For MSc projects (both face-to-face and distance learning . 8 6.3 For formal exams (both face-to-face and distance learning . 8 6.4 For short courses . 8

3 of 62 6.5 For research degrees . 8 7. Following up suspected plagiarism . 9 7.1 Notification of suspicions . 9 7.2 Communication with students . 9 7.3 Formal procedures for face-to-face programmes . 9 7.4 Formal procedures for distance learning programmes . 10 7.5 Legal implications . 10 8. Distinguishing plagiarism from poor academic practice . 10 9. Feeding back to students about their work . 11 10. Further guidance on this topic . 11 1. Scope of this guidance This guidance is aimed at all staff involved in reviewing student work, particularly markers, Course Directors, Module Organisers, tutors and supervisors – across both face-to-face and distance learning modes, and all forms of provision (including modules, MScs, Diplomas, short courses and research degrees).

It sets out the School‟s policy on:  how you are expected to look out for plagiarism (or related assessment irregularities) in student work;  how you should follow up when you suspect plagiarism in a piece of student work;  the more formal first steps to be taken when you believe you have identified plagiarism; and  distinguishing plagiarism from poor academic practice. The guidance should apply for all types of work done by students or prospective students and reviewed by staff – particularly assessed work, but potentially anything else, e.g. formative essays that do not count towards a degree, research proposals from Research Degree application forms. While focused on written work, it may be applied for work of all kinds, e.g. multimedia submissions, posters, computer code.

2. Context – „prevention is better than cure‟ Before getting into the detail of how to spot and follow up on plagiarism in student work, it should be emphasised that the School‟s policy is to encourage preventative measures against plagiarism, rather than to take a punitively-focused approach. Two key approaches are encouraged: (i) Guidance for students should make very clear what is expected of them in their assessed work.  The School provides extensive standard information in documents such as Course Handbooks or the Academic Writing handbook – including descriptions of what plagiarism is, how to avoid it, how to cite and reference correctly, etc.

 At course level, this should be supplemented by clear guidance on the conventions that apply for the relevant subject, field or discipline. The key points should be included in Course Handbooks, although more detailed information may be given through other means such as face-to-face sessions.  At module level, relevant information should be integrated into teaching wherever possible – e.g. when introducing the assessment, to give examples of what is expected or what is not acceptable for the specific task at hand. Such guidance may be given either in writing or through other means. Where specific conventions apply for the particular subject, field or discipline the module is part of, this should be made clear.

(ii) Good assessment design should minimise opportunities for plagiarism, and encourage appropriate use of sources and citations. Any staff who are developing assessments for new modules or overhauling old ones may benefit from investigating the following:  Some excellent ideas and good practice for assessment design are given in Carroll (2002), chapters 2 and 3 (full reference given in Section 10).

4 of 62  A number of useful online resources and academic papers about „designing out plagiarism‟ and encouraging originality in student work are hosted by the JISC Internet Plagiarism Advisory Service, at: http://archive.plagiarismadvice.org/designing-out-plagiarism (resources/papers) http://archive.plagiarismadvice.org/briefing-papers (good practice guide) Finally, feedback to students about issues like referencing and use of sources in their assessed work can also play an important role in improving their future standard of work. More guidance on this is also given later in this document.

3. The School‟s definition of plagiarism, and related procedures All staff involved in assessing student work should be aware of the School‟s definitions of plagiarism and assessment irregularities, and the related procedures and documents which apply. On registering, all students must sign a statement to say they will comply with the School‟s regulations, including the Assessment Irregularities procedure – as shown at Annex 1, or available via the LSHTM web site at www.lshtm.ac.uk/edu/taughtcourses/plagiarismdecform.doc The School‟s definitions of assessment irregularities are given in this procedure. The key ones to be aware of are on plagiarism and cheating, as follow. Related definitions of collusion, personation and fraud are also given.

Plagiarism is the copying or use of the work of others, whether intentionally or unintentionally, as if it were your own. Such work may come from any source whether published or unpublished, in print or online – including words, images, audio recordings, diagrams, formulae, computer code, performances, ideas, judgements, discoveries and results. To avoid plagiarism:  Where any use or mention is made of the work of others, it should be acknowledged.  A recognised citation system should be used.  Quotations must accurately refer to and acknowledge the originator(s) of the work.  Direct quotations, whether extended or short, must always be clearly identified.  Paraphrasing – using other words to express the ideas or judgements of others – must be clearly acknowledged.

 Work done in collaboration with others must appropriately refer to their involvement and input.  Use of your own past work should be referenced as clearly as the work of others. Cheating is a deliberate attempt to deceive in order to gain advantage in an assessed piece of work, including coursework, in-module assessments and examinations. This covers a range of offences, from significant instances of plagiarism to exam misconduct. Students are given guidance on all these topics as part of course handbooks – with slightly different tailored guidance being given in face-to-face MSc handbooks, Distance Learning course handbooks, and the research degrees handbook. The most comprehensive guidance, including how to avoid committing an offence, is drawn together in a generic Academic Writing handbook which serves as a resource for all students – including those on individual modules or short courses who may not otherwise be given detailed guidance.

Note that students are also required to submit a „plagiarism declaration form‟ prior to submitting their first piece of assessed work (the form only needs to be filled in once). Students must declare on this form that they have read and understood the School‟s definitions of plagiarism and cheating, and that all material they submit for assessment during their LSHTM studies will be their own work, and appropriately acknowledge any use of the work of others. The form should be lodged with

5 of 62 either the Teaching Support Office, the DL Office or the relevant Research Degrees Administrator; it is the responsibility of these offices to check that all students have submitted a form. 4. Looking out for plagiarism in student work When marking work, you have a responsibility to consider whether it fits the marking criteria you have been given, the assessment guidance the students were given, and the School‟s expectations on academic standards. This does not mean you are expected to go through everything with a „fine tooth-comb‟; but that you should mark as normal while being alert to any discrepancies that suggest an irregularity. If you encounter anything that raises your suspicions, do not hesitate to follow up – either investigating further or referring the issue on, as described later. The School‟s position is that to protect academic standards, any suspected plagiarism should be investigated and resolved.

The School uses the Turnitin „originality checking and plagiarism prevention‟ service as one means of checking for and evidencing plagiarism in student work. This is described in more detail later. However, it is important to note that Turnitin should not be the only method of checking for plagiarism – markers are expected to use their own professional expertise and experience to evaluate whether a piece of work appears bona fide or may be suspect. Factors which might typically arouse suspicion or warrant further investigation include:  Any extended pieces of writing which clearly draw on established ideas or literature but do not contain quotations or citations.

 Work that closely resembles that submitted by other students.  Sections or passages with a markedly different writing style to the rest of the text – e.g. in an extreme case, introductions and conclusions written in grammatically incorrect English and not addressing the body of the paper that is written in flawless, complex English.  Unusual use of terminology – e.g. highly specific professional jargon from a student just starting out in the discipline.  Work that addresses the topic only obliquely, or addresses just one aspect.  Discrepancies in the flow of argument, or between standard of language and the meaning conveyed – e.g. a complex sentence that is well-written in itself, but does not fit with the sentences around it.

 Strange or abrupt changes in grammar – e.g. tense, use of active/passive, use of first/third person.  Strange or abrupt changes in font and/or layout.  Variant use of sentence structure – e.g. if sentences are unusually long; or if most sections of a paper have short (average 15 word) sentences, but some have much longer (average 30+ word) sentences.  Signs of datedness – e.g. lack of recent or topical references, use of very old or out-of-date papers/sources where more recent material is easily available, bibliographies where all sources are several years old.

 Use of a mixture of referencing styles, both in the paper itself or in the bibliography.  Bibliographies that do not reflect the topic of the assignment, or only cite material not available locally.  URLs or other identifications of external sources left in headers or footers.  Inconsistent use of American versus British spelling.  Work that is out of character for this particular student, especially if it exceeds their previously observed level of performance or language. [The above list has been drawn from, and for some points quotes verbatim, Carroll (2002:63-64) – full reference given in Section 10] Of course, none of these are definitive signs of plagiarism, and it is important not to jump to conclusions. Students whose first language is not English may be capable of producing work that is original and of a good intellectual standard, despite making some of the kind of errors of presentation described above. Things like sentence length and complexity can vary in many people‟s writing; and inconsistencies of style may be relatively commonplace. However, these kind

6 of 62 of points are generally good indicators that the work should be investigated further. Once suspicion has been raised, it is usually relatively easy to determine whether or not plagiarism has taken place. 5. Use of the Turnitin tool Background: LSHTM subscribes to the Turnitin UK online plagiarism detection service, recommended by HEFCE and JISC. The software is provided by a US company, iParadigms, but delivered online via the Turnitin UK website (www.submit.ac.uk) run by the Northumbria Learning group, an offshoot of Northumbria University, who also run the JISC Plagiarism Advisory Service. It has been used successfully at LSHTM since 2004-05.

How it works: Turnitin compares students' work against a very extensive pool of journals, periodicals, books, databases, current and archived internet pages, and other published or grey literature, as well as previously submitted student work from subscribing institutions around the world (including from current and past LSHTM students). It then generates an “originality report” highlighting text from the submitted work which has been found at other sources. This includes a facility for instant side-by-side comparisons between submitted work and any individual sources.

Turnitin screenshot: comparison against an individual text source Coverage: At the last count, in 2012, Turnitin covered 20+ billion pages of web content, 110,000+ professional, academic and commercial journals and publications, 220 million student papers, and was continuing to add content at a rate of 150,000 papers per day. However, please also remember that the comparison database is finite, and can never guarantee to be a 100% comprehensive resource of published literature/text – particularly in more specialised fields. Just because something is not picked up by Turnitin as matching to another source does not mean it is original work.

7 of 62 Copyright and Data Protection: There should be no copyright, data protection or confidentiality implications from use of the Turnitin service – it is simply a tool to make plagiarism procedures easier to implement, and is consistent with the School‟s Assessment Irregularity procedures. Moreover, all students are required to sign a declaration when registering for their course, to state: “I understand that when submitting work to the School for assessment it may be necessary for the School to make copies, or authorise third parties to make copies, for purposes of identifying and preventing plagiarism. I consent to the transfer of my assignments and any other submitted material, plus any necessary personal data, to accomplish this. I understand that the School uses the TurnitinUK service, and that TurnitinUK and its parent or associated companies will at all times abide by the applicable EU rules regarding the use and protection of my personal data.” Purpose: Turnitin should have two main benefits for markers at LSHTM. First, it will identify where there is a large proportion of copied text, legitimate or otherwise. Second, it pulls together and presents all source texts which it identifies as relating to the document under scrutiny, so as to allow easier comparison. This should be a more comprehensive approach to checking quotes, citations or potential plagiarism than hit-and-miss use of internet search engines or similar. Usage: Turnitin will be used in all cases where suspicions have been raised about a piece of work and are being formally followed up. This should be prompted by the responsible Taught Course Director or Research Degrees Director at the „initial investigation‟ stage. Additionally, MSc projects and Research Degree upgrading/review documents are checked in Turnitin as standard, and certain MSc modules are piloting use of Turnitin for checking assessments. Access: Staff in the Teaching Support Office and Distance Learning Office, as well as Research Degrees Administrators, have standard access to Turnitin and will normally be expected to upload any work for scrutiny. Additional logins may be requested via the Teaching Support Office. Note that Turnitin is designed as an interactive online system, and although Originality Reports can be printed out this does not provide the same ease of use for looking through and evaluating matches. More detailed procedures for the use of Turnitin are given at Annex 3. Informing decisions: It is vital to note that Turnitin does not make decisions about a piece of work or its author. Rather, it provides information from which members of staff can make a judgement about whether any copied text is an accurate and legitimate citation/quote/reference, or has been plagiarised. It is anticipated that Turnitin may be used at two distinct stages within the process of investigating potential plagiarism –  First, to inform an initial investigation (by Taught Course Director or Research Degrees Director) of whether there is a case to answer.

 Second, to provide more formal evidence for a Panel or Committee looking to make decisions about a case. 6. Current procedures for different types of work The following notes describe current standard practice and expectations about how different types of assessment should be checked for plagiarism. 6.1 For taught modules (both face-to-face and distance learning) Scrutiny by markers is the main method for detecting plagiarism in module assignments, as these are not run through Turnitin as standard. If a marker becomes suspicious when reading a particular piece of work, they should immediately contact the Module Organiser, who will refer this on to the Taught Course Director for investigation.

At the discretion of the Module Organiser and Taught Course Director, it may be decided that all student work for a particular module or module task should be run through Turnitin as standard. If so, then for reasons of consistency and fairness, all submitted work should be uploaded and checked, rather than just uploading a random sample for spot-checking.

8 of 62 Note that Turnitin scrutiny requires an electronic version of material, so will be more difficult for modules which require submissions in hardcopy only. If Turnitin is to be used as standard for a module, the assessment criteria should require work to be submitted electronically. Otherwise, since most hardcopy student work is likely to have been done on a computer and printed off, it will generally be possible to scan it in and submit the scanned file to Turnitin. Most modern scanners will have a character-recognition mode which picks up the actual text rather than scanning the full page as a picture, and will then be capable of saving this as a PDF file suitable for Turnitin. As a worst-case scenario, even if a student has submitted a handwritten assignment, key paragraphs for scrutiny may be electronically transcribed – although the TSO or DL Office will not necessarily have the resources to do this for a large amount of work.

6.2 For MSc projects (both face-to-face and distance learning) Projects are significant extended pieces of academic writing which, where taken, form a major component of an MSc degree at the School. Project markers are therefore expected to be particularly alert for plagiarism. All projects are also run through Turnitin on a standard basis (students are required to submit their reports in both hardcopy and electronic format, the latter being used); with the full set of projects for a course or even an entire Faculty being scrutinised by a designated „project moderator‟ – normally the Taught Course Director. Such horizontal scrutiny provides a consistent means of detecting substantially plagiarised work. However, it should be noted that this is necessarily top- level; „project moderators‟ will focus on projects which show larger proportional matches to other sources.

6.3 For formal exams (both face-to-face and distance learning) Rigorous exam hall procedures are the School‟s main approach to preventing irregularities in examinations. When reading through scripts, the main thing markers may wish to look out for is evidence of collusion (such as very similar answers from different students) or even cheating (such as correct answers without any evidence of workings or calculations). Plagiarism is not normally an issue for exams, and students are not generally expected to provide references or citations in work under exam conditions to the same standard as work done in private study time. However, one other thing to look out for is rote learning, where a student memorises someone else‟s text and regurgitates it without attribution – this may be classed as either plagiarism or poor academic practice, subject to judgement on the case in question. 6.4 For short courses Short course assessments should normally follow the procedures outlined above for module assignments or exams, as appropriate and at the discretion of involved staff. 6.5 For research degrees Research degree students are expected to display the highest standards of academic good practice in all work related to their degree. Supervisors should ensure they are confident that from an early stage of study, their students understand how to cite and reference correctly and avoid any risks of plagiarism or other irregularities. For the main elements of student work:  Upgrading reports or DrPH review reports should be run through Turnitin by the Faculty Research Degrees Administrator prior to the meeting. The version submitted may be a penultimate draft, and does not have to be the final document. In addition to top-level scrutiny by the RDA, the Chair of the relevant Panel should also review the Originality Report.  As good practice, penultimate versions of research degree theses should be run through Turnitin prior to formal submission. Scrutiny of the Originality Report may be undertaken by the supervisor or another appropriate Faculty nominee. While it is hoped that any instances of plagiarism at this stage would be very rare, such a review is likely to be useful in checking the quality of citations and references and prompting any last corrections or improvements.  DrPH Organisational & Policy Analysis reports should also be run through Turnitin as standard, by Research Degrees Administrators, and scrutinised by the DrPH Course Director or their nominee.

9 of 62  DrPH module assignments may be scrutinised in line with the procedures outlined above for other taught modules.  Research degree poster presentations, or any other work done during the course of a degree, may be referred for further scrutiny at the instigation of any concerned member of staff. Staff should also note that prospective research degree applicants are required to confirm on their application form "I declare that this application is my own work, and that any elements which make use of the work of others have been clearly indicated through a citation or acknowledgement. I consent to information from this application being transferred to the plagiarism detection service TurnitinUK to check originality.” Project proposals or other information from application forms will be run through Turnitin on a standard basis by either Research Degrees Administrators or the Registry. Where an issue is identified, it should be referred to the relevant Research Degrees Director to follow up and take action as appropriate.

7. Following up suspected plagiarism 7.1 Notification of suspicions Where a marker or another member of staff suspects plagiarism (or any other forms of assessment irregularity, like collusion or exam misconduct), they should normally investigate slightly further themselves – e.g. by checking suspicious phrases in an internet search engine, a likely source textbook, other scripts seen, etc. However, even if this turns up no further evidence, if suspicions remain then the matter should be reported.

In the first instance, such suspicions or allegations should be notified – without undue delay – to the member of staff with management responsibility for the relevant assessment, e.g. the Module Organiser (for a module assignment), Course Director (for an MSc project), or Research Degrees Coordinator (for research degree work). This member of staff should then inform the relevant Taught Course Director or Research Degrees Director, who will carry out an initial investigation to establish whether there is a case to answer.

7.2 Communication with students Staff who have reported suspected plagiarism are not necessarily expected to be identified as part of formal proceedings. All subsequent follow-up with the student should be handled via the Taught Course Director or Research Degrees Director and other staff with management responsibility for the assessment, i.e. Module Organiser or Course Director. Where the initial investigation suggests there is a case to answer, the Taught Course Director or Research Degrees Director will notify students. A template for doing so is provided at Annex 6.

Note that where an irregularity is alleged, results should not be confirmed for the assessment in question until a verdict is reached. Where this involves work which is expected to form the basis for a separate subsequent assessment (e.g. a module assignment which will be further developed in a later advanced module), then initiation or submission/examination/marking of the subsequent assessment should be deferred until a verdict has been reached. 7.3 Formal procedures for face-to-face programmes For students registered on face-to-face LSHTM courses, any allegations should be followed up under the Assessment Irregularities procedure (see links given earlier in this document). This has two main „levels‟ after an initial investigation by the Taught Course Director or Research Degrees Director has determined that there is a case to answer.

 In general, most cases will be dealt with by a less formal Irregularity Investigation Panel (IIP) consisting of the Taught Course Director plus the relevant Course Director or Module Organiser, or Research Degrees Director plus the relevant Research Degrees Coordinator. If

10 of 62 the Panel decides that an irregularity has occurred, the student will be given the opportunity to accept a decision and penalty set by the IIP.  In certain cases, a more formal Assessment Irregularities Committee (AIC) may be required. Cases should proceed directly to an AIC if warranted by severity of the allegation, if the allegation would constitute a repeat offence, or if specifically requested by student. Otherwise, an AIC will be required if the IIP believe that the case warrants more severe penalties, or if the student is unwilling to accept the decision or penalty of the IIP.

This process will apply for all LSHTM-registered students, whether on award-bearing courses or individual modules. The procedures also make reference to what to do for cases where students are registered for a primary award with other institutions (e.g. intercollegiate students), or for cases involving LSHTM students taking modules at other institutions 7.4 Formal procedures for distance learning programmes Students on the School‟s distance learning courses are registered with the University of London International Programmes, whose Regulation 1 Annex 6 „Procedures for the Consideration of Allegations of Examination Offence‟ apply. This defines plagiarism in almost identically the same way as the School‟s internal procedure, and staff should not need to treat distance learning work in any way „differently‟ when marking. Any suspicions or allegations should be identified as described above, and notified to the relevant member of staff (normally the Course Director or Module Organiser) to take forward with the Taught Course Director.

As per LSHTM procedures, Taught Course Directors should then conduct an initial investigation, and may convene an Irregularities Investigation Panel to help clarify matters further. Where there appears to be a substantive case to answer, the matter will need to be referred to the International Programmes to take forward under their procedures. However, cases of poor academic practice or poor scholarship should not be referred; and IIPs (or Taught Course Directors liaising direct with markers) may make recommendations as appropriate where matters are not being referred on to the International Programmes.

7.5 Legal implications Staff who become involved in a case of (potential) student plagiarism or other irregularities may sometimes worry about the possibility of legal implications. Please be reassured that this remains rare and unlikely, and were it to arise then any action would be expected to be against the School rather than individual staff. However, to remain fully protected staff should ensure that they follow the School‟s procedures rigorously from the moment any potential case is identified. Please also remember that under the Data Protection Act, students are entitled to see any records held about them; so use appropriately cautious language in any emails about particular cases, or any documents placed on file.

The main areas in which an institution might be legally challenged are over procedures (as per the Human Rights Act these must be clear and transparent and provide rights of appeal etc.) or bias (failing to treat everyone equally and in accordance with the procedures). Otherwise, the School‟s policy makes clear that irregularities should be dealt with as an academic judgement only; such matters are not reviewable by the courts – although note that they would be reviewable if treated as disciplinary matters, and students have the right to legal representation if a judgement will affect their career.

Plagiarism cases may also sometimes throw up the possibility of copyright infringement (possibly even infringement of staff members‟ copyrights); but this should be dealt with as a separate matter. Some further information on this topic is available at http://archive.plagiarismadvice.org/resources/legal-issues 8. Distinguishing plagiarism from poor academic practice Suspicious or inappropriate-seeming elements of work may potentially constitute „poor academic practice‟ (defined further below), rather than „plagiarism‟ as defined by the School. Markers are not

11 of 62 expected to have to make judgements to distinguish between the two – rather, any suspicious or inappropriate work that potentially meets the School‟s definition of plagiarism should be referred for investigation under the Assessment Irregularities procedure. Formal investigations may end up concluding that something was poor academic practice rather than plagiarism; but if in any doubt, the decision should be made in a formal way rather than based on markers‟ individual judgements. However, markers are expected to use their own expertise to make judgements about cases of poor academic practice which do not represent potential plagiarism, and may choose to award marks that are lower than they might otherwise have been. Examples of poor academic practice can include:  where work has been attributed, but not using a recognised citation style;  inconsistent use of different referencing styles in the main text or the bibliography;  poor quality of referencing;  overuse of potentially low-quality sources such as wiki-based internet sites;  excessive use of referencing; etc.

Academic judgements about the quality of work should take note of poor academic practice, i.e. this can quite appropriately affect marking. For example, a piece of work consisting almost entirely of referenced quotations may be liable to fail if it demonstrates a lack of original argument or analysis, or understanding and engagement with the topic. 9. Feeding back to students about their work If a piece of work has been referred for investigation under the Assessment Irregularities procedure, the student should not be given feedback until a verdict has been reached. However, as with any other piece of work, the student will be entitled to feedback. Markers will be expected to write the feedback, but the Taught Course Director (or Research Degrees Director) must be given the opportunity to review it and may choose to edit or add to it before it is sent to the student. Whatever the verdict, where a piece of work has been referred on for investigation, it will usually be appropriate to give the student some specific feedback on academic writing issues – e.g. noting alternative approaches that might have been taken, indicating good or bad referencing practice, or suggesting how the student might improve their next submission. Investigations may recommend that the student be asked to improve their understanding of School guidance in specific areas. Where a marker has identified elements of poor academic practice that do not constitute plagiarism and have not been referred on, these should likewise be mentioned in feedback and the student encouraged to improve.

Please be aware that markers must not make decisions about plagiarism – e.g. awarding a lower mark, while mentioning errors and areas to improve as part of the feedback to the student. Such issues should always be referred on and decisions made about the issue. This helps ensure that consistent standards and penalties are applied across the School, in a way that is equitable for all students. 10. Further guidance on this topic Two of the most well-recognised standard texts on plagiarism prevention and detection for UK higher education are: Carroll, J. (2002), A handbook for deterring plagiarism in higher education (Oxford: Oxford Centre for Staff and Learning Development) Carroll, J. and Appleton, J. (2001), „Plagiarism: a good practice guide‟ (JISC and Oxford Brookes University, http://plagiarismadvice.org/images/plagad/resources/institutional_approache s/Carroll_good practice.pdf )

12 of 62 Both of these are highly commended for all staff interested in developing an understanding of plagiarism-related issues. The other major support resource for staff in UK higher education institutions interested in best practice to address plagiarism and ensure the authenticity of student work is the JISC-established Plagiarism Advisory Service based at Northumbria University, www.plagiarismadvice.org The „resources‟ section of the site provides a wealth of useful information, of which the „good practice guide‟ mentioned above is just one.

13 of 62 Annex 2: Plagiarism declaration form for students DECLARATION ON PLAGIARISM AND CHEATING All students are required to complete the following declaration before taking any assessment at LSHTM. Only one declaration is required per student for the duration of a student’s course of study, but it must be returned before any work is assessed – i.e. prior to the submission date for module assignments (such as essays) or projects, or prior to the test date for module tests, practicals, or other types of formal exam. School policy LSHTM defines plagiarism, cheating and other forms of assessment irregularity (such as fraud, collusion and personation) in formal Assessment Irregularities procedures. These also set out how any allegations will be dealt with, and potential penalties that may be applied.  Procedures and further documents for taught courses (including all MScs, diplomas, certificates, diplomas and short courses) and research degrees are all available via www.lshtm.ac.uk/edu/taughtcourses/exams_assmt_staff/assessmentirregularityr esources/ Plagiarism is the copying or use of the work of others, whether intentionally or unintentionally, as if it were your own. Such work may come from any source whether published or unpublished, in print or online – including words, images, audio recordings, diagrams, formulae, computer code, performances, ideas, judgements, discoveries and results. To avoid plagiarism:  Where any use or mention is made of the work of others, it should be acknowledged.  A recognised citation system should be used.

 Quotations must accurately refer to and acknowledge the originator(s) of the work.  Direct quotations, whether extended or short, must always be clearly identified.  Paraphrasing – using other words to express the ideas or judgements of others – must be clearly acknowledged.  Work done in collaboration with others must appropriately refer to their involvement and input.  Use of your own past work should be referenced as clearly as the work of others. Cheating is a deliberate attempt to deceive in order to gain advantage in an assessed piece of work, including coursework, in-module assessments and examinations. This covers a range of offences, from significant instances of plagiarism to exam misconduct. Please consult your tutor, Course Director or supervisor if you are in any doubt about what is or is not permissible. Further outline guidance is given in course handbooks; and extensive guidance on good practice and how to avoid plagiarism is given in the Academic Writing handbook, at www.lshtm.ac.uk/edu/qualityassurance/academicwritinghandbook.pdf The School also uses a software program called Turnitin to check for plagiarism, helping to ensure that all assessed work is marked fairly and equitably, and no student gains an unfair advantage. Please note that any work submitted for assessment may be checked using Turnitin. > See overleaf for declaration to be signed by each student

14 of 62 Declaration by student I have read and understood the School’s definitions of plagiarism and cheating given on the preceding page, and I am aware that more extensive explanations about these and related matters are given in the Assessment Irregularity procedures and my course handbook. I declare that all material I submit for assessment during my registration as a student at the London School of Hygiene & Tropical Medicine is and will be my own work, and that when quoting, referring to or otherwise making use of the work of others I shall acknowledge this appropriately. I understand that potentially severe penalties may be applied if I fail to comply with School policies and guidance in these matters.

I understand that when submitting work to the School for assessment it may be necessary for the School to make copies, or share copies with others, or authorise third parties to make copies, for purposes of identifying and preventing plagiarism. I consent to the transfer of my assignments and any other submitted material, plus any necessary personal data, to accomplish this. I understand that the School uses the TurnitinUK service, and that TurnitinUK and its parent or associated companies will at all times abide by the applicable EU rules regarding the use and protection of my personal data.

Signature Full Name (printed) Course/Department Date Please return the completed form to your Course Administrator or Research Degrees Administrator

15 of 62 Annex 3: Procedures for the use of Turnitin at LSHTM Staff access to Turnitin Turnitin access should be managed via the Teaching Support Office, Distance Learning Office or Research Degrees Administrators, who can supply login details or set staff up with a personal login. For individual courses, project work should normally be uploaded to a course login account (corresponding to the course email address). It is the responsibility of the relevant administrative staff to ensure that course accounts are administered correctly.

Student access to Turnitin Turnitin access details for any accounts holding student work should not be given to students – not least as this would give access to view other students‟ work. It is not current School policy for students to be given their own access to Turnitin. However, in the unlikely event of students requesting visibility of the report on their work produced by Turnitin, the relevant administrator could download a copy of the Originality Report for them. Getting started A selection of useful training materials is available on the Turnitin UK website at www.submit.ac.uk/en_gb/support-services These include a „quickstart‟ guide, narrated videos and an instructor‟s manual which provides step- by-step guides to uploading and viewing material (their term „instructor‟ will apply to both LSHTM administrators uploading material and LSHTM academics checking Originality Reports). The system is ultimately fairly simple, although tends to use its own terminology (e.g. „classes‟, „assignments‟, „Originality Reports‟) and does not always make it immediately obvious where to click for a particular function. It also offers a wide range of additional functions that are not currently in use at LSHTM (e.g. for having students check their own work, or using Turnitin as platform for grading work) which may safely be ignored.

Good practice for uploading student work to Turnitin Work should normally be uploaded to Turnitin by staff in the TSO or DL Office. In all cases, it is important that work be uploaded in a clear and consistent way – to make individual pieces of work easy to find, and minimise issues such as identifiability. School policy is that all student work uploaded to Turnitin should be anonymised by candidate number – the only identifying information should be course, year and candidate number. Turnitin uses a structure of nested „classes‟ and „assignments‟ to organise work; their training materials include a short step-by-step video on setting these up. It is suggested that „classes‟ should normally be set up for each different academic year, and the different „assignments‟ set up within these – e.g. with separate assignment folders for things like individual submissions and groupwork submissions, and perhaps a “test” assignment for one-off or ad-hoc items. Note that when prompted to set a „class enrolment‟ password after creating a new class, this is not relevant (we are not asking LSHTM students to use the system directly) so just set it to anything. Instructions on uploading student work to Turnitin Administrators should upload work to Turnitin as follows: (i) Preparation – collate work from each student into a single file and anonymise it.  It is recommended that you copy all student work received electronically (e.g. via email or on a CD-ROM) over to a restricted-access folder on the shared office drive. Take whatever filename the students have given, and „save as‟ with their candidate number at the start of the filename. This should make it easier for you to later check off what you have uploaded.

16 of 62  Turnitin currently accepts Word, Text, Postscript, PDF, HTML, and RTF file types. If a student has submitted work in any other format (notably Excel), they should be asked to re-submit in an appropriate format – usually, by creating a PDF.  Where a student has supplied multiple files, you should aim to collate these and save into a single electronic file which can be uploaded to the system. If this is particularly difficult, then it is possible to upload multiple files to Turnitin – although that is not recommended, and files would need to be clearly distinguished, e.g. „Candidate X part 1 of 4‟.  Please ensure the file is anonymised to Candidate number only (removing student name or other personally identifiable information which is not relevant to the project itself). You should also remove any metadata – e.g. for Microsoft Word files, clicking on „File‟, „Properties‟, then removing any personal information in the tab for „Author‟.

(ii) Uploading – the system is quite straightforward and easy to use.  Go to the Turnitin UK site at www.submit.ac.uk, click User Login and enter login details (email address and password – the password is case-sensitive) for the course / area the work falls under.  Navigate through the list of classes and assignments, e.g. clicking class “Student Work 2010- 11” so you then see assignment "MSc Projects 2010-11", or similar. As per the notes above on administering accounts, you may need to create a new „class‟ or „assignment‟ in which to put the work you are about to upload.

 Click the Submit icon next to the assignment name, which brings up a submission screen. The method should be set to „file upload‟, although you may find it slightly easier to switch to „bulk upload‟ when about to deal with a whole batch of work from different students. In either case, the information you need to give is first name (state course/module/area – may wish to put an abbreviation, e.g. MSc PH); last name (put the candidate no.), and submission title (put the candidate no. again, then add their assignment or project title after this if you so wish).  Click „Browse‟ to select the appropriate file you have saved on your drive – this is where it can be very helpful to have put the candidate number in the filename – then attach and submit.  The system can let you view the text of the project before you confirm upload. This can be helpful to make sure you‟ve put the right file against the right candidate number, and that Turnitin has picked it all up appropriately if the student has used any unusual formats.  Once submitted, you then have options to either make another submission, or return to the inbox which shows all submitted work for that assignment.

 Note that after submission, reports may typically take about 20 minutes to process on the system before you can view them. After uploading a large batch, it may take longer before they are all ready to view. Instructions for academic staff checking student work on Turnitin Once uploaded, academic staff can view Originality Reports online as follows:  Go to the Turnitin UK site at www.submit.ac.uk, click User Login and enter login details (email address and password – the password is case-sensitive) for the account to which work has been uploaded.

 This will show a list of "classes"; click the relevant one e.g. “Student Work 2011-12”.  This will then brings up a list of "assignments"; click the View icon next to the relevant one (e.g. "MSc Projects 2011-12", or similar) to bring up the relevant work.  Work should have been uploaded by candidate number. Click on any of the Report icons next to a candidate number / assignment title to see the relevant „Originality Report‟ for that candidate. This highlights all text sourced from other documents, with facility to click through to review any of the source texts. Each report has an “overall similarity index” showing the percentage of text which matches to sources in the Turnitin database.

 A source numbering system is used to show which parts of the text correspond to which source, and what percentage that represents overall. Clicking on a particular phrase will bring up a "side by side" report comparing student text against the specific source, in two parallel panes.

17 of 62  It is possible to exclude any of the indicated sources from the report, which then recalculates the overall similarity percentages. Simply click the relevant “x” icon to the right of the source details displayed in the right-hand pane; it removes that source from the cumulative view, to show any smaller matches which may be hidden underneath. This function is useful, for instance, where a student submits a revised version of a piece of work; initially the originality report would show a very substantial match to the previous version, but to make appropriate external comparisons the previous version should be excluded. Excluded sources can still be viewed and restored using the „single source mode‟ of the report.  Various other functions are also available in the software, e.g. to see the original (fully- formatted) version of the file uploaded for that student then click on their name / candidate number in the main Assignment screen.

 When suspected plagiarism is identified, the Originality Report and source files highlighted by Turnitin can easily be viewed/saved/printed for use as supporting evidence in a case. Guidance and expectations for using Turnitin to identify plagiarism It is important to note that the Turnitin software does not “identify” plagiarism per se; it simply provides an Originality Report highlighting text within the assignment that has been found at another source. A level of matching will always be expected, as citations, references etc. will all be picked up; e.g. 15% would be normal for many types of project, and for some types (such as literature reviews) a higher proportion of matches would be expected. Thus, in using Turnitin it will always be necessary for a relevant member of academic staff to review the Originality Report and decide on what may constitute plagiarism or inappropriate citation. This scrutiny should normally be conducted either by Taught Course Directors or Research Degrees Directors conducting an initial investigation of an alleged case, or by another designated member of staff who has been asked to check or moderate a batch of work (e.g. a set of MSc projects or work for a specific module).

When reviewing a batch of student work, individual elements may be scrutinised to a greater or lesser level of detail as appropriate to the work in question. At minimum, it is suggested that Originality Reports be scrutinised in detail for all work which shows an overall „similarity index‟ (text matching to external sources) of greater than 30%. Preferably, each Originality Report should be opened up individually, and if a similarity index of greater than 5-10% is shown against any single source then it should be looked at in closer detail.

Messages from other institutions Turnitin users at LSHTM will always be using a login account associated with a particular email address. For MSc work, this will normally be the generic MSc email address also used for prospective student enquiries etc.; but for other types of work e.g. modules or research degrees, accounts may be set up for individuals. Note that occasionally, the email address associated with an account may received automated messages from Turnitin on behalf of staff at other institutions. This may happen and should be acted on as follows.

 If someone at another institution runs a report through Turnitin that matches in part to a report previously uploaded at LSHTM, then they will see that the report at their institution has an x% match to this report at LSHTM. They will not have direct visibility of the original report text; rather, Turnitin will offer them the opportunity to click a button to send an automated email requesting visibility. This will go to the LSHTM email account under which the report was originally uploaded – staff at other institutions are not given direct LSHTM contact details.  Whoever receives this request at LSHTM should then decide whether to allow or deny visibility. The declaration which all students sign on registration includes a clause granting blanket permission for the School to share their work with others where appropriate to aid the prevention or detection of plagiarism; so it is not necessary to ask permission from the student involved. Staff should normally grant visibility on requests for any % match above 5%, but may

18 of 62 use their discretion to deny visibility for any % matches below that level without needing to double-check the work involved.  It is possible that more than one „instructors‟ may be associated with the login account under which a piece of work was uploaded, and that these may all receive the same automated request for visibility. In the event that duplicate requests are received, they should be dealt with by the Course, Module or Research Degrees administrator for the LSHTM area concerned.

19 of 62 Annex 4: Formal Assessment Irregularities procedure for taught courses ASSESSMENT IRREGULARITIES PROCEDURE FOR TAUGHT COURSES OVERARCHING CONTEXT Scope 1. These procedures are made under the auspices of the LSHTM Examination Procedures and Regulations. They apply in respect of any alleged assessment irregularities, plagiarism or cheating connected with LSHTM students or LSHTM courses. In particular, they will apply for all aspects of the assessment of London-based MSc, Diploma, Certificate and assessed Short Courses. 2. Distance Learning students are primarily registered with the University of London International Programmes, and International Programmes Regulations and Procedures will take precedence should there be any conflict or overlap with these procedures.

3. Research Degree student work (including PhD Upgrading, DrPH Review, assessments under the remit of the DrPH Board of Examiners, and the thesis and oral examination) is covered by separate, but similar, procedures. However, for research degree students taking assessed modules or short courses, any alleged irregularities may first be investigated under these procedures – see specific section below on “Applicability of procedures to Research Degree students”. 4. For students registered with other institutions but undertaking work at LSHTM which is to be accredited towards their qualification, any alleged irregularities may first be investigated under these procedures – see specific section below on “Applicability of procedures to module students or students registered with other institutions”. For any LSHTM students undertaking work at other institutions which is to be accredited towards their qualification, the relevant Taught Course Director should follow up on any allegations reported – see specific section below on “Applicability of procedures to LSHTM students taking modules at other institutions”.

5. Any dispute as to the interpretation of these procedures shall be referred to the Associate Dean of Studies. Principles 6. These procedures are intended to be fair, consistent, transparent, accessible, and avoid undue additional administrative burden for staff and students; whilst forming part of a framework which promotes good academic practice across all forms of teaching, learning and assessment. o In line with the School‟s equal opportunities policy and code of practice on dignity at work and study, these procedures should treat students no differently based on any matter related to their age, race or ethnicity, religion or belief, gender or sexual orientation, or any disability. Application 7. All allegations or suggestions of plagiarism and assessment irregularities will be investigated by the School, with appropriate penalties issued to students (or details referred to the appropriate bodies) where it is found that there is a case to answer.

8. In any proceedings under these procedures, the student shall be presumed to be innocent until the contrary is established on the balance of probabilities. Staff responsibilities 9. Staff who should be aware of their responsibilities under these procedures are: all staff involved in assessment, especially markers and invigilators; Module Organisers; Course Directors; Taught Course Directors; the Dean and Associate Dean of Studies; and the Assistant Registrar (Student Records & Assessments). 10. In the case of the temporary absence or incapacity of any officer or other official named in these procedures, responsibility devolves to the person appointed as his/her deputy. If no deputy has been appointed, the Dean of Studies (or the Director, relevant Dean of Faculty, or relevant Taught Course Director, as responsible for line management of the absent staff member) will appoint a deputy. 11. The Dean of Studies may delegate any of the duties assigned to him/her under these procedures to another member of the School's Senior Management Team or to the Associate Dean of Studies.

20 of 62 Definition of time limits 12. For the purpose of the regulations set out in this procedure, a “working day” is defined as a weekday during which the School is not closed through School closures, Bank Holidays, Director‟s Days or other days in which staff are not expected to work. Updates to these procedures 13. The Associate Dean of Studies (as Chair of the Quality & Standards Committee) will be responsible for approving any updates to these procedures. Any substantive updates should first be discussed at a relevant School committee, e.g. Teaching Management Group, Quality & Standards Committee or Learning & Teaching Committee. Any very substantive changes should be put forward to the Senate. 14. Changes to procedures should normally be agreed for implementation from the start of the next academic session, ensuring that all relevant documentation is updated before being made available to the new intake of students. Before approving any changes, consideration should be given to how they will affect continuing students (e.g. part-time MSc students, re-sit students). At the discretion of the Associate Dean of Studies, updates to the procedures may be made effective during the course of an academic year; however such changes should not normally be substantive. DEFINITIONS AND GOOD PRACTICE Definitions 15. Plagiarism is the copying or use of the work of others, whether intentionally or unintentionally, as if it were your own. Such work may come from any source whether published or unpublished, in print or online – including words, images, audio recordings, diagrams, formulae, computer code, performances, ideas, judgements, discoveries and results. To avoid plagiarism:  Where any use or mention is made of the work of others, it should be acknowledged.  A recognised citation system should be used.

 Quotations must accurately refer to and acknowledge the originator(s) of the work.  Direct quotations, whether extended or short, must always be clearly identified.  Paraphrasing – using other words to express the ideas or judgements of others – must be clearly acknowledged.  Work done in collaboration with others must appropriately refer to their involvement and input.  Use of your own past work should be referenced as clearly as the work of others. 16. Cheating is a deliberate attempt to deceive in order to gain advantage in an assessed piece of work, including coursework, in-module assessments and examinations. This covers a range of offences, from significant instances of plagiarism to exam misconduct.

17. Fraud is the submission of any work which may cause others to regard as true that which is not true. This covers work which has been fabricated (e.g. with invented data or cases), falsified (e.g. with wilfully distorted data), omits significant items (e.g. ignoring outliers, not admitting that some data are missing, not admitting other relevant post-hoc analyses, omitting data on side effects in a clinical trial, non- disclosure of a conflict of interest, etc.), or in any way misrepresents the work or research carried out. Fraud may be by intention, by disregard of possible consequences (e.g. in failing to adequately describe the input of others), or by negligence (e.g. submission of work based on distorted data due to poor data handling practice). Assessment or research fraud may cross over with a range of other offences, from plagiarism (e.g. unattributed copying of the research data of others) to cheating, collusion or personation. 18. Collusion is any form of collaboration with another person, including another student, which has not been clearly acknowledged or permitted for assessment purposes (either when being submitted, or during the course of an examination). Different forms of collusion may be regarded as either plagiarism or cheating. 19. Personation is the deliberate submission of work done by another person (e.g. another student, a friend, a relative, a peer, a tutor, or anyone else) as if it were the student‟s own. Another person‟s work may cover any source whether published or unpublished, including words, images, audio recordings, diagrams, formulae, computer codes, ideas, judgements, discoveries and results. This may cross over with a range of other offences; submission of another person‟s work with their knowledge is likely to constitute collusion; doing so without their knowledge may constitute plagiarism; representing a piece of joint or group work as the student‟s own is likely to constitute fraud; and deliberately procuring work from sources or commercial entities such as essay banks would be very likely considered cheating. Arranging

21 of 62 for another person to falsely identify themselves as the student and take an exam on their behalf would be seen as a particularly severe form of personation and cheating. 20. The term „assessment irregularity‟ applies to any suspected instance of plagiarism, cheating, fraud, collusion, personation or other non-standard activity identified in connection with an assessment (including essays or other coursework assessments written in a student‟s own time) or formal examination. The term „irregularity‟ does not necessarily imply misconduct on the part of a student; judgement as to whether a specific offence has occurred should only be made following proper investigation of the case under these procedures.

21. Students are each individually responsible for safeguarding their own work (e.g. assignments, essays, projects, reports, dissertations, theses and other similar work) to prevent such work from being copied inappropriately by other students or persons. Examination hall conduct 22. Further to the above definitions, conduct in examination rooms or halls – that is, any test taken under formal assessment conditions – is also subject to specific restrictions, as follow. This covers written papers taken under supervision and within a defined time limit, as well as any practical, oral or similar examinations, and where appropriate to assessments taken online. Any offences or misconduct under such conditions will be followed up under these procedures, and will be treated extremely seriously. 23. The conditions under which any particular examination or assessment is to be taken should be set in advance by the responsible Board of Examiners, and made clear to the candidates concerned. The following notes should be seen as standard „ground rules‟ which all students should be aware of and expected to follow; but individual tests may entail further or different restrictions. 24. Conduct which is not permitted and will constitute an examination offence includes: (i) To introduce, handle or consult unauthorized materials, aids, instruments or equipment in the examination, however they are stored or transported, which might be used to the student‟s advantage – including the use of inappropriate (i.e. programmable) calculators, or other inappropriate devices including mobile phones, Personal Digital Assistants or any wireless devices.

(ii) To personally annotate books, statutes or other materials permitted in the examination. (iii) To make unauthorised use of material stored in or communicated to a device such as a calculator, computer or mobile phone, or to make unauthorised use of software or other functions or information stored electronically on such a device. Even if the device itself has been permitted, the use of inappropriate material will not be. (iv) To communicate (in written, verbal, gestural, electronic or any other form, except where expressly permitted), collude or engage in any other unauthorised activity with any other persons during the examination. This includes copying or reading from the work of another candidate or from another student‟s books, notes, instruments, computer files or any other materials or aids. (v) To offer an inducement of any kind to an invigilator, examiner or other person connected with the assessment.

(vi) Failure to comply with the reasonable request of an invigilator. (vii) Any conduct of which the result would be an advantage for the student obtained by subterfuge or action contrary to published rules or guidance. (viii) To remove from the examination room, without prior authorisation, stationery or other materials supplied for examination purposes by the School, University or examination centre. 25. Regarding materials or conduct which may or may not be permitted in an examination: (i) Where expressly permitted by the Board of Examiners for the examination in question, candidates may use specific books, notes, instruments or other materials or aids in the examination.

(ii) Where candidates are permitted to use their own electronic calculators at examinations, the machine to be used must be of the hand-held type, quiet in operation and compact, and must have its own power supply. Candidates are entirely responsible for ensuring that their machines are in working order for their examination and for providing in advance for alternative means of calculating in the event of the calculator failing during the examination. When candidates use

22 of 62 electronic calculators at examinations they must state clearly on their examination scripts the name and type of machine used. (iii) Any materials or aids in the possession of the candidate on entry to an examination room – such as books, notes, instruments, or any other materials or aids whatsoever – must be deposited immediately with the Invigilator if not expressly permitted in the examination. Any such materials or aids suspected of being unauthorised must be surrendered to an Invigilator upon request. Any materials or aids so surrendered may be handed over by the Invigilator to the School or University authorities which may make copies of them, and the original materials or aids (together with all such copies) may be retained by the School or University at its absolute discretion.

Referencing, good practice and sources 26. In addition to the definitions of various types of assessment irregularity given above, the School provides student-focused written guidance on referencing, citation and the acknowledgement of sources – with summary information in course handbooks, and more detailed guidance in the „Academic Writing handbook‟ which is applicable School-wide. 27. Students are each individually responsible for learning the correct forms of referencing, citation and the acknowledgement of sources, and avoiding any assessment irregularities in the work they undertake. 28. Teaching staff – particularly Course Directors, Project Supervisors, and Module Organisers – should endeavour to ensure that prior to undertaking assessment, students have been made aware of guidance about good practice, and how to avoid assessment irregularities and their potential consequences. Staff are strongly encouraged to place such guidance in context within the conventions of the subject, field or discipline relevant to the particular assessment, i.e. to illustrate how good practice should apply for the task at hand.

29. It should be noted that poor or inappropriate use of referencing is liable to be investigated under these procedures, and students may be asked as a result to improve their understanding of School guidance. Poorly or inappropriately referenced work may also attract a lower mark. This is likewise the case for excessive use of referencing, which while it may not constitute an assessment irregularity may attract a lower mark – e.g. a piece of work consisting almost entirely of referenced quotations is liable to fail if it demonstrates a lack of original argument or analysis, or understanding and engagement with the topic. 30. In the event that a student unwittingly uses a secondary source which itself turns out to be plagiarised, misattributed or incorrectly referenced, the case may be investigated (retrospectively identifying the errors) but the student should not normally be penalised provided they have followed correct practice and fully referenced their use of the erroneous source or sources. However, while students are not expected to comprehensively check all secondary sources, use or overuse of potentially poor-quality sources (such as wiki-based internet sites) may attract a lower mark and be liable to be penalised. 31. Students should take care in re-using their own previous work. Presenting work for assessment which was originally completed for other purposes, whether at LSHTM or elsewhere, may be treated as self- plagiarism (or even cheating) under these procedures, unless this work is properly identified or unless instructed otherwise, e.g. if students have been asked to resubmit the work. Students who have previously submitted an original piece of work for assessment at LSHTM or for any other University of London award may not re-submit it, in whole or in part, for consideration towards an LSHTM qualification – i.e. credit can only be given once for a particular piece of assessed work. It may be possible to build on work done previously, e.g. to take a topic initiated in a module assignment and develop it fully as part of a project report (personal tutors or involved academic staff should be able to advise on what is acceptable); but in such cases students should identify and reference their own previous work as carefully as any other source.

32. In assessments taken under exam conditions, candidates are not necessarily expected to give detailed references. However, care must still be taken to avoid plagiarism and ensure that the work of other people is not presented as if it were the candidate‟s own. Any memorised quotations must be duly acknowledged, and quotations presented without attribution or as if they were the candidate‟s own work may be treated as plagiarism. Examination submissions should preferably be expressed in the student‟s own words, appropriately indicating the work of others, but incorporating the student‟s own ideas and judgements.

APPLICABLE PENALTIES

23 of 62 Factors determining severity of irregularity 33. Any decisions made concerning assessment irregularities should take all relevant factors into account before determining a penalty. These may include: (i) The extent of any academic misconduct or poor practice. (ii) The motivation and intention of the student in respect of the irregularity. (iii) The effect of the intended penalty on the student's progression or overall award. (iv) The relation of the examination(s) in question to the structure of the award for which the student is a candidate.

(v) The effect that the cancellation of the paper(s) or test(s) would have on the student (e.g. whether they could re-enter that paper alone, or if they are required to pass all the papers on the same occasion). (vi) The arrangements for re-entry to the examination(s) or assessment(s) in question. (vii) The comparable position of a student who had simply failed the paper(s) or test(s) in question. (viii) Whether the student had been found guilty of a previous assessment irregularity at the School (In order to check this, the responsible Taught Course Director will need to check with Registry whether any previous offences are recorded on the student‟s file).

(ix) The stage the student is at in their programme of study, and their prior academic experience as may be relevant to the standards expected in UK Higher Education (including where their previous education was undertaken, and whether their prior qualifications include undergraduate, postgraduate or doctoral degrees). (x) Where students have a disability or medical condition, the School may make reasonable adjustments to the assessment to ensure fair and equal treatment. Such students are strongly encouraged to disclose their situation and speak to the Registry well in advance regarding any special arrangements that may be appropriate for their assessment. Adjustments cannot be made retrospectively. If a student‟s disability or medical condition appears to have a bearing on an assessment irregularity, this may potentially mitigate the severity of the irregularity but should not result in de facto differential treatment.

Scale of penalties 34. Penalties for assessment irregularities should be determined on a sliding scale that takes account of the severity of the offence, and should be applied in a consistent way across the School. Penalties may cover any combination of the following: (i) That no further action is taken. (ii) That the student is reprimanded (either verbally or in writing) by the responsible Taught Course Director and reminded of the need to strictly observe assessment requirements, with a note to this effect added to their student file.

(iii) That in addition to other penalties, the student be required to attend a nominated course or training session on good referencing practice and avoiding plagiarism. (iv) That where the offence is one of identified plagiarism, the plagiarised section of the work is ignored, removed or revised for re-submission and the remaining portion of the work marked in accordance with normal course regulations. (v) That where the offence is one of identified fraud, the fraudulent section of the work is ignored, removed or revised for re-submission and the remaining portion of the work marked in accordance with normal course regulations; with the penalty to specify any further restrictions on potential future publication (or requirements for revision prior to such publication) if the work is to be in any way associated with LSHTM.

(vi) That the result for the piece of work be reduced by one or more gradepoints, which may include being marked down to the minimum pass mark or below. Where this penalty is a reduction to a fail grade, the student may be permitted to re-sit under standard re-sit procedures (i.e. if the irregularity has been on a first attempt, it will normally be possible to re-sit); but the penalty may specify any maximum pass grade achievable in re-sitting. (vii) That the result for the piece of work be reduced to grade 0 (zero). The student may be permitted to re-sit under standard re-sit procedures (i.e. if the irregularity has been on a first attempt, it will

24 of 62 normally be possible to re-sit); but the penalty may specify any maximum pass grade achievable in re-sitting. (viii) That (for serious offences in relation to module assessment only) the result for the piece of work be reduced by a set number of gradepoints or to grade 0, with a requirement that this piece of work and associated module result must contribute to the outcome of the student's final award. The student may not be permitted to undertake a re-sit to be counted towards their final award; although standard re-sit procedures may allow a re-sit to be taken to demonstrate academic capability, e.g. if the student‟s award outcome is a borderline case and the Exam Board is required to consider a portfolio of work.

(ix) That the student not be permitted to re-enter for any or all of these assessments or examinations before the expiry of a stated period of time. [This penalty may only be given by an Assessment Irregularities Committee] (x) That the student be permitted to re-enter for those assessments or examinations on the next normal occasion, but that no degree, diploma or certificate be awarded to the student before the expiry of a stated period of time. [This penalty may only be given by an Assessment Irregularities Committee] (xi) That the student be excluded from future assessments or examinations for awards of the School. [This penalty may only be given by an Assessment Irregularities Committee] (xii) That the student be excluded from the award for which they have been entered/registered. [This penalty may only be given by an Assessment Irregularities Committee] (xiii) That withdrawal proceedings be initiated against the student with immediate effect. [This penalty may only be given by an Assessment Irregularities Committee] (xiv) That a recommendation be made to the Senate for the student's award to be revoked. [This penalty may only be recommended to the Senate by an Assessment Irregularities Committee] 35. The most significant penalties, which have ramifications beyond the marking of an individual piece of work, may only be formally levied by an Assessment Irregularities Committee or the Senate (as indicated above). Discussions at earlier stages of investigation, including at Irregularity Investigation Panels, may recommend such penalties as being appropriate; but an Assessment Irregularities Committee will always need to be convened to determine this formally.

36. The School reserves the right to inform appropriate external bodies (e.g. the General Medical Council) in any upheld cases of academic misconduct, especially any cases of fraud. ASSESSMENT FEEDBACK 37. Where a piece of work has been deemed irregular and reported to the student as such under the below procedures, the Taught Course Director is responsible for reviewing any feedback from markers about the work before it is sent to the student, to ensure it is appropriate for this specific case – e.g. noting alternative approaches that might have been taken, indicating good or bad referencing practice, or suggesting how the student might improve their next submission.

PROCEDURES Initiation of proceedings 38. Cases of suspected assessment irregularity, including examination misconduct, should be reported in the first instance to the Course Director or Module Organiser for the MSc Course or Module for which the assessment was held. 39. The relevant MSc Course Director or Module Organiser should then inform the Faculty Taught Course Director (TCD) with responsibility for that MSc or Module, for the TCD to make an initial investigation of the alleged irregularity and establish whether there is a case to answer.

40. Where an irregularity is alleged, no assessment result should be confirmed for the piece of work in question until a verdict is reached on the allegation. In the rare event that a case is not resolved ahead of the final Board of Examiners meeting at which the involved student's results would have been considered, then both the student and the relevant Exam Board Chair should be informed and, if unavoidable, consideration of these results may need to be deferred to a subsequent or special meeting of the relevant Board of Examiners.

25 of 62 41. Where an irregularity is alleged for an assessment task which will form the basis for a separate subsequent assessment (e.g. a module assignment which will be further developed in a later advanced module, or a submitted thesis which will be subsequently examined at a viva), then initiation of the subsequent assessment should be postponed, or submission/examination/marking of the subsequent assessment should be deferred, until such a time as a verdict has been reached on the assessment task for which an irregularity has been alleged.

42. There is no statute of limitations on when an assessment irregularity allegation may be made. However, all staff who are aware of any potential issues are obliged to report them as they arise or within a reasonable time; failure to do so may be grounds for any future case to be dismissed. In the rare event that a case is brought subsequent to the final Board of Examiners having met or the student having graduated, these procedures will still apply. Such a situation may require that the Board of Examiners reconsider their previous decision, and that they or the Senate amend or rescind grades or awards previously made.

Initial investigations 43. All investigations shall be carried out as soon as possible. After being notified about the alleged irregularity, the responsible Taught Course Director should endeavour to complete their initial investigation within no more than 10 working days. 44. As part of their investigation, the Taught Course Director should ask the Registry to check the Assessment Irregularities file to confirm whether any prior allegations have been made or cases taken forward regarding the student in question; and if so to provide details. 45. If the nature of the alleged irregularity is such that some form of disability may have had a bearing on it, the Taught Course Director should check with the Student Adviser as to whether the student has declared a disability and given permission for staff to be informed about this. However the Student Adviser will not be in a position to inform the TCD if a disability has been declared but permission to inform other staff withheld.

46. Having made an initial investigation of an allegation, if the responsible Taught Course Director determines that there is no case to answer they need not record a report on the allegation. 47. There may be circumstances where, upon investigation, the Taught Course Director decides there is no case to answer but the student has demonstrated poor practice (e.g. in referencing or citing). In this case the Taught Course Director may wish to informally contact the student to remind them of best practice and the need to strictly observe assessment requirements.

48. Where initial investigation by the responsible Taught Course Director indicates that there is a case to answer, they should next determine whether there is any need for the case to progress directly to an Assessment Irregularities Committee (see specific criteria in section on AICs below). If not, it will be appropriate to progress to a Irregularity Investigation Panel. 49. The Taught Course Director should then contact the student: (i) describing the alleged irregularity (in writing, phrased according to established precedents); (ii) enclosing a copy of these Procedures; and (iii) requesting the student to explain their conduct or give any other evidence to the relevant Panel or Committee. It should be made clear that the explanation and evidence from the student may be given either in person at a meeting (the preferable option – though the Panel or Committee would be meeting anyway to discuss the case) or in writing (though there should be no requirement at this stage to give a written statement). The student should also be encouraged to disclose any disability or medical condition to the Panel that may have a bearing on the alleged irregularity.

50. If an initial investigation indicates that there is a case to answer arising from a previous assessment, but the student is at a crucial juncture in their overall course of study (e.g. about to take exams or other assessments), then the Taught Course Director may at their discretion put the case on hold and not contact the student or progress the case further until this immediate juncture has passed – so as to avoid affecting the student‟s performance in other assessments. However this may not be appropriate in every case, and decisions may be informed by the type and apparent severity of the irregularity being investigated.

Contact with students, and timescales for procedures

26 of 62 51. Staff with responsibilities under these procedures should make reasonable efforts to contact involved students: normally via email in the first instance; secondly checking with other staff who may know when or how best to contact the student, including via telephone; and if all other methods of contact have failed, delivering notification in writing by hand or by recorded delivery to the student at his/her last known address. Involved staff should keep a record of the date and general content of all attempted communications with students. If relevant staff fail to meet their responsibilities regarding timely and appropriate contact with students, this may constitute grounds for a subsequent appeal. 52. MSc students will be expected to check their School email accounts regularly throughout the academic year, and should let Registry or the Teaching Support Office know if their contact details change or if they will be out of contact for a sustained period of time. MSc students undertaking summer projects will be expected to have given their supervisors notification of when and how they will be contactable. 53. Other taught course students (inc. for Diplomas, Certificates and Short Courses) will be expected to be contactable through standard channels while their course is still running, and should let Registry or the Teaching Support Office know if their contact details change or if they will be out of contact for a sustained period of time.

54. Students whose course has finished should be contacted using their file details – initially via the primary email address held on file for them, then via telephone and/or post as appropriate. 55. Students are required to respond promptly on receipt of any and all communications about possible assessment irregularities, and to comply with all indicated timescales. Where their circumstances may prevent them from meeting obligations under these procedures, students should notify the relevant staff as soon as possible. In such cases, staff should attempt to make alternative arrangements if reasonable (e.g. to set a slightly later meeting date), and may work outside the deadlines indicated elsewhere in these procedures.

56. Involved students or staff may request extension of any timescales or deadlines given in the procedure; such extensions may be granted at the discretion of the relevant Taught Course Director, the Assessment Irregularities Committee Chair if one has been convened, or the Appellate Committee Chair if one has been convened. 57. There is no expectation that students who are normally based away from London (especially Distance Learning students) should be able to attend meetings in London. In these cases, input may be given in written form, usually via email; or alternative participation arrangements such as teleconferencing or videoconferencing may be made at the discretion of the responsible Taught Course Director. 58. In the event that a student has indicated their intention to attend or participate in a meeting, but then cannot do so for good reason, an adjournment should normally be considered.

59. Where reasonable efforts have been made to contact a student in respect of an alleged assessment irregularity, but no response has been received, proceedings may be taken, a verdict reached and a penalty applied in their absence. Meeting of the Irregularity Investigation Panel 60. As indicated above, initiation of proceedings by the responsible Taught Course Director will normally result in an invitation for the student to meet with a Irregularity Investigation Panel – to discuss the allegations, or else respond with a written explanation of their conduct or any other evidence for consideration. The purpose of this Panel shall be to consider details of the alleged irregularity and the involved student's response, with the authority to make a final recommendation on the matter if the student is prepared to accept this.

61. If the student does not wish the case to be considered through an Irregularity Investigation Panel then it should progress directly to an Assessment Irregularities Committee. 62. The Irregularity Investigation Panel shall be constituted of: the responsible Taught Course Director (Chair); AND either the relevant Course Director or their nominated deputy (where the irregularity is at Course level) or else the relevant Module Organiser or their nominated deputy (where the irregularity is at Module level). Further Panel members may be nominated by the responsible Taught Course Director or the Dean of Studies. The quorum for any meeting or decision of the Panel shall be two members.

27 of 62 63. The Panel shall meet as soon as possible, normally within 10 working days from the student being sent notification that there is a case to answer. In exceptional circumstances (e.g. if the student is overseas) this may not be feasible, and the responsible Taught Course Director may set dates as appropriate. If the involved student is unable or does not wish to attend in person, for instance if they are a Distance Learning student, the Panel may reach a decision without a formal meeting (e.g. by email contact) at the discretion of the TCD.

64. The involved student may choose to either meet with the Panel and present a further statement in mitigation or explanation of the matter being discussed; or choose not to meet with them, having provided relevant information for consideration. 65. The meeting is not a hearing and may be kept relatively informal. A friend or representative may accompany the student at the meeting if desired, for instance a fellow-student, course representative, or an Officer of the Student Representative Council. This is a courtesy; such an individual should not be a formal legal counsel, and should not actively participate in the Panel meeting. 66. The Panel may, at its discretion, have private discussions – requesting that the student and any other attendees vacate the room, or themselves retiring to another room.

67. The Panel should normally retire for private discussion before deciding any provisional penalty (i.e before this is mentioned to the student). 68. Discussion at the meeting should aim for consensus between the Panel members and the involved student as to what has occurred, whether it constitutes an assessment irregularity, how severe it is, and what penalty is likely to be most appropriate. The potential impact of this penalty on the student's final award should also be made clear. In the event that the student is absent, or is present but cannot reach agreement with the Panel members, then the Panel must reach their own clear decision on the case, and should aim to do so without adjourning to a later date.

Outcome of the Irregularity Investigation Panel 69. At the end of the Panel meeting, if the student is present (or via subsequent contact if they are not present), the Taught Course Director should offer the student the option of accepting the Panel's decision on their part in the irregularity, and have the TCD make a subsequent decision on the penalty to be applied. Students should reasonably expect that such this subsequent (final) penalty will be in line with what has been discussed with the Panel. However, if the student does not accept this option, or if other factors require it (as detailed below, including any cases where the student has previously been found to have committed an assessment offence), then the case will be escalated to a formal Assessment Irregularities Committee (AIC) – in which case the Taught Course Director should write up a report on the Panel‟s discussions, and forward this to the Assistant Registrar (Student Records & Assessments) to initiate the AIC.

70. If the student indicates their willingness to accept such a decision, the responsible Taught Course Director should then take any advice required to reach a final decision on the case and the penalty to be applied. Such advice may include consultation with the Dean of Studies or Assistant Registrar (Student Records & Assessments) to determine that the penalty is appropriate and in line with past precedents and current practice across the School. This final penalty should usually be as provisionally recommended by the Irregularity Investigation Panel.

71. Having taken such advice, the Taught Course Director should prepare a brief report detailing the allegation, the evidence that was considered, and the outcome. This should be done as soon as possible, and within 5 working days from the date of the Irregularity Investigation Panel meeting. The report should include a standard statement for the student to sign against, to say "I agree with this statement of facts concerning my work as indicated above, and agree to the penalty or penalties indicated". 72. Where the evidence about a case suggests that it fits with standard precedents, it may not be necessary for the Taught Course Director to seek further advice before reaching a final decision, and they may choose to prepare such a report in advance of the Irregularity Investigation Panel. This would allow the student to sign the report at the end of the meeting, if they agree and provided no conflicting evidence has come to light.

73. If the student has given their consent in absentia to the verdict and penalties proposed by the Panel, or is otherwise unable to sign in hard copy, then relevant evidence that they have given their consent to the recommended penalty (e.g. e-mail or a signed statement from a staff member regarding a phone

28 of 62 conversation with the student) should be included with the file copy of the Assessment Irregularity Record Form, in lieu of a hard copy student signature. 74. If no response has been received from the student within 15 working days of their being contacted regarding the Panel‟s decision and proposed penalty, proceedings should be completed without the student‟s input, the TCD determining the final penalty and this being applied. 75. The Taught Course Director will then arrange for the relevant penalty or penalties to be applied, and for signed copies of this report to be sent to (i) the student; (ii) the Assistant Registrar (Student Records & Assessments) for inclusion in the student‟s file and in the Assessment Irregularities file; and (iii) the Dean of Studies. No further escalation to a formal Assessment Irregularities Committee should be required. The case should be reported on anonymously in annual assessment irregularities monitoring. Constitution of Assessment Irregularities Committee 76. The purpose of an Assessment Irregularities Committee (AIC) shall be to consider details of any alleged irregularity and the involved student's explanation, with the authority to make a final decision on the matter. It is a more formal mechanism than an Irregularity Investigation Panel, with authority to levy more severe penalties.

77. An Assessment Irregularities Committee shall be established in the following circumstances (either following a Irregularity Investigation Panel, or directly if a need for a formal AIC can be determined at an earlier stage): (i) If the student specifically requests a formal hearing by an Assessment Irregularities Committee. (ii) If the student admits to only part of the allegation or denies part of the allegation. (iii) If the student admits the allegation but contests the penalty proposed at or following the Irregularity Investigation Panel.

(iv) If the student admits the allegation but the responsible Taught Course Director feels it necessary to refer the matter to an Assessment Irregularities Committee. (v) If the Taught Course Director believes the allegations are sufficiently serious to warrant a level of penalty which may only by levied by an Assessment Irregularities Committee. (vi) If the student has previously been involved in an assessment irregularity case at the School for which they were found to have a case to answer and the decision was at the level of a reprimand or above (NB that all repeat cases must be referred to an Assessment Irregularities Committee). 78. The Assessment Irregularities Committee should arrange to meet as soon as possible, and within 15 working days of the need for an AIC being identified (i.e. either following specific student request for a hearing, following the report of the Irregularity Investigation Panel, or after the responsible Taught Course Director has identified that an AIC is required).

79. The Assessment Irregularities Committee shall consist of at least three persons nominated by the Dean of Studies, on the advice of the Assistant Registrar (Student Records & Assessments), from: (i) Chairs of Boards of Examiners. (ii) Deans of Faculty. (iii) Faculty Taught Course Directors. 80. One of the persons appointed will be nominated as Chair by the Dean of Studies. 81. Persons who have already served as a member of an Irregularity Investigation Panel which has considered the case, who have any direct interest in the case or who might be involved in an appeal at a later stage are not permitted to serve on the Assessment Irregularities Committee. 82. The Assistant Registrar (Student Records & Assessments) or his/her nominee shall act as Clerk to the Assessment Irregularities Committee. The proceedings before the Committee and its deliberations shall be recorded, and a full report of these proceedings and deliberations prepared in the event of an appeal being lodged.

83. The quorum for a hearing of the Assessment Irregularities Committee shall be three members. If it is not possible to arrange a quorate meeting within the required timescales, the Chair should request that the

29 of 62 Dean of Studies extend or amend the membership, to enable a quorate meeting to be arranged with alternative members. Notification to the student 84. If the case has progressed directly to an Assessment Irregularities Committee without an Irregularity Investigation Panel having met, the Clerk of the Assessment Irregularities Committee shall contact the student to request that they provide either a verbal or a written explanation of their conduct with respect to the allegations, and any further evidence for consideration. Any verbal explanation may be written up by the Clerk in documentary form. The Clerk may delegate responsibility for such contact to the responsible Taught Course Director where appropriate.

85. The Clerk of the Assessment Irregularities Committee shall arrange for a copy of each document which will be presented to the Assessment Irregularities Committee to be delivered to the student. Such documents shall include any written statement or statements made by the student and the report of the Irregularity Investigation Panel (if this met) or else report from the initial investigations of the responsible Taught Course Director. Along with these documents, notice should be given of the purpose of the meeting and details of the time and place at which it will be held.

86. The documents and notice shall be sent to the student in reasonable time. If the student has previously engaged in email correspondence about the alleged irregularity, the details may be sent via email no later than 5 working days before the date set for the hearing. Otherwise, the details should be posted in hard copy at least 7 working days before the date set for the hearing, to the student's current or last known address. Assessment Irregularities Committee Hearing 87. The proceedings of the Assessment Irregularities Committee shall be held in private, i.e. persons or roles not mentioned in these procedures should not be present.

88. The student shall have the right to be present at all proceedings of the Assessment Irregularities Committee subject to the further provisions (below) for Committee members to consider their findings and agree a decision in private, and to retire for private discussions at any time. 89. Proceedings of the Assessment Irregularities Committee shall not be invalidated through the student being absent from the meeting of the Committee, provided that documents and notice have been sent to the student in reasonable time (as per the conditions above).

90. A friend or representative may accompany the student at the hearing if desired, for instance a fellow- student, course representative, or an Officer of the Student Representative Council. Such an individual should not be a formal legal counsel, and should not speak on the student's behalf. 91. The responsible Faculty Taught Course Director, having been involved in the earlier stages of the case, shall present their evidence to the Assessment Irregularities Committee. The Committee should not ask the TCD to recommend a specific penalty. However, TCDs should normally give contextual information on past precedents, and may give their personal opinion (clearly distinguishing subjective opinions from objective information) on the case and potential penalties to be applied. 92. The Clerk to the Assessment Irregularities Committee shall read to the student the particulars of the allegation. If at this time the student admits to the allegation a statement of fact shall be made; and if agreed by the student and by the responsible Taught Course Director, the Committee shall proceed to consider its finding.

93. Each side, first the responsible Taught Course Director and then the student, may call witnesses who may be examined, or may present documentary material. A witness who is a student of the School may, with the Chair‟s permission, be accompanied by any person while giving evidence. Evidence may be admitted which is relevant and fair. 94. The student shall have the right to examine any documents, reports or written statements which have been used in the case – with the proviso that the Chair may anonymise the identity of persons who have provided evidence (e.g. other students reporting an incident). Such a requirement for anonymity is expected to be rare, and in such cases the Chair must have satisfied themselves as to the credibility of the person and their evidence.

30 of 62 95. The Assessment Irregularities Committee shall have the right to examine any documents, reports or written statements which have been introduced by the student. 96. The student may, with his/her consent, give evidence, and may be questioned by the responsible Taught Course Director and the members of the Assessment Irregularities Committee. 97. At the conclusion of the evidence the responsible Taught Course Director and then the student may address the Committee. 98. The Committee shall consider its findings and decision in private and shall if possible reach its finding and decision without adjournment.

99. The Committee may, at its discretion, at any time during the proceedings order the room to be vacated, or the members of the Committee may themselves retire to another room for private discussions. The student and the responsible Taught Course Director shall not be entitled to be present at such times. 100. For the purpose of the hearing, a decision made by the Assessment Irregularities Committee on any point of procedure will be binding. Any such decision may be the subject of appeal before the Appeals Committee, subject to the grounds detailed in the below section of the procedure about appeals. Decisions of the Assessment Irregularities Committee 101. The decision of the Assessment Irregularities Committee shall be reached by a majority vote of the members of the Committee present at the hearing, but such decision shall be, and shall be announced as, the decision of the Assessment Irregularities Committee.

102. If the votes of the Assessment Irregularities Committee are evenly divided on the question of the appropriate finding or order then its decision shall always be in favour of the less serious finding or order. 103. The votes of individual Assessment Irregularities Committee members shall always be treated as confidential and there shall be no disclosure either of such votes or of information showing whether the decision was reached by a unanimous or majority or evenly divided vote. 104. At the conclusion of the evidence Assessment Irregularities Committee shall determine whether an offence has been committed. The Committee shall give reasons for its decision. 105. Where the Assessment Irregularities Committee finds that particulars of the allegation have been established, then firstly the responsible Taught Course Director, and secondly the involved student or his/her representative, shall have a further opportunity to address the Committee regarding the order to be made.

106. Before reaching any decision on the order, the Assessment Irregularities Committee shall consider any written statements (which may include statements by a personal tutor, Dean of Faculty or medical adviser) submitted to the Committee by the responsible Taught Course Director or by the student who has been found to have committed an offence. Copies shall be provided for both sides. No witnesses may be called at this stage. 107. The Clerk shall provide the Assessment Irregularities Committee with all relevant information relating to the student‟s position in the School and the programme of study for which they are registered, including their stage of progress within the structure of that programme, and other components completed or graded which will affect their final qualification and award classification. 108. When reaching the decision on the order the Assessment Irregularities Committee shall consider all factors determining severity of irregularity, as per the section above on applicable penalties. 109. The Assessment Irregularities Committee will then order a penalty or penalties in line with the scale of outcomes detailed in the section above on applicable penalties. Variations or other appropriate penalties not specifically detailed in these Procedures may be ordered, although giving due consideration to the importance of fairness and consistency with policy and precedent. 110. Findings and orders of the Assessment Irregularities Committee shall be announced by the Chair at the close of the meeting.

31 of 62 111. The Chair of the Assessment Irregularities Committee shall then prepare a report form and report detailing the allegation, the evidence that was considered, and the outcome. This should be passed on to the Registry no later than 3 clear working days from the date of the meeting, for Registry to arrange further dissemination. A copy of this report shall be given to the student by hand, or sent by recorded delivery to the student‟s last known address as soon as possible, and no later than 5 clear working days from the date of the meeting; and also sent to the Dean of Studies and relevant Taught Course Director. The Assistant Registrar (Student Records & Assessments) and the Taught Course Director shall arrange for the relevant penalty or penalties to be applied. Details of the case should be included in the student‟s file and in the Assessment Irregularities file, and reported on anonymously in annual assessment irregularities monitoring.

112. Should the Assessment Irregularities Committee‟s decision be that no irregularity has been committed or that there was a genuine mistake with no intention of committing an irregularity, that decision shall also be communicated to any other persons in the case whether as witnesses or otherwise. Applicability of procedures to Research Degree students 113. In the event of an assessment irregularity allegation concerning an LSHTM Research Degree student taking an assessed module from the suite available to MSc, Diploma or Certificate students, or taking an assessed Short Course, then the above Assessment Irregularities procedure for Taught Course should apply in the first instance – i.e. the allegation should first be put to the Module Organiser or Course Director of the Module or Short Course concerned, who should then inform the relevant Faculty Taught Course Director. The TCD should then investigate the alleged irregularity and initiate an Irregularity Investigation Panel if there is a case to answer.

114. In such cases, the relevant Faculty Research Degrees Director may also be invited to join the Irregularity Investigation Panel. 115. If the student accepts the recommendation of this Panel, that decision may be applied and recorded as indicated under the procedures above, and no recourse to other procedures is required. 116. However if the student does not accept this recommendation, or the decision of the Panel would normally require that an Assessment Irregularities Committee be initiated, then the case moves into the ambit of the Assessment Irregularities procedure for Research Degrees (the equivalent section of which will also require setup of an Assessment Irregularities Committee, though with slightly different membership than for taught courses). This should be followed up by the Assistant Registrar (Student Records & Assessments).

Applicability of procedures to module students or students registered with other institutions 117. In the event of an assessment irregularity allegation concerning a student who is registered only for a specific module or modules rather than an LSHTM qualification, then the above procedures should apply up to the stage of the Irregularity Investigation Panel (i.e. allegation is reported to the relevant Module Organiser then investigated by the relevant Taught Course Director, with the TCD initiating an Irregularity Investigation Panel if there is a case to answer).

118. However, at the stage of making the initial investigation, the TCD should also check with the Registry to determine whether the student is taking the module(s) concerned on a standalone basis, i.e. for their own personal reasons; or has been registered by another institution to undertake assessed work at LSHTM which is to be accredited towards their qualification at the other institution. Examples of the latter case might include students registered on the European Union Masters of Science (Epidemiology) degree, or students registered on particular courses at University College London or the London School of Economics.

119. For students registered on a standalone basis: (i) If the student accepts the recommendation of the Irregularity Investigation Panel, that decision may be applied and recorded as indicated under the procedure above, and no recourse to other procedures is required. Resolution of the matter at this stage is strongly encouraged. (ii) However, if the matter cannot be resolved by an Irregularity Investigation Panel, the case should proceed as per the procedures for LSHTM-registered students. 120. For students registered with other institutions:

32 of 62 (i) If initial investigation by the TCD identifies that there is a case to answer, then an Irregularity Investigation Panel should always be constituted in the first instance. (ii) A member of staff from the student‟s home institution may also be invited to join the Irregularity Investigation Panel. (iii) The report of and recommendation from the Irregularity Investigation Panel (as prepared by the Taught Course Director and passed to the Registry for file purposes), should always be forwarded on by the Registry to the student‟s home institution. (iv) If the student accepts the recommendation of this Panel, that decision may be applied and recorded as indicated under the procedure above, insofar as they affect the grade given to the student by LSHTM. If the Irregularity Investigation Panel recommends a penalty outside the remit of LSHTM to apply to a student registered elsewhere, the student‟s home institution should be informed of this. If the case would have gone to an Assessment Irregularities Committee were the student registered for an LSHTM qualification, then their home institution should be asked to follow up under their own procedures, taking any punitive action against the student themselves (with reference as appropriate to the student‟s file, e.g. for any previous irregularity offences), and reporting back to LSHTM Registry on the final grade to be awarded/recorded for that student‟s work at LSHTM. If the student‟s home institution asks that LSHTM determine the final outcome or penalty, this should be done as per the procedures for LSHTM-registered students, with any additional details (e.g. any previous irregularity offences on the student‟s file) to be supplied by the home institution. If the student‟s home institution makes a request concerning the grade to be given to the student by LSHTM, then this may be implemented if practical and reasonably consistent with LSHTM procedures; but if this conflicts with LSHTM procedures or deviates significantly from the recommendation of the Irregularity Investigation Panel, any decision on the matter should be taken by the responsible LSHTM Exam Board Chair in consultation with the relevant Taught Course Director and the Assistant Registrar (Student Records & Assessments).

Applicability of procedures to LSHTM students taking modules at other institutions 121. In the event of an assessment irregularity allegation concerning a student who is registered for an LSHTM qualification, but in respect of a module they are taking at another institution, then the Registry of the relevant institution should be asked to make a report on the case for consideration by the Taught Course Director responsible for that student at LSHTM. The TCD should follow up to determine whether there is a case for the student to answer under standard LSHTM procedures, further to any procedures or grade reduction–type penalty already applied or being applied by that institution. APPEALS Grounds for Appeal 122. An appeal may be made on the following grounds: (i) That the proceedings of the Hearing of the Assessment Irregularities Committee were not carried out in accordance with these Procedures.

(ii) That there is fresh evidence to be presented, which was not, or could not reasonably have been, made available to the Hearing of the Assessment Irregularities Committee. (iii) That the decision of the Assessment Irregularities Committee was against the weight of the evidence. (iv) That the penalty imposed by the Assessment Irregularities Committee was out of proportion to the offence committed. Notice of Intention to Appeal 123. Notice of intention to appeal must be given in writing to the Clerk to the Assessment Irregularities Committee within 10 working days of the date of notification to the person concerned of the order in respect of which the appeal is made. The notice shall include the grounds for appeal. Where the appeal is on the grounds of fresh evidence, the appellant must submit a summary of the evidence to the Clerk to the Assessment Irregularities Committee with the notice of appeal.

124. The Clerk to the Assessment Irregularities Committee shall prepare a full report of the proceedings of the Assessment Irregularities Committee. The report shall contain a statement of the matters investigated, a summary of the evidence given by each witness, and the reasons for the decisions

33 of 62 reached, both in respect of guilt and in respect of the order made, and shall state the grounds of appeal. Such documents shall include any written statement or statements made by the student. 125. Such a report will be delivered to the Dean of Studies for consideration of whether the grounds for appeal are justified under the procedures. 126. If a request to appeal is rejected, reasons will be given. 127. If the grounds for appeal are accepted, the report of the proceedings of the Assessment Irregularities Committee shall be delivered to the appellant by hand, or sent by recorded delivery to the appellant‟s current or last known address as soon as possible, and at least 7 working days before the date appointed for the meeting of the Appeals Committee.

128. An appellant may prepare a written submission to the Appeals Committee. Such a report shall be submitted to the Clerk to the Appeals Committee at least 7 working days before the date appointed for the meeting of the Appeals Committee. Constitution of Appeals Committee 129. An Appeals Committee shall be convened for the purpose of hearing the appeal as soon as possible, and within 15 working days after the receipt of such notification of intention to appeal. The Assistant Registrar (Student Records & Assessments), or his/her nominee, shall act as Clerk to the Appeals Committee.

130. The appellant shall be notified by the Clerk to the Appeals Committee of the date of the hearing as soon as possible and at least 7 working days before the date appointed for the meeting of the Appeals Committee. Such notification shall be delivered by hand to the appellant, or sent by recorded delivery to the appellant‟s current or last known address. The Clerk may also wish to contact the appellant by email or telephone as a courtesy. 131. The Appeals Committee shall consist of three persons as follows: (i) Chair – The Dean of Studies, or his/her nominee, (ii) A senior member of the Academic Staff, appointed by the Director of the School; and (iii) One student of the School who shall be appointed by the Chair of the Student Representatives Council.

132. Persons who served on the Assessment Irregularities Committee which made the order against which the appeal is made, who have been directly concerned with the matters relating to the order or to the appeal or who have any direct interest in the case, may not serve on the Appeals Committee. 133. The quorum for the Appeals Committee shall be three. Proceedings of the Appeals Committee 134. Sittings of the Appeals Committee shall be held in private. 135. Proceedings of the Appeals Committee shall not be invalidated through the absence of the appellant from the meeting or meetings of the Committee, provided that the appellant has had notice of the purpose of the meeting and details of the time and place at which it will be held sent in reasonable time (as per the conditions above).

136. An appeal shall be by consideration of the documentation previously prepared by the Clerk to the Appeals Committee and seen by the Dean of Studies in determining that there are adequate grounds for appeal. This documentation should be supplied in full to the Appeals Committee, and constitute a full record of the proceedings of the Assessment Irregularities Committee – including a statement of the matters investigated, a summary of the evidence given by each witness, the reasons for the decisions reached (both in respect of guilt and in respect of the order made), the grounds for appeal, and any written statement or statements made by the student. NB that the appeal shall not take the form of a re- hearing of the case.

137. Any specific written submission by the appellant to the Appeals Committee, as submitted at least 7 working days beforehand to the Clerk to the Appeals Committee, should also be considered. An Appeals Committee may also, at its discretion, hear and take into account new evidence called into

34 of 62 account by either side which was not, and which could not reasonably have been made available at the hearing of the Assessment Irregularities Committee 138. The appellant or his/her representative shall then address the Appeals Committee; the responsible Taught Course Director may then address the Committee if they so wish. 139. An Appeals Committee may, at its discretion, at any time during the hearing of an appeal order the room to be vacated or the members may themselves retire to another room for private discussions. Decisions of the Appeals Committee 140. The decision of an Appeals Committee shall be reached by a majority or unanimous vote of the members of the Committee present at the meeting, but in either case shall be announced as the decision of the Committee. The Chair shall have a second or casting vote.

141. The votes of the individual Committee members shall always be treated as confidential and there shall be no disclosure either of such votes or of information showing whether the decision was reached by unanimous or majority vote. 142. The Appeals Committee shall reach its decision, whether to allow or dismiss the appeal, without adjournment (except such temporary adjournment as is involved in the procedure laid down above, i.e. for private discussions). The Committee shall give reasons for its decision. 143. The Appeals Committee shall have power to reverse or modify the decision or penalty appealed against in any way, including cases where the judgement of irregularity has been accepted but the severity of penalty appealed. However, the Committee shall not have power to impose any measure which is more severe that that appealed against, other than the award of costs as provided for in the following paragraph.

144. Where the appeal is dismissed, and the Appeals Committee is satisfied that the appeal was without merit, the Committee shall have power to order, in addition to any penalty, that the appellant should pay a sum to be determined annually by the School by way of contribution to the costs of the appeal. Such contribution shall be recoverable from the appellant as a civil debt due to the School, and the appellant shall be taken to having agreed, by lodging his/her appeal, to meet such contribution if ordered. 145. If an appeal has been allowed, in part or whole, the Appeals Committee may hear further submissions on the question of the appropriate order to be made, but no further witnesses shall be heard at this stage.

146. The Committee may adjourn for a period not exceeding 10 working days for the purpose of deciding the appropriate order to be made upon the appeal. 147. The decisions of the Appeals Committee shall be final. 148. At the conclusion of the appeals hearing the Clerk to the Appeals Committee shall submit a report to the Dean of Studies and the Director of the School, copied to the Taught Course Director. A copy of this report shall be sent by registered post to the student‟s current or last known address, and to the Assistant Registrar (Student Records & Assessments) for inclusion in the student‟s file and in the Assessment Irregularities file. Such a report shall be sent as soon as possible, and no later than 5 clear working days from the date of the Appeals Committee meeting.

149. Should the Appeals Committee‟s decision be that no irregularity has been committed or that there was a genuine mistake with no intention of committing an irregularity, that decision shall also be communicated to any other persons in the case whether as witnesses or otherwise. The Office of the Independent Adjudicator for Higher Education 150. The complete extent of the School‟s procedures for considering Assessment Irregularity matters are as set out above. Attention is, however, drawn to the Office of the Independent Adjudicator for Higher Education (OIAHE). The OIAHE provides an independent scheme for the review of student complaints about a final decision of a University‟s disciplinary or appeal body. Having exhausted the School's internal procedures as detailed above, a student may ask the OIAHE to consider any unresolved complaint against the School, subject to certain criteria. Full details about this are available from the Assistant Registrar (Student Records & Assessments) of the School, or on the website of the OIAHE at www.oiahe.org.uk.

35 of 62 RECORDING AND MONITORING OF ASSESSMENT IRREGULARITIES Data protection responsibilities 151. Information about proven or alleged irregularities constitutes Personal Data under the terms of the Data Protection Act, and all staff involved in cases must take care to ensure safe, secure and appropriate storage and use of this information – including keeping it up-to-date, which would be particularly vital if there is a subsequent appeal. Data relating to a named individual may need to be released to that individual if they make a formal Subject Access Request; however full personally- identifiable information should not be released any more widely.

152. The School will endeavour to limit the disclosure of information as is consistent with conducting an investigation and the provisions of the Human Rights Act 1998, the Data Protection Act 1998, the Freedom of Information Act 2002, and any other relevant legislation. 153. The procedures, guidance and regulations of the School or University in relation to what appears on degree transcripts or Diploma supplements will determine whether or not these should indicate grades or elements of the course for which an assessment irregularity has been found to have occurred. 154. The Registry should act as the main repository of all files in relation to assessment irregularity cases (across all provision, both face-to-face and distance learning). All staff seeking further information in relation to a case should contact the Registry. Master copies of all reports and information should be kept by the Registry in the Assessment Irregularities file (AI file), stored by academic year, and destroyed five years after the end of each year in question, or within five years of a student‟s completing their course. Additional copies may be placed in individual students' files where relevant (as indicated above), and destroyed as and when that student file is destroyed. Since Registry staff will act as Clerks to any Assessment Irregularity or Appeal Committees, master files for those may be maintained as part of the main AI file. Registry will maintain a master list (in database or spreadsheet –type format) of all cases recorded and on file, by academic year – this should serve as a means of reviewing and reporting on past cases.

155. Other staff who may have data storage responsibilities under these procedures include: (i) Taught Course Directors –  Must record details of all assessment irregularity allegations reported to them and where there is found to be a case to answer, writing up a file report and passing on to Registry in due course, as part of the process noted above.  Must pass on any further information or paperwork received as part of the case to Registry, for inclusion in the files for that case.  May maintain personal files with copies of reports they have written or received as part of a case, plus any further information they have received which is not appropriate to be passed on for the Registry file (e.g. the names of individuals reporting the alleged irregularity). Such information should be destroyed on conclusion of the case or at the end of the academic year, whichever is later. (ii) Chairs of Assessment Irregularity Committees –  Must write up a file report and pass on to Registry in due course, as part of the process noted above.  Must pass on any further information or paperwork received as part of the case to Registry, for inclusion in the files for that case.

 May maintain personal files with copies of reports they have written or received as part of a case. Such information should be destroyed on conclusion of the case or at the end of the academic year, whichever is later. (iii) Other involved staff (including the Dean of Studies, the Director, and members of Assessment Irregularity Committees) –  May maintain personal files with copies of reports they have received as part of a case. Such information should be destroyed on conclusion of the case or at the end of the student‟s course of study, whichever is later.

(iv) The University of London International Programmes –  Will maintain their own separate master records in relation to any substantive cases for distance learning students passed over to them for resolution under their procedures. Outcomes from those procedures are expected to be reported back to LSHTM Registry. Reporting and recording of irregularities

36 of 62 156. The key stages at which information about an assessment irregularity case must be recorded are as follows: (i) Irregularity Investigation Panel  For all outcomes, including 'no case to answer', TCD completes form plus report including judgement of IIP and final penalty recommended subsequently.  If student signs (or no response is received further to a request to sign), outcome is treated as agreed and TCD sends form plus report to: (i) the student; (ii) Registry, for inclusion in student's file and AI file; and (iii) the DoS, for awareness.

 If student does not agree (i.e. refuses to sign), case proceeds to AIC and TCD sends form plus report to Registry for inclusion in AIC papers and case notes. (ii) Assessment Irregularities Committee  AIC Chair prepares form plus report detailing allegation, evidence and outcome, then sends this to the Registry.  Registry send copies of the form plus report to: (i) the student; (ii) Registry, for inclusion in student's file and AI file; and (iii) the DoS and TCD, for awareness.  Registry file all further paperwork/evidence connected with the AIC, including minutes of proceedings and deliberations, in AI file only.

(iii) Appeals  Clerk to Appeals Committee (from Registry) prepares report on the outcome; sends report to: (i) the student; (ii) Registry, for inclusion in student's file and AI file; and (iii) the DoS, the Director of the School, and the TCD.  Clerk to Appeals Committee also passes all paperwork/evidence/further submissions connected with the appeal to Registry, for inclusion in AI file only. 157. A standard „Assessment Irregularity Record‟ form should be used for recording case details, which may contain the following information for each individual student involved:  Student name  Student candidate number, where applicable  Course of study (e.g. MSc, Diploma, Certificate)  Module(s) involved, where applicable  Type of assessment (e.g. module assignment, exam, project, professional attachment)  Date(s) suggested irregularity took place (=submission date for assignment work)  Type of irregularity suggested  Date reported to TCD  Brief anonymised summary of case (for reporting more widely)  Action recommended or taken Full details about the case, established through investigation, should be attached with this form. 158. The responsible Taught Course Director should record all appropriate details in the „full details of case‟ section. It will normally be appropriate to indicate staff roles, e.g. “the first marker noticed”, “the invigilator observed”, “the Course Administrator using Turnitin reported”. However, it would not be appropriate to record the name of another student if they have made an allegation (though general non- personally-identifiable details of their credibility may be relevant to note). Monitoring of irregularities 159. Towards the end of each academic year, ahead of final Exam Boards, Registry shall check the Assessment Irregularities file for that year and supply all Taught Course Directors with a list of names of students for whom an assessment irregularity has been suggested. No further details of allegations or cases need be provided; but the list should be cross-checked to identify any students against whom concerns have been raised in more than one Faculty. For any such cases, the Assistant Registrar (Student Records & Assessments) and the TCD for the Faculty to which the student belongs may wish to investigate and take any further action as they deem necessary. Note that such information-sharing may take place face to face, at an unminuted meeting; if a written list of names is supplied, it should be destroyed once checked.

160. Registry shall produce an annual report on assessment irregularities for the Quality & Standards Committee. This should be based on information in the AI file for the complete preceding academic year (including allegations for which there was found to be no case to answer). Information should include a summary of the number of cases reported, with breakdowns according to Course/Faculty, type of assessment, and outcome/penalty invoked; plus trend data to compare against previous years where

37 of 62 possible. A full set of anonymised details from all cases should also be provided: detailing Faculty, Course of study, Module(s) involved (where applicable), type of assessment, type of irregularity suggested, summary of case, and action taken. QSC is expected to scrutinise this data annually, to monitor the level and type of irregularities being identified, and identify any differences between courses or Faculties (including in the severity of the penalties applied). 161. The Dean of Studies or Chair of QSC may also request that a similar summary of assessment irregularities be produced ad-hoc during the course of an academic year if problems are felt to be emerging.

Flowchart summary of process - glossary 162. A flowchart summary of the above process is given on the following pages. Acronyms used are:  CD = Course Director  MO = Module Organiser  TCD = Taught Course Director  DoS = Dean of Studies  IIP = Irregularity Investigation Panel  AIC = Assessment Irregularities Committee Procedures approved by the Associate Dean of Studies. Last updated 22 February 2013.

38 of 62 FLOWCHART OF ASSESSMENT IRREGULARITIES PROCEDURE  TCD decides there is a case  Contacts student to invite them to respond to an Irregularity Investigation Panel  Notifies DoS that case has been initiated  TCD decides there is no case  NO FURTHER ACTION  Consider whether a formal Assessment Irregularities Committee is required (e.g. if specifically requested by student, if a repeat offence, if warranted by severity of allegation)  Member of staff suspects an irregularity  Reports it to relevant CD, MO or other member of staff responsible for that assessment task  CD/MO informs TCD  TCD makes initial investigation of the allegation INITIATION OF PROCEEDINGS IRREGULARITY INVESTIGATION PANEL  IIP decides there is no case or no further action to be taken  TCD records allegation/case details on file for monitoring purposes  TCD reports outcome back to student, and both Registry and DoS for monitoring purposes  CASE RESOLVED WITHOUT PENALTY  IIP decides there has been an irregularity  Student offered decision based on the IIP  Student indicates willingness to accept IIP outcome  TCD takes further advice, then reaches final decision & writes up report statement  Student signs report statement and agrees to penalty  TCD reports outcome back to student, and both Registry and DoS for monitoring purposes  CASE RESOLVED, PENALTY APPLIES Student rejects IIP outcome, or will not accept decision/penalty, or recommended penalty requires an AIC  TCD convenes IIP with CD/MO  Student can either attend in person or provide input through other channels  IIP agrees what has happened, how severe it is, and a provisional penalty A.I.C.

10 working days 5 working days 10 working days

39 of 62  AIC decides there is no case or no further action to be taken  TCD reports outcome back to student, and both Registry and DoS for monitoring purposes  CASE RESOLVED WITHOUT PENALTY  This outcome is communicated to other involved parties  AIC decides there has been an irregularity  Opportunity for last statements and information to be seen by AIC before penalty is decided  AIC decides penalty  Chair reports outcome back to student, and both Registry and DoS for monitoring purposes  CASE RESOLVED, PENALTY APPLIES FROM FULL RANGE OPEN TO A.I.C.

 TCD convenes Assessment Irregularities Committee (AIC)  Clerk to AIC sends notification and relevant documentation out to student and AIC members  Hearing takes place, which may include discussion, cross-examination and witnesses  Student may admit to allegation during these proceedings ASSESSMENT IRREGULARITIES COMMITTEE APPEALS  Notice of Intention to Appeal made to Clerk of AIC  Appeal considered by Dean of Studies  Appeal denied  Student is notified of decision  NO FURTHER ACTION  Appeal allowed  Dean of Studies convenes Appeals Committee  Clerk to Committee sends notification and relevant documentation out to student and members Appeals Committee sits and considers documentation (appellant and TCD may address Committee if desired)  Original decision upheld  Student is notified of decision  NO FURTHER ACTION  Original decision modified or reversed  Chair reports outcome back to student, and both Registry and DoS for monitoring purposes  CASE RESOLVED, PENALTY MODIFIED OR OVERTURNED AS APPROPRIATE  If final outcome overturns case or indicates no penalty should be applied, communicate to other involved parties 15 working days 10 working days 15 working days Glossary: CD = Course Director MO = Module Organiser TCD = Taught Course Director DoS = Dean of Studies IIP = Irregularity Investigation Panel AIC = Assessment Irregularities Committee

40 of 62 Annex 5: Formal Assessment Irregularities procedure for research degrees ASSESSMENT IRREGULARITIES PROCEDURE FOR RESEARCH DEGREES OVERARCHING CONTEXT Scope 1. These procedures are made under the auspices of the LSHTM Regulations for the Degrees of MPhil, PhD and DrPH. They apply in respect of any alleged assessment irregularities, plagiarism or cheating connected with LSHTM research degree students – including PhD Upgrading, DrPH Review, assessments under the remit of the DrPH Board of Examiners, the thesis and oral examination, or any other assessments which may be taken other than for non-DrPH taught courses. 2. Note that a separate Assessment Irregularity procedure exists for LSHTM taught courses, and any alleged irregularities by research degree students taking assessed modules or short courses may first be investigated under those procedures – see specific section below on “Applicability of procedures”. 3. For any LSHTM research degree students undertaking work at other institutions which is to be accredited towards their qualification, the relevant Faculty Research Degrees Director should follow up on any allegations reported – see specific section below on “Applicability of procedures”. 4. Any dispute as to the interpretation of these procedures shall be referred to the Associate Dean of Studies.

Principles 5. These procedures are intended to be fair, consistent, transparent, accessible, and avoid undue additional administrative burden for staff and students; whilst forming part of a framework which promotes good academic practice across all forms of teaching, learning and assessment. o In line with the School‟s equal opportunities policy and code of practice on dignity at work and in study, these procedures should treat students no differently based on any matter related to their age, race or ethnicity, religion or belief, gender or sexual orientation, or any disability. Application 6. All allegations or suggestions of plagiarism and assessment irregularities will be investigated by the School, with appropriate penalties issued to students (or details referred to the appropriate bodies) where it is found that there is a case to answer.

7. In any proceedings under these procedures, the student shall be presumed to be innocent until the contrary is established on the balance of probabilities. Staff responsibilities 8. Staff who should be aware of their responsibilities under these procedures are: all staff involved in assessing research degree students, especially Supervisors, Chairs of PhD Upgrading or DrPH Review panels, Department Research Degrees Co-ordinators, Faculty Research Degrees Directors, the Dean and Associate Dean of Studies, and the Assistant Registrar (Student Records & Assessments). 9. In the case of the temporary absence or incapacity of any officer or other official named in these procedures, responsibility devolves to the person appointed as his/her deputy. If no deputy has been appointed, the Dean of Studies (or the Director, relevant Dean of Faculty, or relevant Research Degrees Director, as responsible for line management of the absent staff member) will appoint a deputy. 10. The Dean of Studies may delegate any of the duties assigned to him/her under these procedures to another member of the School's Senior Management Team or to the Associate Dean of Studies. Updates to these procedures 11. The Associate Dean of Studies (as Chair of the Quality & Standards Committee) will be responsible for approving any updates to these procedures. Any substantive updates should first be discussed at a relevant School committee, e.g. Quality & Standards Committee (for assuring rigour, good practice and consistency with taught courses procedures) or Research Degrees Committee (for matters specific to research degrees study). Any very substantive changes should be put forward to the Senate.

41 of 62 12. Changes to procedures should normally be agreed for implementation from the start of the next academic session, ensuring that all relevant documentation is updated before being made available to the new intake of students. Before approving any changes, consideration should be given to how they will affect continuing students. At the discretion of the Associate Dean of Studies, updates to the procedures may be made effective during the course of an academic year; however such changes should not normally be substantive.

Definitions 13. Plagiarism is the copying or use of the work of others, whether intentionally or unintentionally, as if it were your own. Such work may come from any source whether published or unpublished, in print or online – including words, images, audio recordings, diagrams, formulae, computer code, performances, ideas, judgements, discoveries and results. To avoid plagiarism:  Where any use or mention is made of the work of others, it should be acknowledged.  A recognised citation system should be used.

 Quotations must accurately refer to and acknowledge the originator(s) of the work.  Direct quotations, whether extended or short, must always be clearly identified.  Paraphrasing – using other words to express the ideas or judgements of others – must be clearly acknowledged.  Work done in collaboration with others must appropriately refer to their involvement and input.  Use of your own past work should be referenced as clearly as the work of others 14. Cheating is a deliberate attempt to deceive in order to gain advantage in an assessed piece of work, including coursework, in-module assessments and examinations. This covers a range of offences, from significant instances of plagiarism to exam misconduct.

15. Fraud is the submission of any work which may cause others to regard as true that which is not true. This covers work which has been fabricated (e.g. with invented data or cases), falsified (e.g. with wilfully distorted data), omits significant items (e.g. ignoring outliers, not admitting that some data are missing, not admitting other relevant post-hoc analyses, omitting data on side effects in a clinical trial, non- disclosure of a conflict of interest, etc.), or in any way misrepresents the work or research carried out. Fraud may be by intention, by disregard of possible consequences (e.g. in failing to adequately describe the input of others), or by negligence (e.g. submission of work based on distorted data due to poor data handling practice). Assessment or research fraud may cross over with a range of other offences, from plagiarism (e.g. unattributed copying of the research data of others) to cheating, collusion or personation. 16. Collusion is any form of collaboration with another person, including another student, which has not been clearly acknowledged or permitted for assessment purposes (either when being submitted, or during the course of an examination). Different forms of collusion may be regarded as either plagiarism or cheating. 17. Personation is the deliberate submission of work done by another person (e.g. another student, a friend, a relative, a peer, a tutor, or anyone else) as if it were the student‟s own. Another person‟s work may cover any source whether published or unpublished, including words, images, audio recordings, diagrams, formulae, computer codes, ideas, judgements, discoveries and results. This may cross over with a range of other offences; submission of another person‟s work with their knowledge is likely to constitute collusion; doing so without their knowledge may constitute plagiarism; representing a piece of joint or group work as the student‟s own is likely to constitute fraud; and deliberately procuring work from sources or commercial entities such as essay banks would be very likely considered cheating. Arranging for another person to falsely identify themselves as the student and take an exam on their behalf would be seen as a particularly severe form of personation and cheating.

18. The term „assessment irregularity‟ applies to any suspected instance of plagiarism, cheating, fraud, collusion, personation or other non-standard activity identified in connection with an assessment (including essays or other coursework assessments written in a student‟s own time) or formal examination. The term „irregularity‟ does not necessarily imply misconduct on the part of a student; judgement as to whether a specific offence has occurred should only be made following proper investigation of the case under these procedures.

19. Further to the above definitions, conduct in examination rooms or halls – that is, any test taken under formal assessment conditions – may also be subject to specific restrictions. More detailed guidance on this is given in the assessment irregularity procedures for taught courses, and this guidance may also apply where specific tests are set for research degree students, to be taken under formal assessment conditions. For the most part those restrictions will not apply to research degree components such as

42 of 62 PhD upgrading, DrPH review or oral examination of the thesis. However it should be specifically noted that conduct which is not permitted in the latter cases and will constitute an examination offence includes offering an inducement of any kind to an examiner or other person connected with the assessment, or any conduct of which the result would be an advantage for the student obtained by subterfuge or action contrary to published rules or guidance. Any offences or misconduct by research degree students under exam conditions may be followed up under these procedures, and will be treated extremely seriously. 20. Students are each individually responsible for safeguarding their own work (e.g. assignments, essays, projects, reports, dissertations, theses and other similar work) to prevent such work from being copied inappropriately by other students or persons.

Referencing, good practice and sources 21. In addition to the definitions of various types of assessment irregularity given above, the School provides student-focused written guidance on referencing, citation and the acknowledgement of sources – with summary information in the research degrees handbook, and more detailed guidance in the „Academic Writing handbook‟ which is applicable School-wide. 22. Students are each individually responsible for learning the correct forms of referencing, citation and the acknowledgement of sources, and avoiding any assessment irregularities in the work they undertake. 23. Supervisors and other relevant staff should endeavour to ensure that prior to undertaking assessment, students have been made aware of guidance about good practice, and how to avoid assessment irregularities and their potential consequences. Staff are strongly encouraged to place such guidance in context within the conventions of the subject, field or discipline relevant to the particular assessment, i.e. to illustrate how good practice should apply for the task at hand.

24. It should be noted that poor or inappropriate use of referencing is liable to be investigated under these procedures, and students may be asked as a result to improve their understanding of School guidance. Poorly or inappropriately referenced work may also attract a lower mark. This is likewise the case for excessive use of referencing, which while it may not constitute an assessment irregularity may attract a lower mark – e.g. a piece of work consisting almost entirely of referenced quotations is liable to fail if it demonstrates a lack of original argument or analysis, or understanding and engagement with the topic. 25. In the event that a student unwittingly uses a secondary source which itself turns out to be plagiarised, misattributed or incorrectly referenced, the case may be investigated (retrospectively identifying the errors) but the student should not normally be penalised provided they have followed correct practice and fully referenced their use of the erroneous source or sources. However, while students are not expected to comprehensively check all secondary sources, use or overuse of potentially poor-quality sources (such as wiki-based internet sites) may attract a lower mark and be liable to be penalised. 26. Students should take care in re-using their own previous work. Presenting work for assessment which was originally completed for other purposes, whether at LSHTM or elsewhere, may be treated as self- plagiarism (or even cheating) under these procedures, unless this work is properly identified or unless instructed otherwise, e.g. if students have been asked to resubmit the work. Students who have previously submitted an original piece of work for assessment at LSHTM or for any other University of London award may not re-submit it, in whole or in part, for consideration towards an LSHTM qualification – i.e. credit can only be given once for a particular piece of assessed work. It may be possible to build on work done previously, e.g. to take a topic initiated in a module assignment and develop it fully as part of a project report (personal tutors or involved academic staff should be able to advise on what is acceptable); but in such cases students should identify and reference their own previous work as carefully as any other source.

27. In assessments taken under exam conditions, candidates are not necessarily expected to give detailed references. However, care must still be taken to avoid plagiarism and ensure that the work of other people is not presented as if it were the candidate‟s own. Any memorised quotations must be duly acknowledged, and quotations presented without attribution or as if they were the candidate‟s own work may be treated as plagiarism. Examination submissions should preferably be expressed in the student‟s own words, appropriately indicating the work of others, but incorporating the student‟s own ideas and judgements.

Definition of time limits

43 of 62 28. For the purpose of the regulations set out in this procedure, a “working day” is defined as a weekday during which the School is not closed through School closures, Bank Holidays, Director‟s Days or other days in which staff are not expected to work. APPLICABLE PENALTIES Factors determining severity of irregularity 29. Any decisions made concerning assessment irregularities should take all relevant factors into account before determining a penalty. These may include: (i) The extent of any academic misconduct or poor practice. (ii) The motivation and intention of the student in respect of the irregularity. (iii) The effect of the intended penalty on the student's progression or overall award. (iv) The relation of the examination(s) in question to the structure of the award for which the student is a candidate.

(v) The effect that the cancellation of the paper(s) or test(s) would have on the student (e.g. whether they could re-enter that paper alone, or if they are required to pass all the papers on the same occasion). (vi) The arrangements for re-entry to the examination(s) or assessment(s) in question. (vii) The comparable position of a student who had simply failed the paper(s) or test(s) in question. (viii) Whether the student had been found guilty of a previous assessment irregularity at the School (In order to check this, the responsible Research Degrees Director will need to check with Registry whether any previous offences are recorded on the student‟s file). (ix) The stage the student is at in their programme of study, and their prior academic experience as may be relevant to the standards expected in UK Higher Education (including where their previous education was undertaken, and whether their prior qualifications include undergraduate, postgraduate or doctoral degrees).

(x) Where students have a disability or medical condition, the School may make reasonable adjustments to the assessment to ensure fair and equal treatment. Such students are strongly encouraged to disclose their situation and speak to the Registry well in advance regarding any special arrangements that may be appropriate for their assessment. Adjustments cannot be made retrospectively. If a student‟s disability or medical condition appears to have a bearing on an assessment irregularity, this may potentially mitigate the severity of the irregularity but should not result in de facto differential treatment.

Scale of penalties 30. Penalties for assessment irregularities should be determined on a sliding scale that takes account of the severity of the offence, and should be applied in a consistent way across the School. Penalties may cover any combination of the following: (i) That no further action is taken. (ii) That the student is reprimanded (either verbally or in writing) by the responsible Research Degrees Director and reminded of the need to strictly observe assessment requirements, with a note to this effect added to their student file.

(iii) That in addition to other penalties, the student be required to attend a nominated course or training session on good referencing practice and avoiding plagiarism. (iv) That where the offence is one of identified plagiarism, the plagiarised section of the work is ignored, removed or revised for re-submission and the remaining portion of the work marked in accordance with normal course regulations. (v) That where the offence is one of identified fraud, the fraudulent section of the work is ignored, removed or revised for re-submission and the remaining portion of the work marked in accordance with normal course regulations; with the penalty to specify any further restriction on potential future publication (or requirements for revision prior to such publication) if the work is to be in any way associated with LSHTM.

(vi) That (for graded work) the result for the piece of work be reduced by one or more gradepoints, which may include being marked down to the minimum pass mark or below, including to grade 0

44 of 62 (zero). Where this penalty is a reduction to a fail grade, the student may be permitted to re-sit under standard re-sit procedures (i.e. if the irregularity has been on a first attempt, it will normally be possible to re-sit); but the penalty may specify any maximum pass grade achievable in re- sitting. (vii) That no publication of the plagiarised or fraudulent material obtained as a result of the transgression be allowed. (viii) That for irregularities identified in formative or draft work prior to formal submission, the candidate be reprimanded either verbally or in writing, and required to revise the work before submission to the assessors. At the discretion of the responsible Research Degrees Director, the assessors may also be informed that an irregularity had been identified in previous draft work and given relevant documentation pertaining to it.

(ix) That the candidate be permitted to continue in their studies or proceed to examination, subject to corrections/revisions being specified and subsequently approved by appropriate assessors (e.g. PhD Upgrading Panel, DrPH Review Panel, thesis/viva Examiners) who shall be informed that an irregularity has been identified and given relevant documentation pertaining to it. The assessors may determine how corrections/revisions are to be approved, e.g. delegating responsibility to a nominee, scrutinising the revised document and giving approval by email, or through a second examination of the student.

(x) That for irregularities identified in formally submitted work where a serious offence of plagiarism or another type of irregularity is identified, the work be judged inadequate for the assessment requirements and withdrawn from consideration. This should count as one attempt at submission; any further revisions and re-submissions may only be permitted in line with standard examination and re-sit regulations. [This penalty may only be given by an Assessment Irregularities Committee] (xi) That in order to continue their studies, the candidate be required to commence a new project with none of the previous studies taken into account or recognised. [This penalty may only be given by an Assessment Irregularities Committee] (xii) That the student not be permitted to re-enter for any or all of these assessments or examinations before the expiry of a stated period of time. [This penalty may only be given by an Assessment Irregularities Committee] (xiii) That the student be permitted to re-enter for those assessments or examinations on the next normal occasion, but that no degree, diploma or certificate be awarded to the student before the expiry of a stated period of time. [This penalty may only be given by an Assessment Irregularities Committee] (xiv) That the student be excluded from future assessments or examinations for awards of the School. [This penalty may only be given by an Assessment Irregularities Committee] (xv) That the student be excluded from the award for which they have been entered/registered. [This penalty may only be given by an Assessment Irregularities Committee] (xvi) That withdrawal proceedings be initiated against the student with immediate effect. [This penalty may only be given by an Assessment Irregularities Committee] (xvii) That a recommendation be made to the Senate for the student's award to be revoked. [This penalty may only be recommended to the Senate by an Assessment Irregularities Committee] 31. The most significant penalties, which have ramifications beyond the marking of an individual piece of work, may only be formally levied by an Assessment Irregularities Committee or the Senate (as indicated above). Discussions at earlier stages of investigation, including at Irregularity Investigation Panels, may recommend such penalties as being appropriate; but an Assessment Irregularities Committee will always need to be convened to determine this formally 32. The School reserves the right to inform appropriate bodies (e.g. the General Medical Council) in any upheld cases of academic misconduct, especially any cases of fraud.

PROCEDURES Initiation of proceedings 33. Cases of suspected assessment irregularity should be reported in the first instance to the Department Research Degrees Co-ordinator of the Department to which the student belongs.

45 of 62 34. The relevant Department Research Degrees Co-ordinator should then inform the Faculty Research Degrees Director (FRDD) with responsibility for the assessment in question (normally, the FRDD for the Faculty to which the student belongs), for the FRDD to make an initial investigation of the alleged irregularity and establish whether there is a case to answer. 35. Where an irregularity is alleged, no assessment result should be confirmed for the piece of work in question until a verdict is reached on the allegation. Where the work involved comes under the responsibility of a Board of Examiners, in the rare event that a case is not resolved ahead of the final Board of Examiners meeting at which the involved student's results would have been considered then both the student and the relevant Exam Board Chair should be informed and, if unavoidable, consideration of these results may need to be deferred to a subsequent or special meeting of the relevant Board of Examiners. In the event that a case is not resolved before the work is due to be considered by appointed Examiners for the award of a research degree (i.e. following thesis submission and oral examination), then their decision will need to be deferred pending confirmation of the outcome of the case.

36. Where an irregularity is alleged for an assessment task which will form the basis for a separate subsequent assessment (e.g. a module assignment which will be further developed in a later advanced module, or a submitted thesis which will be subsequently examined at a viva), then initiation of the subsequent assessment should be postponed, or submission/examination/marking of the subsequent assessment should be deferred, until such a time as a verdict has been reached on the assessment task for which an irregularity has been alleged.

37. There is no statute of limitations on when an assessment irregularity allegation may be made. However, all staff who are aware of any potential issues are obliged to report them as they arise or within a reasonable time; failure to do so may be grounds for any future case to be dismissed. In the rare event that a case is brought subsequent to the final Board of Examiners having met or the student having been awarded a degree, these procedures will still apply. Such a situation may require that Examiners reconsider their previous decision, and that the Senate amend or rescind grades or awards previously made.

Initial investigations 38. All investigations shall be carried out as soon as possible. After being notified about the alleged irregularity, the responsible Research Degrees Director should endeavour to complete their initial investigation within no more than 10 working days. 39. As part of their investigation, the Research Degrees Director should ask the Registry to check the Assessment Irregularities file to confirm whether any prior allegations have been made or cases taken forward regarding the student in question; and if so to provide details. 40. If the nature of the alleged irregularity is such that some form of disability may have had a bearing on it, the Research Degrees Director should check with the Student Adviser as to whether the student has declared a disability and given permission for staff to be informed about this. However the Student Adviser will not be in a position to inform the FRDD if a disability has been declared but permission to inform other staff withheld.

41. Having made an initial investigation of an allegation, if the responsible Research Degrees Director determines that there is no case to answer they need not record a report on the allegation. 42. There may be circumstances where, upon investigation, the responsible Research Degrees Director decides there is no case to answer but the student has demonstrated poor practice (e.g. in referencing or citing). In this case the Research Degrees Director may wish to informally contact the student to remind them of best practice and the need to strictly observe assessment requirements. 43. Where initial investigation by the responsible Research Degrees Director indicates that there is a case to answer, they should next determine whether there is any need for the case to progress directly to an Assessment Irregularities Committee (AIC – see specific criteria in later section). If not, it will be appropriate to progress to a Irregularity Investigation Panel.

44. Where initial investigation indicates that there is a case to answer regarding submissions for either Upgrading/Review or the Thesis Examination (specifically):

46 of 62  The Research Degrees Director should further determine whether it is possible to schedule an IIP or AIC meeting to consider the matter prior to the Upgrading/Review or Thesis Examination meeting taking place.  If it is not feasible to schedule an IIP or AIC in the intervening period, and the allegation appears serious enough to require formal resolution before the work can be meaningfully assessed, then the Research Degrees Director should ensure that the Upgrading/Review or Thesis Examination meeting is deferred until an appropriate point after an IIP or AIC can be scheduled.  In cases where an IIP is required in relation to Upgrading/Review work, but it is not feasible or felt helpful to schedule this beforehand, then the IIP may take place as an embedded part of the Upgrading/Review meeting. The Research Degrees Director should advise the Chair of the Upgrading/Review Panel and the relevant Department Research Degrees Co-ordinator of the details of the case beforehand.

 For alleged irregularities in Thesis work, if an IIP or AIC is required then this must always take place before the Thesis Examination and thus may require deferral or cancellation of the originally- scheduled Examination. However, the Thesis Examiners have discretion to address and discuss any issues of poor academic practice (e.g. problems with referencing) as part of the Examination, and may recommend related amendments, provided that these issues are not so serious as to constitute assessment irregularities requiring an IIP or AIC. If issues potentially requiring an IIP or AIC are not identified until the Thesis Examination is in progress, the Examiners must defer their decision until the matter can be reviewed by the Research Degrees Director, and if necessary an IIP or AIC held. 45. Where an IIP or AIC is required, the Research Degrees Director should normally contact the student: (i) describing the alleged irregularity (in writing, phrased according to established precedents); (ii) enclosing a copy of these Procedures; and (iii) requesting the student to explain their conduct or give any other evidence to the relevant Panel or Committee. It should be made clear that the explanation and evidence from the student may be given either in person at a meeting (the preferable option – though the Panel or Committee would be meeting anyway to discuss the case) or in writing (though there should be no requirement at this stage to give a written statement). The student should also be encouraged to disclose any disability or medical condition to the Panel that may have a bearing on the alleged irregularity.

46. Where it is intended that an IIP take place as an embedded part of an Upgrading/Review meeting, the Research Degrees Director may exercise discretion as to whether or not the student should be advised of the allegation in advance of the meeting. Where doing so may cause undue distress, it may be preferable to wait and raise the matter with the student on the day. 47. If an initial investigation indicates that there is a case to answer arising from a previous assessment, but the student is at a crucial juncture in their overall course of study, then the Research Degrees Director may at their discretion put the case on hold and not contact the student or progress the case further until this immediate juncture has passed – so as to avoid affecting the student‟s performance in other assessments. However this may not be appropriate in every case, and decisions may be informed by the type and apparent severity of the irregularity being investigated.

Contact with students, and timescales for procedures 48. Staff with responsibilities under these procedures should make reasonable efforts to contact involved students: normally via email in the first instance; secondly checking with other staff who may know when or how best to contact the student, including via telephone; and if all other methods of contact have failed, delivering notification in writing by hand or by recorded delivery to the student at his/her last known address. Involved staff should keep a record of the date and general content of all attempted communications with students. If relevant staff fail to meet their responsibilities regarding timely and appropriate contact with students, this may constitute grounds for a subsequent appeal. 49. Research Degree students will be expected to check their School email accounts regularly throughout the year. Research Degree students on research study leave will be expected to have given their supervisors notification of when and how they will be contactable. Students whose course has finished should be contacted using their file details – initially via the primary email address held on file for them, then via telephone and/or post as appropriate.

50. Students are required to respond promptly on receipt of any and all communications about possible assessment irregularities, and to comply with all indicated timescales. Where their circumstances may prevent them from meeting obligations under these procedures, students should notify the relevant staff as soon as possible. In such cases, staff should attempt to make alternative arrangements if reasonable

47 of 62 (e.g. to set a slightly later meeting date), and may work outside the deadlines indicated elsewhere in these procedures. 51. Involved students or staff may request extension of any timescales or deadlines given in the procedure; such extensions may be granted at the discretion of the relevant Research Degrees Director, the Assessment Irregularities Committee Chair if one has been convened, or the Appellate Committee Chair if one has been convened. 52. Students who are normally based away from London are not necessarily expected to be able to attend meetings in London. In these cases, input may be given in written form, usually via email; or alternative participation arrangements such as teleconferencing or videoconferencing may be made at the discretion of the responsible Research Degrees Director.

53. In the event that a student has indicated their intention to attend or participate in a meeting, but then cannot do so for good reason, an adjournment should normally be considered. 54. Where reasonable efforts have been made to contact a student in respect of an alleged assessment irregularity, but no response has been received, proceedings may be taken, a verdict reached and a penalty applied in their absence. Meeting of the Irregularity Investigation Panel 55. As indicated above, initiation of proceedings by the responsible Research Degrees Director will normally result in an invitation for the student to meet with a Irregularity Investigation Panel – to discuss the allegations, or else respond with a written explanation of their conduct or any other evidence for consideration. The purpose of this Panel shall be to consider details of the alleged irregularity and the involved student's response, with the authority to make a final recommendation on the matter if the student is prepared to accept this.

56. If the student does not wish the case to be considered through an Irregularity Investigation Panel then it should progress directly to an Assessment Irregularities Committee. 57. The Irregularity Investigation Panel shall be constituted of: the responsible Research Degrees Director (Chair); AND the most appropriate other member of staff with responsibility for the assessment being considered – e.g. the Chair of the Upgrading or Review Committee (if the work relates to Upgrading or Review, the DrPH Course Director (if the work relates to the DrPH taught component or professional attachment), or the Department Research Degrees Co-ordinator (for most other issues, especially in relation to the thesis). Deputies may be nominated and further Panel members may also be nominated by the responsible Research Degrees Director or the Dean of Studies. The Dean of Studies may decide the membership of the Panel should any queries arise. The quorum for any meeting or decision of the Panel shall be two members.

58. Where an IIP is to be held as an embedded part of an Upgrading/Review meeting, the Department Research Degrees Co-ordinator (who would normally be in attendance for Upgrading/Review) should chair the IIP element, acting on behalf of the Faculty Research Degrees Director. The other members of the Upgrading/Review Panel should also serve as members of the embedded Irregularity Investigation Panel. 59. The Panel shall meet as soon as possible, normally within 10 working days from the student being sent notification that there is a case to answer. In exceptional circumstances (e.g. if the student is overseas) this may not be feasible, and the responsible Research Degrees Director may set dates as appropriate. If the involved student is unable or does not wish to attend in person, the Panel may reach a decision without a formal meeting (e.g. by email contact) at the discretion of the FRDD. 60. The involved student may choose to either meet with the Panel and present a further statement in mitigation or explanation of the matter being discussed; or choose not to meet with them, having provided relevant information for consideration.

61. The meeting is not a hearing and may be kept relatively informal. A friend or representative may accompany the student at the meeting if desired, for instance a fellow-student, course representative, or an Officer of the Student Representative Council. This is a courtesy; such an individual should not be a formal legal counsel, and should not actively participate in the Panel meeting.

48 of 62 62. The Panel may, at its discretion, have private discussions – requesting that the student and any other attendees vacate the room, or themselves retiring to another room. This will be particularly relevant before mentioning any provisional penalty to the student. 63. The Panel should normally retire for private discussion before deciding any provisional penalty (i.e. before this is mentioned to the student). 64. Discussion at the meeting should aim for consensus between the Panel members and the involved student as to what has occurred, whether it constitutes an assessment irregularity, how severe it is, and what penalty is likely to be most appropriate. The potential impact of this penalty on the student's final award should also be made clear. In the event that the student is absent, or is present but cannot reach agreement with the Panel members, then the Panel must reach their own clear decision on the case, and should aim to do so without adjourning to a later date.

65. For cases where an IIP is to be held as an embedded part of an Upgrading/Review meeting:  The main meeting should go ahead broadly as normal, focusing on the academic/scientific content of the work.  Consideration of the element(s) for which an irregularity has been alleged (and any related discussion of writing, referencing and use of sources) should if possible be deferred to later in the meeting. The allegation should then be broached in a way that does not pre-judge the matter, but with the student should be asked to explain their conduct or give any other evidence about the alleged irregularity. It should be made clear that the Panel has authority to act as an IIP and make a decision on this matter which may affect the Upgrading/Review outcome.

 As is normal for an IIP, the Panel should retire for private discussion before deciding any provisional penalty, as well as the Upgrading/Review outcome. They should then return to discuss these outcomes with the student (treatment of IIP outcomes is outlined in the next section).  If on the recommendation of the relevant Research Degrees Director the student had not been advised of the allegation prior to the meeting, they should be offered additional time of up to 10 days to provide a more considered response or any further evidence. However they may also be advised that it is preferable to resolve such matters through discussion there and then, if possible. If a follow- up meeting or decision will be required (i.e. to allow for further input from the student, or other additional consideration of evidence) this should be announced and a date set. No outcome should be decided for either the alleged irregularity or the assessment overall until that time. Follow-up meetings may be conducted or decisions arrived at virtually, e.g. by email or telephone. Outcome of the Irregularity Investigation Panel 66. At the end of the Panel meeting, if the student is present (or via subsequent contact if they are not present), the Research Degrees Director should offer the student the option of accepting the Panel's decision on their part in the irregularity, and have the FRDD make a subsequent decision on the penalty to be applied. Students should reasonably expect that this subsequent (final) penalty will be in line with what has been discussed with the Panel. However, if the student does not accept this option, or if other factors require it (as detailed below, including any cases where the student has previously been found to have committed an assessment offence), then the case will be escalated to a formal Assessment Irregularities Committee (AIC) – in which case the Research Degrees Director should write up a report on the Panel‟s discussions, and forward this to the Assistant Registrar (Student Records & Assessments) to initiate the AIC.

67. Where an IIP has been held as an embedded part of an Upgrading/Review meeting, decisions may be made about both the alleged irregularity and the assessment overall. This may include requirements for revision and re-submission of work, in which case appropriate deadlines should be given and responsibilities assigned for approving the revised or re-submitted work. 68. If the student indicates their willingness to accept a decision about an irregularity as described above, the responsible Research Degrees Director should then take any advice required to reach a final decision on the case and the penalty to be applied. Such advice may include consultation with the Dean of Studies or Assistant Registrar (Student Records & Assessments) to determine that the penalty is appropriate and in line with past precedents and current practice across the School. This final penalty should usually be as provisionally recommended by the Irregularity Investigation Panel. 69. Having taken such advice, the Research Degrees Director should prepare a brief report detailing the allegation, the evidence considered, and the outcome. This should be done as soon as possible, and within 5 working days from the date of the Irregularity Investigation Panel meeting. The report should

49 of 62 include a standard statement for the student to sign against, to say "I agree with this statement of facts concerning my work as indicated above, and agree to the penalty or penalties indicated". 70. Where the evidence about a case suggests that it fits with standard precedents, it may not be necessary for the Research Degrees Director to seek further advice before reaching a final decision, and they may choose to prepare such a report in advance of the Irregularity Investigation Panel. This would allow the student to sign the report at the end of the meeting, if they agree and provided no conflicting evidence has come to light.

71. If the student has given their consent in absentia to the verdict and penalties proposed by the Panel, or is otherwise unable to sign in hard copy, then relevant evidence that they have given their consent to the recommended penalty (e.g. e-mail or a signed statement from a staff member regarding a phone conversation with the student) should be included with the file copy of the Assessment Irregularity Record Form, in lieu of a hard copy student signature. 72. If no response has been received from the student within 15 working days of their being contacted regarding the Panel‟s decision and proposed penalty, proceedings should be completed without the student‟s input, the Research Degrees Director determining the final penalty and this being applied. 73. The Research Degrees Director will then arrange for the relevant penalty or penalties to be applied, and for signed copies of this report to be sent to (i) the student; (ii) the Assistant Registrar (Student Records & Assessments) for inclusion in the student‟s file and in the Assessment Irregularities file; and (iii) the Dean of Studies. No further escalation to a formal Assessment Irregularities Committee should be required. The case should be reported on anonymously in annual assessment irregularities monitoring. Constitution of Assessment Irregularities Committee 74. The purpose of an Assessment Irregularities Committee (AIC) shall be to consider details of any alleged irregularity and the involved student's explanation, with the authority to make a final decision on the matter. It is a more formal mechanism than an Irregularity Investigation Panel, with authority to levy more severe penalties.

75. An Assessment Irregularities Committee shall be established in the following circumstances (either following an Irregularity Investigation Panel, or directly if a need for a formal AIC can be determined at an earlier stage): (i) If the student specifically requests a formal hearing by an Assessment Irregularities Committee. (ii) If the student admits to only part of the allegation or denies part of the allegation. (iii) If the student admits the allegation but contests the penalty proposed at or following the Irregularity Investigation Panel.

(iv) If the student admits the allegation but the responsible Research Degrees Director feels it necessary to refer the matter to an Assessment Irregularities Committee. (v) If the Research Degrees Director believes the allegations are sufficiently serious to warrant a level of penalty which may only by levied by an Assessment Irregularities Committee. (vi) If the student has previously been involved in an assessment irregularity case at the School for which they were found to have a case to answer and the decision was at the level of a reprimand or above (NB that all repeat cases must be referred to an Assessment Irregularities Committee). 76. The Assessment Irregularities Committee should arrange to meet as soon as possible, and within 15 working days of the need for an AIC being identified (i.e. either following specific student request for a hearing, following the report of the Irregularity Investigation Panel, or after the responsible Research Degrees Director has identified that an AIC is required).

77. The Assessment Irregularities Committee shall consist of at least three persons nominated by the Dean of Studies, on the advice of the Assistant Registrar (Student Records & Assessments), from any of the following groups: (i) Deans of Faculty. (ii) Faculty Research Degrees Directors. (iii) Professors or Readers of the School. (iv) Chairs of Boards of Examiners.

50 of 62 (v) Department Research Degrees Co-ordinators. 78. One of the persons appointed will be nominated as Chair by the Dean of Studies. 79. Persons who have already served as a member of an Irregularity Investigation Panel which has considered the case, who have any direct interest in the case or who might be involved in an appeal at a later stage are not permitted to serve on the Assessment Irregularities Committee. No member of the Assessment Irregularities Committee shall be the supervisor of, or a member of the same Department as, any person against whom an allegation is made.

80. The Assistant Registrar (Student Records & Assessments) or his/her nominee shall act as Clerk to the Assessment Irregularities Committee. The proceedings before the Committee and its deliberations shall be recorded, and a full report of these proceedings and deliberations prepared in the event of an appeal being lodged. 81. The quorum for a hearing of the Assessment Irregularities Committee shall be three members. If it is not possible to arrange a quorate meeting within the required timescales, the Chair should request that the Dean of Studies extend or amend the membership, to enable a quorate meeting to be arranged with alternative members.

Notification to the student 82. If the case has progressed directly to an Assessment Irregularities Committee without an Irregularity Investigation Panel having met, the Clerk of the Assessment Irregularities Committee shall contact the student to request that they provide either a verbal or a written explanation of their conduct with respect to the allegations, and any further evidence for consideration. Any verbal explanation may be written up by the Clerk in documentary form. The Clerk may delegate responsibility for such contact to the responsible Research Degrees Director where appropriate.

83. The Clerk of the Assessment Irregularities Committee shall arrange for a copy of each document which will be presented to the Assessment Irregularities Committee to be delivered to the student. Such documents shall include any written statement or statements made by the student and the report of the Irregularity Investigation Panel (if this met) or else report from the initial investigations of the responsible Research Degrees Director. Along with these documents, notice should be given of the purpose of the meeting and details of the time and place at which it will be held.

84. The documents and notice shall be sent to the student in reasonable time. If the student has previously engaged in email correspondence about the alleged irregularity, the details may be sent via email no later than 5 working days before the date set for the hearing. Otherwise, the details should be posted in hard copy at least 7 working days before the date set for the hearing, to the student's current or last known address. Assessment Irregularities Committee Hearing 85. The proceedings of the Assessment Irregularities Committee shall be held in private, i.e. persons or roles not mentioned in these procedures should not be present.

86. The student shall have the right to be present at all proceedings of the Assessment Irregularities Committee subject to the further provisions (below) for Committee members to consider their findings and agree a decision in private, and to retire for private discussions at any time. 87. Proceedings of the Assessment Irregularities Committee shall not be invalidated through the student being absent from the meeting of the Committee, provided that documents and notice have been sent to the student in reasonable time (as per the conditions above).

88. A friend or representative may accompany the student at the hearing if desired, for instance a fellow- student, course representative, or an Officer of the Student Representative Council. Such an individual should not be a formal legal counsel, and should not speak on the student's behalf. 89. The responsible Faculty Research Degrees Director, having been involved in the earlier stages of the case, shall present their evidence to the Assessment Irregularities Committee. The Committee should not ask the FRDD to recommend a specific penalty. However, FRDDs should normally give contextual information on past precedents, and may give a personal opinion (clearly distinguishing subjective opinions from objective information) on the case and potential penalties to be applied.

51 of 62 90. The Clerk to the Assessment Irregularities Committee shall read to the student the particulars of the allegation. If at this time the student admits to the allegation a statement of fact shall be made; and if agreed by the student and by the responsible Research Degrees Director, the Committee shall proceed to consider its finding. 91. Each side, first the responsible Research Degrees Director and then the student, may call witnesses who may be examined, or may present documentary material. A witness who is a student of the School may, with the Chair‟s permission, be accompanied by any person while giving evidence. Evidence may be admitted which is relevant and fair.

92. The student shall have the right to examine any documents, reports or written statements which have been used in the case – with the proviso that the Chair may anonymise the identity of persons who have provided evidence (e.g. other students reporting an incident). Such a requirement for anonymity is expected to be rare, and in such cases the Chair must have satisfied themselves as to the credibility of the person and their evidence. 93. The Assessment Irregularities Committee shall have the right to examine any documents, reports or written statements which have been introduced by the student.

94. The student may, with his/her consent, give evidence, and may be questioned by the responsible Research Degrees Director and the members of the Assessment Irregularities Committee. 95. At the conclusion of the evidence the responsible Research Degrees Director and then the student may address the Committee. 96. The Committee shall consider its findings and decision in private and shall if possible reach its finding and decision without adjournment. 97. The Committee may, at its discretion, at any time during the proceedings order the room to be vacated, or the members of the Committee may themselves retire to another room for private discussions. The student and the responsible Research Degrees Director shall not be entitled to be present at such times. 98. For the purpose of the hearing, a decision made by the Assessment Irregularities Committee on any point of procedure will be binding. Any such decision may be the subject of appeal before the Appeals Committee, subject to the grounds detailed in the below section of the procedure about appeals. Decisions of the Assessment Irregularities Committee 99. The decision of the Assessment Irregularities Committee shall be reached by a majority vote of the members of the Committee present at the hearing, but such decision shall be, and shall be announced as, the decision of the Assessment Irregularities Committee.

100. If the votes of the Assessment Irregularities Committee are evenly divided on the question of the appropriate finding or order then its decision shall always be in favour of the less serious finding or order. 101. The votes of individual Assessment Irregularities Committee members shall always be treated as confidential and there shall be no disclosure either of such votes or of information showing whether the decision was reached by a unanimous or majority or evenly divided vote. 102. At the conclusion of the evidence Assessment Irregularities Committee shall determine whether an offence has been committed. The Committee shall give reasons for its decision. 103. Where the Assessment Irregularities Committee finds that particulars of the allegation have been established, then firstly the responsible Research Degrees Director, and secondly the involved student or his/her representative, shall have a further opportunity to address the Committee regarding the order to be made.

104. Before reaching any decision on the order, the Assessment Irregularities Committee shall consider any written statements (which may include statements by a supervisor, Dean of Faculty or medical adviser) submitted to the Committee by the responsible Research Degrees Director or by the student who has been found to have committed an offence. Copies shall be provided for both sides. No witnesses may be called at this stage.

52 of 62 105. The Clerk shall provide the Assessment Irregularities Committee with all relevant information relating to the student‟s position in the School and the programme of study for which they are registered, including their stage of progress within the structure of that programme, and other components completed or graded which will affect their final qualification and award classification. 106. When reaching the decision on the order the Assessment Irregularities Committee shall consider all factors determining severity of irregularity, as per the section above on applicable penalties. 107. The Assessment Irregularities Committee will then order a penalty or penalties in line with the scale of outcomes detailed in the section above on applicable penalties. Variations or other appropriate penalties not specifically detailed in these Procedures may be ordered, although giving due consideration to the importance of fairness and consistency with policy and precedent. 108. Findings and orders of the Assessment Irregularities Committee shall be announced by the Chair at the close of the meeting.

109. The Chair of the Assessment Irregularities Committee shall then prepare a report form and report detailing the allegation, the evidence that was considered, and the outcome. This should be passed on to the Registry no later than 3 clear working days from the date of the meeting, for Registry to arrange further dissemination. A copy of this report shall be given to the student by hand, or sent by recorded delivery to the student‟s last known address as soon as possible, and no later than 5 clear working days from the date of the meeting; and also sent to the Dean of Studies and the Research Degrees Director. The Assistant Registrar (Student Records & Assessments) and the Research Degrees Director shall arrange for the relevant penalty or penalties to be applied. Details of the case should be included in the student‟s file and in the Assessment Irregularities file, and reported on anonymously in annual assessment irregularities monitoring.

110. Should the Assessment Irregularities Committee‟s decision be that no irregularity has been committed or that there was a genuine mistake with no intention of committing an irregularity, that decision shall also be communicated to any other persons in the case whether as witnesses or otherwise. Applicability of procedures 111. In the event of an assessment irregularity allegation concerning an LSHTM Research Degree student taking an assessed module from the suite available to MSc, Diploma or Certificate students, or taking an assessed Short Course, then separate Assessment Irregularities procedure for Taught Courses should apply in the first instance – i.e. the allegation should first be put to the Module Organiser or Course Director of the Module or Short Course concerned, who should then inform the relevant Faculty Taught Course Director. The TCD should then investigate the alleged irregularity and initiate an Irregularity Investigation Panel if there is a case to answer.

112. In such cases, the relevant Faculty Research Degrees Director may also be invited to join the Irregularity Investigation Panel. 113. If the student accepts the recommendation of this Panel, that decision may be applied and recorded as indicated under the procedures above, and no recourse to other procedures is required. 114. However if the student does not accept this recommendation, or the decision of the Panel would normally require that an Assessment Irregularities Committee be initiated, then the case moves into the ambit of the procedure above. This should be followed up by the Assistant Registrar (Student Records & Assessments).

115. In the event of an assessment irregularity allegation concerning a student who is registered for an LSHTM research degree, but in respect of a course they are taking at another institution, then the Registry of the relevant institution should be asked to make a report on the case for consideration by the Research Degrees Director responsible for that student at LSHTM. The FRDD should follow up to determine whether there is a case for the student to answer under standard LSHTM procedures, further to any procedures or grade reduction –type penalty already applied or being applied by that institution. APPEALS Grounds for Appeal 116. An appeal may be made on the following grounds:

53 of 62 (i) That the proceedings of the Hearing of the Assessment Irregularities Committee were not carried out in accordance with these Procedures. (ii) That there is fresh evidence to be presented, which was not, or could not reasonably have been, made available to the Hearing of the Assessment Irregularities Committee. (iii) That the decision of the Assessment Irregularities Committee was against the weight of the evidence. (iv) That the penalty imposed by the Assessment Irregularities Committee was out of proportion to the offence committed.

Notice of Intention to Appeal 117. Notice of intention to appeal must be given in writing to the Clerk to the Assessment Irregularities Committee within 10 working days of the date of notification to the person concerned of the order in respect of which the appeal is made. The notice shall include the grounds for appeal. Where the appeal is on the grounds of fresh evidence, the appellant must submit a summary of the evidence to the Clerk to Assessment Irregularities Committee with the notice of appeal.

118. The Clerk to the Assessment Irregularities Committee shall prepare a full report of the proceedings of the Assessment Irregularities Committee. The report shall contain a statement of the matters investigated, a summary of the evidence given by each witness, and the reasons for the decisions reached, both in respect of guilt and in respect of the order made, and shall state the grounds of appeal. Such documents shall include any written statement or statements made by the student. 119. Such a report will be delivered to the Dean of Studies for consideration of whether the grounds for appeal are justified under the procedures.

120. If a request to appeal is rejected, reasons will be given. 121. If the grounds for appeal are accepted, the report of the proceedings of the Assessment Irregularities Committee shall be delivered to the appellant by hand, or sent by recorded delivery to the appellant‟s current or last known address as soon as possible, and at least 7 working days before the date appointed for the meeting of the Appeals Committee. 122. An appellant may prepare a written submission to the Appeals Committee. Such a report shall be submitted to the Clerk to the Appeals Committee at least 7 working days before the date appointed for the meeting of the Appeals Committee.

Constitution of Appeals Committee 123. An Appeals Committee shall be convened for the purpose of hearing the appeal as soon as possible, and within 15 working days after the receipt of such notification of intention to appeal. The Assistant Registrar (Student Records & Assessments), or his/her nominee, shall act as Clerk to the Appeals Committee. 124. The appellant shall be notified by the Clerk to the Appeals Committee of the date of the hearing as soon as possible and at least 7 working days before the date appointed for the meeting of the Appeals Committee. Such notification shall be delivered by hand to the appellant, or sent by recorded delivery to the appellant‟s current or last known address. The Clerk may also wish to contact the appellant by email or telephone as a courtesy.

125. The Appeals Committee shall consist of three persons as follows: (i) Chair – The Dean of Studies, or his/her nominee, (ii) A senior member of the Academic Staff, appointed by the Director of the School; and (iii) One student of the School who shall be appointed by the Chair of the Student Representatives Council. 126. Persons who served on the Assessment Irregularities Committee which made the order against which the appeal is made, who have been directly concerned with the matters relating to the order or to the appeal or who have any direct interest in the case, may not serve on the Appeals Committee. 127. The quorum for the Appeals Committee shall be three.

54 of 62 Proceedings of the Appeals Committee 128. Sittings of the Appeals Committee shall be held in private. 129. Proceedings of the Appeals Committee shall not be invalidated through the absence of the appellant from the meeting or meetings of the Committee, provided that the appellant has had notice of the purpose of the meeting and details of the time and place at which it will be held sent in reasonable time (as per the conditions above). 130. An appeal shall be by consideration of the documentation previously prepared by the Clerk to the Appeals Committee and seen by the Dean of Studies in determining that there are adequate grounds for appeal. This documentation should be supplied in full to the Appeals Committee, and constitute a full record of the proceedings of the Assessment Irregularities Committee – including a statement of the matters investigated, a summary of the evidence given by each witness, the reasons for the decisions reached (both in respect of guilt and in respect of the order made), the grounds for appeal, and any written statement or statements made by the student. NB that the appeal shall not take the form of a re- hearing of the case.

131. Any specific written submission by the appellant to the Appeals Committee, as submitted at least 7 working days beforehand to the Clerk to the Appeals Committee, should also be considered. An Appeals Committee may also, at its discretion, hear and take into account new evidence called into account by either side which was not, and which could not reasonably have been made available at the hearing of the Assessment Irregularities Committee 132. The appellant or his/her representative shall then address the Appeals Committee; the responsible Research Degrees Director may then address the Committee if they so wish. 133. An Appeals Committee may, at its discretion, at any time during the hearing of an appeal order the room to be vacated or the members may themselves retire to another room for private discussions. Decisions of the Appeals Committee 134. The decision of an Appeals Committee shall be reached by a majority or unanimous vote of the members of the Committee present at the meeting, but in either case shall be announced as the decision of the Committee. The Chair shall have a second or casting vote.

135. The votes of the individual Committee members shall always be treated as confidential and there shall be no disclosure either of such votes or of information showing whether the decision was reached by unanimous or majority vote. 136. The Appeals Committee shall reach its decision, whether to allow or dismiss the appeal, without adjournment (except such temporary adjournment as is involved in the procedure laid down above, i.e. for private discussions). The Committee shall give reasons for its decision. 137. The Appeals Committee shall have power to reverse or modify the decision or penalty appealed against in any way, including cases where the judgement of irregularity has been accepted but the severity of penalty appealed. However, the Committee shall not have power to impose any measure which is more severe that that appealed against, other than the award of costs as provided for in the following paragraph.

138. Where the appeal is dismissed, and the Appeals Committee is satisfied that the appeal was without merit, the Committee shall have power to order, in addition to any penalty, that the appellant should pay a sum to be determined annually by the School by way of contribution to the costs of the appeal. Such contribution shall be recoverable from the appellant as a civil debt due to the School, and the appellant shall be taken to having agreed, by lodging his/her appeal, to meet such contribution if ordered. 139. If an appeal has been allowed, in part or whole, the Appeals Committee may hear further submissions on the question of the appropriate order to be made, but no further witnesses shall be heard at this stage.

140. The Committee may adjourn for a period not exceeding 10 working days for the purpose of deciding the appropriate order to be made upon the appeal. 141. The decisions of the Appeals Committee shall be final.

55 of 62 142. At the conclusion of the appeals hearing the Clerk to the Appeals Committee shall submit a report to the Dean of Studies and the Director of the School, copied to the Research Degrees Director. A copy of this report shall be sent by registered post to the student‟s current or last known address, and to the Assistant Registrar (Student Records & Assessments) for inclusion in the student‟s file and in the Assessment Irregularities file. Such a report shall be sent as soon as possible, and no later than 5 clear working days from the date of the Appeals Committee meeting.

143. Should the Appeals Committee‟s decision be that no irregularity has been committed or that there was a genuine mistake with no intention of committing an irregularity, that decision shall also be communicated to any other persons in the case whether as witnesses or otherwise. The Office of the Independent Adjudicator for Higher Education 144. The extent of the School‟s procedures for considering Assessment Irregularity matters for research degrees are as set out above. Attention is, however, drawn to the Office of the Independent Adjudicator for Higher Education (OIAHE). The OIAHE provides an independent scheme for the review of student complaints about a final decision of a University‟s disciplinary or appeal body. Having exhausted the School's internal procedures as detailed above, a student may ask the OIAHE to consider any unresolved complaint against the School, subject to certain criteria. Full details about this are available from the Assistant Registrar (Student Records & Assessments) of the School, or on the website of the OIAHE at www.oiahe.org.uk.

RECORDING AND MONITORING OF ASSESSMENT IRREGULARITIES Data protection responsibilities 145. Information about proven or alleged irregularities constitutes Personal Data under the terms of the Data Protection Act, and all staff involved in cases must take care to ensure safe, secure and appropriate storage and use of this information – including keeping it up-to-date, which would be particularly vital if there is a subsequent appeal. Data relating to a named individual may need to be released to that individual if they make a formal Subject Access Request; however full personally- identifiable information should not be released any more widely.

146. The School will endeavour to limit the disclosure of information as is consistent with conducting an investigation and the provisions of the Human Rights Act 1998, the Data Protection Act 1998, the Freedom of Information Act 2002, and any other relevant legislation. 147. The procedures, guidance and regulations of the School or University in relation to what appears on degree transcripts or Diploma supplements will determine whether or not these should indicate grades or elements of the course for which an assessment irregularity has been found to have occurred. 148. The Registry should act as the main repository of all files in relation to assessment irregularity cases, and all staff seeking further information in relation to a case should contact the Registry. Master copies of all reports and information should be kept by the Registry in the Assessment Irregularities file (AI file), stored by academic year, and destroyed five years after the end of each year in question, or within five years of a student‟s completing their course. Additional copies may be placed in individual students' files where relevant (as indicated above), and destroyed as and when that student file is destroyed. Since Registry staff will act as Clerks to any Assessment Irregularity or Appeal Committees, master files for those may be maintained as part of the main AI file. Registry will maintain a master list (in database or spreadsheet –type format) of all cases recorded and on file, by academic year – this should serve as a means of reviewing and reporting on past cases.

149. Other staff who may have data storage responsibilities under these (Research Degrees) procedures include: (i) Research Degrees Directors –  Must record details of all assessment irregularity allegations reported to them and where there is found to be a case to answer, writing up a file report and passing on to Registry in due course, as part of the process noted above.  Must pass on any further information or paperwork received as part of the case to Registry, for inclusion in the files for that case.

 May maintain personal files with copies of reports they have written or received as part of a case, plus any further information they have received which is not appropriate to be passed on for the Registry file (e.g. the names of individuals reporting the alleged irregularity). Such information should be destroyed on conclusion of the case or at the end of the academic year, whichever is later.

56 of 62 (ii) Chairs of Assessment Irregularity Committees –  Must write up a file report and pass on to Registry in due course, as part of the process noted above.  Must pass on any further information or paperwork received as part of the case to Registry, for inclusion in the files for that case.  May maintain personal files with copies of reports they have written or received as part of a case. Such information should be destroyed on conclusion of the case or at the end of the academic year, whichever is later.

(iii) Other involved staff (including the Dean of Studies, the Director, and members of Assessment Irregularity Committees) –  May maintain personal files with copies of reports they have received as part of a case. Such information should be destroyed on conclusion of the case or at the end of the student‟s course of study, whichever is later. Reporting and recording of irregularities 150. The key stages at which information about a research degrees assessment irregularity case must be recorded are as follows: (i) Irregularity Investigation Panel  For all outcomes, including 'no case to answer', FRDD completes form plus report including judgement of IIP and final penalty recommended subsequently.

 If student signs (or no response is received further to a request to sign), outcome is treated as agreed and FRDD sends form plus report to: (i) the student; (ii) Registry, for inclusion in student's file and AI file; and (iii) the DoS, for awareness.  If student does not agree (i.e. refuses to sign), case proceeds to AIC and FRDD sends form plus report to Registry for inclusion in AIC papers and case notes. (ii) Assessment Irregularities Committee  AIC Chair prepares form plus report detailing allegation, evidence and outcome, then sends this to the Registry.

 Registry send copies of the form plus report to: (i) the student; (ii) Registry, for inclusion in student's file and AI file; and (iii) the DoS and FRDD, for awareness.  Registry file all further paperwork/evidence connected with the AIC, including minutes of proceedings and deliberations, in AI file only. (iii) Appeals  Clerk to Appeals Committee (from Registry) prepares report on the outcome; sends report to: (i) the student; (ii) Registry, for inclusion in student's file and AI file; and (iii) the DoS, the Director of the School and the FRDD.

 Clerk to Appeals Committee also passes all paperwork/evidence/further submissions connected with the appeal to Registry, for inclusion in AI file only. 151. A standard „Assessment Irregularity Record‟ form should be used for recording case details, which may contain the following information for each individual student involved:  Student name  Student candidate number, where applicable  Course of study (e.g. MPhil, PhD, DrPH)  Module(s) involved, where applicable  Type of assessment (e.g. PhD upgrading, DrPH professional attachment)  Date(s) suggested irregularity took place (=submission date for assignment work)  Type of irregularity suggested  Date reported to FRDD  Brief anonymised summary of case (for reporting more widely)  Action recommended or taken Full details about the case, established through investigation, should be attached with this form. 152. The responsible Research Degrees Director should record all appropriate details in the „full details of case‟ section. It will normally be appropriate to indicate staff roles, e.g. “the first marker noticed”, “the invigilator observed”, “the staff member using Turnitin reported”. However, it would not be appropriate to record the name of another student if they have made an allegation (though general non-personally- identifiable details of their credibility may be relevant to note).

Monitoring of irregularities

57 of 62 153. Towards the end of each academic year, ahead of final Exam Boards, Registry shall check the Assessment Irregularities file for that year and supply all Research Degrees Directors with a list of names of research degrees students for whom an assessment irregularity has been suggested. No further details of allegations or cases need to be provided; but the list should be cross-checked to identify any students against whom concerns have been raised on more than one Faculty. For any such cases, the Assistant Registrar (Student Records & Assessments) and the FRDD for the Faculty to which the student belongs may wish to investigate and take any further action as they deem necessary. Note that such information-sharing may take place face to face, at an unminuted meeting; if a written list of names is supplied, it should be destroyed once checked.

154. Registry shall produce an annual report on assessment irregularities for the Research Degrees Committee (further to RDC‟s responsibilities for quality monitoring). This should be based on information in the AI file for the complete preceding academic year, including allegations for which there was found to be no case to answer. Information should include a summary of the number of cases reported, with breakdowns according to Course/Faculty, type of assessment, and outcome/penalty invoked; plus trend data to compare against previous years where possible. Full anonymised details from all cases should also be provided: detailing Faculty, Course of study, Module(s) involved (where applicable), type of assessment, type of irregularity suggested, summary of case, and action taken. RDC is expected to scrutinise this data annually, to monitor the level and type of irregularities being identified, and identify any differences between courses or Faculties (including in the severity of the penalties applied). 155. The Dean of Studies or Chair of RDC may also request that a similar summary of assessment irregularities be produced ad-hoc during the course of an academic year if problems are felt to be emerging.

Flowchart summary of process - glossary 156. A flowchart summary of the above process is given on the following pages. Acronyms used are:  DRDC = Department Research Degrees Co-ordinator  FRDD = Faculty Research Degrees Director  DoS = Dean of Studies  IIP = Irregularity Investigation Panel  AIC = Assessment Irregularities Committee Procedures approved by the Associate Dean of Studies. Last updated 22 February 2013.

58 of 62 FLOWCHART OF ASSESSMENT IRREGULARITIES PROCEDURE  FRDD decides there is a case  Contacts student to invite them to respond to an Irregularity Investigation Panel  Notifies DoS that case has been initiated  FRDD decides there is no case  NO FURTHER ACTION  Consider whether a formal Assessment Irregularities Committee is required (e.g. if specifically requested by student, if a repeat offence, if warranted by severity of allegation)  Member of staff suspects an irregularity  Reports it to relevant DRDC or other member of staff responsible for that assessment task  DRDC informs FRDD  FRDD makes initial investigation of the allegation INITIATION OF PROCEEDINGS IRREGULARITY INVESTIGATION PANEL  IIP decides there is no case or no further action to be taken  FRDD records allegation/case details on file for monitoring purposes  FRDD reports outcome back to student, and both Registry and DoS for monitoring purposes  CASE RESOLVED WITHOUT PENALTY  IIP decides there has been an irregularity  Student offered decision based on the IIP  Student indicates willingness to accept IIP outcome  FRDD takes further advice, then reaches final decision & writes up report statement  Student signs report statement and agrees to penalty  FRDD reports outcome back to student, and both Registry and DoS for monitoring purposes  CASE RESOLVED, PENALTY APPLIES Student rejects IIP outcome, or will not accept decision/penalty, or recommended penalty requires an AIC  FRDD convenes IIP with DRDC  Student can either attend in person or provide input through other channels  IIP agrees what has happened, how severe it is, and a provisional penalty A.I.C.

10 working days 5 working days 10 working days

59 of 62  AIC decides there is no case or no further action to be taken  FRDD reports outcome back to student, and both Registry and DoS for monitoring purposes  CASE RESOLVED WITHOUT PENALTY  This outcome is communicated to other involved parties  AIC decides there has been an irregularity  Opportunity for last statements and information to be seen by AIC before penalty is decided  AIC decides penalty  Chair reports outcome back to student, and both Registry and DoS for monitoring purposes  CASE RESOLVED, PENALTY APPLIES FROM FULL RANGE OPEN TO A.I.C.

 FRDD convenes Assessment Irregularities Committee (AIC)  Clerk to AIC sends notification and relevant documentation out to student and AIC members  Hearing takes place, which may include discussion, cross-examination and witnesses  Student may admit to allegation during these proceedings ASSESSMENT IRREGULARITIES COMMITTEE APPEALS  Notice of Intention to Appeal made to Clerk of AIC  Appeal considered by Dean of Studies  Appeal denied  Student is notified of decision  NO FURTHER ACTION  Appeal allowed  Dean of Studies convenes Appeals Committee  Clerk to Committee sends notification and relevant documentation out to student and members Appeals Committee sits and considers documentation (appellant and FRDD may address Committee if desired)  Original decision upheld  Student is notified of decision  NO FURTHER ACTION  Original decision modified or reversed  Chair reports outcome back to student, and both Registry and DoS for monitoring purposes  CASE RESOLVED, PENALTY MODIFIED OR OVERTURNED AS APPROPRIATE  If final outcome overturns case or indicates no penalty should be applied, communicate to other involved parties 15 working days 10 working days 15 working days Glossary: DRDC = Dept Research Degrees Co-ordinator FRDD = Research Degrees Director DoS = Dean of Studies IIP = Irregularity Investigation Panel AIC = Assessment Irregularities Committee

60 of 62 Annex 6: Standard notification to students about suspected assessment irregularities The following standard template should be used to notify individual students regarding allegations of an assessment irregularity – to let them know where allegations are being investigated, and invite them to attend an Irregularity Investigation Panel. Taught Course Directors may freely amend this text as appropriate for individual cases. Research Degrees Directors should likewise amend this text to be relevant for any research degrees cases. Subject: Assessment Irregularities – [Module name(s) OR Project Report OR Exam/Paper/Date OR other assessment task].

Dear [student first name], In my role as Taught Course Director for the Faculty it is my responsibility to investigate assessment irregularities. Your assessed work for [Module name(s) OR Project Report OR Exam/Paper/Date OR other assessment task] has been brought to my attention in this regard. Attached is an Assessment Irregularity Record Form detailing the alleged irregularity and my initial investigation; plus a copy of the School’s Assessment Irregularities procedures, which include relevant definitions and details of how these matters will be followed up. An Irregularity Investigation Panel will be meeting to discuss this on [date] at [time] in [location – inc. room number, building name and full address]. The Panel will consist of [Course Director or Module Organiser – name and title] and myself.

[for London-based students only]: You are invited to attend this Panel meeting to explain or discuss this matter and provide any further relevant evidence. A friend or representative may accompany you. If you are unable to attend in person, your explanation and evidence may be given in writing; or directly via phone, video link or similar. If the date and time are not convenient then I will be willing to reschedule, though not so as to delay the process unduly (I would like the Panel to meet within the next two weeks).

[for Distance Learning students only]: You are invited to explain or discuss this matter and provide any further relevant evidence to the Panel. As a distance-based student, you are not required to attend in person but instead may give your explanation and evidence either in writing or directly via phone, video link or similar. If the date and time are not convenient then I will be willing to reschedule, though not so as to delay the process unduly (I would like the Panel to meet within the next two weeks). You would also be welcome to attend the Panel meeting in person, and if so a friend or representative may accompany you.

By return of email, please can you: * Confirm whether you will attend the Panel meeting, or would like to participate remotely via another method, or will provide input in writing ahead of the meeting. * If you wish to attend or participate but the date or time is not convenient, let me know that this is the case and suggest alternative dates. Yours sincerely, [Name, title and correspondence details of Taught Course Director]

61 of 62 Annex 7: Assessment Irregularity record form Assessment Irregularity Record Form CONFIDENTIAL This form records: The below information constitutes Personal Data under the terms of the Data Protection Act. A master copy of this form will be held by the Registry, and destroyed five years after the end of the academic year in question, or within five years of completion of the course. Irregularity Investigation Panel outcome Assessment Irregularity Committee outcome Student name Student candidate number (where applicable) Course of study (specific MSc, Diploma, Certificate, Research Degree) Module(s) involved (where applicable) Type of assessment (e.g. module assignment, exam, project, professional attachment) Date(s) suggested irregularity took place (=submission date for assignment work) Type of irregularity suggested (tick more than one box if necessary) Poor referencing practice Minor plagiarism Substantial plagiarism Fraud Exam offence Collusion Personation Cheating Date reported to TCD or FRDD Brief anonymised summary of case (for reporting more widely) Action recommended (by TCD/FRDD after IIP, or by AIC) Please attach a separate report setting out full details of case, established through investigation. This full report may be appropriate to return to the student.

62 of 62 Report made by Taught Course Director Faculty Research Degrees Director Chair of Assessment Irregularities Committee Name e-Signature (optional) Date Student statement (only needs to be signed following a Irregularity Investigation Panel) I agree with this statement of facts concerning my work as indicated above, and agree to the penalty or penalties indicated Name Signature Date For students who have given consent in absentia, or are otherwise unable to sign in hard copy, the staff member who has signed above should give details of this consent: Relevant evidence of consent (e.g. an e-mail from the student, a signed statement from a staff member regarding a phone conversation with the student) should be attached with the file copy of this form in lieu of a hard copy student signature.

If no response has been received from the student within 15 working days of their being advised of the Panel’s decision and proposed penalty, this should be noted above and the TCD or FRDD should determine and apply the final penalty. A version of this form should be passed on at each major stage of the process, as may apply – by the TCD or FRDD after an Irregularity Investigation Panel; and by the Chair after any Assessment Irregularity Committee. Once complete, please email a master copy of this form (plus supporting report) to the Examinations Officer in the Registry, cc the Dean of Studies.

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