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VENUE STAFF FREELANCE AGREEMENT

(STRICTLY PRIVATE AND CONFIDENTIAL)

Date: March 08, 2019

Dear safi ullah khan (N10298),

I am pleased to offer you this venue staff (“VS”) freelance agreement within the Exams Test Centre network
in Pakistan. This letter contains all the details relating to this arrangement, including pay, notice provisions
etc., and should be read carefully as it forms the agreement between the British Council and yourself to
provide services.

The Parties

This agreement is between you and The British Council, incorporated by Royal Charter and registered as a
charity (under number 209131 in England & Wales and number SC037733 in Scotland), with its principal
office at 10 Spring Gardens, London, SW1A 2BN and country office at British High Commission, Ramna 5,
Diplomatic Enclave, Islamabad Pakistan.

Start Date

The date of commencement of this arrangement with the British Council is 1st April 2019.

Duties

You have agreed to provide your services for the role/s in line with the attached role description.

Terms of the Appointment

This appointment is on an hourly rate basis and is expected to run until 30th March 2021 or until either
party terminates the arrangement.

During this time, you will not be an employee of the British Council. The services you provide to the British
Council are on an ad hoc and freelance basis. This means that whilst the British Council will try to give you
as much notice as possible when offering work, there is no obligation on the part of the British Council to
provide such work nor for you to accept any work so offered.

Conditions of Offer

This offer is subject to your selection as recorded by relevant recruiting authority of the British Council and
providing satisfactory documentary evidence of police checks and reference checks.

Location

You will provide your services at such sites as the British Council may reasonably require.

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Taking an Examination with the British Council

Under normal circumstances, while you are providing service to the British Council in this capacity, you will
not be eligible to take an examination with the British Council. In case you are required to sit an exam
administered by the British Council and no alternative is available, then you should seek the advice of the
British Council Exams Director.

During your period of service, you should not be involved in similar work for any other organisation.

Training

You agree to attend/complete the mandatory training(s) for your role. You will not be able to commence
your role until this is completed as per our policy.

British Council Systems and Property

This offer is subject to you agreeing to the Terms and Conditions of using British Council Systems and
Property. All such Terms and Conditions will be presented for acceptance before providing you access to
any System or Property.

Pay

Your rate of pay will be (as applicable);

Venue Staff Category Rate of Pay (PKR)/ Hour

Supervisor 605

Assistant Supervisor 525

Invigilator 449

Marshal 225

Payments will be processed on an accumulated duties basis.

You will not be eligible for enhancements for evening, weekend, or Bank Holiday working. However, for
outreach services, day trip rate of PKR 1000/ per day and PKR 2000/ per night stay in other cities shall be
paid. The British Council also reserves the right to deduct any sums that are owed by you, including any
overpayments.

Hours of Work

This post carries no fixed hours per week however tests normally take place on week days and weekend
for some exams products and it is therefore likely that your services will be needed on these days. Working
hours will be communicated to you in advance.

Notice

The British Council requires a minimum of one month’s notice of termination of this arrangement, where
you wish to cease this arrangement.

Where the British Council ceases to require your casual services, you will be given one week’s written
notice.

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Sickness Absence

There is no entitlement to payment during absence due to sickness. Where you are unable to work as
arranged, due to sickness, you must inform the relevant British Council representative as soon as possible
and no later than one day before the day in question.

Intellectual Property (IP) rights

Any documents, related IP or items you produce as part of your service for the duration of this agreement,
will stay with the British Council.

Limitation of liability

The British Council shall incur no liability to you should you fail to accept opportunities to work. Under this
service freelance agreement, you are not an employee and the policies and practices applicable for
employees will not apply under this agreement.

Governing Law and Jurisdiction

This freelance agreement is governed by the law of England and Wales and is subject to the exclusive
jurisdiction of the courts of England and Wales.

Code of Conduct and Policies

As this letter and the documents/Annexes it refers to constitute one agreement, by signing this agreement,
you are agreeing to abide by the instructions, requirements, policies, codes of conduct, guidelines, forms
and other documents notified to the Service Provider in writing or set out on the British Council’s website at
http://www.britishcouncil.org/new/about-us/jobs/folder_jobs/register-as-a-Service Provider/policies-for-
Service Providers-and-associates/ or such other web address as may be notified to the Service Provider
from time to time (as such documents may be amended, updated or supplemented from time to time during
the Term).

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Annexures
Annexure 1 – Conflict of Interest (“COI”) Form

Annexure 2 – The Child Protection (“CP”) Policy

Annexure 3 – The Child Protection Declaration Form

Annexure 4 – Role Profile

Annexure 5 – General Data Protection Regulation (“GDPR”) - [Schedule 2 & 3]

Annexure 6 – British Council Examinations Services Code of Conduct – Venue Staff

Signed on behalf of the British Council:

-------------------------------------------------------------

Date: March 08, 2019

PLEASE SIGN AND RETURN THE SECOND COPY OF THIS STATEMENT TO INDICATE YOUR
ACCEPTANCE OF THIS ARRANGEMENT

Name: safi ullah khan ............................ CNIC: ....................................................

Signature: ................................................... Date: ....................................................

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Annexure 1 – Conflict of Interest Form
Invigilator Name: safi ullah khan

Invigilator ID: N10298

Invigilator CNIC: __________________________________

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Part A: Declaration

 I have close family member, friend or associate that I believe will be taking an exam delivered by the
British Council (Tick the box, if applicable)

Candidate Name: __________________________________

Exam: __________________________________

Exam Board: __________________________________

 I have close family member, friend or associate that is working for British Council (Tick the box, if
applicable)

Name: __________________________________

Designation: __________________________________

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PART B: Statement to be made by ESM (if ESM is making the declaration, then CEM completes this part)

I agree to notify the VSM unit, through the VS Manager, promptly if any new situation or actions that might
be regarded as a potential conflict of interest with my duties as a Venue Staff to the British Council should
develop at any time during my tenure.

I confirm that I have been made aware of the above declaration and will manage any potential conflicts
appropriately.

Signature: __________________________________

Date: __________________________________

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Summary of Actions Taken  


VSM Unit

Name & Signatures:

________________________

(After ESM has signed and summarised the action taken, form should be submitted to the VS Unit for
retention in the individual’s personal file)

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Annexure 2 – The Child Protection Policy

All British Council staff48 who works with children must sign up and abide by this Code
of Conduct.

ALWAYS:
• Listen to and respect children, empower them and let them participate in planning and delivering
activities as much as possible
• Be aware of situations which may present risks for children and take appropriate actions
• As far as possible, be visible when working with children
• Consider your physical appearance at work. Adults working with children should dress
appropriately for the task undertaken
• Contribute to ensure a sense of accountability amongst staff so that poor practice or potentially
abusive behavior does not go unchallenged
• Report any concerns you may have about the protection or wellbeing of a child/children to your
• Child Protection Focal Point, line manager or the corporate Child Protection Team
• Observe confidentiality and not talk about any situations of actual or suspected abuse that occurs
except in accordance with this policy. This is necessary to protect the privacy of those
involved

NEVER:
• Hit or otherwise physically assault or abuse children
• Act in ways meant to shame, humiliate, belittle or degrade children
• Show differential treatment, or favor particular children to the exclusion of others
• Use language or make suggestions which are inappropriate, offensive or abusive
• Spend excessive time alone with children away from others
• Develop relationships with children which could in any way be seen as exploitative or abusive
• Develop intimate sexual relationships with children
• Pay for sexual services, of any kind, at any time, with anyone under the age of 18 years old, even
if the age of sexual consent in the country is under 18 years.
• Expose children to pornographic materials in electronic or any other form
• Permit children to take part in activities that are illegal, unsafe or abusive
• Whilst working:
o take or condone the taking of illegal drugs
o drink alcohol when with children (or prior to contact)
• Invite, or allow, a child you have met through work into your home
• Offer to transport a child alone in a car
• Enter a child’s private home unless there is a responsible adult present.
• Use personal email accounts, social networking sites, mobile phones or other means of
communication to contact children. Always use business email accounts and copy in parents
when sending out communication to children.
• Don’t take photos of children participating in British Council activities
• Let allegations go unreported, including any made against them
• Agree to keep any information relating to the abuse of a child confidential. You should always
follow the procedures for reporting concerns

                                                            
48
 Staff’ is defined as anyone who works for the British Council, either in a paid or unpaid, full- o r p a r t - t i m e capacity. This includes directly
employed staff, trustees, contractors, agency staff, consultants, volunteers and interns. 

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Annexure 3 – The Child Protection Declaration Form

I declare that I have never been convicted of any offence involving any type of harm to a child or
children, nor have I ever been warned or cautioned in relation to such a matter. I also declare that there
are no civil or criminal proceedings of any nature pending against me at the date of this declaration
relating to any allegation concerning any type of harm to a child or children.

I authorise the British Council to seek references or approach previous employers for information to verify
information on disciplinary offences relating to children.

I authorise the British Council to ask for criminal records information in relation to any allegation
concerning any type of harm to a child or children in other countries if necessary. I expressly authorise
the British Council to pass personal details to the relevant authorities in countries where I have lived or
worked for the purpose of obtaining criminal records information.

I give my permission to The British Council to check the above-mentioned criminal records periodically.

I understand that if I withhold any relevant information, or present false or inaccurate information, I may
render myself liable to disqualification from the recruitment exercise or, if appointed, to disciplinary action
including fair dismissal.

I will adhere to the British Council’s Child Protection Policy, Child Protection Code of Conduct (4.1), and
the British Council Code of Conduct. I confirm that I have received and read these documents at the time
of signing this declaration.

In accordance with the British Council’s Privacy Policy, the UK’s Data Protection Act (1998) and any
other relevant privacy law which applies in the country of employment, this declaration is confidential and
is extended solely in order to accredit my suitability to work with children at the British Council; this
declaration may not be used totally or partially for any other purpose save that for which it is expressly
made.

If you have any past conviction(s)/cautions, warnings or reprimands in relation to offences involving
children or other vulnerable people, please declare this below, even if these were dismissed or you were
declared innocent.

Note: Failure to disclose an offence, without a satisfactory reason, will lead to the rejection/termination of
you appointment.
 

Name: safi ullah khan ............................ Invigilator ID: N10298 .......................................

Signature: ................................................... Date: ....................................................

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FOR BRITISH COUNCIL USE

VSM Unit
Name: ................................................... Signature: ....................................................

Date: ...................................................

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Annexure 4 – Role Profile
The Venue Staff designation on a particular test day is dependent on the underlying business reasons,
including coordination with concerned stakeholders in line with potential skillset and performance
evaluation of the individual, and the role can differ for different exams products and test dates.

Venue Staff General Roles and Responsibilities (Applicable to all Designations)

• Report promptly to test venue at agreed time. In case of any delays or if unable to get to the test
venue, inform the appropriate test day or British Council Examinations Services staff in a timely
manner.
• Follow all relevant standards & procedures, based on training and reference materials provided by
the British Council Examinations Services and the relevant Exam Boards.
• Enable good customer flow by giving candidates clear direction and answering their enquiries.
• Ensure that candidates follow the agreed exam procedures regarding the location and security of
their belongings.
• Conduct candidate entry, exit, identity checks and Test Day Photography procedures according to
exam requirements.
• Attend all briefing and training sessions as requested by the BC Exams.
• Ensure special arrangements are provided as required.
• Be familiar with the emergency procedures for the test day venue.
• Invigilate examinations to the standard required by the British Council Examinations Service and the
relevant Exams Boards.
• Actively monitor candidates during tests to make sure that there is no violation of test conditions.
• Support the supervisor to ensure that candidates have a positive and consistent test day experience
and a positive image of the British Council.
• Ensure all material is accounted for and handed over securely to the supervisor.
• Complete and maintain accurate records of exam assignments. Complete all reports, logs and
claims accurately as required by British Council Examinations Services.
• Follow all relevant guidelines and policies in the areas of: Data Protection, Child Protection, Health
& Safety, Equal Opportunities and Diversity, and Anti-Fraud.
• Report any incidents, emergencies or breaches of security to the appropriate test day supervisor.
• Work with the test day supervisor to promote and ensure the wellbeing of candidates at all time. In
case of emergencies, follow correct procedures and involve appropriate authorities as required.
• Additional duties in line with the role may be required.
• To ensure hall is set up, manage VS and to invigilate exam venues according to UK Exam board
and British Council requirements.
• To monitor the exam venue security, as per British Council requirements.
• To manage exam confidential material, as per British Council requirements.
• To manage exam candidates.
• To provide appropriate customer care, as per British Council requirements.
• To provide support to the British Council, to manage pre and post exam issues.
• To assist British Council staff members during various internal (British Council) and external (UK
exam boards) audits.
• To maintain the integrity and security of the exam (including pre and post exam stages).
• To develop a conducive work environment at the exam venue for VS.
• Exam invigilation duties in Outreaches.
• Flexibility to work beyond the prior agreed work schedule as per business needs.
• Ability to work with a team of individuals of diverse backgrounds.
• Good communication skills (English and Urdu).
• Ability to manage large groups of candidates.

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• Understanding of British Council’s role in Pakistan.
• Complete all mandatory training modules: Data Protection, Child Protection, Health & Safety, Equal
Opportunities and Diversity, Anti-Fraud, Identify Checks., etc
• The British Council takes the welfare and safety of children very seriously and as such your
behavior is expected to be in line with British Council’s Child Protection Policy and Code of
Conduct. Irrespective of your individual role, you will have the responsibility for safeguarding
and promoting the welfare of children and supporting the implementation of the Policy.

Key relationships: (include internal and external):

• Invigilation group at the relevant exam venue (internal).


• British Council staff (external).
• Exam candidates (external).
• Local representatives of the UK exam boards.
• GCE school/ACCA CBE institutes/UOL representatives, etc.

Accountabilities, responsibilities and Main Duties:

Supervisor

• Ensuring hall/room is prepared (including seating plans, clocks, desks and chairs’ setting, branding
etc.).
• Inspection of the venue to ensure arrangements meet agreed requirements and standards
Operations Requirement.
• Ensuring necessary equipment, material for candidate, signage, branding and seating
arrangements and plans are in place and ready to be used as required, including material
movement to the exam venue.
• Where possible, resolve issues that arise on the day according to procedures.
• To hold pre-examinations briefing with VS before every examination.
• Management of exam candidate’s entry and welcome.
• Making Examinations announcements.
• Supervision of exam candidates during the exam conduction.
• Follow the British Council required Dress Code ~ Smart Casual.
• Ensuring candidate identification check.
• Ensuring right question papers are with candidates.
• Ensure all examinations documents are prepared and filed.
• Delegation and monitoring of VS duties.
• Ensure questions papers remain under British Council custody as per regulations.
• Management of security of exam venue.
• Assistance to the British Council staff members as per the exam/ British Council requirement.
• Pre-exam & post exam support to the British Council.
• Conduct exam in a child safe environment.
• Evaluate and monitor VS performance.
• Adhere to the British Council code of conduct.
• Setting up of the venue according to the CP, health and safety policy of the British Council.
• Management of smooth exams in the challenging environment of security alerts.
• The British Council takes the welfare and safety of children very seriously and as such your
behavior is expected to be in line with British Council’s Child Protection Policy and Code of
Conduct. Irrespective of your individual role, you will have the responsibility for safeguarding
and promoting the welfare of children and supporting the implementation of the Policy.

Assistant Supervisor:

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• Ensuring setting up of the venue (including seating plans, clocks, branding, desks and chairs’
setting, etc.).
• Management of exam candidates, entry and welcome.
• Complete candidate attendance, seating plan and reports for supervisor.
• Follow the British Council required Dress Code ~ Smart Casual.
• Assist supervisor for exam candidates during the exam.
• Management of exam candidates’ appropriate expectations for the smooth conduct of exam/s.
• Ensuring candidate identification check.
• Assist supervisor in delegation and monitoring of VS duties.
• Management of security of exam venue.
• Assistance to the British Council staff members as per the exam/ British Council requirement.
• Pre-exam and Post-exam support to the British Council.
• Conduct exam in a child safe environment.
• Leading the VS team.
• Evaluate and monitor VS performance.
• Supporting exam venue supervisor in leading and managing VS at the exam venue.
• Work according to the British Council code of conduct.
• Setting up of the venue according to the CP, health and safety policy of the British Council.
• Management of smooth exams in the challenging environment of security alerts.
• The British Council takes the welfare and safety of children very seriously and as such your
behavior is expected to be in line with British Council’s Child Protection Policy and Code of
Conduct. Irrespective of your individual role, you will have the responsibility for safeguarding
and promoting the welfare of children and supporting the implementation of the Policy.

Invigilator:

• Setting up of the venue (Place Signage, Notices, Clocks).


• Be familiar with all relevant notices, instructions, codes, duration of the specific examinations.
• Manage and welcome exam candidates.
• Supervision of exam candidates during the exam conduction.
• Follow the British Council required Dress Code ~ Smart Casual.
• Manage exam candidates’ appropriate expectations for the smooth conduct of exam/s.
• Check each candidate ID and statement of entry before and during examination.
• Issue and collect examination stationary promptly, correctly and efficiently.
• Ensure only permitted materials are on each candidate’s desks (pen, pencil, eraser, Identification,
Statement of Entry).
• Ensure candidates do not communicate with each other during the exam.
• Ensure that no unauthorised person enters the exam room/hall.
• Escorting candidates to wash room if required.
• Row duty invigilation.
• Floating duty invigilation.
• Be impartially friendly to candidates without helping any candidate with the answers.
• Reporting any unusual activity to the Assistant Supervisor/Supervisor at the venue
• Not to exchange personal details with any candidate at any point.
• Adhere to all instructions issued by Supervisor/Exam boards.
• Pre-exam support to the British Council.
• Post-exam support to the British Council.
• Conduction of exam in a child safe environment.
• Work according to the British Council code of conduct.
• The British Council takes the welfare and safety of children very seriously and as such your
behavior is expected to be in line with British Council’s Child Protection Policy and Code of

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Conduct. Irrespective of your individual role, you will have the responsibility for safeguarding
and promoting the welfare of children and supporting the implementation of the Policy.

Marshal:

• Setting up of the venue (Place Signage, Notices, Clocks).


• Be familiar with all relevant notices, instructions, codes, duration of the specific examinations.
• Follow the British Council required Dress Code ~ Smart Casual.
• Manage and welcome exam candidates
• Manage exam candidates’ appropriate expectations for the smooth conduct of exam/s
• Check each candidate ID and statement of entry before and during examination
• Issue and collect examination stationary promptly, correctly and efficiently
• Ensure only permitted materials are on each candidate’s desks (pen, pencil, eraser, Identification,
Statement of Entry).
• Ensure candidates do not communicate with each other during the exam.
• Ensure that no unauthorised person enters the exam room/hall.
• Escorting candidates to wash room if required.
• Floating duty invigilation.
• Be impartially friendly to candidates. Not to help any candidate with the answers.
• Reporting any unusual activity to the Assistant Supervisor/Supervisor at the venue.
• Not to exchange personal details with any candidate at any point.
• Adhere to all instructions issued by Supervisor/Exam boards.
• Pre-exam support to the British Council.
• Post-exam support to the British Council.
• Conduction of exam in a child safe environment.
• Work according to the British Council code of conduct.
• The British Council takes the welfare and safety of children very seriously and as such your
behavior is expected to be in line with British Council’s Child Protection Policy and Code of
Conduct. Irrespective of your individual role, you will have the responsibility for safeguarding
and promoting the welfare of children and supporting the implementation of the Policy.

Venue Child Protection Focal Person:

• Develop complete understanding of the CPP, its implementation standards, Code of Conduct,
handline disclosures and reporting procedures.
• Act as the point of contact for all child protection concerns at the venue.
• Be aware of situations, which may present risks and take/propose appropriate actions
• Coordinate the child protection branding at the venue.
• Be aware of the risk identified in the CP risk assessment for the venue and take steps to mitigate
the risk and/or ensure that actions are completed.
• Coordinate the safe collection process.
• Ensure that CP reporting format is available at the venue.
• In case of a CP incident complete the format and send it to samina.sardar@britishcouncil.org.pk
and lyca.bhatti@britishcouncil.org.pk within 24 hours of the incident.
• Seek clarity and advice on child protection from samina.sardar@britishcouncil.org.pk
• The British Council takes the welfare and safety of children very seriously and as such your
behavior is expected to be in line with British Council’s Child Protection Policy and Code of
Conduct. Irrespective of your individual role, you will have the responsibility for safeguarding
and promoting the welfare of children and supporting the implementation of the Policy.

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Annexure 5 – General Data Protection Regulation (Schedule 2 & 3)
Schedule 2

36 Data Processing
36.1 In this clause:

36.1.1. “Controller” means a “data controller” for the purposes of the DPA and a “controller” for the
purposes of the GDPR (as such legislation is applicable);
36.1.2. “Data Subject” has the same meaning as in the Data Protection Legislation;
36.1.3. “DPA” means the UK Data Protection Act 1998;
36.1.4. “GDPR” means the General Data Protection Regulation (EU) 2016/679;
36.1.5. “Personal Data” means “personal data” (as defined in the Data Protection Legislation) that
are Processed under this Agreement;
36.1.6. “Personal Data Breach” means a breach of security leading to the accidental or unlawful
destruction, corruption, loss, alteration, unauthorised disclosure of unauthorised access,
attempted access (physical or otherwise) or access to, Personal Data transmitted, stored
or otherwise processed
36.1.7. “Processing” has the same meaning as in the Data Protection Legislation and
“Process” and “Processed” shall be construed accordingly; and
36.1.8. “Processor” means a “data processor” for the purposes of the DPA and a “processor”
for the purposes of the GDPR (as such legislation is applicable).
36.1.9. “Sub-Processor” means a third party engaged by the Processor to carrying out
processing activities in respect of the Personal Data on behalf of the Processor;
36.2 For the purposes of the Data Protection Legislation, the British Council is the Controller and the
Consultant is the Processor.

36.3 Details of the subject matter and duration of the Processing, the nature and purpose of the
Processing, the type of Personal Data and the categories of Data Subjects whose Personal Data is
being Processed in connection with this Agreement are set out in Schedule 5 of this Agreement].

36.4 Consultant shall comply with its obligations under the Data Protection Legislation and shall, in
particular:

36.2.1. process the Personal Data only to the extent, and in such manner, as is necessary for the
purpose of carry out its duties under this Agreement and in accordance with the British
Council’s written instructions and this clause (unless otherwise required by European Union
laws or the laws of the European jurisdiction in which Consultant Processes the Personal
Data; or unless otherwise required by laws outside the European Union in which Consultant
Processes the Personal Data as referred to in 1.9);

36.2.2. implement appropriate technical and organisational measures in accordance with the Data
Protection Legislation to ensure a level of security appropriate to the risks that are presented
by such Processing, in particular from accidental or unlawful destruction, loss, alteration,
unauthorised disclosure of, or access to Personal Data, taking into account the state of the
art, the costs of implementation, the nature, scope, context and purposes of processing and
the likelihood and severity of risk in relation to the rights and freedoms of the Data Subjects;

36.2.3. not transfer the Personal Data outside of the European Economic Area without the prior written
consent of the British Council and where such consent is given the Consultant shall;

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36.331.3.1 provide appropriate safeguards in relation to the transfer;

36.331.3.2 ensure the Data Subject has enforceable rights and effective legal remedies;

36.331.3.3 comply with its obligations under the Data Protection Legislation by providing
an adequate level of protection to any Personal Data that is transferred; and

36.331.3.4 comply with reasonable instructions notified to it in advance by the British


Council with respect to the processing of the Personal Data and

36.331.3.5 only transfer Personal Data outside the European Union Economic Area
provided that it meets the relevant requirements under Articles 44 to 50 of the
GDPR;

36.331.4 ensure that any employees or other persons authorised to process the Personal Data are
subject to appropriate obligations of confidentiality;

36.331.5 not engage any Sub-Processor to carry out its Processing obligations under this Agreement
without obtaining the prior written consent of the British Council and, where such consent is given,
procuring by way of a written contract that such Sub-Processor will, at all times during the
engagement, be subject to data Processing obligations equivalent to those set out in this clause
and may upon request provide evidence of the same to the British Council within three working
days;

36.331.6 notify the British Council, as soon as reasonably practicable, about any request or complaint
received by the Consultant or a Sub-Processor from Data Subjects without responding to that
request (unless authorised to do so by the British Council) and assist the British Council by
technical and organisational measures, insofar as possible, for the fulfilment of the British Council's
obligations in respect of such requests and complaints including where the requests and/or
complaint was received by the Consultant a Sub-Processor or the British Council;

36.331.7 notify the British Council immediately on becoming aware of a Personal Data Breach;

36.331.8 assist the British Council in ensuring compliance with its obligations under the Data
Protection Legislation with respect to security, Personal Data Breach notifications, impact
assessments and consultations with supervisory authorities or regulators;

36.331.9 maintain accurate written records of the Processing it carries out in connection with this
Agreement and on request by the British Council, make available all information necessary to
demonstrate Consultant's compliance under Data Protection Legislation and the terms of this
Agreement.

36.332 The Consultant and its Sub-Processor’s shall allow for and contribute to audits, including
inspections, by the British Council (or its authorised representative) in relation to the Processing of
the British Council’s Personal Data by the Consultant and its Sub-Processors to support the
Consultant in their compliance of clause 1.4.9.

36.333 On termination or expiry of this Agreement, the Consultant (or any Sub-Processor) shall, except to
the extent it is required to retain a copy by law, stop Processing the Personal Data and return
and/or destroy it at the request of the British Council. The Consultant shall provide confirmation of
destruction of any other copies including details of the date, time and method of destruction.

36.334 In the event of a notification under clause 1.4, the Consultant shall not notify the Data Subject or
any third party unless such disclosure is required by Data Protection Legislation or other law or is
otherwise approved by the British Council.

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36.335 The Consultant warrants that in carrying out its obligations under this Agreement it will not breach
the Data Protection Legislation or do or omit to do anything that might cause the British Council to
be in breach of the Data Protection Legislation.

36.336 If the Consultant believes it is under a legal obligation to Process the Personal Data other than in
accordance with the British Council’s instructions it will provide the British Council with details of
such legal obligation, unless the law prohibits such information on important grounds of public
interest;

36.337 The Consultant shall indemnify and keep indemnified the British Council and the British Council
Entities against all Personal Data losses suffered or incurred by, awarded against or agreed to be
paid by, the British Council or British Council Entities arising from a breach by the Consultant ( or
any Sub-Processor ) of (a) its data protection obligations under this Agreement; or (b) the
Consultant (or any Sub-Processor acting on its behalf) acting outside or contrary to the lawful
instruction of the British Council.

36.338 These clauses may be amended at any time by the British Council giving at least 30 days’ written
notice to the other stating that applicable controller to processor standard clauses laid down by the
European Commission or adopted by the UK Information Commissioner’s office or other
supervisory authority are to be incorporated into this Agreement and replace clauses 36.1 to 36.4.9
above.

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Schedule 3
Data Processing Schedule:

Description Details
Duration of Processing March 31, 2021
Venue Staff will hold data & information of Candidates while
Nature/purpose of Processing
engaging with British Council’s Activity
Type of Personal Data Candidates/Venue Staff Appearing in Exams activity.
Candidates/Venue Staff Information (CNIC, Passport
Categories of Data Subjects
Number, Contact details, Exams Information)
Countries or International
Organisations Personal Data will be Not Applicable
transferred to
Sub-Processors Not Applicable
 

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Annexure 6 – British Council Examinations Services Code of Conduct –
Venue Staff
Contents

Introduction 16

Our values 17

1. Legal compliance 17
2. Working together 17
3. Equality, diversity and inclusion 17
4. Health and safety 18
5. Child protection 18
6. Our relationship with customers 19
7. Our relationship with clients 19
8. Dealing with competitors and suppliers 19
9. Upholding public trust 20
10. Confidentiality and information security 20
11. IT and telecommunications 21
12. Gifts, entertainment and payments 21
13. Conflicts of interest 22
14. Duty of disclosure 22
15. Personal relationships at work 23
16. Recruiting relatives and friends 23
17. Dealing with wrongdoing 23

Breaches of the Code 24

Introduction

The British Council is an organisation that respects diversity, believes in equal opportunities, and works
professionally and creatively to help build a more inclusive and prosperous world. We’re here to create
opportunities and build trust internationally. To do this effectively, the way we behave must reflect our
values and stand up to scrutiny wherever we work.

This Code of Practice sets out the principles you should follow in aspects of your association with the
British Council. These principles are designed to help you behave in ways that earn people’s trust, create
understanding and build mutual respect. Ensuring that you meet them is essential both to our reputation
and to the success and effectiveness of our work.

However, this code can’t cover everything. So, when dealing with an issue that is not addressed here
directly, you should use our values to help resolve it or speak to someone in the Examinations Team with
which you are associated. Similarly, if you need clarification about anything in the code, either talk to
someone in the Examinations Team, or read the relevant policy in detail. You will be provided access to
the most relevant policies for your role as part of your service agreement or contract with us. These and
any other policies mentioned in this document are also available at:
http://www.britishcouncil.org/organisation/transparency/policies 

Our Values

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The British Council’s five core values underpin everything we say and do. This code sets the standards
for the way we work, including how we work with people, behave towards them and communicate.

Here is a brief description of what each one means to us:

Valuing people: The world is a diverse place, which is why our work starts by giving everyone the
chance to participate. This means treating people with courtesy and respect. By listening and responding
in a helpful way, we are able to unlock potential and help people be the best they can be.

Integrity: Keeping our promises and being consistent in what we say and do builds trust. We are always
honest and take responsibility for our actions.

Mutuality: Effective relationships are at the heart of our work. It’s a two-way exchange: we learn from all
those we interact with and they learn from us, all with a view to advancing the creation of global citizens.

Creativity: Creativity is the key that will unlock the world’s potential. We are constantly looking for new
sources of inspiration, encouraging resourcefulness and the development of new ideas that will shape the
future.

Professionalism: As leaders in the exams field, it is our responsibility to deliver excellent service to all our
customers and colleagues.

1. Legal compliance

Respecting the law


The British Council is committed to complying with the law in all the countries and territories in which we
work. This is a fundamental principle and we must follow it in all our dealings and behaviors. If there is
any doubt or dispute, you should speak to the local Exams Manager who can seek more specialised
advice if required.

2. Working together

Respecting our colleagues


As individuals, you should always treat colleagues with politeness and respect. You should also show
respect for each other’s cultures and customs. If you are affected by what you believe to be
unacceptable or disrespectful behavior, you should consult your center’s Exams Administrator or Exams
Services Manager (ESM). In case you witness what, you believe to be unacceptable behavior towards
others, even if you’re not directly affected by it, you can raise specific concerns under our Raising
Concerns Policy, which is set out in brief as principle 17 of this code in Dealing with Wrongdoing. The
complete version of the policy is available from the Exams Centre with which you are associated.

3. Equality, diversity and inclusion

Avoiding discrimination
The British Council is an equal opportunities employer. This means that we are committed to ensuring
that there is no unjustified discrimination on the basis of any of the following: age, disability, gender,
including transgender, having or not having dependents, HIV/AIDS status, marital status, political
opinion, race, religion and belief, sexual identity, socioeconomic background, spent convictions, trade
union activity or membership, work pattern or any other such grounds.

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The principles which underlie our Equality Policy (and our wider commitment to equality, diversity and
inclusion - EDI) apply worldwide and must be followed unless local law restricts this in some way. If you
believe such a restriction exists, please consult someone in the examinations team for guidance.
Meanwhile, please take the time to make sure that you are familiar with the policy’s terms and do not
allow unjustified discrimination to affect your judgement or behavior, either with colleagues, or in dealing
with anyone outside the British Council such as candidates.

You should read and be compliant with the EDI policy which forms part of your service agreement. It
is available: http://www.britishcouncil.org/organisation/transparency/policies/equality-diversity-inclusion.

4. Health and safety (H&S)

Looking after people


As far as it is reasonably practicable, the British Council makes every effort to ensure the health and
safety of everyone who works with us, wherever they may be working, and also of candidates, visitors,
students, contractors and others who use our premises.

You should take responsibility for your own health and safety and, as far as you are able, that of the
candidates and any colleagues you are working with.

You should observe our H & S Policy, which is available in every British Council office, and follow the
regulations and procedures that apply in the workplace. This is also available in the link below.
http://www.britishcouncil.org/organisation/transparency/policies/health-and-safety

You will also be provided with any specific guidance for the exams you may be involved with.

5. Child protection

Protecting children
We all have a fundamental duty of care for the children who engage in activities with us. We recognise
our responsibility to protect them from abuse, exploitation and negligence, applying zero tolerance and
aiming to create a safe environment for them.

NB: A child is defined as any person who has not yet reached their 18th birthday, regardless of the age
of majority in the country where the child is, or his or her country of origin – UN Conventions on the
Rights of the Child 1989.

We are committed to:


 valuing, respecting and listening to children
 ensuring all necessary checks are made when recruiting staff
 maintaining strong child protection systems and procedures for staff
 training our staff and providing a common understanding of child protection issues to inform
planning and practice
 sharing information about concerns with agencies who need to know, and involving parents
and children appropriately

Anyone working with the British Council, either in a paid or unpaid, full or part time capacity including
employees, contractors, agency staff, consultants, volunteers and interns must make sure that they
are familiar with and abide by the mandatory Child Protection Policy, a statement of which can be

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found on the British Council website:
http://www.britishcouncil.org/organisation/transparency/policies/child-protection. 

All staff are responsible for implementing the Child Protection Policy, which includes a responsibility to
report any allegations or expression of concern involving either a:

1. child who has contact with the British Council who is at risk of harm within the family or
community; and / or

2. employee of the British Council, either in a paid or unpaid , full or part time capacity
including contractors, agency staff, consultants, volunteers and interns

You must promptly report any allegations or expressions of concern to your country Child Protection
Focal Point, Naveed Hussain at Naveed.Hussain@britishcouncil.org.pk or subsequently at our
designated Child Protection forum at CP@britishcouncil.org.pk

In addition to abiding by the policy you must complete the mandatory Child Protection Basic Awareness
training and have read and be compliant with the Child Protection Code of Conduct which outlines what
is and is not acceptable behavior towards children.

6. Our relationships with customers

These are the people who are already using our services or may do in future, such as candidates,
visitors, scholars, students and their parents. In all our dealings with them – face-to-face, over the
telephone, digitally or in print – we should be helpful, quick to respond, polite and efficient.

7. Our relationships with clients

These are the organisations and people who pay for our services and it is important for us to build
lasting and successful relationships with them. We should take the time and trouble to understand their
needs and provide them with timely and effective service.

8. Dealing with competitors and suppliers

Treating and competing with people fairly


The British Council is committed to conducting all its trading activities in a fair, reasonable and
transparent manner.

We are working in an increasingly competitive environment and need to compete strongly and
successfully. But, however fierce the competition, we should always behave professionally and
conduct our business in a way that is ethical, fair and legal.

Being even-handed
Our suppliers, for example venue/equipment suppliers, quite rightly expect to receive decent treatment
from the British Council and be measured by their ability to deliver the right products and services, and
offer us value for money. To make sure this happens, we must always be fair and transparent in our
dealings with them and follow our established procurement procedures. For more information on these
procedures, speak to your Examinations Manager.
Furthermore, you must not engage relatives as suppliers nor give any endorsements, testimonials or

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comments on the performance of suppliers, without first getting approval from a Senior British Council
Manager such as the ESM.

9. Upholding public trust

Behaving ethically and responsibly


Trust is at the heart of everything we do and everyone who works with us has a duty to behave in ways
that actively uphold public trust and give people confidence in the integrity of the British Council as an
organisation.

You must never abuse or harm colleagues, customers, clients, partners, associates or any member of
the community, nor exploit them in any way, nor form inappropriate personal or financial relationships.

You should also never behave, at work or in public, in a manner which may damage the British Council’s
reputation.

10. Confidentiality and information security

Being careful with information


Managing information and confidentiality is crucial to the way the British Council operates and is viewed
in the world at large. This part of the code is in three parts – information about the British Council,
information about individual people and information security.

Information about the British Council


We are legally obliged to provide information about our activities, operations, policies and staff to the
general public on request. Doing this helps us to build trust worldwide, and we are committed to
making the maximum amount of information about us readily available at minimum inconvenience and
cost.

We do, however, have to balance this obligation with the need to protect the British Council’s operational
interests and its responsibilities towards partners, the public and anyone else who works with or for us.

You must not disclose any information that is commercially or politically sensitive to anyone outside the
British Council. Furthermore, such information may only be disclosed to colleagues on ‘a need to know’
basis. If in any doubt, consult a senior manager such as the ESM before you do so.

Information about individual people


We treat all personal information about colleagues, customers, clients, competitors and other
business contacts as confidential. You must make yourself aware of policies and procedures relating
to personal information. You should read and be compliant with the Information Security and Privacy
policy which forms part of your service agreement or contract. For further guidance you should
contact the ESM.

Information security
We all have a role to play in protecting the information held on our systems and must adhere to the
guidance and standards set out in our Information Security and Privacy Policy.

These principles apply whether information is held manually or electronically. Information which is
considered confidential during your association with the British Council remains so after your association
ends.

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For more on information security, please refer to the policy at:
http://www.britishcouncil.org/organisation/transparency/policies/information‐security‐privacy 
 

Being sensible online


Many of us make personal use of the internet, email, websites and social media, such as blogs,
microblogs, Facebook, YouTube and Twitter. However, when you are online please do not identify
your association with the British Council by discussing our work or by other means.
You must not reveal confidential information about the British Council, its people or activities nor disclose
any information that might bring it into disrepute or prompt a conflict of
interest. Also, you should never make offensive comments about people; this could be seen as ‘cyber-
bullying’ and would be a serious matter which could lead, for instance, to the British Council terminating
its association with you or which could be a disciplinary offence.

11. IT and telecommunications

Using our systems


If you use the British Council’s IT and telecommunications equipment and systems you must adhere to
the standards set out in our Acceptable Use of IT Systems Policy. This includes controlling access and
avoiding inappropriate use of the British Council’s hardware, software, internet and email. You should be
provided with a copy of the Acceptable Use of It Systems Policy.

12. Gifts, entertainment and payments

Avoiding unethical rewards and inducements


In carrying out your duties, you should not seek to gain advantage by giving or accepting any improper
gifts, entertainment or payments. We do not tolerate any level of corruption.
You should always be sure that your conduct is ethical, would be justifiable under internal or external
review or assessment by individuals or organisations, and can stand up to examination by those the
British Council is accountable to.

No gifts or services
When dealing with existing or potential contacts on behalf of the British Council, you must never give
or accept any gift or service which has financial value or could be viewed as a reward or inducement
for business. A gift may be accepted if it has only a nominal value, is a genuine token of thanks and is
declared to the ESM.

Where you have reason to think that a polite refusal may cause offence or damage the British
Council’s interests, you should consult the ESM, who can consult the Gifts and Hospitality Policy.

No other payments without consultation


Depending on where in the world you are working, you may find yourself in a situation where these
principles are in conflict with local business practices, for example on facilitation payments.
This is a difficult area and the following guidance is designed to help you to deal with this dilemma. You
must always behave with honesty and integrity when dealing with business contacts and public officials,
and must not offer or give them inducements, tips or payments. If you find yourself in difficulty, you
must consult the ESM or Country Exams Manager (CEM) for advice.

13. Conflicts of interest

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Separating the personal from the professional
To maintain our standards of integrity, it is important to avoid any activities that are in conflict or
competition with the British Council’s business or are, in some other way, prejudicial to its interests.
You should never use your position in the British Council for personal advantage or gain. If you think
that there may be a potential conflict of interest, you should follow the guidance set out below.

Outside business interests


For example, if you run your own business, hold directorships or trusteeships, or have any interests in
the businesses of existing or potential British Council clients, competitors or suppliers, you should inform
ESM in writing by completing a self-declaration form available from the exams centre you are associated
with.

If the British Council feels that there is a conflict, we may ask you to give up your association with us, or
restrict your involvement on our behalf.

The business interests of family members may also create conflicts. If you think that this might be the
case, you should ask the advice of the ESM, who will consult with the CEM or Country Director as
required.

Outside work or employment


If you want to take up any similar paid employment outside the British Council, you should first
discuss this with the Exams Administrator or ESM, to ensure to ensure the work is not likely to either
create a conflict of interest or adversely affect your ability to carry out your British Council work
effectively.

14. Duty of disclosure

Telling us what we need to know


As well as disclosing any outside activities which may be in conflict with the British Council’s interests
(see principle 16 below), you also have a duty to disclose the following.

Bankruptcy and Legal proceedings


If you are declared bankrupt, involved in legal proceedings or have any criminal convictions that may
affect your suitability for certain activities (working with children and young people, for example), or
which may discredit the British Council or bring it adverse publicity, you must report these. You should
declare these using the disclosure form which you can obtain from the examinations office and may be
asked to give details of the case.

Other situations
You may find yourself in another situation where non-disclosure might prejudice the British Council’s
interests. If you think that this might be the case or you’re unsure, talk to your ESM.

Confidentiality
All disclosures will be treated in confidence by the British Council. If there is in any doubt about how to
deal with the information you have disclosed, any information shared, will be on ‘a need to know’ basis in
consultation with Human Resources.

15. Personal relationships at work

Being professional about relationships

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When people form close personal relationships at work it is not usually the business of the British
Council to interfere with them. However, our conduct and performance at work should not be adversely
affected by such relationships with colleagues, candidates or suppliers.

To avoid bias and conflicts of interest, we should not work in the immediate management line as
colleagues who are partners or relatives.

If you do have a close personal relationship with a colleague working in the exams department or taking
an exam that is delivered by the British Council, you should let the ESM know. Similarly, if you have a
personal relationship with someone who reports to you, you should tell the Exams Administrator or
ESM. Where this is the case, the information will be treated in confidence.

16. Recruiting relatives and friends

Giving everyone the same opportunities


If you receive a query or request regarding employment from a friend or relative, you must speak to
someone in the exams office for advice and agreement of the ESM before encouraging their application
or any appointment or job offer is made.

Agreement will usually be given so long as the appointment does not compromise the integrity and
independence of the financial or other management control systems in place in the office or workgroup
concerned.

If your partner, relative or friend is recruited, these control systems may need to be altered to make sure
that the necessary separation of duties is maintained.

17. Dealing with wrongdoing

Raising Concerns
The British Council is committed to upholding the highest ethical and legal standards and has zero
tolerance for malpractice or wrongdoing anywhere in the organisation and is extremely important in
the examinations work we do. To deal with this, we want people to feel that they can speak-up and
raise concerns about wrongdoing confidentially, and our Raising Concerns Policy enables us to do
this.

Examples of malpractice or wrongdoing include child abuse, theft, fraud, facilitating cheating, false
accounting, misuse of assets, receiving bribes, failing to disclose outside business interests, and
breaches of regulatory requirements, as well as breaches of this code of practice and other British
Council policies.

If you become aware of, or suspect, any serious wrongdoing, you must report it as soon as possible to
the ESM or someone else in the examinations team. Do not confront the suspected perpetrator, discuss
the case with colleagues, anyone outside the British Council, or try to conduct your own investigations.

If you feel unable to discuss the matter with the ESM, or you still have concerns, you should contact the
CEM or Country Director.

Please note: if you ask for your identity to be protected, it will not be disclosed without your consent
unless in response to a legal requirement. Concerns should not be raised to pursue private disputes,
and malicious false allegations will be regarded as a serious matter which could lead, for instance, to the

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British Council terminating its association with you or which could be a disciplinary offence.

Breaches of this code

This code is in everyone’s interests and you must familiarise yourself with it, refer to it and follow it.

Please be aware that breaches of this code can lead to action under the disciplinary procedure
applicable in the British Council office with which you are associated, and serious breaches will result in
suspension of any agreements we have with you. All breaches will be investigated before formal
disciplinary action is taken. Investigations will take account of all the relevant circumstances, including
the seriousness of the breach and the guidance which had been provided to the people concerned.

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