Policies

CANCELLATIONS AND REFUNDS POLICY

Places will be confirmed and, when applicable, course materials will be sent, only after payment is received. Once payment is received Student Services will email a booking confirmation.
• Cancellations of confirmed places are accepted up to 10 working days prior to the start of the course. An administration fee of 30 € plus the full cost of the study materials supplied will be deducted and the remainder of the course fee refunded to the payee.
• Transfers of a confirmed booking either to another course or student can be made up to 10 working days before the course start date on payment of a 30 € administration fee plus the cost of any additional study materials which might be required.
• If a confirmed course booking is cancelled later than 10 working days prior to the start of the course, or at any time after the start of the course, no refund or transfer of the course fees will be made.
• Examination dates are fixed to the course onto which you book and any transfer to an alternative date will incur an administration fee of 30 €. All transfer requests must be made in writing or by email to ana@wineway.org at least 10 working days before the original examination date.
• Failure to attend booked examinations, or transfers requested later than 10 working days before the start of the course, will result in the student being liable to subsequent examination fees.
• All transfers of courses and examination dates are subject to availability.
• Course fees will be refunded in full if Wine Way changes a course date or cancels a course if enrollments do not reach the required minimum numbers – notification will be made at least 10 working days prior to the planned start date of the course.
• Students requiring special examination conditions must submit their request 5 weeks before starting the course. Such requests must be supported by a doctor’s certificate or similar document.
• No refund will be offered if the following circumstances apply:
– students are unable to attend a course due to changes in personal circumstances;
– students are unable to attend a course due to travel problems caused by unfavorable weather or cancellations by travel operators.
Wine Way does not compensate for travel or accommodation expenses should a course be canceled or rescheduled for an alternative date.

Course Cancellations

Wine Way reserves the right to cancel or change a course date. In these very rare circumstances, Wine Way will normally arrange an alternative date and offer students either a transfer to this new date or, if this date is not convenient an alternative course. If neither is possible, a full refund will be offered.
Students must fill out a course cancellation form to be approved by the Wine Way.
* The Course Cancellation Form is available upon a request. Please contact us at ana@wineway.org
Wine Way will offer students a transfer to another course in exceptional circumstances, and if the students confirmed enrollment can be resold to another student. A 30 € administrative fee will be charged.
Further information about the cancellations policy is available at ana@wineway.org

Adverse Weather Conditions

If adverse weather conditions or natural disasters have affected the mode of transport needed to attend a booked course at Wine Way and you are unable to be present, please note the following procedures:
• Please notify the Wine Way Team, by phone or email, as far in advance as possible that you will not be able to attend (e.g. if flights have been canceled in advance, etc.)
• If you are unable to attend a booked course due to the weather or natural disaster conditions, we will offer a transfer to another course for a 30 € administration fee. This will apply ONLY if roads are unsurpassable or trains and flights are canceled, which will be determined at the sole discretion of Wine Way.

International Students

If a VISA is required to enter Macedonia, Wine Way recommends that students book at least three months in advance to allow time for processing of the VISA application. Wine Way will not provide a letter of invitation but will provide students with a letter confirming the booking, to give to the relevant embassy. Refunds will not be offered under any circumstances should a VISA application be declined or delayed.

Instructors

In the unlikely event that the advertised instructor is unable to teach the class, Wine Way reserves the right to substitute the advertised instructor with another appropriate instruct

CONFLICTS OF INTEREST POLICY

Wine Way LLC has a responsibility to identify, monitor and manage all perceived and real conflicts of interest and take reasonable steps to mitigate such adverse effect where it exists.
This policy applies to all Wine Way LLC employees and consultants.

Conflict of Interest categories

Conventional conflicts of interest are situations in which employees may have the opportunity to influence Wine Way LLC business decisions in ways that could or could appear to lead to personal gain or give improper advantage to themselves, their family or associates.
Conflicts of commitment are situations in which employees’ external activities interfere or appear to interfere with their paramount obligations to students, colleagues and Wine Way LLC.

Purpose and Principles

Wine Way LLC operates in the public domain. As such, it has a responsibility to ensure employees identify perceived and real conflict of interest situations so that appropriate action is taken. By addressing any conflict of interest in a responsible manner, the integrity of both the company and the employee can be upheld.
This policy is intended to promote transparency and to create a culture of trust in the company.
The key to managing conflicts of interest is to ensure that they are declared.

POLICY

• Employees are encouraged to participate in external activities that enhance their professional standing. Employees are expected to manage these external interests or activities so that no conflicts of interest arise.
• Employees must act honestly and uphold high ethical standards to maintain and enhance public confidence and trust in the integrity, objectivity and impartiality of Wine Way LLC.
• Employees are obligated to perform their official duties and conduct themselves in a manner that will bear close public scrutiny.
• Employees are obliged to disclose any actual, potential or perceived conflict of interest as soon as it becomes known to them. Disclosure is to be made to the employees’ direct manager. Where it is not certain whether a matter entails a conflict of interest, they shall disclose the matter in accordance with this section.
• Employees shall not provide preferential treatment to relatives, friends or organizations in which they or their relatives or friends have an interest, financial or otherwise, nor shall they supervise or evaluate relatives or persons with whom they have a personal or intimate relationship.
• Except as otherwise provided, employees may not take any employment, consulting or teaching activity outside Wine Way LLC except with the prior written consent of their manager. Consent will not be unreasonably withheld provided there is no conflict of interest. Where it is determined that a conflict of interest exists, Wine Way LLC will respond within a reasonable length of time (within 10 working days) advising of the necessary action to avoid, withdraw from, or otherwise resolve the situation.
• Where consent has been provided, but a potential conflict of interest arises during the activity, it is the responsibility of the employee to immediately raise the potential conflict with their manager. Management team of Wine Way LLC will respond within a reasonable length of time (within 10 working days).
• As part of performance review, managers will review this policy and request that employees acknowledge that they are aware of the policy and are not currently in a conflict of interest situation. If employees believe that they may be in a conflict of interest situation, they are to inform their manager immediately.
• Employees are not to solicit or accept fees, gifts or other benefits that are connected directly or indirectly with the performance of their duties from individuals, organizations or corporations (other than the normal exchange of gifts among friends, the normal exchange of hospitality between persons doing business together, tokens exchanged as part of protocol such as the normal presentation of gifts to persons participating in public functions).
• Wine Way LLC maintains a legal interest in the activities of former employees who, because of their former association with the company, have privileged and confidential knowledge of it’s business and operations that if used or disclosed, could have a detrimental impact.
No employee or former employee may disclose any privileged or confidential information that is not already in the public domain without seeking explicit permission from the company to do so. It is understood that any such disclosure could have a detrimental effect on the Wine Way LLC.
• Violations of this policy will be subject to discipline. Legal action may be taken against any employee, organization or entity in circumstances where the breach of this policy results in any type of loss or damage to Wine Way LLC.
Whilst this document describes and provides guidelines for situations in which conflicts
can arise, it is not meant to be exhaustive. If an individual is uncertain about how this Policy
might affect his or her activities or has any questions about its application, s/he should contact
his/her manager in the first instance. Such cases will be handled on an individual basis to ensure that our integrity is not compromised.

Guidance on handling conflict of interest

Any individual engaged with Wine Way LLC is required to inform the Management Team of any potential conflict of interest.
Certain individuals, such as those involved in the examination process are also required to submit a signed declaration of “Non-disclosure”.
It is essential that any real or potential conflict of interest is declared to WSET Awards immediately. Wine Way LLC will welcome any guidance and advice from WSET in dealing with conflict of interest situation.
APP that fails to declare a potential conflict of interest is in breach of WSET Awards criteria for approval, and sanctions may be applied to their approval status because of any such non-disclosure.

Roles and Responsibilities

The Management Team, Petar Velickovic and Ana Stojanova Velickovic are responsible for the overall management and operation of Wine Way LLC. The Management Team will ensure the policy is implemented and that compliance is monitored. They will be responsible for the effective implementation of this policy and resolve any disputes arising over policy interpretation.

Evaluation

This policy will be reviewed every three years.

COMPLAINTS AND APPEALS POLICY

Complaints against any action or practice which threatens the integrity of our courses, either Wine Way staff, representative or student should in the first instance be discussed with APP Wine Way contact.

Wine Way guarantees confidentiality and that the complaint will not prejudice the student.

The APP undertakes to investigate all complaints in a thorough and professional manner. This includes, but is not limited to:

Notifying the complainant that their complaint will be investigated by a named individual within 3 working days;
Informing the complainant of the outcome of the investigation in writing within 20 working days. Where it is not possible to respond within this time frame, a written response will be given providing a date for completion;
Informing the complainant of the appropriate escalation of the complaint if the initial outcome is still unsatisfactory.

An outline of the problem and the main points should be documented and dated.

The complainant needs to provide:

Name, address and contact information;
Full details of the complaint (with any supporting documents);
Details of any previous attempts made to resolve the problem.

If the problem is not resolved at this stage the candidate will be referred to contact a higher authority in The Wine and Spirit Education Trust.

Note: WSET Awards is only able to action complaints from students if they have been

addressed with the APP and the student remains dissatisfied with the level of service and

solutions offered.

Examples of complaints would be:

Dis-satisfaction with teaching, facilities or administration of WSET courses;
Allegations of discrimination or unfair treatment;
Falsifying results, assisting candidates with answers;
Allowing unauthorized material into the exam room e.g. phones, notes etc.;
Allowing candidates to copy from each other;
Disruptive behaviors e.g. talking during the exam.

Complaints against the awarding body

Complaints against the Wine and Spirit Education Trust should, in the first instance, be discussed with the Wine Way contact. Documented evidence will then be forwarded to The Wine and Spirit Education Trust who have their own complaints policy.
Candidates who are unhappy with their exam results can appeal via the Wine Way contact.

REASONABLE ADJUSTMENTS POLICY

A reasonable adjustment is any action that helps to reduce the effect of a disability or difficulty that places the candidate at a substantial disadvantage in the assessment situation.

The Wine Way seeks to conduct the assessment of all candidates in a way that puts them at no disadvantage or advantage over other candidates.

Reasonable adjustments must not affect the integrity of what needs to be assessed, but may involve:

Changing standard assessment arrangements, for example, allowing candidates extra time to complete the assessment activity;
Adapting assessment materials, such as providing materials in large text format;
Providing access facilitators during assessment, such as a sign language interpreter or reader;
Re-organizing the assessment room, such as removal of visual stimuli for an autistic candidate.

Reasonable adjustments are approved or set in place before the assessment activity takes place; they constitute an arrangement to give the candidate access to the qualification.

The use of reasonable adjustment will not be taken into consideration during the assessment of a candidate’s work. Out of fairness to all candidates, evidence of the individual circumstances giving rise to the request must be produced.

The Wine Way will:

identify any special assessment needs at the time of candidate registration;
inform WSET® Awards at the earliest opportunity so that appropriate arrangements can be approved and made;
agree the specific arrangements for the examination, or for marking with WSET® Awards, which will vary according to individual circumstances.

WSET® Awards reserves the right to seek the advice of independent agencies as appropriate in coming to a decision on specific arrangements and must agree before any reasonable adjustments are offered by this APP to its students.

Candidates are required to submit any Requests for Reasonable Adjustments at least 5 weeks before the date of the examination. This APP will forward any Requests for Reasonable Adjustments to WSET® Awards within 5 working days of receipt and WSET® Awards will respond after 4 working weeks after giving the request due consideration.

Candidates and their advisors should also be aware:

that it is not appropriate to make requests for special arrangements where the candidate’s particular difficulty directly affects performance in the actual attributes that are the focus of the assessment.
reasonable adjustments will not give unfair advantage over candidates for whom reasonable adjustments are not being made or alter the assessment demands of the qualification as detailed in the qualification specification

SPECIAL CONSIDERATION POLICY

Wine Way recognizes that students may experience events or conditions that adversely affect their academic performance.

Special consideration is an action taken after an assessment to allow candidates who have been disadvantaged by temporary illness, injury, indisposition or adverse circumstances at the time of the assessment to demonstrate attainment.

If the candidate experiences serious and unavoidable difficulties at exam time, they can consider applying for Special Consideration.

A candidate may be eligible for special considerations if:

Performance in an examination is affected by circumstances beyond the control of the candidate. This may include recent personal illness, accident or examination room conditions;
alternative assessment arrangements which were agreed in advance of the assessment proved inappropriate or inadequate;
the application of special consideration would not mislead the end-user of the certificate.

The supporting evidence should include the following:

identify the circumstances;
include dates and/or the length of the circumstances
explain the severity and impact of the circumstances
clearly describe how the circumstances have adversely affected the capacity for effective study and/or taking the exam
include the date(s) on which you were seen by the professional providing the evidence

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If a candidate is unable to attend an examination for which they have been registered due to circumstances outside their direct control, they should notify Wine Way in writing not later than 3 weeks of the examination date.

In this case, WSET® Awards will be notified in writing within 14 days of the examination date where special consideration is being requested using the Request for Special Consideration Form.

In the case candidate is taken ill during the exam or may not have been fit to make reasonable judgement on their fitness at the time (for example, but not limited to: death in the family, hardship and trauma, unavoidable commitments) – they should advise this APP’s Examination Officer and/or invigilator, who will record the case in the Examination Room Report for the candidate to be able to apply for special consideration.

Alternatively, the candidate can apply for special consideration, no later than 3 days after the exam took place. Please allow time for this APP to pass your request to WSET Awards (within 7 days after the exam took place).

Special consideration is being requested using the Special Consideration Application Form and by submitting written 3rd party evidence to support their application.

Special Consideration Application Form:

Students must complete this form if they wish to demonstrate that illness or other significant circumstances have had an adverse effect on their academic performance and to seek consideration of their circumstances. Applications for special consideration should be made with reference to this Special Consideration Policy which can be found at Wine Way web site.

Eligibility will only be considered if accompanied by supporting independent documentation.

This APP will aim to let the candidate know the outcome of their application via email within 2 weeks of receipt of the application and all necessary supporting evidence.

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In cases of serious disruption during the examination, the Examinations Officer of this APP will submit a detailed report of the circumstances and candidates affected to the Examinations Administrator at WSET® Awards, in addition to the Examination Papers.

It should be noted that WSET® Awards does not offer aegrotat awards and that all assessment requirements of WSET® qualifications must be met.
It is also WSET® Awards and this APP’s policy that special considerations will not give unfair advantage over candidates for whom special considerations are not being applied or alter the assessment demands of the qualification as detailed in the qualification specification.
Failure to attend due to work commitments does not qualify for “special consideration”. The Wine Way will not charge an unused paper fee for applications where approval from WSET® Awards is granted

MALPRACTICE AND MALADMINISTRATION POLICY

The Wine Way Academy will ensure that their programme for the delivery and administration of any WSET qualification complies in all respects to the rules, regulations and procedures set out in the WSET APP Operating Handbook.

All WSET® examinations run by this APP will be administered in line with the Centre Agreement, Code of Practice and Invigilation Instructions provided in the Operating handbook, and Examination Regulations issued to all APPs and Students in the Qualification Specifications.

Failure to abide by these criteria will be considered Malpractice and or Maladministration and may affect our ability to continue teaching WSET qualifications.

Malpractice can arise from any act, omission, event, incident or circumstance that prejudices learners, affects public confidence in qualifications, affects the standards of qualifications which the awarding body makes available or affects the ability of the awarding body to undertake the development, delivery or award of qualifications.

Maladministration relates to a failure by the APP to offer WSET Qualifications in accordance with the rules, regulations and operating procedures set out in the Operating Handbook.

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Programme Providers must have in place procedures for dealing with instances of Malpractice and Maladministration should they arise. These policies will be made available to WSET® Awards upon request, and form part of the criteria which must be met to become an APP.

The headings below list categories of maladministration by the staff of the APP and malpractice by APP staff and/or candidates which may adversely affect the integrity of WSET® qualifications and certification. These examples are not exhaustive and are intended as guidance to APPs and their candidates on the WSET®’s definition of malpractice and maladministration.

Malpractice will include, but is not limited to:

Actual or attempted plagiarism, or cheating, of any nature by candidates;

Use or attempted use of any reference material or electronic devise during a closed book examination;

Disruptive behavior by candidates in the examination;

Candidates in breach of published Examination Regulations and APP in breach of invigilation rules or the Code of Conduct;

Fraudulent use of WSET® certificates;

A deliberate attempt to discredit the WSET®, or to bring the WSET® into disrepute in any way;

Issue of bogus examination results;

Insecure storage of examination papers;

Unauthorized amendment, copying or distribution of examination papers;

Use of unapproved or ineligible educators to deliver a qualification course, or use of un-authorized internal assessors;

Change of examination location or altered facilities so they no longer meet the required standards;

Failure to administer examination in line with the assessment requirements;

Denial of access to resources (premises, records, information, candidates and staff) by authorized WSET® representatives and/or the Regulatory Authorities.

Maladministration will include, but is not limited to:

Failure to follow procedures or adhere to regulations as laid out in the APP Operating Handbook;

Failure to return examination papers within the required timeframe or

Returning exam papers by regular post and not recorded delivery or trackable courier;

Failure to issues results to candidates in a timely manner;

Breach or infringement of WSET® copyright and trademarks;

Non-payment of fees for WSET® services or examinations;

Breach of the Conflicts of Interest Policy

Breach of the Centre Agreement or APP Code of Conduct;

A change in control of the APP that results in new management being unable to meet WSET® Awards criteria.

Malpractice is divided into two main categories:

Major Malpractice

Serious and/or deliberate breaches of conduct, or serious neglect of professional duty, represents a high risk to the integrity of the qualification.

Major Malpractice could result in the invalidation or revocation of examination results to a student and/or approval of the APP. In this instance OfQual must be informed of the malpractice case and WSET® Awards will take all appropriate action as directed by the Regulatory Authority, which may include notification to other Awarding Bodies.

An example of Major Malpractice would be, ‘Fraudulent use of WSET® certificates and the issue of false examination results’ or ‘Unauthorized amendment, copying or distribution of examination papers’.

Minor Malpractice

Minor and/or accidental breaches of conduct or neglect of professional duty, or those more major breaches not considered to be deliberate or malicious in intent, represents a lower risk to the integrity of the qualification and would not affect examination results or certification. Examples of minor malpractice could include, ‘failure to follow procedures laid out in the Operating Handbook’ or ‘Change of examination location or altered facilities so they no longer meet the required standards’.

Reporting Malpractice

This APP will report any potential case of malpractice by candidates, educators, invigilators or Wine Way Academy staff to the Centers Co-ordinator and Quality Assurance Manager at WSET® Awards immediately using the Notification of Potential Malpractice Form.

Failure to do so may result in the refusal to issue results and Certification to candidates, the invalidation of examination results or the withdrawal of approval to offer WSET® qualifications.

Where APP personnel are involved, the APP should follow its own procedures and keep WSET® Awards informed of the steps taken to resolve the situation.

Malpractice may be reported to WSET® Awards by a WSET® Awards appointed Approval Visitor. In this instance the APP will be advised during the approval visit that a case of Malpractice is being reported.

WSET® Awards will also act upon reports of suspected or actual malpractice received from candidates or other parties regarding an APP’s activities or personnel which may affect the integrity of WSET® qualifications.

WSET® Awards responsibility

WSET® Awards will confirm receipt of a report of suspected or actual malpractice within 3 working days.

Should a case of malpractice be raised with WSET® Awards against the Program Provider, the main contact, or other appropriate person within the management of the APP, will be notified and invited to respond prior to further action being taken. Notwithstanding the foregoing, WSET® Awards reserves the right to immediately suspend an APP’s approval if, after consultation with the WSET’s Chief Executive, it is decided that such a suspension is required to protect the reputation of the WSET, and to prevent any possible re-occurence of the alleged malpractice. In such circumstances, the APP will be notified immediately and will be required to co-operate with the WSET® whilst the alleged malpractice is investigated.

WSET® Awards will appoint a suitably trained officer to investigate the alleged malpractice and this officer will request supporting evidence from the APP, Candidate or other parties to validate the report of suspected or actual malpractice.

When supporting evidence has been supplied, WSET® Awards will conduct a full investigation of the suspected or actual malpractice to identify the cause and to determine whether malpractice has occurred.

Where it is determined that malpractice has occurred, a report will be filed. This will include whether the malpractice is accidental or deliberate and represents a major or minor threat to the integrity of the qualification and specify any sanctions that are to be applied to the APP, their staff or the candidate concerned. If malpractice has been alleged against a candidate, a summary of the investigation and the findings will be sent to the candidate; if the malpractice has been alleged against the APP the summary will be sent to the Main Contact, and the candidate or APP Main Contact will be advised of the sanctions being imposed. They will also be advised of the General Appeals Policy should they wish to appeal the decision that has been made.

Any case of malpractice that threatens the integrity of the qualification, results issued, or certification will be reported to the Regulatory Authority, and following discussion with the Regulatory Authority, other Awarding Bodies may be notified.

Where the report is the result of an internal investigation by the APP, WSET® Awards will review all the documentation supplied and action taken to ensure that any decisions made by the APP are valid and conform to this policy. WSET® Awards may request additional information to determine whether any additional sanctions should be applied to the APP, their staff or the candidate concerned.

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Our responsibility as the Wine Way Academy which we agree to carry out in full

The examiner/tutor is responsible for ensuring that all staff involved in the delivery and / or administration of the WSET® program run it in accordance with the rules, regulations and procedures set out in this manual, and are aware of, and comply with, this policy.

The APP must also establish their own framework of controls and checks that in their opinion is adequate to minimize and identify any instances of malpractice and is fit for purpose of reporting and investigating any alleged malpractice.

(Note: Should an APP require help in establishing a framework that will prevent, investigate and deal with Malpractice, please contact awards@wset.co.uk)

The main Contact agrees to co-operate fully with WSET® Awards in any investigation of alleged malpractice at the APP including the removal and / or suspension of staff from their WSET® duties during such investigation.

Sanctions

In cases of alleged malpractice or maladministration WSET® Awards has the right to apply sanctions. This may include suspend an APP’s approval with immediate effect if such action is approved by the Chief Executive of the WSET® whilst an investigation is carried out.

Following an investigation by WSET® Awards, it may be necessary to apply one or more of the following sanctions against the APP and/or their staff.

Creation of an action plan / letter of warning;
Completion of a self-assessment form by the APP;
Completion of an APP re-approval visit (travel costs may be charged to the APP);
Mandatory re-training of educators and / or assessors;
Application of administration charges;
Withdrawal of internal assessment permissions;
Invalidation of examination results / certification;
Withdrawal or temporary suspension of approval to offer a specific WSET® qualification;
Withdrawal or temporary suspension of approval to offer all WSET® qualifications;
Withholding examination results that are under investigation;
Rejection of orders for further materials or examination papers;
Withdrawal of credit facilities, and moving account to a “cash on order” basis;
Charging of interest on overdue amounts.

Where previously agreed corrective measures are not implemented, the sanctions will progress to the next level of severity following the guidelines of the NVQ Code of Practice.

It is WSET Awards intent that no learner should be disadvantaged by any instance of malpractice or maladministration that has arisen by the actions (or non-action) of the APP. However, where such breach undermines the integrity of the assessment process, it may be necessary to invalidate the exam that has been held and require the APP to arrange a free resit for candidates at their convenience.

Following an investigation by WSET® Awards, it may be necessary to apply one of more of the following sanctions against an individual candidate or candidates.

Letter of warning;
The disallowing of an examination result;
The invalidation of a certificate and/or unit certificate and recall of certification already issued;
Refusal of entry to future WSET® qualifications.

All decisions regarding malpractice will be communicated in writing within 20 working days following receipt of supporting documentation. Where it is not possible to respond within this timeframe, a written response will be given providing a date for completion.

Any candidate, educator, invigilator or APP has the right to appeal any decision made against them using the General Appeals section, or as detailed in the WSET® Customer Service Statement.

DIVERSITY AND EQUALITY POLICY

Wine Way is committed to upholding the principles of diversity and equality in all areas of its work, seeking to ensure that all candidates are always treated fairly and equally.

This policy applies to all Wine Way staff and to any individual acting on behalf of Wine Way.

EQUAL OPPORTUNITIES POLICY

Equal Opportunities are assured by:

ensuring there are no barriers to entry the courses/qualifications, which we deliver and/or offer, for disabled people, women or men, or people from different racial groups, other than those directly related to the integrity of the qualifications.

The nature of any barriers will be stated and the inclusion of the requirements that create the barrier justified only and explicitly in terms of the integrity of the qualification.

Details of how the effect of any barriers will be mitigated will be recorded, including using access arrangements or including reasonable adjustments;

making every effort to ensure that there is equality of opportunity in its assessment process, regardless of the candidate’s gender, age, racial origin, religious persuasion, sexual orientation or disability;
the selection, recruitment and training of those working for this APP;
clarifying the responsibility of all members of staff and/or consultants who are involved in the delivery of WSET courses within this APP, to comply with this policy;
promoting practices and procedures that give equal opportunities to everyone;
the variation of any conventional rules and regulations for the conduct of examinations which might inhibit the performance of candidates with specific needs, provided that the standard, quality and integrity of the assessment is not compromised;
working as appropriate with relevant organizations and agencies to develop measures to identify and prevent inequality of opportunity;
ensuring, to the best of our ability, that any documentation produced does not contain language or images which may be regarded as offensive or stereotypical, and that they reflect the diversity of contemporary society;
being required to have equal opportunity policies in place.

This APP is an equal opportunities organization and will consider applications from any organization or individual who can demonstrate that they meet our approval criteria.

Monitoring

Wine Way will comply with all current and relevant legislation and this policy will be monitored and reviewed annually. At the time of writing relevant legislation includes, but is not limited to:

The Constitution of the Republic of Macedonia, Article 9
The Department for Equal Opportunities at the Ministry of Labor and Social Policy founded 2007

As part of the monitoring of candidates registering for a WSET® qualification we will collect information on diversity, requests for special consideration, access arrangements and feedback from students.

NOTE TO CANDIDATES:Candidates who believe they have been discriminated against should contact us in the first instance for advice.

Data Protection Policy

Pursuant to Article 75, Paragraphs 1 and 2 of the Constitution of the Republic of Macedonia – the Law on Personal Data Protection was passed on January 25th, 2005

Based on the Law on Personal Data Protection (“Official gazette of Republic of Macedonia” no.7/2005. 103/2008 and 124/2010), and in compliance with the Rulebook on Technical and Organizational Measures for Providing Secrecy and Protection of Personal Data Processing (“Official gazette of Republic of Macedonia” no.38/2009 and 158/2010), the management team of Wine Way LLC prepared:

Data Protection Policy

Key Details

Policy prepared and approved by management team of Wine Way LLC
Policy became operational on: 01.09.2018
Next review date: 01.09.2019

Introduction

Wine Way LLC needs to gather and use certain information about individuals.

These can include students, customers, suppliers, business contacts, employees and other people the Academy has a relationship with or may need to contact.

This policy describes how this personal data must be collected, handled and stored to meet the company’s data protection standards – and to comply with the law.

Why this policy exists

This data protection policy ensures Wine Way LLC:

Complies with data protection and follows good practice
Protects the rights of staff, students, customers and partners
Is open about how it stores and processes individuals’ data
Protects itself from the risks of a data breach

Data Protection Law

The Data Protection Law recognizes that organizations – including Wine Way LLC – must collect, handle and store personal information.

These rules apply regardless of whether data is stored electronically, on paper or on other materials.

To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully. Personal data must:

Be processed fairly and lawfully
Be obtained only for specific, lawful purposes
Be adequate, relevant and not excessive
Be accurate and kept up to date
Not be held for any longer than necessary
Processed in accordance with the rights of data subjects
Be protected in appropriate ways
Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures adequate level of protection

People, Risks and Responsibilities

Policy Scope

This policy applies to:

The Head Office of Wine Way LLC
All future branches of Wine Way LLC
All staff of Wine Way LLC
All contractors, suppliers and other people working on behalf of Wine Way LLC

It applies to all data that the company holds relating to identifiable individuals. This can include:

Name of the individual
Date of birth
Postal addresses – home and business
Email addresses
Telephone numbers
Job position
Information disclosed in regards with the Special consideration policy
Information disclosed in regards with the Reasonable adjustment policy
Any other information in relation to the individual

Data Protection Risks

This policy helps to protect Wine Way LLC from some very real data security risks, including:

Breaches of confidentiality. For instance, information being given out inappropriately.
Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.

Responsibilities

Everyone who works for or with Wine Way LLC has some responsibility for ensuring data is collected, stored and handled appropriately.

Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.

However, these people have key areas of responsibility:

The Management Team Petar Velickovic and Ana Stojanova Velickovic are ultimately responsible for ensuring that Wine Way LLC complies with data protection principles.
The Data Protection Officer, Ana Stojanova Velickovic, is responsible for:
Keeping the management team updated about data protection responsibilities, risks and issues.
Reviewing all data protection procedures and related policies, in line with an agreed schedule.
Arranging data protection training and advice for the people covered by this policy.
Handling data protection questions from staff and anyone else covered by this policy.
Dealing with requests from individuals to see the data Wine Way LLC holds about them (‘subject access requests’).
Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
The IT team is responsible for:
Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
Performing regular checks and scans to ensure security hardware and software is functioning properly.
Evaluating any third-party services, the company is considering using to store or process data. For instance, cloud computing services.
Regarding the marketing, Ana Stojanova Velickovic, is responsible for:
Approving any data protection statements attached to communications such as emails and letters.
Addressing any data protection queries from the media.
Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.

General Staff Guidelines

The only people able to access data covered by this policy should be those who need it for professional use, and exclusively for the needs of Wine Way LLC.
Data should not be shared informally. When access to confidential information is required, employees can request it from their managers.
Wine Way LLC will provide training to all employees to help them understand their responsibilities when handling data.
Employees should keep all data secure, by taking sensible precautions and following the guidelines below.
Strong passwords must be used, and they should never be shared.
Personal data should not be disclosed to unauthorized people, either within the company or externally.
Data should be regularly reviewed and updated. If no longer required, it should be deleted and disposed of.
Employees should request help from the Data Protection Officer if they are unsure about any aspect of data protection.

Data Storage

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the Data Protection Manager.

When data is stored on paper, it should be kept in a secure place where unauthorized people cannot see it. These guidelines also apply to data that is usually stored electronically but has been printed out:

When not required, the paper or files should be kept in a locked drawer of filing cabinet.
Employees should make sure paper and printouts are not left where unauthorized people could see them.
Data printouts should be shredded and disposed of securely when no longer required.

When data is stored electronically, it must be protected from unauthorized access, accidental deletion and malicious hacking attempts:

Data should be protected by strong passwords that are changed regularly and never shared between employees.
If data is stored on removable media (like CD, USB, external hard drive), these should be kept locked away securely when not being used.
Data should only be stored on designated drives and services and should only be uploaded to an approved cloud computing services.
Data should be backed up frequently, on the end of each working week.
Data should never be saved directly to laptops or other mobile devices like tablets or smartphones.
All servers and computers containing data should be protected by security software and a firewall.

In compliance with the Article 20 of the Rulebook on Technical and Organizational Measures for Providing Secrecy and Protection of Personal Data Processing, after transferring the personal data from the media, or after the period for its storage, media needs to be destroyed or erased:

Destroying of the media by mechanical separation of its part, after which they cannot be restored or reused.
Erasure of the media should be done in a way that further reconstruction of recorded personal data will not be possible.

Data Use

Personal data is of no value to Wine Way LLC unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:

When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
Personal data should not be shared informally. It should never be sent by email, as this form of communications in not secure.
Data must be encrypted before being transferred electronically. The IT team can explain how to send data to authorized external contacts.
Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.

Data accuracy

The law requires Wine Way LLC to take reasonable steps to ensure data is kept accurate and up to date.

It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.

Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
Staff should take every opportunity to ensure data is updated. For instance, by confirming a student’s details when they call.
Wine Way LLC will make it easy for data subjects to update the information Wine Way LLC holds about them.
Data should be updated as inaccuracies are discovered. For example, if a student can no longer be reached on their stored telephone number, it should be removed from the database.
Marketing databases need to be checked against industry suppression files every six months.

Subject Access Requests

All individuals who are the subject of personal data held by Wine Way LLC are entitled to:

Ask what information the company holds about them and why.
Ask how to gain access to it.
Be informed how to keep it up to date.
Be informed how the company is meeting its data protection obligations.

If an individual contact the company requesting this information, this is called a ‘subject access request’.

Subject access request from individuals should be made by email, addresses to the Data Protection Officer at ana@wineway.org

The Data Protection Officer will aim to provide the relevant data within 3 working days.

The Data Protection Officer will always verify the identity of anyone making a subject access request before handling over any information.

Disclosing Data for other Reasons

In certain circumstances, the Data Protection Law allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.

Under these circumstances, Wine Way LLC will disclose requested data. However, the Data Protection Officer will ensure the request is legitimate, seeking assistance from the company’s legal advisers where necessary.

Providing Information

Wine Way LLC aims to ensure that individuals are aware that their data is being processed, and that they understand:

How the data is being used
How to exercise their rights

To these ends, the company has a privacy statements, setting out how data relating to individuals is used by the company.