Investigation Service Terms

1. About these Terms

1.1. These Investigation Service Terms ("Terms") govern the submission of concerns to, and the provision of investigations by, the Investigation Service operated by The CPD Register Ltd at https://thecpdregister.com/report (the "Investigation Service").

1.2. The Investigation Service is operated by The CPD Register Ltd, a company registered in England and Wales under company number 13075495, with its registered office at International House, 6 South Molton Street, London W1K 5QF (referred to in these Terms as "we", "us", or "The CPD Register").

1.3. By submitting a concern to the Investigation Service, you ("you", the "Submitter") agree to be bound by these Terms. If you do not agree to these Terms, you must not submit a concern.

1.4. These Terms sit alongside our Website Terms of Use and our Privacy Policy, both of which apply to your use of the Investigation Service. Where there is any inconsistency between documents, these Terms take precedence in relation to the Investigation Service.

2. What the Investigation Service is

2.1. The Investigation Service is a free, voluntary service we provide in the public interest to members of the public, CPD Training Providers, CPD consumers, and other parties who have concerns about:

• •A CPD Accreditation Organisation
• •A CPD course, activity, or accreditation scheme
• •A CPD certificate or trustmark they have been presented with
• •The conduct of a training provider or practitioner in connection with CPD accreditation

2.2. On receipt of a concern, we carry out an independent investigation using publicly available information and, where appropriate, correspondence with the parties concerned. We produce a written report of our findings and recommendations, which is sent to the Submitter.

2.3. The Investigation Service is provided free of charge to all Submitters, regardless of whether they are consumers, training providers, or other parties.

2.4. The Investigation Service is provided in the public interest. Its purpose is to support informed decision-making by CPD consumers and training providers, and to contribute to transparency in the CPD accreditation sector.

3. What the Investigation Service is NOT

3.1. To avoid any misunderstanding, the Investigation Service is not, and must not be treated as:

3.1.1. A statutory regulatory function. We are not a regulator. Submitting a concern to the Investigation Service is not equivalent to, and does not replace, filing a complaint with:

• •The Advertising Standards Authority for advertising complaints
• •Trading Standards for consumer protection complaints
• •The Information Commissioner's Office for data protection complaints
• •The Competition and Markets Authority for competition or consumer market complaints
• •Action Fraud or the Police for suspected criminal conduct
• •A relevant professional regulator where one applies

Where a concern falls within the jurisdiction of a statutory regulator, we strongly recommend that you submit the concern directly to that regulator, whether or not you also submit it to us. Doing so preserves your rights and protects any statutory time limits that may apply.

3.1.2. A legal service. We are not solicitors or legal advisers. Our investigations and reports do not constitute legal advice. If you need legal advice, you should consult a qualified solicitor.

3.1.3. A guarantee of outcome. Submitting a concern does not guarantee that we will investigate, that the investigation will reach findings favourable to you, that any action will be taken as a result of the investigation, or that any remedy, redress, or compensation will follow.

3.1.4. A financial recovery service. We cannot recover money, secure refunds, or obtain compensation on your behalf. Where your concern involves financial loss, we may be able to identify routes for you to pursue recovery, but we do not pursue recovery ourselves.

3.1.5. A confidential counselling or support service. The Investigation Service is not designed to provide emotional support, advocacy, or counselling. If you are experiencing distress, we strongly encourage you to contact appropriate support services.

4. Who can submit a concern

4.1. The Investigation Service is open to submissions from:

• •CPD consumers who have received training, a certificate, or a course in connection with CPD accreditation
• •CPD Training Providers who have engaged or are considering engaging with a CPD Accreditation Organisation
• •Professional bodies, employers, and regulators
• •Members of the public with concerns about conduct in the CPD accreditation sector
• •Journalists, researchers, and others with a public-interest concern

4.2. Anonymous submissions are accepted, but may be more difficult for us to investigate fully because we may be unable to contact you for clarification or further evidence. We recommend that you provide contact details, even if you request that your identity is not disclosed in any subsequent communications with third parties.

5. What kinds of concerns are within scope

5.1. The Investigation Service covers concerns about:

• •The standing, operations, or conduct of a CPD Accreditation Organisation
• •The validity of a CPD accreditation, certificate, or trustmark
• •Misleading or unsubstantiated claims made by CPD Accreditation Organisations or training providers in connection with accreditation
• •Patterns of conduct in the CPD accreditation sector that raise concerns about consumer protection or professional standards
• •Other matters directly connected to the functioning of the CPD accreditation sector in the UK

5.2. The Investigation Service does not cover:

• •Personal employment disputes or grievances
• •Commercial disputes unrelated to CPD accreditation
• •Complaints about the content or quality of a course itself (as opposed to concerns about its accreditation)
• •Matters entirely outside the CPD accreditation sector
• •Vexatious or abusive submissions
• •Submissions made for commercial advantage over a competitor that do not raise genuine consumer-protection concerns

5.3. We reserve the right to determine, at our sole discretion, whether a particular submission is within the scope of the Investigation Service. Where a submission is out of scope, we will notify the Submitter, and where possible we will signpost to appropriate alternative routes.

6. How to submit a concern

6.1. Concerns should be submitted through the form at https://thecpdregister.com/report or by email to [email protected].

6.2. A submission should include:

• •Your name and contact details (unless you are submitting anonymously)
• •The organisation, course, certificate, or party your concern relates to
• •A clear description of the concern
• •Any supporting evidence, such as certificates, correspondence, website URLs, or screenshots

6.3. We acknowledge receipt of submissions within two working days.

6.4. Where a submission is unclear or incomplete, we may request further information. We cannot begin a substantive investigation until we have enough information to understand the concern.

7. Our investigation process

7.1. On receipt of a submission, we conduct an initial assessment to determine whether the submission is within scope and whether we have sufficient information to investigate.

7.2. Where we proceed with an investigation, we typically:

• •Review the evidence you have provided
• •Conduct independent desk research using public sources, including Companies House, the Information Commissioner's Office register, regulatory records, court records, and publicly available information about the parties concerned
• •Where appropriate, contact the organisation or party concerned to invite their response to the matters raised
• •Review information already held by us, such as existing public Register listings

7.3. We aim to complete investigations within 30 working days of receipt of a complete submission. Where an investigation is likely to take longer — for example, because it is particularly complex or requires extended correspondence with third parties — we notify the Submitter and provide an updated timeframe.

7.4. Our investigations are conducted using publicly available information and voluntary correspondence. We have no powers of compulsion. We cannot require any party to provide information, attend interviews, or respond to questions. Where a party declines to engage with our investigation, we record that fact and continue with the information available.

7.5. The depth and scope of each investigation is determined by us based on the nature and seriousness of the concern. Minor or narrow matters may be investigated briefly; matters of broader significance may be investigated more extensively. The Investigation Service is a public-interest service with finite resources, and we allocate those resources based on the likely public-interest benefit of each investigation.

8. The written report

8.1. On completion of an investigation, we produce a written report and send it to the Submitter.

8.2. The report sets out:

• •A description of the concern
• •The scope of the investigation we conducted
• •The evidence we considered
• •Our findings against the concerns raised
• •Any recommendations we consider appropriate
• •Where applicable, signposting to regulators, legal routes, or other bodies the Submitter may wish to approach

8.3. The report is provided to the Submitter only. We do not publish reports as a matter of course, and we do not share them with the party who was the subject of the investigation unless we consider it appropriate to do so.

8.4. Ownership and use of the report. The report is provided for the Submitter's personal use, including for the purpose of pursuing any regulatory, legal, or commercial action they choose to take. The Submitter may:

• •Share the report with their own professional advisers (solicitors, accountants, etc.)
• •Submit the report as part of a complaint to a regulator, court, or other body with authority to consider it
• •Reference the report in their own dealings with the organisation concerned

8.5. The Submitter may not:

• •Publish the report publicly (for example, on social media or on a website), without our prior written consent
• •Use the report for commercial advantage unrelated to the subject matter of the concern
• •Alter, edit, or misrepresent the content of the report

8.6. We retain copyright in the report. The Submitter is granted a limited, non-exclusive licence to use the report for the purposes set out in clause 8.4.

8.7. Status of the report. The report represents our findings based on the information available to us at the time of the investigation. It is not a legal judgment, a regulatory ruling, or a determination of any party's rights or obligations. Weight given to the report in any downstream process (regulatory, legal, or commercial) is a matter for the body considering it.

9. Referrals to regulators and other bodies

9.1. Where, in the course of an investigation, we identify matters that appear to us to warrant consideration by a statutory regulator, enforcement body, or other authority, we may refer those matters separately to the body concerned.

9.2. Referral decisions are made at our discretion based on the nature, seriousness, and apparent jurisdiction of the matters identified. Factors we take into account include:

• •Whether the matter falls within the jurisdiction of a particular regulator
• •The seriousness of the concerns raised
• •Whether the Submitter appears to have the capacity to pursue the matter themselves
• •Whether delay in referral would cause further harm
• •The public-interest benefit of a referral

9.3. Where we make a referral, we typically:

• •Notify the Submitter that we have done so
• •Provide the regulator or body with a copy of the relevant parts of the report and any supporting evidence that is appropriate to share
• •Identify the Submitter to the regulator where necessary for the referral to be effective, and where the Submitter has consented (or where we have a lawful basis to do so without consent, for example in circumstances of serious concern)

9.4. Where we do not make a referral, we may still recommend that the Submitter consider making one themselves. Our decision not to refer does not prevent the Submitter from referring the matter directly.

9.5. We do not make referrals for purposes unrelated to the concerns raised in the submission, and we do not use the Investigation Service as a source of general intelligence for unrelated activities.

10. Confidentiality

10.1. We treat the identity of Submitters as confidential within the following limits:

10.1.1. We do not disclose the Submitter's identity to the organisation or party that is the subject of the investigation unless:

• •The Submitter has consented to disclosure
• •Disclosure is necessary to enable the party to respond substantively to a specific matter (in which case we seek the Submitter's consent in advance where practical)
• •We are required to disclose by law, by court order, or by a regulator with authority to compel disclosure

10.1.2. We may disclose the Submitter's identity to a regulator or other body to whom we are making a referral, where disclosure is necessary for the referral to be actioned. Where practical, we seek the Submitter's consent before doing so.

10.1.3. We may need to disclose the Submitter's identity where a serious safeguarding or safety concern arises, including where there is a risk of significant harm to an individual or where criminal conduct appears to be in progress. In such circumstances, we may refer to the Police or safeguarding authorities without the Submitter's consent.

10.2. The content of a submission — the concerns raised, the evidence provided — may be shared with the party who is the subject of the investigation where necessary to enable them to respond. We do not share the full submission where it is not necessary to do so, and we do not share material that appears to be privileged, private, or irrelevant to the investigation.

10.3. Submissions, investigation records, and reports are retained by us for a period consistent with our data retention policy, which is set out in our Privacy Policy.

11. Personal data

11.1. In providing the Investigation Service, we process personal data about the Submitter, about the party that is the subject of the investigation, and sometimes about third parties whose information is contained in the submission.

11.2. The lawful bases on which we process this personal data are:

• •For the Submitter's personal data: the performance of the service requested by the Submitter (Article 6(1)(b) UK GDPR) and the pursuit of our legitimate interests in providing a public-interest investigation service (Article 6(1)(f) UK GDPR)
• •For the subject party's personal data: the pursuit of our legitimate interests in providing a public-interest investigation service, in the context of transparency and consumer protection in the CPD accreditation sector (Article 6(1)(f) UK GDPR)
• •For third party personal data: the pursuit of our legitimate interests where such data is necessary to investigate the concern raised

11.3. Special category data. Where a submission involves training related to health, therapy, or other sensitive fields, submissions may inadvertently include special category personal data under Article 9 UK GDPR. Submitters should avoid including such data where it is not necessary to the concern raised. Where we receive it, we process it on the basis of substantial public interest (Article 9(2)(g) UK GDPR, read with Schedule 1 of the Data Protection Act 2018) or, where that basis does not apply, on the basis of explicit consent.

11.4. Third-party personal data. Submitters must not include personal data about third parties that they do not have a lawful basis to share. Submitters are responsible for the lawfulness of the data they submit to us. Where we identify that personal data in a submission has been shared without a lawful basis, we may redact or remove it from the investigation.

11.5. Individuals whose personal data is processed through the Investigation Service have the rights set out in the UK GDPR, including (where applicable) the right of access, the right to rectification, the right to object to processing, the right to restriction of processing, and the right to erasure. The exercise of these rights is subject to the limitations set out in the UK GDPR, including where processing is necessary for reasons of substantial public interest.

11.6. Further information about how we handle personal data, including retention periods and contact details for the Information Commissioner's Office, is available in our Privacy Policy.

12. What we do not accept

12.1. We do not accept submissions that:

• •Contain threats, abuse, or harassment directed at any party
• •Are manifestly vexatious, malicious, or made in bad faith
• •Have been made repeatedly about the same matter after a previous investigation has been closed, unless there is new evidence
• •Are made for the purpose of commercial advantage over a competitor without a genuine consumer-protection concern
• •Seek to use the Investigation Service to pursue a personal grievance unconnected to CPD accreditation

12.2. Where we determine that a submission falls within any of these categories, we may decline to investigate and inform the Submitter accordingly. We reserve the right to retain a record of such submissions and, in cases of abusive or threatening conduct, to report the matter to the Police.

13. What Submitters commit to

13.1. By submitting a concern, the Submitter confirms that:

• •The information provided is, to the best of their knowledge, true and accurate
• •The concern is raised in good faith and is not made maliciously, vexatiously, or for commercial advantage unrelated to consumer protection
• •They have a lawful basis for sharing any personal data included in the submission
• •They have not been compelled by a third party to make the submission
• •They are over 18 years of age, or are submitting with the knowledge and consent of a parent or guardian

13.2. Submitters are asked to notify us if, during the course of an investigation, they become aware that:

• •Information they previously submitted was inaccurate or incomplete
• •They have separately referred the matter to another body (such as a regulator or the Police)
• •They no longer wish us to continue with the investigation

14. Our obligations

14.1. We commit to:

• •Acknowledge submissions within two working days
• •Conduct investigations in good faith, using reasonable care and skill
• •Apply our methodology consistently across submissions
• •Treat Submitters fairly and respectfully throughout the process
• •Handle personal data in accordance with the UK GDPR and our Privacy Policy
• •Produce a written report for every investigation we conduct
• •Complete investigations within 30 working days where reasonably practicable, and notify Submitters where the timeframe is likely to be extended

14.2. Our obligations are subject to:

• •The quality and completeness of the information provided to us
• •The availability of public information about the matters raised
• •The cooperation (or non-cooperation) of third parties we contact in the course of the investigation
• •Our finite resources as a public-interest service

15. Our liability

15.1. Nothing in these Terms limits or excludes our liability for:

• •Death or personal injury caused by our negligence
• •Fraud or fraudulent misrepresentation
• •Any other liability that cannot be limited or excluded by applicable law

15.2. Subject to clause 15.1, our total liability to a Submitter in connection with the Investigation Service is limited to £100.

15.3. The Investigation Service is provided free of charge as a public-interest service. The Submitter uses the Investigation Service and relies on any findings or recommendations in the report, at their own risk.

15.4. We are not liable for:

• •Any action or inaction taken by the Submitter, or by any third party, in reliance on the report
• •Any loss or damage arising from delay in completing an investigation
• •Any action or inaction by a regulator, court, or other body to whom a referral is made
• •Any consequences of a decision not to investigate, a decision to close an investigation, or a finding adverse to the Submitter

16. Complaints about the Investigation Service

16.1. Submitters who are dissatisfied with the handling of their submission, the conduct of an investigation, or the content of a report may make a complaint in accordance with our Complaints Procedure.

16.2. Complaints should be submitted in writing to [email protected]. We acknowledge complaints within two working days and aim to provide a substantive response within ten working days.

16.3. Where a complaint relates to the findings of a report, we will review the report against the evidence and the methodology applied. We will not, however, re-investigate the matter, unless new evidence is provided that materially changes the picture.

17. Changes to these Terms

17.1. We may update these Terms from time to time. The date of the most recent update is shown at the foot of this page.

17.2. Changes apply to submissions made after the date of the update. Submissions already in progress are handled under the Terms in force at the time of submission, unless otherwise agreed with the Submitter.

18. Governing law and jurisdiction

18.1. These Terms, and any dispute or claim arising out of or in connection with them, are governed by the laws of England and Wales.

18.2. The courts of England and Wales have exclusive jurisdiction to settle any dispute or claim arising out of or in connection with these Terms.

18.3. If you are a consumer resident in Scotland or Northern Ireland, you may bring proceedings in your local courts and the relevant local law may apply to the extent required by that local law.

19. Contact

For questions about these Terms or the Investigation Service generally: