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Inspected — · published 22 Aug 2001

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    Oracle Training Consultants Limited INSPECTION REPORT

Page 1 of 17
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−35Criticalmore positive than 9% of reports of this type

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Praiseexcellenteffectivecleareffectivelywell plannedvery effectiveoutstandingclearly
Criticismlimitedlackinsufficientinadequatepoorweaknot yetinsufficiently

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FindingsLeadershipWhat needs to improve positive critical
  • Findings2614w−29
  • Leadership457w−19
  • What needs to improve1225w−66

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Pages
17
Words of findings
4,184
longer than usual (typical 1049)
Reading level
Hard
Flesch 41, typical 45
Average sentence
13 words
Next steps
8
typical 5
Hedged sentences
4%
“some”, “not always”, “most”…

Where the words go

Findings 61%Leadership 11%What needs to improve 29%

Full report text

04 June 2001

Inspectors use a seven-point scale to summarise their judgements about the quality of learning sessions. The descriptors for the seven grades are: • grade 1 - excellent • grade 2 - very good • grade 3 - good • grade 4 - satisfactory • grade 5 - unsatisfactory • grade 6 - poor • grade 7 - very poor.

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04 June 2001

Inspectors use a five-point scale to summarise their judgements about the quality of provision in occupational/curriculum areas and in New Deal options. The same scale is used to describe the quality of leadership and management, which includes quality assurance and equality of opportunity. The descriptors for the five grades are: • grade 1 - outstanding • grade 2 - good • grade 3 - satisfactory • grade 4 - unsatisfactory • grade 5 - very weak.

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04 June 2001

The two grading scales relate to each other as follows:

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SEVEN-POINT SCALE FIVE-POINT SCALE

grade 1 grade 2 grade 3 grade 4 grade 5 grade 6 grade 7 grade 2 grade 3 grade 4

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Adult Learning Inspectorate

The Adult Learning Inspectorate (ALI) was established under the provisions of the Learning and Skills Act 2000 to bring the inspection of all aspects of adult learning and work-based training within the remit of a single inspectorate. The ALI is responsible for inspecting a wide range of government-funded learning, including:

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Adult Learning Inspectorate

• work-based training for all people over 16 • provision in further education colleges for people aged 19 and over • the University for Industry’s provision • adult and community learning • training given by the Employment Service under the New Deals. learndirect

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Adult Learning Inspectorate

Inspections are carried out in accordance with the by teams of full-time inspectors and part-time associate inspectors who have knowledge of, and experience in, the work which they inspect. All providers are invited to nominate a senior member of their staff to participate in the inspection as a team member. Common Inspection Framework

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Inadequate provision

The final decision as to whether the provision is inadequate rests with the Chief Inspector of Adult Learning. The overall judgement as to whether the provision is adequate or inadequate is included in the summary section of the inspection report. A provider’s provision will normally be deemed to be less than adequate where • one third or more of published grades for occupational/curriculum areas and New Deal options are judged less than satisfactory, or • leadership and management are judged to be less than satisfactory ORACLE TRAINING CONSULTANTS LIMITED

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SUMMARY

Oracle Training Consultants Limited is a private training organisation based in Doncaster. It offers foundation and advanced modern apprenticeships in the occupational area of hair and beauty.

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SUMMARY

The quality of the provision is adequate to meet the reasonable needs of those receiving it. Training in hair and beauty is satisfactory. The leadership and management of Oracle Training Consultants Limited is also satisfactory.

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SUMMARY

The leadership and management of Oracle Training Consultants Limited is satisfactory. Communications within Oracle Training Consultants Limited are good. However, the company does not give employers sufficient information about apprentices’ programmes and progress. Oracle Training Consultants Limited sets clear targets, which it disseminates effectively to staff, and regularly reviews its performance against the targets. Staff at Oracle Training Consultants Limited receive excellent training, which is linked to the company’s targets. Oracle Training Consultants Limited has comprehensive policies and procedures and clear arrangements for assuring quality. Although the company has a clear document setting out processes for reviewing its policies and procedures, it does not carry out adequate reviews. There is a lack of strategic planning. Staff receive little training in equal opportunities. Apprentices understand the procedures for complaints and

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Leadership and management

Oracle Training Consultants Limited has 16 foundation modern apprentices and 35 advanced modern apprentices in hairdressing. In addition, there are seven advanced modern apprentices in beauty therapy. Training in the occupational area of hair and beauty is satisfactory. The training centre has spacious, well-equipped salons, a dedicated room for training in theory and a computer suite. Trainers plan their lessons well and maintain apprentices’ interest. A lack of clients at the training centre restricts opportunities for assessment in hairdressing. There are insufficient work placements for apprentices in beauty therapy. A high proportion of apprentices in beauty therapy remain in training and achieve their qualifications. The rate of achievement in hairdressing is low but improving. As the number of apprentices in hairdressing has increased, the proportion of apprentices who leave their programmes early has risen.

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Work-based learning for young people

ADULT LEARNING INSPECTORATE 1 ORACLE TRAINING CONSULTANTS LIMITED

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GRADES

Hair & beauty 3 Contributory grades: Work-based learning for young people 3

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KEY STRENGTHS

• effective and interesting lessons • good resources in training centre • open and consultative style of management • excellent training and appraisal of staff

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KEY WEAKNESSES

• poor arrangements for assessment in hairdressing • insufficient work placements for trainees in beauty therapy • lack of involvement by employers in trainees’ development • lack of strategic planning • little training for staff in equal opportunities

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OTHER IMPROVEMENTS NEEDED

• wider range of hairdressing clients at training centre • more information for employers • clearer promotion of equal opportunities to employers • production of action plans as a result of self-assessment Equality of opportunity 3 Contributory grades: Leadership and management 3

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OTHER IMPROVEMENTS NEEDED

ADULT LEARNING INSPECTORATE 2 ORACLE TRAINING CONSULTANTS LIMITED

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THE PROVIDER AND ITS CONTEXT

1. Oracle Training Consultants Limited (OTC) was formed in 1999. Originally, the company provided training at two sites, in Barnsley and Doncaster. It now provides all its training from a single site in Doncaster, which it acquired in August 2000. OTC has seven staff and currently has 58 foundation and advanced modern apprentices in hairdressing and beauty therapy. OTC is offering training in beauty therapy as a pilot during 2000-01. Apprentices receive training at OTC’s training centre and from their employers. OTC carries out all assessments. The training is currently funded through the local Learning and Skills Council (LSC) for South Yorkshire.

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THE PROVIDER AND ITS CONTEXT

2. Doncaster is geographically the largest borough in England and has a population of 290,000. Since the collapse of the mining industries in the 1980s, the borough has experienced considerable social and economic decline. The rate of unemployment in Doncaster is 5.4 per cent, compared with an average of 4.2 per cent for Yorkshire and Humberside and a national average of 3.3 per cent. Minority ethnic groups make up only 1.6 per cent of the population in Doncaster. In September 2000, the proportion of school leavers in Doncaster achieving five or more general certificates of secondary education (GCSEs) at grade C and above was 36.2 per cent, compared with a national average of 49.2 per cent.

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THE PROVIDER AND ITS CONTEXT

ADULT LEARNING INSPECTORATE 3 ORACLE TRAINING CONSULTANTS LIMITED

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THE INSPECTION

3. A team of three inspectors spent a total of 12 days at OTC in June 2001. They interviewed assessors, trainers and 29 trainees and visited 11 employers. Inspectors observed six lessons and assessments. They examined a range of documents, including trainees’ portfolios of evidence, trainees’ records, the company’s policies and procedures, records of staff development and appraisal, promotional materials and the awarding body’s reports. Inspectors studied OTC’s self-assessment report, which it had produced in September 2000 and updated in February 2001.

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THE INSPECTION

Grade 1 Grade 2 Grade 3 Grade 4 Grade 7 Total Grades awarded to learning sessions Grade 5 Grade 6 Hair & beauty 0 3 2 1 0 6 0 0 Total 0 3 2 1 0 6 0 0

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THE INSPECTION

ADULT LEARNING INSPECTORATE 4 ORACLE TRAINING CONSULTANTS LIMITED

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Hair & beauty Grade 3

4. In hairdressing, OTC has 16 foundation modern apprentices working towards national vocational qualifications (NVQs) at level 2 and 35 advanced modern apprentices working towards NVQs at level 3. In beauty therapy, there are seven advanced modern apprentices, working towards NVQs at level 3. OTC admits apprentices to its programmes throughout the year. However, most apprentices start their training in June or July. Some apprentices apply directly to OTC. Others are referred by their employers or the careers service. All the apprentices in hairdressing are employed. These apprentices attend OTC’s training centre for training and are assessed at the training centre and at work. For the first six months of their programmes, all the apprentices in beauty therapy are employed by OTC and attend its training centre. During this time, they gain practical skills through working on fee-paying clients at OTC’s commercial salon. When these apprentices have achieved their NVQ

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Hair & beauty Grade 3

at level 2 in beauty therapy, they progress to employment with local salons and spend one day each week at the training centre. Apprentices work towards key skills throughout their training.

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Hair & beauty Grade 3

The tables show the achievement and retention rates of apprentices between 1999- 2000 and the end of March 2001. It does not show apprentices who have started training since April 2001. Programmes inspected Number of learners Contributory grade 58 Work-based learning for young people 3

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Hair & beauty Grade 3

Per cent Per cent Per cent Per cent Foundation modern apprenticeships (FMA) 1997-98 1998-99 1999-2000

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Hair & beauty Grade 3

Number Number Number Work-based learning for young people

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Hair & beauty Grade 3

7 15 Number that started 4 57 11 73 Still in training 0 0 0 0 FMA framework completed 1 14 0 0 NVQ level 2 completed

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Hair & beauty Grade 3

ADULT LEARNING INSPECTORATE 5 ORACLE TRAINING CONSULTANTS LIMITED

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STRENGTHS

• effective and interesting lessons • good resources in training centre • intensive and effective programme in beauty therapy • frequent work-based assessment

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WEAKNESSES

• poor arrangements for assessment in hairdressing • ineffective use of initial assessment • lack of detail in some individual training plans • lack of involvement by employers in trainees’ development • insufficient work placements for trainees in beauty therapy Per cent Per cent Per cent Per cent Advanced modern apprenticeships (AMA) 1997-98 1998-99 1999-2000

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WEAKNESSES

Number Number Number Work-based learning for young people

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WEAKNESSES

15 5 36 Number that started 13 87 4 80 25 69 Still in training 5 33 0 0 7 19 AMA framework completed 6 40 1 20 8 22 NVQ level 2 completed 7 47 0 0 7 19 NVQ level 3 completed

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WEAKNESSES

Per cent Per cent Per cent Per cent NVQ Training 1997-98 1998-99 1999-2000

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WEAKNESSES

2 Number that started 2 100 Still in training 2 100 Individual learning plan completed 0 0 Left without completing individual learning plan 2 100 NVQ level 2 completed

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WEAKNESSES

ADULT LEARNING INSPECTORATE 6 ORACLE TRAINING CONSULTANTS LIMITED

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WEAKNESSES

5. Lessons are well planned and maintain apprentices’ interest. OTC makes theory meaningful by linking it to practical activities. The training centre has excellent resources and spacious, well-equipped salons. Apprentices use a wide range of professional products when practising their hairdressing skills. Leading manufacturers of products provide additional training in commercial techniques. The room for training in theory has a computer with software for formatting presentations and an electronic whiteboard. In addition, apprentices can use a suite of seven computers at any time. OTC is currently developing a website and interactive, computer-based training materials.

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WEAKNESSES

6. Training in beauty therapy is intensive and encourages apprentices to reach their full potential. A high proportion of apprentices remain in training and achieve their qualifications. All the apprentices in beauty therapy have achieved NVQs at level 2 within six months of starting their programmes. They have also gained an additional qualification in body massage. These apprentices have developed appropriate practical skills and can carry out a range of treatments with confidence. Their understanding of theory is thorough. In hairdressing, however, the rate of achievement is low. Few apprentices achieve the advanced modern apprenticeship and no apprentice has yet completed the foundation modern apprenticeship. OTC has taken steps to improve the rate of achievement in hairdressing, and expects 50 per cent of the apprentices to achieve their full apprenticeship framework in 2000-01. The proportion of apprentices in

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WEAKNESSES

hairdressing who leave their programmes early has risen as the number of apprentices has increased.

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WEAKNESSES

7. Assessments are well planned and apprentices have a clear understanding of the process. Apprentices agree with their trainers when assessments will take place. There are appropriate systems for recording assessments and apprentices receive clear and prompt feedback on their performance. Apprentices participate in recording evidence of their performance, which helps them to understand the process. There is a wallchart for recording assessments in beauty therapy, which clearly indicates apprentices’ progress towards achieving units of their NVQs. Work-based assessments take place weekly. In most cases, apprentices can request additional assessments if opportunities for assessment arise before the next scheduled assessor’s visit. Employers help to facilitate the assessors’ visits. Some employers’ staff have gained appropriate assessors’ qualifications but they are not yet assessing apprentices in the workplace. OTC can

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WEAKNESSES

carry out assessments outside normal office hours for apprentices who do not have opportunities for assessment in the workplace or during their training at the training

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OTHER IMPROVEMENTS NEEDED

• higher rate of achievement in hairdressing • wider range of hairdressing clients at training centre • systematic additional learning support • further integration of key skills with training in hairdressing • more informative marketing and promotional materials

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OTHER IMPROVEMENTS NEEDED

ADULT LEARNING INSPECTORATE 7 ORACLE TRAINING CONSULTANTS LIMITED

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OTHER IMPROVEMENTS NEEDED

centre. Apprentices in hairdressing have too few clients to practise on in the training centre, which results in insufficient opportunities for assessment. Many assessments are carried out with apprentices using their friends or members of their families as clients. Often, apprentices use the same clients for several weeks. Apprentices lack opportunities to improve their skills because of this shortage of clients. The shortage of clients also results in insufficient opportunities to internally verify assessments.

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OTHER IMPROVEMENTS NEEDED

8. All applicants for training attend an information day followed by an interview. When they join their programmes, apprentices have a one-day induction. The induction includes an initial assessment of apprentices’ skills in literacy and numeracy. OTC does not inform apprentices of the results of their initial assessments or arrange additional learning support for apprentices whose results indicate a need for it. Since training takes place in groups of fewer than eight, however, individual attention is normally available to apprentices. In addition, apprentices can attend OTC’s training centre for additional one- to-one tutorials with their trainers at any time. OTC aims to review each apprentice’s progress once each month and some apprentices have had their progress reviewed more frequently. Others, however, have not had a progress review for three months. Some individual training plans lack precise targets and dates for achieving them and fail

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OTHER IMPROVEMENTS NEEDED

to indicate if the apprentice has met previous targets.

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OTHER IMPROVEMENTS NEEDED

9. A high proportion of apprentices receive additional training at their workplace. This covers new products, current techniques and more advanced treatments. Although employers want apprentices to progress, they are unable to co-ordinate training in the salons with training at the training centre. There is an expectation that apprentices will inform their employers of their training and progress. Employers do not receive OTC’s annual training plan.

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OTHER IMPROVEMENTS NEEDED

10. OTC has not been able to find sufficient salons to employ its apprentices in beauty therapy. This has resulted in some apprentices spending 14 of the 17 weeks since they completed their NVQ at level 2 without work in a salon. Some apprentices have become self-employed and others have continued to attend OTC’s training centre full time. These apprentices do not have the opportunity to work in a commercial environment with more experienced beauty therapists. They are also unable to follow the additional training courses offered by commercial salons.

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OTHER IMPROVEMENTS NEEDED

11. OTC effectively integrates key skills with training in beauty therapy. All the apprentices in beauty therapy, who started their training during 2000-01, have achieved the key skills of application of number and information technology at level 1. They are currently working towards key skills at level 3 and all have achieved the key skill of communication at level 3. In hairdressing, however, some apprentices are unsure of their progress and of which key skills they are working towards. OTC has recently improved its training in key skills for apprentices in hairdressing. Apprentices can now choose from among several projects which combine the key skills of information technology, application of number and communication. Some apprentices’ portfolios now contain evidence of a clear understanding of key skills and of their relevance to employment.

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OTHER IMPROVEMENTS NEEDED

ADULT LEARNING INSPECTORATE 8 ORACLE TRAINING CONSULTANTS LIMITED

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OTHER IMPROVEMENTS NEEDED

12. Staff are careful to ensure that applicants for training receive support and they help them to secure employment before they start their programmes. However, applicants do not receive any written information about their training programme or about OTC before their interviews to help them make an informed choice of future career.

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Good Practice

Following a lesson in the theory of colouring, apprentices attended demonstrations of colouring techniques. The team of three demonstrators used various fashionable colouring techniques on six models simultaneously. The demonstration provided apprentices with constant visual information and explanations of the techniques used and the choice of colours. Apprentices were encouraged to watch the techniques closely by standing with the demonstrators. The use of six models allowed apprentices to observe many different techniques. The apprentices were well motivated and constantly engaged in learning.

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Poor Practice

Some assessments in hairdressing do not comply with the requirements of the awarding body. Apprentices complete compulsory written questions under examination conditions following the awarding body’s guidelines. However, apprentices complete non-mandatory knowledge questions in their own time. OTC issues these questions to apprentices at the beginning of their training and asks the apprentices to complete them using knowledge gained from lessons in theory, learning materials or support from their trainers. This practice does not fully test apprentices’ knowledge.

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Poor Practice

ADULT LEARNING INSPECTORATE 9 ORACLE TRAINING CONSULTANTS LIMITED

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LEADERSHIP AND MANAGEMENT Grade 3

14. The self-assessment report accurately identified effective communication between managers and staff as a strength. Managers keep staff well informed. There are regular meetings, at which decisions and actions to be taken are recorded. These have standard agendas, which are linked to OTC’s objectives. Managers encourage staff to express their opinions, which they value and use to guide their decisions. OTC provides an induction and mentoring for all new staff. Staff feel supported by management. 13. OTC has two directors. One of the directors is responsible for training in hairdressing and the other is responsible for training in beauty therapy. A company secretary is responsible for finance. OTC employs four further staff, who carry out training and assessments. OTC has comprehensive policies and procedures relating to quality assurance, equal opportunities, health and safety and staff development and

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LEADERSHIP AND MANAGEMENT Grade 3

appraisal. The company produced its first self-assessment report in September 2000 and updated it in February 2001 in preparation for the inspection.

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STRENGTHS

• open and consultative style of management • effective target-setting and dissemination of targets to staff • comprehensive and easily available policies and procedures • effective procedure for complaints • effective approach to health and safety • good handbooks for staff and trainees • excellent training and appraisal of staff

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WEAKNESSES

• lack of strategic planning • little training for staff in equal opportunities • inadequate reviewing of policies and processes • insufficient sharing of good practice • insufficiently rigorous internal verification

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OTHER IMPROVEMENTS NEEDED

• more information for employers • involvement of employers’ staff in assessments • strategic planning to promote equal opportunities • clearer promotion of equal opportunities to employers • production of action plans as a result of self-assessment

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OTHER IMPROVEMENTS NEEDED

ADULT LEARNING INSPECTORATE 10 ORACLE TRAINING CONSULTANTS LIMITED

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OTHER IMPROVEMENTS NEEDED

15. Operational planning is good. OTC sets targets for performance and disseminates them to all staff. The staff handbook sets out these targets. There are weekly and monthly meetings to review the targets. At staff appraisals, managers assess individual staff members’ contribution to achieving the targets. OTC has good systems for monitoring apprentices’ performance and achievements. It has recently introduced a computer-based system for recording apprentices’ progress. Apprentices’ progress is discussed at weekly meetings.

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OTHER IMPROVEMENTS NEEDED

16. There is a lack of strategic planning. Representatives of OTC meet the company’s bank manager each quarter to monitor performance against financial targets, but the directors do not link these meetings to OTC’s strategic aims. The company has not set written short-term or long-term goals or reviewed its progress. OTC has not yet decided how to offer training in beauty therapy from August 2001. OTC has piloted training in beauty therapy during 2000-01. OTC took a decision to employ the apprentices in beauty therapy itself for the first six months of their programmes while they achieved their NVQs at level 2. OTC has since decided that this is not feasible in the long term. However, it has not made a final decision on how to carry out the training after August 2001. OTC is currently recruiting apprentices in beauty therapy.

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OTHER IMPROVEMENTS NEEDED

17. OTC does not share information adequately with employers. Employers do not receive information about OTC’s training to help them link training in the salons to the training in the training centre. Although some employers’ staff hold assessors’ qualifications, they are not yet assessing apprentices in the workplace. There is no handbook for employers setting out their responsibilities. Although OTC has good links with employers and carries out regular visits to monitor apprentices’ workplaces, it does not systematically record employers’ views. OTC holds meetings for employers, but these have a low attendance. OTC has not reviewed the effectiveness of these meetings or considered how best to record employers’ opinions. OTC does not use questionnaires to obtain employers’ views

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OTHER IMPROVEMENTS NEEDED

ADULT LEARNING INSPECTORATE 11 ORACLE TRAINING CONSULTANTS LIMITED

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Equality of opportunity

18. OTC has a detailed equal opportunities policy. However, it has not updated or revised the policy as required by its arrangements for assuring quality. OTC displays all its policies relating to equal opportunities on notice boards in the training centre. The policies are comprehensive and cover grievances, complaints, discipline and smoking. At the beginning of their programmes, apprentices receive a students’ handbook containing the policies and their rights and responsibilities are explained. Apprentices have a basic understanding of fair treatment at work. Staff receive manuals containing OTC’s policy on equal opportunities. The procedure for complaints is clear and concise and both employers and apprentices understand how to lodge a complaint. OTC’s staff take all complaints seriously and deal with them promptly and effectively. Recent marketing material carries a statement of OTC’s commitment to equal opportunities. The self-

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Equality of opportunity

assessment report identified that OTC’s training centre is not accessible to wheelchair users. However, OTC can provide training in the workplace for apprentices with mobility difficulties. OTC collects data on apprentices’ gender, ethnicity and disabilities but does not analyse them in order to target under-represented groups in its marketing. The company has recently installed a computerised system which will allow effective analysis of these data.

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Equality of opportunity

19. OTC has no strategy to promote equality of opportunity. Although staff act immediately and effectively to remedy any incidents of discrimination, they do not take steps to prevent discrimination occurring. One member of staff is well qualified and experienced in equal opportunities. However, the other staff have not had sufficient training and show little understanding of the broader issues. Employers do not receive a copy of the policy and are unclear about their responsibilities. Reviews of apprentices’ progress do not involve employers in discussions of equal opportunities.

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Contributory grade 3

ADULT LEARNING INSPECTORATE 12 ORACLE TRAINING CONSULTANTS LIMITED

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Quality assurance

20. OTC has a clear framework for quality assurance. It includes comprehensive policies on health and safety, equal opportunities, recruitment and staff appraisal. OTC has thorough procedures relating to health and safety. It carries out regular monitoring, including monitoring of the salons where apprentices work, and acts immediately when risks are identified. There are clear arrangements for reviewing the policies and procedures. However, OTC has not carried out adequate reviews in any area except for health and safety.

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Quality assurance

21. There are comprehensive and informative handbooks for apprentices and staff. The handbooks for apprentices are clearly written. They are used at induction and are referred to throughout apprentices’ programmes. Staff handbooks follow a similar format. They contain all OTC’s policies and procedures, records of meetings and information about the individual member of staff’s reviews and appraisals.

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Quality assurance

22. OTC has invested heavily in training for staff. Staff have excellent opportunities to participate in external training. OTC plans training for staff so that it contributes to the company’s objectives. However, there is insufficient recognition of the skills and expertise available within the organisation and little sharing of good practice. There is a good system for appraising staff. The procedures are clearly set out in writing and staff have a thorough understanding of the process.

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Quality assurance

23. Some aspects of internal verification are weak. There is good recording of internal verification. The internal verification co-ordinator communicates regularly with assessors and makes memoranda of important issues. However, there is no overall monitoring of sampling. The lack of clients in the training centre reduces opportunities for internal verification of assessments. OTC is aware of the lack of clients but has not acted to remedy the situation. OTC has not taken sufficient action to prevent apprentices from being assessed working on their friends and members of their families. OTC’s self- assessment report was insufficiently self-critical and did not accurately identify strengths and weaknesses. The company did not produce an action plan as a result of self- assessment.

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Good Practice

The appraisal process is very effective. All staff participate in a monthly review process that assesses their achievements against targets set. There has been initial training on the process encouraging staff to reflect on their achievements and areas for improvements. This information is carefully recorded and an equally thoughtful and succinct response is given by line managers. This process feeds directly into the appraisal process of a six-monthly review and yearly appraisal. There are extensive opportunities for staff development. Training needs are recorded at each stage of the process. Staff have participated in numerous training courses to enable them to improve their own performance, gain qualifications and add to the quality of the company. All training is supported financially by the company. The company gained the Investors in People Standard in June 2000.

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Good Practice

ADULT LEARNING INSPECTORATE 13 ORACLE TRAINING CONSULTANTS LIMITED

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Poor Practice

The company has a number of well-written, comprehensive policies and procedures. All staff are aware of the policies, but senior managers have not reviewed theses policies in line with their quality assurance arrangements.

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