Governing standards under US federal law and the laws of New Jersey
Effective Date: June 2026 | Version: 1.0

1. Purpose and Scope

This Malpractice and Maladministration Policy sets out how Skill Up LLC (trading as PCI Global Standards) defines, prevents, detects, investigates, and responds to malpractice and maladministration in connection with its online professional development courses, assessments, and Certificates of Completion.

This policy is governed by and construed in accordance with applicable United States federal law and the laws of the State of New Jersey. It applies to:

• All learners enrolled in courses offered through www.pcidssglobal.com
• All employees, contractors, and content developers involved in course production, delivery, and administration
• All assessment, completion, and certificate issuance processes

2. Legal Framework

This policy is informed by and seeks compliance with the following applicable laws and regulations:

2.1 US Federal Law

• Federal Trade Commission Act (15 U.S.C. § 45) — prohibition on unfair or deceptive acts and practices in commerce, including misrepresentation of educational qualifications or credentials.
• Higher Education Act regulations and FTC Guidance on endorsements and testimonials — standards for truthful advertising of educational outcomes.
• Family Educational Rights and Privacy Act (FERPA, 20 U.S.C. § 1232g) — applied safely to maintain the security and confidentiality of institutional learner records.
• Computer Fraud and Abuse Act (18 U.S.C. § 1030) — prohibition on unauthorized access to computer systems, including the platform.
• Electronic Communications Privacy Act — governing interception and disclosure of electronic learner communications.

2.2 New Jersey State Law

• New Jersey Consumer Fraud Act (N.J.S.A. 56:8-1 et seq.) — prohibition on unconscionable commercial practices, deception, and misrepresentation in the sale of goods and services, including educational products.
• New Jersey Truth-in-Consumer Contract, Warranty and Notice Act (N.J.S.A. 56:12-14 et seq.) — requirements for clear, non-deceptive contractual terms.
• New Jersey Computer Related Offenses Act (N.J.S.A. 2A:38A-1 et seq.) — prohibition on unauthorized access to, or interference with, computer systems or data.
• New Jersey Law Against Discrimination (N.J.S.A. 10:5-1 et seq.) — prohibition on discriminatory practices in the provision of services.

3. Definitions

3.1 Malpractice

Malpractice means any deliberate act, dishonest conduct, or intentional failure by a learner, member of staff, or contractor that undermines the integrity, validity, or reliability of our courses, assessments, or certificates. Under applicable law — including the NJ Consumer Fraud Act and the FTC Act — conduct that misrepresents educational outcomes or credentials constitutes an unlawful deceptive practice.

Examples of malpractice include:

• Cheating, plagiarism, or use of unauthorized materials during any course assessment.
• Impersonating another learner or allowing another person to complete a course on one's behalf ("contract cheating").
• Sharing, selling, or distributing assessment answers, quiz content, or access credentials.
• Falsifying, altering, or misrepresenting a Certificate of Completion issued by the organization.
• Fraudulently claiming to hold a qualification not earned through completion of the relevant course.
• Deliberate provision of materially inaccurate or misleading course content by staff or contractors.
• Any act of dishonesty that could constitute fraud under federal or New Jersey law.

3.2 Maladministration

Maladministration means unintentional failures, negligence, or systemic errors in the administration of courses, assessments, or certificates that nonetheless cause harm to learners or compromise the quality or accuracy of the organization's services. Under the NJ Consumer Fraud Act, material omissions and negligent misrepresentations can also constitute unlawful practices.

Examples include:

• Issuing a Certificate of Completion containing incorrect learner name, date, or course title.
• Failure to provide course access within the timeframe stated at point of purchase.
• Inaccurate or incomplete maintenance of learner enrollment and completion records.
• Failure to process refund requests in accordance with the published Refund Policy.
• Publishing materially inaccurate course descriptions or outcome statements.
• Administrative errors in assessment scoring or grading.
• Failure to maintain data in accordance with the organization's Privacy Policy and applicable law.

4. Prevention Measures

We take the following steps to prevent malpractice and maladministration, consistent with our obligations under the NJ Consumer Fraud Act and FTC standards:

• Assigning unique, individual course access credentials to each registered learner.
• Designing assessments with question randomization and bank rotation to deter answer sharing.
• Maintaining accurate, time-stamped records of all learner enrollments, progress, and completions.
• Ensuring all Certificates of Completion include verified learner name, date, and course title.
• Regular internal review of all course content for accuracy and compliance with advertised outcomes.
• Clear and accurate representation of course outcomes in all marketing and course descriptions, in compliance with FTC guidelines.
• Secure, access-controlled systems to protect learner data and prevent unauthorized record modification.

5. Reporting

Any learner, employee, contractor, or third party who suspects or identifies malpractice or maladministration must report it promptly. Reports will be treated with confidentiality to the extent permitted by law, and individuals who report concerns in good faith are protected from retaliation.

Reports should be submitted to:

• Email:  [email protected]
• Subject:  Malpractice/Maladministration Report — Confidential
• Postal Address:  971 US Highway 202 N, Suite N, Branchburg, NJ 08876, USA

Where a reported concern involves conduct that may constitute a criminal offense under federal or New Jersey law (including fraud, computer offenses, or identity-related crimes), the organization reserves the right and may be obligated to report the matter to the appropriate law enforcement authority, including:

• The New Jersey Division of Consumer Affairs (for consumer fraud matters)
• The Federal Trade Commission (for deceptive trade practice matters)
• Local or federal law enforcement (for criminal conduct)

6. Investigation Procedure

Upon receipt of a malpractice or maladministration report, the following procedure will be followed:

1. Written acknowledgement of the report via email within three (3) business days.

2. Review and investigation of the matter by a designated senior staff member or manager to ensure an objective and impartial assessment.

3. Collection and secure preservation of all relevant evidence, including access logs, completion records, assessment data, and certificate records.

4. Notification to the subject of the investigation, where appropriate and where doing so does not compromise the investigation.

5. Conduct of a fair and impartial investigation, with opportunity for the subject to respond to findings.

6. Production of a written investigation report with findings, conclusions, and recommended actions within seven (7) to ten (10) business days from the initial acknowledgement.

7. Communication of the outcome to all relevant parties within twenty-one (21) calendar days of the report being received, where reasonably practicable.

7. Outcomes and Sanctions

7.1 Where Learner Malpractice is Confirmed

• Immediate cancellation of the course enrollment, with all fees paid forfeited as liquidated damages resulting from the policy contract violation.
• Revocation of the Certificate of Completion (where issued).
• Permanent ban from registering on the platform.
• Referral to law enforcement or regulatory authorities where conduct may constitute a criminal offense or violation of the NJ Consumer Fraud Act.

7.2 Where Organisational Maladministration is Confirmed

• Prompt correction of the error (re-issuance of certificate, correction of records, provision of access).
• Where the learner has suffered loss, provision of an appropriate remedy which may include a refund or course credit.
• Formal review and improvement of the relevant internal process to prevent recurrence.
• Documentation of the incident and remedial actions taken.

8. Appeals

Any party who wishes to appeal an outcome under this policy must do so in writing within fourteen (14) calendar days of receiving the decision.

Appeals should be addressed to:

• Email:  [email protected]
• Subject:  Malpractice Policy Appeal — [Reference Number]

An appeal will be reviewed by an executive administrator or alternative senior member of the organization who was not the primary investigator in the original case. The outcome of the appeal will be communicated in writing within fourteen (14) calendar days of receipt.

9. External Complaints

If a learner or third party believes that a malpractice or maladministration matter has not been adequately resolved through our internal procedure, they may raise a complaint with the following external bodies:

• New Jersey Division of Consumer Affairs:  www.njconsumeraffairs.gov
• Federal Trade Commission (FTC):  reportfraud.ftc.gov
• Better Business Bureau (BBB):  www.bbb.org

Nothing in this policy limits any statutory rights you may have under federal or New Jersey consumer protection law.

10. Record Keeping

All malpractice and maladministration reports, investigation records, findings, and outcomes will be retained securely for a minimum of five (5) years in compliance with applicable New Jersey records retention obligations.

11. Review

This policy is reviewed annually by senior management of Skill Up LLC, and updated as required to reflect changes in applicable federal or New Jersey state law.

Policy Approved By: Senior Management, Skill Up LLC
Contact: [email protected]