Assessment policies in organisations

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Policy development

What is the function of an assessment policy for an organisation?

An organisational assessment policy is an internal document that guides decisions and actions relating to assessment practices within the organisation. 

Why should psychology professionals contribute to the development of assessment policies?

Psychology professionals have an important role to play in the development of assessment policies in organisations. This is necessary to protect the organisation, the respondents or candidates being assessed, the profession of psychology, and the psychology practitioners themselves. Psychology professionals are required to have extensive, up-to-date knowledge of the relevant legislation and regulations, which other corporate decision-makers might not have. Psychology professionals are also bound by their code of conduct to ensure that no laws are violated in the practicing of their profession, and that human rights are protected.

That being said, it often happens that policies in organisations are made by senior role players who are not psychology professionals. Because psychological assessment is clearly within the scope of the profession, it may be necessary for professionals to insist that they be included in policies that cover this important area.

The need to revise existing policies

Even if an organisation has an existing assessment policy, it will need to be revised from time to time. Because there have been significant changes to the regulatory framework regarding psychological assessment during the past few years, existing policies in many organisations are likely to be outdated now.

Relevant legislation and regulations

Documents that should be consulted and with which the policy should be aligned must include, but are not limited to:

The Constitution of the Republic of South Africa

Particularly Chapter 2, which articulates human rights.

The Health Professions Act

The main body of the Act

Section 16 of the Health Professions Act specifies the penalty for practicing a health profession while being unregistered.

The scope of the profession of Psychology

Regulation 993 defines the acts that must be performed by registered professionals. Assessment is repeatedly mentioned and the constructs that may only be assessed by psychology professionals are listed.

This regulation also refers to the Professional Board’s responsibility to produce and annually update a list of tests that are classified as psychological.

It should be noted that it is a criminal offence for an unregistered person to perform a psychological act, whether they do so in the course of their employment or not.

The code of conduct for the health professions, particularly appendix 12 which pertains to Psychology

Regulation R717 of the Health Professions Act is of critical importance since it contains many stipulations regarding psychological assessment. Importantly, it refers to the obtaining of informed consent for any psychological procedure, the need to avoid unfair discrimination, delegation and supervision of psychological services, confidentiality and the need to clarify the limits thereof, disclosure of information, and record-keeping.

Chapter 5 of this regulation deals with assessment activities and is of critical importance in the formulation of assessment policies. Practitioners should not be put in a position where they are expected to contravene their professional code of conduct. It is important to note that psychological assessment must take place in the context of an established professional relationship. Also note that if computer technology is used for psychological assessment, consent must be obtained even if the assessment is done in an employment context.

The specific requirements regarding feedback on psychological assessments must be observed – it must be done by a registered professional, and in a manner that is understandable to the recipients. In an organisational policy, provision must be made for the feedback service and how the professionals doing the feedback will be remunerated. It is considered an abuse of tests to share raw test data with people who are not qualified to interpret them.

It is not necessary to reiterate or summarise the relevant regulations in an organisational policy, but they should be referenced or included as appendices and it should be clear that the organisation will abide by the law and expect its employees to do so.

The Employment Equity Act

Section 8 of the Employment Equity Act is relevant because it specifies the psychometric properties that a psychometric test or similar instrument that is used in an employment context must meet: Reliability, validity, lack of bias and the ability to be used fairly.

The Promotion of Access to Information Act

According to this Act, respondents have the right to receive feedback if they have been assessed.

The Protection of Personal Information Act

This act serves to emphasise the confidential nature of the information collected during psychological assessment. Generally speaking, the HPCSA’s requirements for the keeping of records are more stringent than the requirements of the POPI Act.

Other documents that articulate best practice include:

The list of classified tests, which is periodically updated by the Professional Board for Psychology.

The most recent list on the HPCSA website was published in 2021. The list is supposed to be updated annually, or even more frequently. Practitioners must take responsibility for ensuring that the organisation always has access to the most recent list.

The Board’s guidelines on system-based testing

This was included in the Board’s 2022 newsletter.

The Board’s guidelines on the keeping of patient records

This is guidelines booklet number 9 published on the HPCSA website, and should be seen in te context of the Protection of Personal Information Act.

Specific aspects that should be covered in an organisational policy:

  • The responsible professionals for psychological assessment should be identified.
  • The policy should make provision for situations where there is no psychology professional available, either because of resignations of leave of absence. The policy should specify that expertise should be contracted in when that occurs.
  • The policy should make it clear that only registered psychology professionals should be responsible for compiling psychological test batteries and having custody of psychological tests,
  • The policy should recognise that employees are entitled to feedback from a qualified professional.
  • The policy should draw a distinction between psychological assessments and other assessments that are not psychological in nature, but that could still be relevant to the performance of an occupational role.
  • Activities that can be performed by other role-players in the organisation such as HR managers and others who are not registered, should be identified. This could include job analysis, background interviews, CV screening and skills assessment.
  • There should be clarity about the need for informed consent, and defined procedures and documents for obtaining consent.
  • Assessment procedures should allow for the establishment of a professional relationship.
  • Security of assessment materials and results, whether physical or electronic, should be covered,
  • Confidentiality of assessment results should be specifically covered.
  • The need for professional staff to be trained in the use of assessment technology should be recognised and funds and time should be made available for this.
  • The need for psychology professionals to accumulate continuing education units to maintain their registration should also be recognized and supported by the organisation.