Can an Accreditation Body that is linked to a separate legal entity that provides consulting services have a website with direct hot links to the website of the linked separate entity that provides consulting services and meet the impartiality requirements of ISO/IEC 17011:2017 Section 4.4?
No, if an AB has publicly available in its website (or otherwise) a direct link to a consultancy organization (that is not an accredited CAB and listed as such in its Directory of Accredited CABs) it should be considered as an infringement of clause 4.4.13 of ISO/IEC 17011: 2017.
Can an Accreditation Body that is linked to a separate legal entity that provides consulting services have personnel (internal staff or external contractors) carry out consulting activities for that linked body and meet the impartiality requirements of ISO/IEC 17011:2017 Section 4.4?
No, unless exceptional conditions are met. If the AB’s ‘internal’ staff is providing consulting services, the AB would need to demonstrate simultaneous compliance with several clauses of the standard, namely: – 4.4.4: staff acting objectively, in absence of pressures and disclosing potential conflict of interests; – 4.4.6-9: risk analysis to impartiality, stakeholder consideration of acceptable public perception if AB internal staff provides consultancy, etc.; – 4.4.12.b) and d): effective mechanisms to prevent influence on the outcome of accreditation activities. – 4.4.13: nothing can be said or implied that would suggest that accreditation would be simpler, easier, faster or less expensive if any specified person(s) or consultancy were used;
The analysis of acceptability needs to include a review of the functions that the staff providing consultancy for the ‘Linked Body’ are assigned to do in the AB and the risk arising can differ significantly depending on the tasks performed. It should be noted that the standard forbids any staff providing consultancy to participate in accreditation decision-making.
Regarding clause 4.4.6, note that it may not be sufficient to forbid consulting and assessing to the same customer, to ensure that self-evaluation risks are sufficiently mitigated.
The note to clause 4.4.13 indicates that AB’s personnel can participate as lecturers in training and similar activities, but states that they cannot provide specific solutions to a CAB, so any form of consultancy that includes this would violate the clause.
Can an Accreditation Body that is linked to a separate legal entity that provides consulting services have shared resources (office space, finances, sales, marketing, accounting, human resources, legal counsel, etc.) and meet the impartiality requirements of ISO/IEC 17011:2017 Section 4.4?
The absence of ‘shared resources’ is not required by clause 4.4.12 and is therefore not applicable; however, ‘shared resources’ can be a source of risk to impartiality (Note 1 of 4.4.6) and it should be considered in the risk analysis process covered by clause 4.4.6. The type of resource being shared can introduce additional requirements that should be considered, for example: – sharing office space can infringe confidentiality and public perception requirements; – sharing personnel can violate confidentiality, impartiality, and public perception requirements; – sharing finances can violate confidentiality requirements and allow commercial and financial pressures to appear; – sharing sales or marketing prevents meeting clause 4.4.13.
Can an Accreditation Body that is linked to a separate legal entity that provides consulting services have common owners, or a person who holds a higher position above the managers of both organizations meet the impartiality requirements of ISO/IEC 17011:2017 Section 4.4?
No, unless strict and exceptional conditions are demonstrated to be met: – Because of the common ownership between the AB and the separate legal entity that provides consulting services, then they are deemed to be linked and the AB must fulfil all the conditions in clause 4.4.12 of ISO/IEC 17011:2017; – Regarding the person who holds a higher position at both organizations, this person cannot perform any of the activities listed in clause 5.7 as this would be a violation of §4.4.12 a). Careful consideration must be made to ensure that person is not involved in any of the AB top management activities outlined in clause 5.7 of ISO/IEC 17011:2017.
Clarification of “distinctly different” as it applies to situations where an AB is linked to a body providing consultancy or conformity assessment services, ISO/IEC 17011 has requirements for the AB including that it has a distinctly different name, logos and symbols (cl 4.4.12(c)).
Example is: “Robert Smith Consultancy” and “Robert Smith Accreditation” and/or entities with similar looking logos and/or symbols
STANDARD: ISO/IEC 17011 · CLAUSE: 4.4.12 c) · TOPIC: Impartiality
Answer:
The name of an accreditation body shall not contain identical/similar parts of the name of a body providing consultancy or conformity assessment services, if those parts are personnel names or not commonly used, because that means that the names are not distinctly different, which violates the requirement of ISO/IEC 17011:2017 cl. 4.4.12 c). The example presented would not fulfil the requirements.
The same requirement to be distinctly different also applies to the logos and symbols of an AB and a body providing consultancy or conformity assessment services.
Does “residual risk” need to be identified and documented at the same time as the demonstration of elimination or minimization of an identified risk to impartiality?
It is required that when a risk is identified, the AB reacts upon it, to eliminate or minimize it. If a risk is sufficiently low, it can also be directly accepted without elimination or mitigation. If a risk is eliminated, no residual risk should remain, but if a risk is minimized, a residual risk always remains.
It is this residual risk arising from the mitigation that needs to be documented, and this is required to be done before its review (§.4.4.8) and acceptance to occur.
There are many ways to perform the evaluation of risks and each AB should select the one which it finds more appropriate. Several standards are at disposal with varying degrees of complexity. Usually, they grade the risk according to its probability to happen and the severity of its impact or consequences.
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