Difference between revisions of "ΔΔ:Operating approval for professional training schools/centres for the issue of CPCs (certificates of professional competence)"

From National Registry of Administrative Public Services
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|process_provided_to=Educational services enterprises,Legal Entities
 
|process_provided_to=Educational services enterprises,Legal Entities
 
|process_tax_type=Approvals,Decisions,Operating Licenses
 
|process_tax_type=Approvals,Decisions,Operating Licenses
|process_life_events=Licences and compliance,Operation of driving schools /training centres,Educational content,Educational matters
+
|process_life_events=Licences and compliance, Educational content, Educational matters
 
|process_sdg_resource=Judicial redress
 
|process_sdg_resource=Judicial redress
 
|process_sdg_lack_of_response_rule=Other
 
|process_sdg_lack_of_response_rule=Other

Revision as of 21:23, 3 November 2024



feb921d1-12b1-47c0-91ab-cf3ed0287b79 467213 Λειτουργία σχολών/κέντρων επαγγελματικής κατάρτισης για τη χορήγηση ΠΕΙ

At a glance

Points of service

Points of Single Contact (ΚΕΠ – EKE), Regional units, Directorate of Transport and Communications of the relevant Regional Unit

Digital provision points

Number of required documents

4 to 9 + (
4
)

Fees

200 €

Deadline of completion

2 months

Description

The procedure pertains to the granting of approval for the operation of professional training schools/centres to issue certificates of professional competence (CPC) to drivers of vehicles for the carriage of goods or passengers by the licensing authority, i.e. the Directorate of Transport and Communications of the relevant regional unit where the CPC professional training school/centre is to be established and will be operating.

Basic information

Competent body

MINISTRY OF INFRASTRUCTURE AND TRANSPORTATION

Authority/Public body’s Unit responsible for the institutional framework of the procedure

Service / organizational unit of a authority entity

Directorate of Transport and Communications of the relevant Regional Unit

Validity duration

Indefinite

Last update

13/12/2024

Application

Application Type

Application

Submission by:

Submitted by the applicant (digital), Submitted by the applicant (in person or by post)

Submitted by:

Legal entities, Persons

Title

Application for approval to operate a school/centre in accordance with the Sample Application Form of Annex I as per Article 14 of Joint Ministerial Decision 314952/2021

Notes:

The Operator wishing to undertake this activity shall submit an application accompanied by the necessary supporting documents (in accordance with applicable legislation) for operating approval for the CPC School/Vocational Training Centre) via the Integrated Licensing & Inspection Management System (ILIMS) pursuant to Article 14 of Law 4442/2016, accessible through the Public Administration Single Digital Portal (gov.gr). Until the Integrated Licensing & Inspection Management System (ILIMS) concerned with approval of the activity becomes operational, the application should be submitted in paper or electronic form to the licensing authority or to any Citizens Service Centre (KEP) that operates as a One-Stop-Shop in accordance with Article 7 of Law 3844/2010 (Government Gazette Series I No 63), with validated authenticity of signature, if not submitted by the Operator in person (natural person or legal representative of a legal person).

What you will need

Means of authentication, identification and signature

Identification document

    Print

    Requirements

      Fees

        Related

        Means of redress or appeal:

        Judicial redress

        Rules concerning a lack of reply from the competent authority and the legal consequences for the use:

        Other

        1. The applicant (natural or legal person) is granted the opportunity to appeal to the ordinary courts against acts or omissions by the administrative authority to which their application has been submitted, if they consider that their application has been rejected or unduly delayed by the administration without legitimate reason. 2. If there is no communication within a deadline of sixty (60) days from appropriate submission of the application and the supporting documents to the licensing authority for the issuance of the approval, by way of derogation from Article 8 of Law 4442/2016, this cannot be presumed to mean that operating approval has been granted.

        NACE

        • 85.59 Other education n.e.c.

        Output & Results

        Output

        Decision

        Steps

          Digital steps

            Other information

            Official title

            Determination of the procedure, content and supporting documents, fees and penalties for granting approval for the operation of professional training schools/centres which issue certificates of professional competence to drivers of vehicles for the carriage of goods or passengers

            Languages supported

            Greek, English

            Ways of provision

            Establishment

            Registries updated

            Μητρώα της Γενικής Γραμματείας Μεταφορών

            Legislation

              Categories

              Τype of procedure

              Trigger

              Applied for

              Trigger (submission method)

              Application (digital), Application (handwritten)

              Type

              Outgoing
              N1

              ,,,,,


            • 1 Administrative The following have the right to operate a CPC professional training school/centre.: a) Theory Training Centres for Candidate Drivers (KETHEYO) b) Transport Operator Vocational Training Schools (SEKAM), c) Hazardous Freight Vehicle Drivers (ADR) Vocational Training Centre (SEKOOMEE), and d) Educational Centres for Transport Operators (EKESYF) for drivers working for a transport operator, if the operator employs more than three hundred (300) drivers. In particular for transport operators, if their registered purpose does not refer to professional training for the issue of Certificates of Professional Competence, a decision of the Board of Directors shall be required to establish a professional training centre.


              No No

            • 2 Building The CPC professional training school/centre must have at least three (3) distinct spaces, one (1) reception area, one (1) designated classroom, and sanitary facilities – (1) toilet. The main designated use of the premises must be as a CPC professional training school/centre and these premises must be a single unit and must not be part of a residence. The reception area must be well lit and adequately ventilated.


              No No

            • 3 Technical The classroom must be one undivided space, must have good lighting, adequate ventilation, good heating and adequate sound insulation. The classroom must also have individual seats and desks or individual seats with an integrated table, that are used by the trainees while they are attending the regular training programmes. The total number of individual seats (at desks or with an integrated table) per classroom must be at least equal to the maximum number of trainees per room. The number and dimensions of the training desks, per classroom, must be sufficient to accommodate the number of users, i.e. must be equal to the maximum number of trainees per room. The classroom must have appropriate supervisory or electronic teaching equipment (such as a computer, whiteboard, projector) and practical training equipment (such as fire extinguishers, a first aid box and materials, a suitable jacket).


              No No

            • 4 Building The classroom must satisfy a ratio of 2m2/person, from which the maximum number of trainees is derived, rounded down to the smallest whole number.


              No No

            • 5 Building The toilet must be directly accessible from the reception area.


              No No

            • 6 Professional Course management, the responsibility for the proper functioning of the CPC professional training school/centre and the observance of the relevant provisions shall be assigned to a Director of Studies, who shall either be the holder of a professional driving instructor for learner drivers’ certificate, or a graduate of a higher education institution in Greece or an equivalent recognised institution abroad. If the Director of Studies does not hold a professional driving instructor for learner drivers’ certificate they must hold a category C or D driving licence.


              No No

            • 7 Educational Driving instructors for learner drivers of cars and motorcycles who hold a valid certificate to practice professionally, and who have not been penalised for disciplinary misconduct or incompatibility with their professional capacity, may teach in CPC professional training school/centres. Instructors from whom the certificate of professional practice as an instructor has been withdrawn for reasons of physical incapacity are permitted to teach. Graduates of domestic tertiary education institutions or recognised equivalent foreign institutions who specialise in subjects that include the teaching material in question are also permitted to teach.


              No No

            • 8 Educational The teaching staff must be familiar with the thematic units in Annex I of Presidential Decree 74/2008, as evidenced by a certificate of successful attendance at a seminar, a certificate as a rapporteur on the above subjects, or a certificate of professional experience from the institution. Driving instructors for learner drivers and directors of studies and lecturers at KETHEYO, SEKAM and SEKOOMEE Training Schools and Centres are excluded from the obligation to submit certificates, since they already have the knowledge related to the above thematic units.


              No No

            • 9 Educational As far as practical training is concerned, the teaching staff must have knowledge of matters pertaining to first aid and firefighting evidenced by a relevant certificate of attendance at a first aid medical assistance seminar (Red Cross, Lifeguard Academy or equivalent body providing similar training), firefighting (Fire Service or equivalent body providing similar training). The above knowledge may be evidenced by a relevant degree or grade transcript for studies at a recognised school.


              No No

            • 10 Conditions for non-commission of criminal offenses Neither the Director of Studies nor any of the teaching staff may be persons convicted of the offences referred to cases (c) and (d) of Article 3(2) of Presidential Decree 208/2002 (Government Gazette Series I, No 194).


              No No

            • 11 Administrative The CPC professional training school/centre may not train or declare learner drivers if the licensing authority has not been duly notified in a timely manner or if its operating terms are not adequately satisfied.


              No No

            • 12 Administrative A list indicating the names of the Director of Studies and the teaching staff of the CPC professional training school/centre with details of their qualifications in brief must be posted in a conspicuous position inside the school/centre.


              No No

            • 13 Administrative A sign must be posted in a conspicuous position outside the professional CPC training school/centre. The wording ‘CPC PROFESSIONAL TRAINING CENTRE’ (or SCHOOL) must be written on the sign.


              No No

            • 14 Administrative A CPC professional training school/centre may be co-located in the same premises as a car and motorcycle driving school, a Theory Training Centre for Candidate Drivers (KETHEYO), a Hazardous Freight Vehicle Drivers (ADR) Vocational Training Centre (S.E.K.O.O.M.E.E.) or a Transport Operator Vocational Training School (SEKAM), as long as it belongs to the same natural or legal person. In the event of co-location: a) All the conditions of operation of the above schools/centres, as provided for in the relevant provisions, must be adhered to and b) They must use different classrooms when their training programmes are being carried out at the same time. The above schools/centres may share reception areas and communal spaces which must, in all cases, be separate from the classrooms. The use of ancillary spaces should not disturb the use of classrooms.


              No No

            • 15 Administrative A CPC professional training school may not carry out its activity in any building that also houses the Ministry of Infrastructure and Transport, any Directorate of Transport and Communications or Vehicle Technical Inspection Centre (KTEO) services in the regional units.


              No No

            • 1 Region of Attica ATTENTION! The following categories of fees have been created and are in force at the ‘Ministry of Infrastructure and Transport/Notifications’. Categories: EUR 200 (Operation of Driving School/KE.TH.E.Y.O.O./S.CPC, fees for Intercity Bus Station Category 3, fees for covered vehicle parking) 36 fee codes have been created for each category, one for each Region – regional unit. Accordingly, the e-fee code 0296 is an sample code and relates exclusively to the implementation of the procedure in the Attica Region. Those with the right to operate a CPC professional training school/centre (natural or legal persons) have the right to operate as many schools/professional training centres as they wish in one or more regional units, in accordance with the terms of Joint Ministerial Decision Δ30/Α3/314952/2021 (Government Gazette Series II, No 5275). 200 €

              e-Administrative Fee code 0296

              Cost Calculation One-off

              Method of Payment Bank cashier, Digital (debit / credit card), Digital (web banking), Hellenic Post

              Type of Cost e-Administrative Fee

              Fee Link https://www1.gsis.gr/sgsisapps/eparavolo/public/create.htm?langId=2

              No

            • 1 Notification of operation of a KETHEYO, SEKAM and/or SEKOOMEE Training School and/or Centre (or an operating license or a certificate of legal operation). Notification / Announcement / Reporting

              Notification of operation of a KETHEYO, SEKAM and/or SEKOOMEE Training School and/or Centre (or an operating license or a certificate of legal operation).

              Submission by: Ex officio (digital), Ex officio (manual)


              Notes: Photocopy of notification of operation of a KETHEYO, SEKAM and/or SEKOOMEE Training School and/or Centre (or the operating license or certificate of legal operation).

              Document submitted under requirements: No


              No 5743

            • 2 Certificate of main use of space from a private engineer, with the necessary accompanying documents. Certificate

              Certificate of main use of space from a private engineer, with the necessary accompanying documents.

              Submission by: Submitted by the applicant (digital), Submitted by the applicant (in person or by post)

              Submitted by: Legal entities, Persons


              Document submitted under requirements: No


              No 9703

            • 3 Passive fire protection study Study of passive fire protection

              Passive fire protection study

              Submission by: Submitted by the applicant (digital), Submitted by the applicant (in person or by post)

              Submitted by: Legal entities, Persons

              Notes: Passive fire protection study for any Professional Training School/Centre housed in buildings that fall within the scope of Presidential Decree 41/2018 (Government Gazette, Series I, No 80) or of Presidential Decree 71/1988 (Government Gazette, Series I, No 32), and an active fire protection study.

              Document submitted under requirements: No


              No 3787

            • 4 Solemn declaration regarding the non-prohibition of the activity by the co-ownership regulation Solemn Declaration

              Solemn declaration regarding the non-prohibition of the activity by the co-ownership regulation

              Relevant link: https://www.gov.gr/en/ipiresies/polites-kai-kathemerinoteta/psephiaka-eggrapha-gov-gr/ekdose-upeuthunes-deloses

              Submission by: Submitted by the applicant (digital), Submitted by the applicant (in person or by post)

              Submitted by: Legal entities, Persons

              Relevant Procedure: Solemn declaration and electronic solemn declaration

              Notes: It is only necessary to submit this supporting document if the activity is housed in a multi-storey building.

              Document submitted under requirements: Yes

              Document’s requirement: Building

              No 7320

            • 5 Currently valid articles of association of a legal entity and any amendments thereto (only for legal entities which are not liable to register with the General Commercial Registry) Legal documents from legal entities

              Currently valid articles of association of a legal entity and any amendments thereto (only for legal entities which are not liable to register with the General Commercial Registry)

              Submission by: Submitted by the applicant (digital), Submitted by the applicant (in person or by post)


              Notes: Photocopy of the current articles of association of a legal entity and any amendments thereto (only for legal entities which are not liable to register with the General Commercial Registry) Only legal entities which are not liable to register with the General Commercial Registry are obliged to submit this supporting document.

              Document submitted under requirements: Yes

              Document’s requirement: Company law

              No 9338

            • 6 Legal documents on the representation of the legal person (only for legal entities which are not liable to register with the General Commercial Registry). Legal documents from legal entities

              Legal documents on the representation of the legal person (only for legal entities which are not liable to register with the General Commercial Registry).

              Submission by: Submitted by the applicant (digital), Submitted by the applicant (in person or by post)

              Submitted by: Legal entities

              Notes: Photocopy of legal documents on the representation of the legal person (only for legal entities which are not liable to register with the General Commercial Registry). Only legal entities which are not liable to register with the General Commercial Registry are obliged to submit this supporting document.

              Document submitted under requirements: Yes

              Document’s requirement: Company law

              No 9338

            • 7 Attestation of the number of drivers employed when this exceeds three hundred Certificate

              Attestation of the number of drivers employed when this exceeds three hundred

              Submission by: Submitted by the applicant (digital), Submitted by the applicant (in person or by post)

              Submitted by: Legal entities, Persons

              Notes: Document with data showing that the number of employed drivers exceeds three hundred (only for Educational Centres for Transport Operators). Only Educational Centres for Transport Operators are obliged to submit this supporting document.

              Document submitted under requirements: Yes

              Document’s requirement: Quantitative

              No 9703

            • 8 Fee payable to the State. Electronic Fee

              Fee payable to the State.

              Relevant link: https://www.gov.gr/en/ipiresies/polites-kai-kathemerinoteta/pleromes-kai-parabola/elektroniko-parabolo-e-parabolo

              Submission by: Ex officio (digital), Ex officio (manual)


              Notes: For approval to operate a CPC vocational training school/centre, two hundred (200) euro. (e-fee type code ,,,,,,,,,,,,,,,,,).

              Document submitted under requirements: No


              No 3385

            • 9 A list containing the names of the Director of Studies and the teaching staff of the vocational training school/centre. Status of staff / associates

              A list containing the names of the Director of Studies and the teaching staff of the vocational training school/centre.

              Submission by: Submitted by the applicant (digital), Submitted by the applicant (in person or by post)


              Document submitted under requirements: No


              No 7338

            • 10 Director of Studies’ driving licence (if they are not an authorised driving instructor for learner drivers). Vehicle license

              Director of Studies’ driving licence (if they are not an authorised driving instructor for learner drivers).

              Submission by: Ex officio (digital), Ex officio (manual)


              Notes: Photocopy of the Director of Studies’ driving licence (if they are not an authorised driving instructor for learner drivers). The Director of Studies is obliged to submit this supporting document if they are not a driving instructor for learner drivers.

              Document submitted under requirements: Yes

              Document’s requirement: Professional

              No 9039

            • 11 Professional learner driver driving instructor’s certificate or a Greek higher education degree/diploma or a higher education degree/diploma from a foreign school recognised as equivalent Proof of Study

              Professional learner driver driving instructor’s certificate or a Greek higher education degree/diploma or a higher education degree/diploma from a foreign school recognised as equivalent

              Submission by: Submitted by the applicant (digital), Submitted by the applicant (in person or by post)

              Submitted by: Legal entities, Persons

              Notes: For the Director of Studies and school staff, a photocopy of the professional learner driver driving instructor’s certificate or a Greek higher education degree/diploma or a higher education degree/diploma from a foreign school duly recognised as equivalent thereto.

              Document submitted under requirements: No


              No 2825

            • 12 Certificates or other details evidencing the suitability of the teaching staff (excluding learner driver driving instructors, Directors of Studies and lecturers at KETHEYO, SEKOOMEE and SEKAM schools or centres). Certificate

              Certificates or other details evidencing the suitability of the teaching staff (excluding learner driver driving instructors, Directors of Studies and lecturers at KETHEYO, SEKOOMEE and SEKAM schools or centres).

              Submission by: Submitted by the applicant (digital), Submitted by the applicant (in person or by post)

              Submitted by: Legal entities, Persons

              Notes: This document must be submitted by teaching staff who are not learner driver driving instructors or Directors of Studies or lecturers at KETHEYO, SEKOOMEE or SEKAM schools or centres.

              Document submitted under requirements: Yes

              Document’s requirement: Educational

              No 9703

            • 13 Copies of the criminal records of the Director of Studies and the teaching staff (excluding driving instructors for learner drivers) Criminal Record Copy for General Use

              Copies of the criminal records of the Director of Studies and the teaching staff (excluding driving instructors for learner drivers)

              Relevant link: https://www.gov.gr/en/ipiresies/dikaiosune/poiniko-metroo/antigrapho-poinikou-metroou

              Submission by: Ex officio (digital), Ex officio (manual)


              Notes: This documentation must be submitted by the Director of Studies and the teaching staff who are not driving instructors for learner drivers.

              Document submitted under requirements: Yes

              Document’s requirement: Professional

              No 4750

            • Joint Ministerial Decision 314952 2021 5275 Β

              Description Determination of procedure, content and supporting documents, fee and penalties for granting approval for the operation of professional training schools/centres to issue certificates of professional competence to drivers of vehicles for the carriage of goods or passengers.

              Legal references https://www.et.gr/api/DownloadFeksApi/?fek pdf=20210205275

              ΑΔΑ ΩΔ34465ΧΘΞ-04Ξ

            • Law 7, 11, 15, 230 4442 2016 230 Α

              Description New institutional framework for the exercise of economic activity with regard to the simplification of the operating framework for professional training schools/centres to issue Certificates of Professional Competence to drivers of vehicles for the carriage of passengers and in particular Article 230 and Article 7(3) and Articles 11 and 15.

              Legal references https://www.et.gr/api/DownloadFeksApi/?fek pdf=20160100230

            • Presidential Decree 74 2008 112 Α

              Description Transposition into Greek Law of Directive 2003/59/EC of the European Parliament and of the Council of 15 July 2003 on the initial qualification and periodic training of drivers of certain road vehicles for the carriage of goods or passengers, amending Regulation (EEC) No .../... Having regard to Council Regulation (EEC) No 3820/1985 and Council Directive 91/439/EEC and repealing Council Directive 76/914/EEC, as amended by Council Directives 2004/66/EC of 26 April 2004 and 2006/103/EC of 20 November 2006, and in particular Article 7(11) thereof.

              Legal references https://www.et.gr/api/DownloadFeksApi/?fek pdf=20080100112

            • 1 Receipt of application and supporting documents

              Responsible for Implementation Competent Directorate

              Μethod of Implementation Manual Action

              Description The operator shall submit an application for approval to operate a school/centre in accordance with the Sample Application Form as per Annex I of Article 14 of Joint Ministerial Decision 314952/2021, accompanied by the necessary supporting documents as specified in Article 5 of the same JMD. The application shall be exclusively submitted via the Integrated Licensing & Inspection Management System (ILIMS) pursuant to Article 14 of Law 4442/2016, accessible through the Public Administration Single Digital Portal (gov.gr). Until the Integrated Licensing & Inspection Management System (ILIMS) concerned with approval of the activity becomes operational, the application should be submitted in paper or electronic form to the licensing authority or to any Citizens Service Centre (KEP) that operates as a One-Stop-Shop in accordance with Article 7 of Law 3844/2010 (Government Gazette Series I No 63), with validated authenticity of signature, if not submitted by the Operator in person (natural person or legal representative of a legal person).

              Notes Prior approval of operation is required to open a CPC professional training school/centre. This approval is granted by the licensing authority (Directorate of Transport and Communications of the relevant regional unit where the CPC professional training school/centre is established and operates).

              No No


            • 2 Verification of application and supporting documents

              Responsible for Implementation Competent Directorate

              Co-responsible for Implementation MINISTRY OF INFRASTRUCTURE AND TRANSPORTATION

              Μethod of Implementation Inspection

              Description The licensing authority will review the application and the supporting documents within thirty (30) days and within the same deadline, it will duly inform the operator of any deficiencies in the application.

              Notes After the application for the issuance of operating approval for a CPC professional training school/centre has been submitted, the licensing authority shall ex officio request the copies of the criminal records of the Director of Studies and the teaching staff, in order to establish that they have not been convicted of the offences mentioned in cases (c) and (d) of Article 3(2) of Presidential Decree 208/2002 (Government Gazette Series I, No 194). It is not necessary to request these for learner driver driving instructors, given that they hold a valid certificate permitting them to practice their profession.

              No No


            • 3 Onsite inspection

              Responsible for Implementation Competent Directorate

              Co-responsible for Implementation MINISTRY OF INFRASTRUCTURE AND TRANSPORTATION

              Μethod of Implementation Action of the executive / co-competent body

              Description Within sixty (60) days from the appropriate submission of the application and supporting documents, the licensing authority shall conduct an onsite inspection to verify that the legal operating conditions are fulfilled and shall then issue the approval in accordance with the Sample Document of Annex II pursuant to Article 14 of Joint Ministerial Decision 314952/2021, or shall reject the application with due justification.

              Notes If there is no communication within the deadline of sixty (60) days for issuing approval, by way of derogation from Article 8 of Law 4442/2016, this cannot be presumed to mean that operating approval has been granted.

              No No


            • 4 Rejection of an application for approval to operate a CPC professional training school/centre.

              Responsible for Implementation Competent Directorate

              Co-responsible for Implementation MINISTRY OF INFRASTRUCTURE AND TRANSPORTATION

              Μethod of Implementation Action of the executive / co-competent body

              Description If there is no communication within the deadline of sixty (60) days for issuing approval, by way of derogation from Article 8 of Law 4442/2016, this cannot be presumed to mean that operating approval has been granted.

              Yes Yes


            • 5 Issue of approval to operate a CPC professional training school/centre.

              Responsible for Implementation Competent Directorate

              Co-responsible for Implementation MINISTRY OF INFRASTRUCTURE AND TRANSPORTATION

              Μethod of Implementation Action of the executive / co-competent body

              Description The decision to grant approval for the operation of professional training schools/centres to issue certificates of professional competence (CPC) to drivers of vehicles for the carriage of goods or passengers is signed by the licensing authority.

              Notes Approval of operation is valid for an indefinite period. Within sixty (60) days from the proper submission of the application and the supporting documents, the licensing authority will conduct an onsite inspection to verify that legal operating conditions are fulfilled, and will issue approval in accordance with the Sample Form of Annex II pursuant Article 14 of Joint Ministerial Decision Δ30/Α3/314952/2021 (Government Gazette Series II No 5275), or shall reject the application with due justification. If there is no communication within the deadline for approval, by way of derogation from Article 8 of Law 4442/2016, this cannot be presumed to mean that operating approval has been granted. After the operation has been approved, the operator of the CPC professional training school/centre can begin its business activities.

              Yes No


            • 6 Notification of approval

              Responsible for Implementation Competent Directorate

              Co-responsible for Implementation MINISTRY OF INFRASTRUCTURE AND TRANSPORTATION

              Μethod of Implementation Action of the executive / co-competent body

              Description Within five (5) working days, the licensing authority is obliged to notify details of the approval and any amendments to the Directorate of Road Traffic and Safety of the Ministry of Infrastructure and Transport, the National Transparency Authority, the relevant Building Service and to the relevant Fire Service, as well as to any other service that, at its discretion, should be informed about the operation of the activity in order to exercise their powers of inspection. The notification of approval shall be made electronically through the system or by email, without any need to issue a covering letter for this purpose.

              Notes After the operation has been approved, the operator of the CPC professional training school/centre can begin its business activities.

              No No


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