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ITACA

Quality Plan
http://www.itaca-project.eu

2012-1-IT1-LEO05-02806

ITACA
IT ADMINISTRATOR COMPETENCES
DEVELOPMENT AND ACKNOWLEDGE
LIFELONG LEARNING PROGRAMME
LEONARDO DA VINCI - TRANSFER OF INNOVATION
2012-1-IT1-LEO05-02806

D.5-3
VALIDATION REPORT
Version 1.2

This project has been funded with support from the European Commission. This plan reflects the views only of the author, and
the Commission cannot be held responsible for any use which may be made of the information contained therein

ITACA Quality Plan


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2012-1-IT1-LEO05-02806

INDEX

INTRODUCTION....................................................................................................................... 3
1 - FEE - ACADEMIC COMMITTEE REPORT ....................................................................... 4
THE ITACA PROJECT AND VET TRAINING (FORMACIN PROFESSIONAL) IN SPAIN ......... 5
The ITACA project is consistent with the regular activities of Fundacin EUCIP Espaa
(FEE) ................................................................................................................................ 5
The contents used in the ITACA project ........................................................................... 5
Feasibility of the ITACA approach in Spain ...................................................................... 6
Analysis of the Spanish system for primary and secondary education ............................ 6
FORMACIN PROFESIONAL ............................................................................................. 7
Basic FP and the ITACA project ....................................................................................... 7
Ciclos Formativos de Grado Medio (Medium level FP educational cycles)...................... 8
Ciclos Formativos de Grado Superior (Higher FP educational cycles) ............................ 9
Medium level and Higher FP educational cycles and the ITACA project ......................... 9
Educational market for Medium Level and Higher FP educational cycles...................... 10
ACREDITA: THE OFFICIAL SYSTEM FOR ACCREDITATION OF PROFESSIONAL COMPETENCIES . 11
2 - MADRID ASSOCIATION OF INFORMATICS TEACHERS REPORT ............................ 13
MEDIUM LEVEL FP CYCLE .............................................................................................. 15
Sistemas Microinformticos y Redes (SMR): Micro Informatics Systems And Networks
........................................................................................................................................ 15
Proposal for integrating exams in the SMR program...................................................... 16
HIGHER LEVEL FP CYCLE ............................................................................................... 17
Administracin de Sistemas Informticos en Red (ASIR): Administration of Informatics
Systems in Networks ...................................................................................................... 17
Proposal for integrating exams in the ASIR program ..................................................... 18
3 CONCLUSIONS .............................................................................................................. 20

ITACA Quality Plan


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2012-1-IT1-LEO05-02806

INTRODUCTION
This report addresses the analysis of the Italian proposal for the ITACA Project under the
point of view of the Spanish partners (FEE and ATI) involved in EUCIP certification training in
Spain. The goal established by the project plan is the evaluation of results in the view of
EUCIP and of its future application in Spain. The Italian proposal has been documented in
D.5-2 Report on the work done by the Italian partnersin WP4. The approach followed for
this report has been based on the analysis of the proposal by experts in EUCIP and VET
education in Spain. They have examined the proposal under two points of view:

EUCIP implementation: this has been done by the Academic Committee of FEE which is
a counseling unit with experts from the industry, the academia and the certification field
which analyzes and proposes the decisions on implementation of EUCIP in Spain.
EUCIP implementation in VET training: taking the experience of experts in VET training
(representatives of the Informatics VET and secondary teachers association, API
Madrid) as well as the analysis of the Academic Committee of FEE, the validation of the
approach is made based on the possible adaptation to the Spanish setting and then
confirming the approach of the design of proposal of WP4.

This document is structured in two main sections which presents the results of analysis from
the two main sources (Academic Committee of FEE and API Madrid) with a final closing
section with conclusions.

ITACA Quality Plan


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2012-1-IT1-LEO05-02806

1 - FEE - Academic Committee Report

ITACA Quality Plan


2012-1-IT1-LEO05-02806

http://www.itaca-project.eu




Fundacin EUCIP Espaa (FEE: www.eucip.es) is the authorized national licensee of the
EUCIP Certification in Spain. It is a foundation legally recognized by the Spanish government
with three main trustees: one of the main trade unions in the ICT field (COMFIA), the main IT
professionals association of Spain (ATI) and an specialized e-learning services company (elogos). Academic and technical decisions on the implementation and management of EUCIP
certifications are analyzed by the FEE Foundation Academic Committee where experts from
industry and academia act as counselling body to propose course of action, to create
supporting documents for operations and management and suggest management decisions.

THE ITACA PROJECT AND VET TRAINING (FORMACIN PROFESSIONAL)


IN SPAIN
The ITACA project is consistent with the regular activities of Fundacin EUCIP Espaa
(FEE)
As applied in Spain according to general guidelines provided by ECDL Foundation, the
owner of EUCIP certification, the model of EUCIP embraces around three types of
certifications the main knowledge and skills required by the IT professionals. Contents of
these certifications are considered as inspiration and are similar to the officially recognized
accreditation of the Spanish official VET programs (in Spain, named as Formacin
Professional, FP), what is an analogy of the experience proposed by the ITACA project in
Italy.
Moreover, experience of FEE in promoting EUCIP certification exams to different types of
students as additional external qualifications has been done in similar way to the proposed
scheme for implementing certifications in FP programs.
The contents used in the ITACA project
The ITACA project works with contents extracted from the above mentioned three EUCIP
Certifications although especially focused on the IT Administrator and the EUCIP Core.
During these recent years, the experience of FEE was mainly concentrated in the CORE
certification, widely implemented and managed by FEE. Regarding the IT Administrator
certification, FEE has had a more limited experience with only one partner (ATI)
implementing the certification but only with the theoretical exam, as the practical one created
many problems in practice. Of course, this is also consistent with the modality of IT
Administrator Fundamentals (ITAF) which does not require the practical exam, as the 47
lessons grouped in 5 modules (hardware, operating system Windows, operating system
Linux, networks and IT security) which are at least equivalent to 50 training hours can be
validated by one single exam, which it is not far different to the CORE one.
The opinion of the FEE Academic Committee supports the idea of the set created with IT
Administrator Fundamentals (ITAF) and IT Administrator. Although CORE contents may be
included as part of FP programs (maybe specific parts of it), in the end FEE mainly considers
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it as the basis for a graduate/master program at university level. Committee strongly agree
with the use of IT Administrator Fundamentals (ITAF) as the common basis for the program
intended for the ITACA project, complemented by the four specialization modules of IT
Administrator. This combined program is considered itself as a possible complete program of
FP accreditation. This design enables an easy adaptation to the official FP programs in
Spain.
As final conclusion, the proposal made in WP4 is validated according to EUCIP philosophy
and guidelines.
Feasibility of the ITACA approach in Spain
The analysis has been made taking D.5-2 Report on the work done by the Italian partners
in WP4 as guideline for checking the feasibility of adoption of such approach in Spain,
adapting the information to the Spanish settings. The scenario in Spain would be less
favourable to direct adoption of the D.5-2 ITACA approach due to two reasons:

A lower level in the Spanish VET system when comparing, e.g., to the presence of a
fifth year in the Italian VET system.
The
ACREDITA
initiative
(http://www.todofp.es/todofp/acreditacion-decompetencias.html) by the Spanish Ministry of Education which it is aimed at
accrediting the professional competences for general public, even recognizing non
formal education as well as working experience.

As a consequence, it is necessary to carry out a deep analysis of several aspects of the


Spanish situation:
1) Curricula of the different official levels and programs of FP in Spain to check which
contents are included in the syllabus of the different EUCIP certifications addressed by the
ITACA project (Core, IT Administrator e IT Administrator Fundamentals).
2) The coexistence - with positive, negative or neutral impact - of the activity of FEE with the
official initiative ACREDITA which allows accreditation of units of professional competence
acquired through working experience and non formal training processes. This competence
units are consistent to the ones included in the official programs of FP.
Analysis of the Spanish system for primary and secondary education
The scheme of Spanish system for primary and secondary education corresponds to the
following levels:
-
-
-

Educacin Infantil, (up to 6 years old)


Educacin Bsica, no charges and compulsory from 6 to 16 years old, with two phases:
primary school and secondary school (ESO: Educacin Secundaria Obligatoria)
Educacin Secundaria Postobligatoria, secondary education after compulsory period
which includes two alternate paths:
o 2 years of Bachillerato, allowing earning the degree of Bachiller and enabling
access to University studies (so far with a specific exam, names as Selectividad)
o Formacin Profesional (FP), official VET training, analyzed in the next section.
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FORMACIN PROFESIONAL
Formacin Profesional (FP), official VET training, is organized in disciplines or branches
named as Familias Profesionales (professional families), amongst them our interest of
analysis is focused on Informtica y Comunicaciones (informatics and communications).
The official degrees of FP are organized in three levels: "Tcnico Profesional Bsico (basic
professional technician), Tcnico en (technician in) and "Tcnico Superior en" (higher
technician in). All the degrees are referred to the official Catalogo Nacional de
Cualificaciones Profesionales (catalogue of professional qualifications) which lists all the
qualifications which can be recognized and accredited, allegedly based on the needs of the
different productive sectors according to the competencies required for professional activity.
FP is structured into three levels:
o
o
o

Ciclos de Formacin Profesional Bsica: basic VET educational programs ("cycles")


Ciclos formativos de Grado Medio: medium level VET educational programs ("cycles")
Ciclos Formativos de Grado Superior: higher medium level VET educational programs
("cycles")

Each educational cycle may be completed by studying "mdulos profesionales" (professional


modules) and with specific subjects and blocks, as determined by specific regulations of the
Government. When a students completes an educational cycle, he/she earns the
corresponding VET degree specified above. More exactly, earning a degree requires that
he/she gets a positive evaluation in all modules (and, in case, subjects and blocks). Those
students who are not finally able of earning the degree may receive academic certificates of
the modules and subjects effectively passed. It is also possible to establish processes of
recognition of modules and other items.

Basic FP and the ITACA project


The basic FP is intended to serve as access way to FP with 15 years old when the student
has not been able to pass the ESO. Former regulation stated that student had to get a
Cualificacin Profesional de Nivel 1 (professional qualification level one) to get the certificate
after a Programa de Cualificacin Profesional Inicial (initial professional qualification
programa: PCPI) with one or two years with 900 hours plus 150 working in a company. It
included specific professional modules related to competency units listed in the professional
qualifications of level of the National Catalogue of Professional Qualifications.
With the new law (LOMCE) to be implemented in the next academic year, the PCPI is
replaced by Ciclos de Formacin Profesional Bsica (Basic professional education cycle)
with duration of two years within the scheme of free and compulsory education. It allows
earning a diploma of Tcnico Profesional Bsico en Informtica y Comunicaciones (Basic
technical professional in informatics and communications) apart from Cualificacin
Profesional de Nivel 1 in the National Catalogue of Professional Qualifications.
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The idea of targeting the application of the ITACA project to Formacin Profesional Bsica is
not recommended given that these courses are aimed at giving a solution to students who
were not able of finishing the basic secondary education (ESO). The programs include:
a) Basic block of communication and social sciences:
1. Spanish language
2. Foreign language
3. Social sciences
4. Co-official regional language (if applicable)

b) Applied sciences block:


1. Mathematics applied to the personal context and to learning in a professional area
2. Applied sciences applied to the personal context and to learning in a professional
area
c) Guaranteeing the necessary education to earn Cualificacin Profesional de Nivel 1 in the
National Catalogue of Professional Qualifications.

In the case of the professional family of Informatics and Communications, the catalogue only
considers Auxiliar operations of installation and maintenance of micro informatics systems".
This could be the only element which may justify applying the ITACA project to this
educational cycle, what it is certainly very limited.

Ciclos Formativos de Grado Medio (Medium level FP educational cycles)


They allow earning a degree of Technician, something similar to the higher secondary
education level. Technician got the necessary qualification to carry out the technical works
which are specific of a profession.
Ways of access to Ciclos Formativos de Grado Medio are the following ones:
-
-

After earning the degree of ESO (Ttulo de Graduado en ESO),


Without having the degree of ESO, with 15 years old and after earn Cualificacin
Profesional de Nivel 1 in the National Catalogue of Professional Qualifications (As
described in previous section).
With a specific exam for students older than 17 years old.

These FP medium cycles are aimed at allowing students to be qualified, in a practical


manner, with the knowledge and skills needed to integrate them in the professional world.
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These programs may also include subjects which may facilitate transition of students to other
types of education:
- Communication in Spanish language
- Communication in a foreign language
- Applied mathematics
- Co-official regional language (if applicable)
Moreover, some additional voluntary subjects related to the corresponding professional field
are taugth to enable a smoother transition to higher cyles of FP education. Regulation allows
that the above courses may be offered in traditional or e-learning mode but they are not part
of the official curriculum of the Medium level FP educational cycles.
Ciclos Formativos de Grado Superior (Higher FP educational cycles)
They allow earning a degree of Higher Technician, getting the necessary qualification to
carry out the technical works which are specific of a profession but also assuming
responsibility of planning, organizing and coordinating works.
Higher FP educational cycles are especially addressed to students with the degree of higher
secondary education (bachillerato) and as alternative to University, pursuing practical higher
programs which lead to a direct qualification for labor market.
Ways of access to Ciclos Formativos de Grado Superior are the following ones:
- With a degree of Technician
- With a degree of Bachiller (Higher Secondary Education) if the student does not want to
access University degrees
- With an specific exam for students older than 19 years old.

The degree of Higher Technician also enables direct access to university degrees, even with
some recognition of credits.

Medium level and Higher FP educational cycles and the ITACA project

The ITACA project seems to be especially adequate for Medium level and Higher FP
educational cycles which provide the needed training to reach level 2 and 3 of the National
Catalogue of Professional Qualifications.
A preliminary analysis of these level 2 and 3 qualifications lead us to confirm that they have
contents present in certifications CORE, IT Administrator and ITAF. A detailed analysis with
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2012-1-IT1-LEO05-02806

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a correspondence table (similar to the one constructed by Italian partners for the Italian case)
between the certifications and the contents of the National Catalogue of Professional
Qualifications grouped in the professional family of "Informatics and communications".

Level 2
IFC078_2 Sistemas microinformticos (microinformatics systems); IFC297_2 Confeccin y
publicacin de pginas Web (development and publication fo web pages); IFC298_2 Montaje
y reparacin de sistemas microinformticos (installation and repairing of microinformatics
systems); IFC299_2 Operacin de redes departamentales (departamental network
operations); IFC300_2 Operacin de sistemas informticos (computing systems operations);
and IFC362_2 Mantenimiento de primer nivel en sistemas de radiocomunicaciones (first
level maintenance of radiocommunications systems).
Level 3
IFC079_3 Administracin de bases de datos (database administration); IFC080_3
Programacin con lenguajes orientados a objetos y bases de datos relacionales
(programming with object-orienetd languages and relational databases); IFC081_3
Administracin y diseo de redes departamentales (departamental network administration
and design); IFC152_3 Gestin de sistemas informticos (computer systems management);
IFC153_3 Seguridad informtica (informatics security); IFC154_3 Desarrollo de aplicaciones
con tecnologas Web (application development with web technologies); IFC155_3
Programacin en lenguajes estructurados de aplicaciones de gestin (programming with
structures languages of business applications); IFC156_3 Administracin de servicios de
Internet (Internet services administration); IFC302_3 Gestin de redes de voz y datos (data
and voice network management); IFC303_3 Programacin de sistemas informticos
(computer systems programming); IFC304_3 Sistemas de gestin de informacin
(information management systems); IFC363_3 Administracin y programacin en sistemas
de planificacin de recursos empresariales y de gestin de relaciones con clientes
(administration and programming of ERP and CRM); IFC364_3 Gestin y supervisin de
alarmas en redes de comunicaciones (management and monitoring of alarms in
communication networks); IFC365_3 Implantacin y gestin de elementos informticos en
sistemas domticos/inmticos, de control de accesos y presencia, y de videovigilancia
(installation and management of domotics/inmotics systems, access and presence control
and videosurveillance); and IFC366_3 Mantenimiento de segundo nivel en sistemas de
radiocomunicaciones (second level maintenance of radiocommunications systems).

Educational market for Medium Level and Higher FP educational cycles


This is the target market for the ITACA project. The analysis is based on a general search of
the existing offer of services educational.
Across the Spanish geography, the educational market covers up to 178 courses and
Training Cycles (Ciclos Formativos) included in the ICT specialties of Medium level FP
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education, each one with around 2000 hours of duration. Prices range from free education to
500 euros. They cover disciplines like informatics systems, telecommunications and
telematics, programming, ICT, Internet, office automation and ofimatics, multimedia and
CAD.
The educational market also includes up to 155 courses and Training Cycles (Ciclos
Formativos) included in the ICT specialties of Higher level FP education, each one with
around 2000 hours of duration (Prices range from free education to 5000 euros). They cover
all the subjects defined in the following programs:

Tcnico Superior en el Desarrollo de aplicaciones multiplataforma (Higher Technician


in Development of Multiplatform Applications)
Tcnico Superior en el Desarrollo de aplicaciones Web (Higher Technician in
Development of Web Applications)
Tcnico Superior en sistemas de Telecomunicaciones e Informticos (Higher
Technician in Telecommunication and Informatics Systems).

ACREDITA: THE

OFFICIAL SYSTEM FOR ACCREDITATION OF PROFESSIONAL

COMPETENCIES
The official program ACREDITA allows accrediting competency unit even recognizing non
formal education as well as working experience. These units are in perfect correspondence
to the ones which are the basis of the FP education. People who participates in this process
can accredit one or more competency units and when all the recognized units match the
same included in a professional certificate (certificado de profesionalidad) they can request
the corresponding diploma only if they fulfill the access requirements to the program and they
passed the modules within the program which are not related to competency units.
Public administration is in charge of definition of calls for requests of recognition and also of
definition of professional profiles which may be accredited in each call. General requirements
for candidates are the following ones:

Minimum working experience of two years for level 1 qualifications and three years
for level 2 and 3.
Minimum educational period of 220 hours for level 1 qualifications and 300 for level 2
and 3.

Public administrations will publish procedures for recognizing this way the degrees of FP of
Tcnico or Tcnico Superior without the specific need of taking all the subjects of the official
programs of medium and higher level of FP. This option is targeted to people with long
experience in an specific field but who do not hold any official diploma. They should be able
to plan their study without the need of support, taking a single exam for each professional
module.

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One of the key points for success of extending the training programs which FEE may
promote in Spain grabbing the experience transferred from the ITACA project is the
possibility that the public administration may recognize them within ACREDITA. If public
administration is not interested in this philosophy, any new certification like the ones covered
by ITACA might find few options of coping with the educational competitors.

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ITACA Quality Plan


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2012-1-IT1-LEO05-02806

2 - Madrid Association of Informatics


Teachers Report

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API Madrid (http://apimadrid.org/) is a non lucrative association of VET and secondary


education teachers specialized in the teaching of informatics in these educational levels.
Representatives of the executive board (Carmen Luengo and Dolores Parra) have developed
this report on the possibilities of integration of the EUCIP Certifications within the regular
programs of VET education (i.e. the already mentioned FP: Formacin Profesional). From
their experience as teachers and managers of educational programs in VET education, they
outline a proposal for the integration of EUCIP certifications in the different modules of the
official VET programs.
Programs and curricula in the region of Madrid corresponding to the education of
Formacin Profesional as they are regulated by Law of Education 2/2006 of 3th May.

Table 1. Available VET programs and regulation


Professional family

INFORMATICS AND
COMMUNICATIONS

Programs
TECHNICIAN IN MICRO
INFORMATICS SYSTEMS AND
NETWORKS
HIGHER TECHNICIAN IN
ADMINISTRATION OF
INFORMATICS SYSTEMS IN
NETWORKS
HIGHER TECHNICIAN IN
DEVELOPMENT OF
MULTIPLATFORM
APPLICATIONS
HIGHER TECHNICIAN IN
DEVELOPMENT OF WEB
APPLICATIONS

Law

Regulation

RD 1691/2007

D 34/2009

RD 1629/2009

D 12/2010

RD
450/2010

RD
686/2010

D 3/2011

D 1/2011

The possibilities of certifications related to the educational paths proposed by the ITACA
project should be concentrated in two of these four programs:

TECHNICIAN IN MICRO INFORMATICS SYSTEMS AND NETWORKS


HIGHER TECHNICIAN IN ADMINISTRATION OF INFORMATICS SYSTEMS IN
NETWORKS

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MEDIUM LEVEL FP CYCLE


Sistemas Microinformticos y Redes (SMR)1: Micro Informatics Systems And
Networks
Table 2. SMR comparison to IT Administrator syllabus
IT ADMINISTRATOR

SMR

MODULES

MODULES

Hardware

Installation
equipment

Operating systems

Monocomputer operating systems

and

maintenance

of

computer

Network operating systems


LAN and network services

LAN
Networks services
Network operating systems

Experts use of networks

LAN
Networks services
Informatics security

IT Security

Informatics security

According to decree REAL DECRETO 1691/2007, 14th December, which defines the
program Tcnico en Sistemas Microinformticos y Redes declaring the minimum contents,
we can confirm that any student who has passed the different modules can be prepared to
easily get the IT Administrator certification.

Note: the names and contents of the modules of cycles are not exactly matching the modules of the IT
Administrator certification although all the contents of the certification are included in the programs. Thus we
have marked with a color each module of the program so contents are marked with the corresponding color of
the module where they are taught.

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Proposal for integrating exams in the SMR program

Once we have analyzed the contents of the certification, we have developed a scheme to
integrate the exams of the certification within the official program. The cycle SMR is
developed along two academic years so the proposal of exams would be the following one2:
Table 3. Modules of the SMR program
Year 1

Year 2

September-June

September-June

Installation
equipment

and

maintenance

of

computer Network operating systems

Monocomputer operating systems

Informatics security

LAN

Network services

Table 4. Correspondence between certification and modules of SMR program


IT ADMINISTRATOR

SMR

MODULES

MODULES

Hardware

Installation
equipment

Operating systems

Monocomputer operating systems

and

maintenance

of

computer

Network operating systems


LAN and network services

LAN
Networks services
Network operating systems

Experts use of networks

LAN
Networks services
Informatics security

Note: En esta tabla slo se nombran los mdulos de SMR que afectan a la certificacin ITAF.

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Given the correspondence between modules of the IT Administrator certification and the
ones from SMR the best exam calendar would be established in the two academic years as
follows:
Table 5. Certification exams calendar within the SMR program
IT ADMINISTRATOR

EXAMS

MDULOS
Hardware

June, first year

Operating systems

March, second year

LAN and network services

March, second year

Experts use of networks

March, second year

HIGHER LEVEL FP CYCLE


Administracin de Sistemas Informticos en Red (ASIR)3: Administration of
Informatics Systems in Networks

Table 6. ASIR comparison to IT Administrator syllabus


IT ADMINISTRATOR

ASIR

MODULES

MODULES

Hardware

Hardware fundamentals

Operating systems

Installation of Operating Systems


Operating systems administration

LAN and network services

Network planning and administration


Network services and internet

Experts use of networks

Network planning and administration

Note: similar to the previous program.

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Operating systems administration
Installation of Operating Systems
Ntework services and internet

IT Security

Security and high availability

According to decree REAL DECRETO 1629/2009, 30th October, which states the program
Tcnico Superior en Administracin de Sistemas Informticos en Red declaring the minimum
contents, we can confirm that any student who has passed the different modules can be
prepared to easily get the IT Administrator certification.

Proposal for integrating exams in the ASIR program


Once we have analyzed the contents of the certification, we have developed a scheme to
integrate the exams of the certification within the official program. The cycle ASIR is
developed along two academic years so the proposal of exams would be the following one4:
Table 7. Modules of the ASIR program
Year 1

Year 2

September-June

September-June

Hardware fundamentals

Operating systems administration

Installation of Operating Systems

Security and high availability

Network planning and administration

Network services and internet

Given the correspondence between modules of the IT Administrator certification and the
ones from ASIR the best exam calendar would be established in the two academic years as
follows:

Note: similar to previous program.

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IT ADMINISTRATOR

EXAMS

MDULOS
Hardware

June, first year

Operating systems

June, first year

LAN and network services

March, second year

Experts use of networks

March, second year

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3 Conclusions

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The conclusions of the analysis by Academic Committee of FEE and API Madrid can be
summarized as follows:

The approach of implementation of EUCIP ITAF and IT Administration in VET


education is consistent with the analysis of the EUCIP experience in Spain and with
the guidelines of EUCIP.

The approach is adequate to a VET educational system and the analysis of feasibility
for the implementation in the Spanish VET system shows good chances of
implementation of
EUCIP ITAF and IT Administration, thus transferring the
innovation of the learning path established in Italy, obviously with the necessary
adaptations to the specific local structure and conditions. However, the specific
details on the EUCIP Core program show that there are some components of it in
some of the Spanish VET programs; but the consideration of Spanish experts of FEE
is that other components are oriented to higher education levels at
graduate/postgraduate programs so they could not be easily inserted in regular
dynamics of VET programs.

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