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FAQ for individuals completing the online annual declaration of interests form

This FAQ is intended for:

  • Heads of Institutions; and
  • Members and regular attendees of the University's principal, central decision making bodies 

 

Q. Why has the University introduced a Conflict of Interest Policy?

The mission of the University of Cambridge is to contribute to society through the pursuit of education, learning and research at the highest international levels of excellence.  Accordingly, many staff of the University are actively engaged in external activities, both within the UK and overseas.  These activities may for example include: providing expert advice and media commentary; serving on the boards of public and private sector organisations; partnerships with business, charitable foundations, and healthcare; collaborative research and development; consultancy work; spin-out companies; and outreach work.  Alternatively, someone with a close personal connection to a member of staff may have such associations. In addition, many staff - or those with a close personal connection to them - will also be affiliated to, and owe duties to, one or more of the Colleges within the collegiate University.

Because of these activities, most staff will almost certainly encounter situations during their careers when personal interests could reasonably be perceived as affecting, or having the potential to affect, their ability to make impartial decisions on the University’s behalf. This does not imply improper conduct or lack of integrity.  What is important is that all such conflicts are disclosed, reviewed and (if necessary) managed in order to avoid the risk of decisions being, or appearing to be, improperly influenced and to prevent damage to the reputation of the individual or the University.

The aims of the University’s new Conflict of Interest Policy are to:

  1. enable staff, plus student and external committee members, to recognise where their personal interests conflict with, or may reasonably be perceived to conflict with, their University duties (see Section C);
  2. communicate the expectations for declaring and recording such conflicts (see Section D); and
  3. set out the processes for managing conflicts of interest in order to ensure that business decisions are made objectively and in the best interests of the University (see Section E). 

Most organisations have policies on disclosing and managing conflicts of interest: this Policy is consistent with those of other UK universities.  It does not differentiate between conflicts that arise from domestic or oversees interests.

Q. Who does this Policy apply to?

Section B of the Policy states that the Policy applies to all those working within the University at all levels (whether paid or unpaid), as well as to student and external members of University committees or equivalent bodies.  All individuals who fit the above definition are encouraged to read the Policy and the relevant FAQs.

Q. What are the main features of the Policy?

The Policy distinguishes between two types of disclosures, which will be recorded in two different types of register:

  • Heads of Institutions, plus members and regular attendees of the University’s principal, central, decision-making bodies, are required to declare any interests which constitute existing or potential conflicts with their University duties annually via an online declaration of interests form,  The form will be administered by the Governance and Compliance Division and the declarations will be recorded in Committee or School-based registers of interests;
  • all other members of staff will only need to disclose conflicts of interest with their University duties when they first arise or become known, including when it is recognised that a conflict might reasonably be perceived. These conflicts will be recorded in the institution's register of conflicts of interests.

‘Declarations of interest’ should also be a standing item at the beginning of every committee meeting, so that members can declare any conflicts of interest in relation to that specific agenda. Both the declarations and any mitigating actions should be minuted.

This approach recognises that for the large majority of members of staff at the University it will be sufficient to declare conflicts of interests with their University duties when they arise. The approach will also reduce the administrative burden on institutions.

Q. Who should complete the online annual declaration of interests form and how does it work?

Heads of Institution, plus members and regular attendees of the University’s principal, central decision-making bodies, are required to declare any personal, financial or other interests (and/or those of their close personal contacts) which constitute existing or potential conflicts with their University duties annually via the online declaration of interests form. 

For the purposes of this Policy, ‘regular attendees’ are those individuals who have a standing invitation to attend the meetings and who receive a full set of the unreserved papers.  In most cases this is likely to include (but not necessarily be limited to) the secretary and those who regularly attend in an advisory capacity or as an observer.

We have set up the form to minimise the burden on individuals of completing and submitting multiple forms, as senior colleagues are often members of many University bodies.  If you are asked to complete the form your declarations will be filtered and sent to the relevant committee and/or School contacts for inclusion in their registers of interests. 

Please note that you should still declare conflicts in relation to particular agenda items as they arise. Unless you are Head of Institution* you should also separately disclose conflicts of interest with your University duties to your Head of Institution at the earliest opportunity, so that these can be recorded in your institution’s register of conflicts of interests.

*NB. if you are a Head of Institution your Head of School (or the Registrary for non-School institutions) will receive your declarations of interests via the annual declaration of interests process and record them in their registers, so you do not need to separately disclose your conflicts to them.

Known limitations of the current design and workarounds

There are a couple of known limitations with the current design of the form – namely that individuals cannot amend their entries and there is no back button.  The form is only intended as an interim solution to avoid the need for a manual process and so reduce the burden on individuals and on those who are responsible for maintaining the registers. 

We aim to introduce a more integrated system for 2022-23, which should allow individuals to amend their entries and enable those who are responsible for reviewing the disclosures to access the relevant declarations and record the agreed management plans.  In the meantime, if you need to add another interest at any point during the academic year, or realise that you made an error in your original submission, you can create a new entry via an open link.

We welcome feedback that will help us to further improve the form; please send any such comments to the Governance and Compliance Division (GCDEnquiries@admin.cam.ac.uk)

Q. How do I know which interests I should declare?

Section C of the Policy provides guidance on how to recognise a conflict/potential conflict of interest. The level of disclosure required in the declaration of interests form exceeds the expectations of other staff, by encompassing not only existing conflicts of interest with University duties but also potential conflicts of interests.  A potential conflict is where an interest is not currently in conflict with your University duties, but there is a reasonable likelihood that it may give rise to a conflict in the future.

Questions to consider when deciding whether an interest, or the interests of someone with a close personal connection to you, could (or could appear to) conflict with, your University duties include:

  • Is there any risk that others might conceivably think my judgment was potentially clouded by this interest?
  • Could a decision in which I was involved be potentially criticised because of my involvement?
  • Do I have any personal reason for wanting a particular outcome from a decision-making process in which I am involved?
  • If I became aware of someone else in a similar position, would I take the view that they might have a conflict of interest?

If you answer ‘yes’ to any of these questions you should declare the interest, even if you believe that there is no actual conflict.  If you are in doubt about whether to disclose a particular interest we suggest that you declare it.  Often disclosure will be sufficient, and your declaration of interest will be on record if questions ever arise. 

Please declare all relevant interests, including any which you may previously have disclosed. This will include declaring other roles that you hold within the Collegiate University, which could potentially lead to conflicts of interests.

NB. Trade Union membership is exempt from disclosure via the declaration of interests form and need only be disclosed when a conflict becomes known, including when it is recognised that a conflict might reasonably be perceived.  

Q. What is meant by a ‘close personal connection’?

The Policy asks you to declare the interests of your ‘close personal connections’, if these interests could reasonably be perceived as representing a conflict of interest with your University duties.  Close personal connections will include, but not be limited to, any children, in-laws, siblings, partner or spouse. You should exercise your judgement if you think that the interests of another close personal connection (for example, a long-standing friend or a niece who lives with you) could reasonably be perceived as representing a conflict of interest with your University duties and so need to be declared.

Q. My interest doesn't seem to fit in any of the categories - where should I record it?

There is a catch-all category at the end of the declarations of interests form where you can record any interests which do not seem to fit within any of the specified categories in the form.

Q. What if I don't have any interests to declare?

If you do not have any standing declarations of interests please select the relevant field in the online form and submit it.  This will ensure that your response is recorded and you won’t receive reminders.

Q. Who will see my information and where will it be stored?

Your information will be accessed by those who need to review it in order to assess whether any action is needed to manage the interest, such as:

  • the Chairs of any principal, central decision-making bodies to which you belong or which you regularly attend (or their nominated delegate);
  • [if you are a Head of Institution which is within a School] the Head of your School (or their nominated delegate);
  • [if you are a Head of Institution which is within the UAS or another NSI] the Registrary;
  • [if you are a Head of School or a member of the Senior Leadership Team] the Vice-Chancellor.

Your information may also be accessed by others (for example, in HR and the Governance and Compliance Division) in order to check that the Policy is being implemented effectively.  It may also be accessed by the administrative team who are responsible for administering the form in order to ensure that the declarations are included in the relevant registers of interests and sent for review by the appropriate contacts.

Your information will be recorded and stored securely in the relevant registers of interests, with access restricted to those who have a legitimate reason to use it.  It will be treated confidentially insofar as the law permits.  Information will be retained while you remain a member of University staff, plus a further six years.  Wider statements about the uses made of the personal data of staff, students and others are published at https://www.information-compliance.admin.cam.ac.uk/data-protection.

Q. Why can't my declarations be reviewed by one contact?

Declarations cannot always be reviewed by a single contact because the relevance of each interest will vary depending on context.  For example, your partner’s role in a company which frequently tenders for University contracts could be relevant if you are a member of the Resource Management Committee, but is very unlikely to be relevant to your membership of the Discipline Board.  Committee Chairs are best placed to assess what action is required (if any) to manage a conflict/potential conflict in the context of their committee’s terms of reference.  Similarly, Heads of School (or the Registrary for non-School institutions) are best place to assess what action is required (if any) to manage a conflict/potential conflict in the context of their institutions.

Q. Will my declarations be subject to Freedom of Information requests?

As mentioned above, information relating to declarations of interest will be treated confidentially insofar as the law permits.  The FOI Act includes an exemption to prevent the disclosure of personal information.  In the vast majority of cases, this will mean that personal information about your interests will not be publicly disclosed in response to an FOI request unless you have consented to it.  However, the exemption works in a case- and circumstance-specific way, and it is conceivable that rare circumstances might arise where declarations needed to be disclosed even in the absence of consent.

Q. What kinds of actions may be put in place and will I be informed?

Section E of the Policy sets out some possible ways of managing conflicts of interest.  These range from a simple record of the declaration, through more active management plans to (in extreme cases) avoidance of the conflict.  In some cases it may be sufficient to simply note the disclosure in the institution’s register as you judge that no further action is required.  Please note that the Head of School/Registrary or Committee Chair (as relevant) has discretion to implement other solutions that are compatible with the principles in Section E.  They should liaise with you to determine how to manage your declared interests and then confirm the agreed actions to you by email.

Q. What if there are material changes to my interests after I have completed the online form?

Please give notice of any changes to your interests via the form at the earliest opportunity, using the open link rather than your individual link.