FAQ for Heads and Secretaries of the Schools

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 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.

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.

The Policy distinguishes between two types of disclosures, which are recorded in two different types of register, both of which are relevant to the Schools:

• 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 which is administered by the Governance and Compliance Division.  These declarations are recorded in School or Committee-based registers of interests;
• all other members of staff will only need to disclose conflicts of interest with their University duties when they arise. These conflicts are recorded in local (institutional) registers of conflicts of interests.

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

The Schools play a role in implementing several aspects of the Policy as follows (also see the flowchart below):

1. Role in the annual declarations of interest process

Heads of School (or their nominated delegate) are asked to ensure that an up-to-date register of interests is maintained for Heads of Institutions within their School by:

• reviewing any declarations of interest made by Heads of Institutions within their School via the online declaration of interests form;
• determining, in liaison with the declarer, whether any actions are needed to manage these interests in their local context; and
• recording the agreed actions in the register (including noting where no actions are necessary).  NB. this should include an annual review of actions for previously declared conflicts to ensure that they remain relevant.

The register should be updated throughout the year as new interests are declared. See the flow chart below for an outline of the process.

Heads of Schools will also be asked to complete the DoI form.  Their declarations will be reviewed by the Vice-Chancellor.

2. Role in local conflict of interest processes

The Schools, like all other institutions within the University, are asked to:

• bring the Policy to the attention of their staff (i.e. staff within the School Office), plus members of their committees;
• advise how individuals should declare conflicts of interests with their University duties (for example, by email to the Head of the School or via a webform);
• ensure that an up-to-date register of conflicts of interests is maintained for their School;
• determine, in liaison with the declarer, how to manage each conflict within their local context;
• record the agreed actions in the register (including noting where no actions are necessary) and send confirmation in writing to the declarer;
• undertake an annual review of actions for previously declared conflicts to ensure they remain relevant; and
• check that ‘Declarations of Interest’ is a standing item on the agenda of every committee within the School, and that any declarations and mitigating actions are minuted.

If a Head of Institution within your School has an interest in a conflict being disclosed by a member of their institution the matter will be referred to the Head of the School for their decision about the appropriate way to manage the conflict.

In some circumstances, particularly those relating to interdisciplinary research projects which involve multiple Schools, neither the Head of Department nor Head of School may be the appropriate individual to decide on mitigation. Most such projects have a board which could be asked to advise the Head of Institution of the individual concerned, and the Head of the Institution can then check that the mitigation is appropriate and note it in the register.

Generally Heads of School are the most appropriate people to review the conflicts in their local context.  On occasion, the Head of School may delegate this responsibility to a suitably qualified named individual (e.g. the Deputy Head or Secretary).

If the Head of School has an interest in a declaration they should contact CoI@admin.cam.ac.uk for advice on how to proceed.

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 School’s register as you judge that no further action is required.  Please note that the Head of School has discretion to implement other solutions that are compatible with the principles in Section E.

In deciding on the most appropriate management plan for each disclosure you may like to consider:

• whether the activity is in the interests of the University?
• is the activity potentially detrimental to the University, either financially or reputationally?
• how potentially material is the conflict?
• is there any gain, financial or otherwise, to the individual or to any of their close personal connections?
• can the activity be kept separate from the individual’s University duties?
• is the conflict straightforward to manage?

Local conflict of interest process

In accordance with Section E of the Policy the Head of the School (or their nominated delegate) should decide on the course of action for each declared interest, confirm this to the declarer in writing and record it in the School’s register of conflicts of interests.  Responsibility for implementing the mitigating action should also be specified in the register if it is not self-evident.  This register should be stored securely, with access restricted to those who have a legitimate reason to use it.  It should be treated confidentially insofar as the law permits. 

The retention period for declarations in a School's register of declarations of interest is ten years. This is the same as the retention period for the central declarations of interest system. 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.

Central annual declaration of interest process 

A Review and Manage app has been created for reviewers that allows each interest to be reviewed and a mitigation recorded.  This automatically populates the School's register of interests which can also be accessed via the app.  This system is intended to be more secure and auditable. 

We have added Heads and Secretaries to the Schools as reviewers to the system and recommend that the Secretaries should generally be responsible for adding the agreed mitigating actions to the system. This will be a two stage process:

1. confirming that the mitigating actions for interests that were declared last year remain appropriate (or amending them as necessary); and
2. agreeing and entering mitigating actions for any newly declared interests .

Last year we know that many Secretaries went through the declarations on a call with their Head of School. We suggest that this might be a straightforward way to agree the mitigating actions for the Secretaries to input into the new system. At the end of the process UIS will send declarers a copy of the mitigating actions for their declared interests.

It is possible to export the register of interests (UIS have provided guidance on how to do this). While we are trying to move away from emailing spreadsheets containing sensitive personal data we recognise that some Heads of School may find it more convenient to review the interests and check that last year’s mitigating actions remain appropriate offline, rather than on a call, so sending them an export of the register may be helpful.

For further information about the new Review and Manage App please see the training notes for reviewers.

There is no expectation that Schools, or other institutions, should publish their registers of conflicts of interest. However, some institutions choose to publish all their conflicts of interest (at a high level) online on their group leaders’ web pages.

Interests and mitigating actions that are declared at committee meetings can just be recorded in the minutes if the conflict relates to a particular item and is unlikely to recur. However, if the Chair thinks that the interest represents a standing conflict of interests they should recommend that it also be included in the School's register of interests.

You are welcome to use or adapt the following wording when emailing staff about the Conflict of Interest Policy:

I am writing with a reminder of what we need to do to comply with the University-wide Conflict of Interest Policy. Most of us will encounter situations during our careers when personal interests could affect, or could reasonably be perceived as affecting, our 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 conflicts arising from such interests 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.

If you have not already done so, please familiarise yourself with the Policy and the FAQ for members of institutions. Please let me know by email [or however the Head of School prefers staff to disclose conflicts] at the earliest opportunity if any conflicts of interest arise with your duties to the University (including when you recognise that a conflict might reasonably be perceived). We can then agree what actions (if any) are necessary to manage each conflict. We will record both the conflict and the mitigating action in School's register of conflicts of interest. Please also let me know if there have been any material changes to previously declared conflicts.

New starters are asked to read the Conflict of Interest Policy as part of the induction checklist.  If you have any new starters in your team throughout the year please convey the above information to them.