Declaration of Interests - frequently asked questions
These FAQs have been drawn up to address the most common questions arising in relation to External Interests and annual declaration of interest returns. If your question is not answered within these FAQs, please contact DOI@imperial.ac.uk.
1. As a new College employee, do I need permission to continue with any external interests that I have prior to my College employment?
Yes, prior to commencing employment or as soon as possible thereafter, new members of staff are required to seek approval from their Head of Department to continue with these where necessary.
2. What type of interest outside of the College do I need to seek permission for?
You are normally required to seek permission for any interest that is additional to your role with the College and has not been allocated by your manager, regardless of your contracted hours.
3. What interests would I not normally be required to seek permission for?
The interests you do not require permission for are listed in section 4.6 of the Register of Interests and Annual Declaration Policy.
4. As an academic I am invited to be a viva examiner or review grant proposals, for which I receive a nominal fee. Am I required to seek permission to undertake these tasks and declare them?
No, you do not need permission to undertake these academic related activities, nor declare them on your Annual Declaration of Interests return.
5. I have been invited to be an external examiner for Undergraduate and/or Master degree programmes taught at other Universities. Do I need permission to undertake these interests and declare them?
You do not need permission for these interests, but you are required to declare them on your Annual Declaration of Interests return.
6. I am employed full time in the College but intend to work part-time in the College’s Library, Sports Centre etc. Do I need permission to do this?
No, you do not need permission to undertake casual work, as such bar or retail work, within College in addition to your full time College duties, but you are required to disclose this on your Annual Declaration of Interest return. However, this casual work cannot be undertaken during your normal full time working hours - including your lunch break.
7. As a full time or part time employee it is my intention to work for another organisation, do I need to seek permission for this?
Yes, permission is required to ensure this does not impact on the delivery of or conflict with your role and responsibilities at the College.
8. Under what circumstances am I required to provide a waiver for private work (Attachment 1 – Wavier for private work) signed and authorised by the external organisation?
A signed and authorised waiver for private work must be provided for all requests to undertake external work, apart from external consultancy work routed through Imperial Consultants, Trusteeships, Membership on an External Committee or work that is clearly distinct from the College Member’s College duties e.g. bar or retail work.
9. Do I need permission for any Intellectual Property Rights filed through Imperial Innovations and any revenues I receive via the College’s Reward to Inventors Scheme?
No, these are excluded interests. You will need to seek permission before beingb assigned IP in a private capacity and annually declare this thereafter. You will also need to seek permission before receiving any IP commercialisation revenue outside of the College’s Reward to Inventors scheme and declare this annually thereafter too.
10. I am a shareholder in a company. Do I need to declare this?
You need to seek permission and declare shareholdings greater than 5% in any one company, or any shareholding in a company which may engage in business with the College and you have a significant influence in that company e.g. being able to influence decisions made by the board of that company.
11. Must the waiver for private work be completed prior to the work commencing?
Yes, it is important that any other organisations for whom you undertake work in a private capacity are clear that they are not working with the College and that you are not undertaking the work in your capacity as an employee of the College.
12. Is there a minimum number of days that have to be declared?
All days must be declared.
13. Once authorisation is given for an external interest, does this need to be re-authorised if the interest goes on for more than a year or evolves into a different interest?
Permission can be granted for an interest for up to five years, and during that period it does not need to be re-authorised, but it must be declared on your Annual Declaration of Interest return for its duration. However, if that interest evolves into a different interest or requires an extension, permission must be sought for that.
Private Clinical Practice requests, where no conflict of interest exists, may be approved for a maximum of five years.
14. The external interest I am seeking permission for is sensitive. Once I have submitted an approval request, who has access to this information?
Access to the ‘Register of Interests’ is limited to the staff listed in the policy.
15. Will my existing interests from the previous return require approval again when the system for registering interests moves online?
No, all existing declarations from the previous return will automatically be set as ‘approved’. This approval will last for a maximum of 5 years, at which point the interest will require re-approval.
1. Do I need permission to be a Member of a Research Council/Professional Body/ Royal Society/Committee?
Yes, you are required to seek permission to undertake these interests and declare them as part of your Annual Declaration of Interests return.
2. If I am undertaking Committee work, is there a requirement for the waiver for private work (Attachment 1 – Wavier for private work) to be signed?
No, it is not required for the waiver for private work to be completed.
1. Do I have to use Imperial Consultants?
College prefers external consultancy work to be routed through Imperial Consultants, as this route protects the interest of both individuals and the College. If you do not use Imperial Consultants you are expected to ensure you have sought legal advice and taken out your own insurance to ensure you are protecting yourself. Additionally you must get the waiver for private work signed by the client before starting any consultancy work to avoid any implied liability to the College.
2. Can non-academics use Imperial Consultants?
It is only in exceptional circumstances that professional services staff would be expected to be in a position to provide external consultancy work via Imperial Consultants. Permission for this would only be granted in a limited capacity.
Yes, there is a cost of 20% of the contract value, in recognition of the skills and expertise of Imperial Consultants in negotiating the contract and the insurance liability they provide.
Annual declaration of interests' return
1. As part of my Annual Declaration of Interests return, do I need to include projects that I am carrying out with Imperial Consultants?
Yes, you should previously have received approval for these consultancies and should check that these are included on the system. If they are not there, please add them.
2. Do I have to complete an Annual Declaration of Interest return if I have nothing to declare?
Yes, you are required to submit a ‘nil’ return.
3. I am an editor for a journal and am paid for this service, the work is directly related to my research but the publisher has no connection to the College. Do I need to declare this?
Yes, you need to declare this on your Annual Declaration of Interest return, but you do not need to seek permission to do this.
4. I am a trustee or board member of a non-scientific society/volunteer group/charity. Do I need to declare this?
No, complete a 'nil' return unless this work is paid or links to what is being carried out by the College or if it falls within the Conflict of Interest definition at section 2.4.1 of the College's Conflict of Interest Policy.
5. I am a member of a residents’ association/society. Do I need to declare this?
No, it is not necessary to declare membership of any societies or residents’ associations. If you have no other external interests please complete a ‘nil’ return.
6. I joined the College after the end of the return period. Do I need to make a declaration?
If you’ve joined the College after the return period you are not required to declare any external interests for that period but you are required to seek approval for any existing external interest.
Activities excluded from the annual declaration of interests return
Are there any activities that I do not need to declare as part of my Annual Declaration of Interests Return?
The activities listed below are exempt from College’s Register of External Interests and Annual Declaration Policy; those listed in section A do not require permission to be undertaken and do not need to be annually declared. Those listed in section B only need to be annually declared.
College Members do not require permission to undertake the exempt activities listed below under the College’s Register of External Interests and Annual Declaration Policy nor do they need to declare these as part of the Annual Declaration of Interest process:
- Academic activities, including but not limited to:
- Awarded grants;
- Research contracts (such as MTAs or CASE studentships) that have been entered into by College with an external organisation;
- Involvement in research programmes or clinical trials (e.g. as a Chief- Investigator, Co-Principal Investigator, or researcher), unless the College Member believes such work falls within section 4.2.2 of the College’s Conflict of Interest Policy;
- Attending a scientific congress or conference.
- Authorship of scholarly works such as books, articles, papers and columns. College Members are required to familiarise themselves with the Copyright section of the Intellectual Property Policy;
- Giving lectures, talks, interviews and speaking to the media;
- External examiner of a PhD viva;
- Revenue received via College’s Reward to Inventors Scheme;
- Intellectual Property Right applications filed by Imperial Innovations;
2. Membership (including unpaid board membership) of a residents’ association or of a property management company operating where the staff member is a resident
3. Shareholding of less than 5%, unless such shareholding is in a company which may engage in business with the College and the College Member has a significant influence in that company;
4. Membership (including being an unpaid board member or trustee) of non-scientific societies (e.g. sporting or leisure societies), charities, and voluntary organisations provided that such work is unpaid, does not fall within the Conflict of Interest definition at section 2.4.1 of the College's Conflict of Interest Policy and that the work has no link to what is being carried out by the College.
Information relating to (1)(g) and (1)(h) above is held centrally in College and summaries can be provided to Heads of Departments to coincide with HR’s Annual Declaration process. Heads of Departments/line managers may request further information to fully consider an approval request for an Interest.
Relating to (4) above: if there is any slight prospect that the voluntary activity or charity work might in future relate or be linked to the work of the College, this should be declared from the start, or, if the circumstances are unexpected, this should be declared when the link arises.
College Members do not require permission to undertake the exempt activities listed below but they must declare these as part of the Annual Declaration of Interest process:
1. Undertaking academic activities on behalf of external organisations (rather than in a College capacity), including but not limited to:
- a) Examining taught degree programmes for other Universities;
- b) Teaching at other Universities;
- c) External assessment (e.g. promotion panels or competition judging) for other Universities;
2. Editor of a journal (including membership on an editorial board);
3. Casual work within Imperial College (outside of contracted hours) e.g. bar or retail work.
However, should any exclusion described in this section B later give rise to a Conflict of Interest as described in the College’s Conflict of Interest Policy, that Interest must be disclosed in accordance with College’s Conflict of Interest Policy and managed as described therein.
Declaration of Interests - ICIS Self Service
- I have logged in to the Self Service DOI pages but I’m having problems making a declaration? What should I do? The declaration website uses pop ups (links which launch new windows in your web browser). Some web browsers block these pop ups for security reasons. In order to continue please click on the blocked pop up notification in your web browser and select 'Allow' in order to proceed with your return. The exact instructions will depend on your web browser software. Instructions for Microsoft Internet Explorer are available to view.
- I am not able to make my declaration using my Mac PC/laptop? What should I do? In order to make your declaration using your Mac PC/laptop, it has to meet the standard College Mac specification details. Please note that if you are also trying to access ICIS remotely, you will need to be connected to VPN. Further details on this can be found here.
- When does the return period run from and to? The return period is for a calendar year from 1 January to 31 December in the year prior to when you make your return. For example, if you are making a return in February 2019, it will be for the period from 1 January 2018 to 31 December 2018.
- I am unable to find the email asking me to make my declaration. Can I do this without the email? Yes, please refer to the relevant guidance notes found here which has a section on how you can make your declaration via self service.
- My details haven’t changed since my previous return. Do I still need to submit for the current return period? Yes, you still need to submit your declaration for the current return period; however, the interests you previously submitted will be carried forward. If you wish to exclude any of these, please untick the relevant box in the Current Interests column. Further information on this can be found in our guidance notes found here.
- How do I declare more than one external interest? Please see page 7, point 6 of the External Interests to Declare (Self Service) guidance notes if you have not previously declared an interest(s) or page 12, point 3a if you have previously declared an interest(s). The guidance notes can be found here.
- What do I do if I submit incorrect information by mistake? Please contact your local HR team who will be able to update your record with the correct information.
- Who should I contact if I have a query? Please send queries to do with registering interests or the annual declaration to firstname.lastname@example.org
- Is the approval process also on-line? Yes, the approval process is now online. Please log onto ICIS to submit approval requests for new interests.
- Are there any guidance notes that I can refer to? Yes, guidance notes can be found here. There are two guidance notes, one for individuals who have an interest(s) to declare and another for those who have no interests to declare and so are required to complete a NIL return.