Frequently asked questions on registering external interests
Frequently asked questions - registering external interests
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 being 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.
- 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 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.
3. Is there a cost to working with Imperial Consultants?
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.