Guidance

External interests to declare - how to submit your return on ICIS

This guidance has been developed to show staff, who have external interests to declare, how to submit their return. 

 

No external interests to declare - how to submit your return on ICIS

This guidance has been developed to show staff, who have NO EXTERNAL interests to declare, how to submit their return. 

Adding new external interests for approval - how to submit your return on ICIS

This guidance has been developed to show staff, who need to add a NEW external interest to declare, how to submit their return.

Guidance for managers and approvers

This guidance has been developed to show managers how to approve a staff members declaration and broader guidance on reviewing a request

Frequently asked questions

Submitting a return
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.

As a new University employee, do I need permission to continue with any external interests that I have prior to my Imperial 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.

What type of interest outside of the University 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 University and has not been allocated by your manager, regardless of your contracted hours.

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.

Is there a minimum number of days that have to be declared?

All days must be declared.

I joined the University after the end of the return period. Do I need to make a declaration?

If you’ve joined the University 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 interests.

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 your role or responsibilities at the University or conflict with them.

Will my existing interests from the previous return require approval again when the interest registration system 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.

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.

Committees
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.

If I am undertaking Committee work, is the waiver for private work (Attachment 1 – Waiver for private work) required to be signed?

No, the waiver for private work is not required to be completed.

Permissions for additional responsibilities and work
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.

I have been invited to be an external examiner for Undergraduate and/or Master's 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.

I am employed full-time at the University but intend to work part-time in the University’s Library, Sports Centre, and related areas. Do I need permission to do this?

No, you do not need permission to undertake casual work, such as bar or retail work, within the University in addition to your full-time University 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.

Do I need permission for any Intellectual Property Rights filed through Imperial Innovations and any revenues I receive via the University’s Reward to Inventors Scheme?

No, these are excluded interests. You will need to obtain permission before being assigned an IP in a private capacity, and you will need to declare this annually. You will also need to seek permission before receiving any IP commercialisation revenue outside of the University’s Reward to Inventors scheme and declare this annually thereafter, too.

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 University, and you have a significant influence in that company, e.g. being able to influence decisions made by the board of that company.

Once authorisation is granted for an external interest, does it need to be re-authorised if the interest continues for more than a year or evolves into a different interest?

Permission can be granted for an interest for up to five years. 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 something else or requires an extension, permission must be obtained.

Private Clinical Practice requests, where no conflict of interest exists, may be approved for up to 5 years.

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.

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 University. 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.

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 University or if it falls within the Conflict of Interest definition at section 2.4.1 of the University's Conflict of Interest Policy.

Imperial Consultants (ICON)
As part of my Annual Declaration of Interests return, do I need to include projects I am undertaking with Imperial Consultants?

Yes, you should have previously received approval for these consultancies and should check that these are included in the system. If they are not there, please add them.

Do I have to use Imperial Consultants?

The University prefers external consultancy work to be routed through Imperial Consultants, as this route protects the interests of both individuals and the University. 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 University.

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.

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.

Private work waiver

The University encourages liaison between external organisations and staff. University Members acting in a personal capacity must obtain the written permission of the University through their Head of Department/line manager before accepting an Appointment. Permission will normally be given so long as acceptance does not prejudice the efficient discharge of the University Member’s University and Faculty/Departmental/Divisional duties.

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 University and that you are not undertaking the work in your capacity as an employee of the University.

Under what circumstances am I required to provide a waiver for private work (Attachment 1 – Waiver 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 University Member’s University duties, e.g. bar or retail work.

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 the University’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.

Section A 

University Members do not require permission to undertake the exempt activities listed below under the Universityc’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:
  1. Academic activities, including but not limited to:
    1. Awarded grants;
    2. Research contracts (such as MTAs or CASE studentships) that have been entered into by the University with an external organisation;
    3. Involvement in research programmes or clinical trials (e.g. as a Chief Investigator, Co-Principal Investigator, or researcher), unless the University Member believes such work falls within section 4.2.2 of the University’s Conflict of Interest Policy;
    4. Attending a scientific congress or conference.
    5. Authorship of scholarly works such as books, articles, papers and columns. University Members are required to familiarise themselves with the Copyright section of the Intellectual Property Policy.
    6. Giving lectures, talks, interviews and speaking to the media;
    7. External examiner of a PhD viva;
    8. Revenue received via the University’s Reward to Inventors Scheme;
    9. Intellectual Property Rights 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 University and the University 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 University's Conflict of Interest Policy and that the work has no link to what is being carried out by the University.

Information relating to (1)(g) and (1)(h) above is held centrally in the University, and summaries can be provided to Heads of Departments to coincide with the 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 University, this should be declared from the start, or, if the circumstances are unexpected, this should be declared when the link arises.

Section B

University 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 University 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 (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 University’s Conflict of Interest Policy, that Interest must be disclosed in accordance with the University’s Conflict of Interest Policy and managed as described therein.

Submitting your declarations on 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?

If you have not logged into an Imperial Office 365 application recently, you may be required to set up Multi-Factor Authentication on your account.

Once on the ICIS Self Service page, please note that the declaration website uses pop-ups (links that open new windows in your web browser). Some web browsers block these pop-ups for security reasons. To continue, please click the blocked pop-up notification in your web browser and select 'Allow' to proceed with your return. The exact instructions will depend on your web browser software. Instructions for Microsoft Edge are available to view. 

I am unable to submit my declaration on my Mac laptop. What should I do?

To make your declaration on your Mac PC/laptop, it must meet the University Mac specification.    Please note that if you are also trying to access ICIS remotely, you will need to log in using the Multi-Factor Authentication. Further details on this can be found here.

When does the return period run from and to?

The return period is for the calendar year from 1 January to 31 December in the year before you file your return.  For example, if you are making a return in February 2024, it will be for the period from 1 January 2023 to 31 December 2023.

I am unable to locate the email requesting my declaration. Can I do this without the email?

Yes, please refer to the relevant guidance notes, which have 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 is available in our guidance notes.

How do I declare more than one external interest?

Please see pages 3 to 8 of the External Interests to Declare (Self Service) guidance notes if you have not previously declared an interest(s) or if you have previously declared an interest(s).  

What do I do if I submit incorrect information by mistake?

Please contact the DOI team at doi@imperial.ac.uk, and the relevant team can assist you in correcting this information.

Who should I contact if I have a query? 

Please send queries related to registering interests or the annual declaration to doi@imperial.ac.uk

Is the approval process also online?

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 are available in the Guidance section of this Declaration of Interest page. There are three guidance notes, one for individuals who have an interest(s) to declare, another for adding new external interests for approval and the other for those who have no interests to declare and so are required to complete a NIL return.