Conflict of Interest Form

• Conflict of Interest Form

Conflict of Interest Register

• Conflict of Interest Central Register

Conflict of Interest Management Procedure

Context

University staff have diverse interests and contacts within the local, national and international community. These links between people engaged in UCC activity and outside bodies are often in the public interest as well as beneficial to the University and to individuals.  However, some potential conflicts of interest may arise from time to time. 

The conflict of interest policy assists staff in recognising and managing any potential conflicts of interest that may arise.  The most important message in the policy is that University staff should always disclose an activity if they are in doubt about whether it represents a conflict of Interest.

Purpose

This procedure details

• the steps to be taken by someone declaring a potential conflict of interest;
• the steps to be taken by the COI reviewer when a potential conflict of interest has been declared.

Procedure

Step 1: Declare the Potential Conflict of Interest

A potential conflict of interest should be declared as soon as:

• the conflict of interest first arises;
• it is recognised that a conflict of interest might be perceived; or
• it is recognised that there is the potential for a conflict of interest.

Staff: Complete the Conflict of Interest Form and send it to your Head of School/ Department / Research Centre.  If the disclosure relates to or involves your Head of School/ Department/ Research Centre, then see Disclosure Channels for the channels to use.

The person to whom the disclosure has been made, within the framework set out at Disclosure Channels, shall become the COI Reviewer for the purpose of determining the appropriate next steps to be taken in relation to the potential conflict of interest.

Staff: Do not take direct part in the activity relating to the potential conflict until you have talked to the COI reviewer and agreed that it is ok to do so.  The COI reviewer will advise you whether you can resume taking part in the activity as soon as is possible but generally within 21 days from the date of disclosure. 

Step 2: Review the Disclosure and Gather Relevant Information

COI Reviewer: Review the disclosure and, if required, request further information from the person who disclosed.

Staff: Provide any further information requested by the COI reviewer.

COI Reviewer: While the majority of potential conflicts of interest can be resolved locally, in some cases you may wish to seek advice from others in the relevant professional areas.  The following table lists some possible sources of advice for the various types of conflict of interest. 

COI Reviewer: Generally, potential conflicts of interest related to research can be resolved at a local level.  However, if the potential conflict relates to an externally funded research project, you are required to consult with the Vice President for Research and Innovation.

COI Reviewer: Document all the information gathered on the Conflict of Interest Form

Step 3: Decide on How to Manage the Potential Conflict

COI Reviewer: Having reviewed all the relevant information and consulted as appropriate, decide how the potential conflict will be managed.  Potential outcomes are:

• there is no conflict and no further action is required;
• permission to continue the activity with modifications;
• the staff member is to desist from partaking in activity.

COI Reviewer: Document the decision on the Conflict of Interest Form and the reason(s) for the outcome.  If the activity is to continue, document what modifications are required. 

COI Reviewer: If ongoing management is required, enter a review date and the steps to be taken during the next review.  The COI Reviewer must ensure the review takes place by the review date and a further review is scheduled if required.

Step 4: Communicate the Outcome

COI Reviewer: Communicate the outcome to the member of staff and any other relevant parties.

Staff: Confirm to the COI reviewer that you agree with and intend to comply with the outcome and actions in the Conflicts Management Plan.

Staff: Implement the modifications detailed, if any, in the Conflict of Interest Management form.

Step 5: Record the Outcome

COI Reviewer: Enter the details from the Conflict of Interest Management form on your school/ department / research centre conflict of interest register.  Send a copy of the form to conflictofinterest@ucc.ie

Conflict of Interest Management Procedure Flow Chart

• Conflict of Interest Management Procedure Flow Chart