Cabinet Office to create register of senior civil servants’ second jobs

Guidance sets out detailed requirements to disclose senior officials’ employment outside the civil service
Image: Gerd Altmann/Pixabay

By Sam Trendall

09 May 2023

The Cabinet Office is to create an online “central register” where the public can access details of second jobs and other outside employment held by senior civil servants.

The department first published guidance last summer advising central government bodie of a new and consistent regime for the “declaration and management of outside interests in the civil service”.

The guidelines include an instruction that departments and agencies must publish annual updates of all the outside interests of permanent secretaries and other members of the senior civil service that sit on the organisation’s board. This includes details of ongoing outside employment and voluntary roles, as well as previous roles, business interests, shareholdings, and personal relationships that could create a conflict of interest. 

For senior officials that do not form part of the top leadership team, “any outside employment, work or appointment – [that is] paid or otherwise remunerated – held by a member of the SCS that has been agreed through the process for the declaration and management of outside interests should also be published” online, with a link to this webpage included in the department’s annual report and accounts (ARA).

In a lengthy update newly added to the guidance, the Cabinet Office provided significant additional detail on the information that departments must publish on senior officials' second jobs, and the regime for doing so.

Government agencies must publish the full name, job title and civil service grade of the employee concerned; and details of any other employers and the role held by the official. 

“Departments can also choose to provide additional information if they believe it would be helpful to do so, e.g by adding a notes column,” the update added. “The information should be published annually after the end of each financial year, but prior to the publication of the department’s ARA. 

“Departments should publish this information on GOV.UK – separately to their ARA – and provide a link within their ARA. The Cabinet Office will also publish a central register of all of the departmental returns alongside this guidance.”

The Cabinet Office told CSW's sister title PublicTechnology that this “register” will constitute a dedicated page on GOV.UK collating and pointing visitors towards all agencies’ submissions of details of outside employment.

'Reasonable test'

In a frequently-asked questions section also freshly added to the guidance, the Cabinet Office makes clear that information on all second jobs must be published even “where there is clearly no conflict of interest”.

Details of “passive income” – such as earnings from rental properties – will “not ordinarily” need to be published but there may instances where it should be disclosed.

“It is impossible to define every potential scenario and departments are instead encouraged to apply a reasonableness test depending on the circumstances of each disclosure,” the update said.

This is likely to encompass all cases where there is “a reasonable expectation of remuneration, including, but not limited to, salary, bonuses and share options would likely trigger the threshold for inclusion".

"This could also include where donations are made to charity or other sources in lieu of an individual receiving them, for secondary employment they have carried out," the guidance adds.

The FAQs also address the potential for organisations to have “security concerns or other justifiable reasons why certain data cannot be published”.

It advises that “departments will only need to publish the name of the individual, job title and the company name/role title of the secondary employment they hold [and] there is precedent for releasing such information on employees”.

It adds: “However, organisations have a duty of care to staff, and so if there is strong reason to suspect that the release of certain information may present a security or other risk to a staff member or their family, then this should be weighed against the reporting requirements and if necessary the information should be withheld.

"There is no exhaustive list of what might prompt the need to withhold certain information, instead, departments should take a pragmatic approach.”

Sam Trendall is editor of PublicTechnology, where this story first appeared

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