NHS Sussex Conflicts of Interest Breach Register Summary May 2024
NHS Sussex manages conflicts of interest breaches by recording and publishing them on their website. Breaches are documented with details of the nature of the breach and actions taken. In May 2024, no breaches were reported. Previous months had breaches due to late declarations of interest. Staff were contacted, policies shared, and meetings offered to address the breaches.
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NHS Sussex Conflicts of Interest Breach Register May 2024 Breaches are published on the NHS Sussex website following presentation to the Audit and Risk Management Committee and are retained on the public register for a period of a year from the breach date.
Number of breaches Date of breach Month Nature of breach Details of action taken May 2024 No breaches reported in month. April 2024 No breaches reported in month. March 2024 No breaches reported in month. 05/02/2024 February 2024 2 breaches reported Further information will be available after the Audit and Risk Management Committee in June 2024. 08/02/2024 The Corporate Governance team send out monthly reminders to staff to make their annual declaration of interest. The breach was the result of the member of staff being prompted by the reminder to declare a new interest which was more than 28 days after the start date. Member of staff was contacted to explain what the breach was and why it occurred. A copy of the COI policy was shared and a meeting offered to discuss the breach and ensure the member of staff was familiar with their responsibilities under the COI policy. January 2024 1 breach reported 10/01/2024 Member of staff was contacted to explain what the breach was and why it occurred. A copy of the COI policy was shared and a meeting offered to discuss the breach and ensure the member of staff was familiar with their responsibilities under the COI policy. A member of staff made a new declaration of interest which was more than 28 days after the start date. They weren t sure whether or not their secondment should have been declared as an interest. 13/12/2023 December 2023 2 breaches reported A member of staff made a new declaration of interest which was more than 28 days after the start date. This was due to them not saving or submitting the interest when they originally made it on Declare as a new member of staff. Member of staff was contacted to explain what the breach was and why it occurred. A copy of the COI policy was shared and a meeting offered to discuss the breach and ensure the member of staff was familiar with their responsibilities under the COI policy. 14/12/2023
Number of breaches Date of breach Month Nature of breach Details of action taken November 2023 No breaches reported in month. Member of staff was contacted to explain what the breach was and why it occurred. A copy of the COI policy was shared and a meeting offered to discuss the breach and ensure the member of staff was familiar with their responsibilities under the COI policy. A member of staff made a new declaration of interest which was more than 28 days after the start date. They didn t think it was an interest that needed to be declared until it was discussed with their manager. 09/10/2023 2 October 2023 A member of staff made a new declaration of interest which was more than 28 days after the start date. They had discussed this declaration in advance of the start date of the declaration but due to their part time working pattern and work pressures, the declaration wasn t entered onto the Declare system within the policy timescales. breaches reported Member of staff was contacted to explain what the breach was and why it occurred. A copy of the COI policy was shared and a meeting offered to discuss the breach and ensure the member of staff was familiar with their responsibilities under the COI policy. 19/10/2023 A member of staff made a new declaration of interest which was more than 28 days after the start date. They didn t think it was an interest that needed to be declared, until it was discussed with their manager during their appraisal. Member of staff was contacted to explain what the breach was and why it occurred. A copy of the COI policy was shared and a meeting offered to discuss the breach and ensure the member of staff was familiar with their responsibilities under the COI policy. September 2023 1 breach reported 04/09/2023
Number of breaches Date of breach Month Nature of breach Details of action taken The Corporate Governance team send out monthly reminders to staff to make their annual declaration of interest. Due to a gap in this process, which meant staff members that have logged into the system recently were missed as the last login date was used when identifying those that needed to make an annual declaration, there were three breaches in August where members of staff did not make their annual declaration in time as they had not received a reminder. The Corporate Governance team send out monthly reminders to staff to undertake their annual mandatory COI training. The breach came from a member of staff being prompted by the training to declare a new interest which was more than 28 days after the start date. 29/08/2023 A member of staff made a new declaration of interest which was more than 28 days after the start date. New starter failing to declare a new interest within 28 days of it arising. This was partly due to the new member of staff having significant problems with their laptop which meant that they were unable to complete their COI training so that they were not fully sighted on the requirements around conflicts of interest. Corporate Governance team process was amended and the last declaration date is now used to identify those members of staff that need to make an annual reminder. Members of staff were contacted to explain what the breach was and why it occurred. A copy of the Conflicts of Interest (COI) policy was shared and a meeting offered to discuss the breach and ensure the member of staff was familiar with their responsibilities under the COI policy. 03/08/2023 10/08/2023 24/08/2023 August 2023 5 breaches reported Member of staff was contacted to explain what the breach was and why it occurred. A copy of the COI policy was shared and a meeting offered to discuss the breach and ensure the member of staff was familiar with their responsibilities under the COI policy. 16/08/2023 Member of staff was contacted to explain what the breach was and why it occurred. A copy of the COI policy was shared and a meeting offered to discuss the breach and ensure the member of staff was familiar with their responsibilities under the COI policy. 1 breach reported July 2023 14/07/2023
Number of breaches Date of breach Month Nature of breach Details of action taken The Corporate Governance team send out monthly reminders to staff to make their annual declaration of interest. All breaches were a result of members of staff being prompted by the reminder to declare a new interest which was more than 28 days after the start date. Members of staff were contacted to explain what the breach was and why it occurred. A copy of the COI policy was shared and a meeting offered to discuss the breach and ensure the members of staff were familiar with their responsibilities under the COI policy. 19/06/2023 3 breaches reported June 2023 20/06/2023 26/06/2023
