Cardiff University committee papers and minutes publication policy

Purpose and scope

1. This purpose of this policy is to confirm:

• a) how minutes and papers will be proactively published in relation to Council, Senate and the sub-committee meetings of these Committees and the process for doing so, and
• b) how requests for copies of minutes and papers shall be dealt with, from those who are not committee members or otherwise holding an office to whom the minutes/papers are normally distributed.

2. The policy applies to papers and minutes of Council, Senate, their major committees and sub-committees, as set out in Appendix A.

Policy statement

3. The University promotes transparent ways of working, in line with the CUC HE Code of Governance, and complies with its obligations to publish information under the Freedom of Information Act 2005.  This policy describes the mechanisms for making decisions and papers available to staff.

4. In addition, the University also recognises the need for confidentiality in relation to the University’s commercial and strategic planning, and the need for privacy in relation to information relating to its staff and students.  This policy, therefore, ensures that the privacy needs of these individuals are protected.

Relationship with existing policies

5. This policy has been created in line with the provisions of the University Ordinances and existing rules around publication of minutes. Ordinance 11 section 12.5 states “The Minutes, with the exception of any confidential Minutes or File Copies, shall be made available under the University’s Publication Scheme, after they have been confirmed”.

6. This policy provides detail to support the relevant sections of the University’s Publication Scheme.  It has been drafted to be consistent with the University’s Information Security Policy and the Information Classification and Handling Policy.  If any conflicts arise with either the Information Security Policy or the Information Classification and Handling Policy, the Information Security Policy and Information Classification and Handling Policy shall take precedence.

7. This policy should be viewed alongside the requirements of the Freedom of Information Act 2000, Data Protection legislation, and any associated guidance.

Roles and responsibilities

8. The University Secretary is the University Executive Board Sponsor of this policy and is responsible for approving the need to develop or substantively amend this policy, for presenting the final draft to the approving body and for ensuring that this policy complies with, and is monitored and reviewed in accordance with, the University policy framework.

9. The Corporate Governance Team and the Secretaries to committees are responsible for applying the provisions of the policy to their respective committee records and the management of the information detailed within this policy.

10. Secretaries of University Committees who are not based within the Corporate Governance Team shall support the University Secretary and the Corporate Governance team in the implementation of this policy.

11. Any requests for information covered under this policy should be directed to the Corporate Governance Team in the first instance.

Key definitions

Corporate Governance Team: this refers to the University Secretary’s Office team. The contact for the Corporate Governance Team in relation to this policy is Committees@cardiff.ac.uk.

Minute Taker: the individual responsible for drafting the minutes.

Paper author: the individual who has written the paper. In instances of multiple authors, this will be the individual who issues the paper to the Corporate Governance Team.

Compliance and Risk Team: refers to the team within the University Secretary’s Office that manages data protection and requests for disclosure of information under Freedom of Information and related legislation.

Full Minutes: denotes the set of minutes without any redactions.

Publishable Copy: denotes that the set of minutes or a paper has been reviewed and any necessary redactions made, such that it may be made public.

Publication of minutes

12. A Publishable Copy of the minutes of Council, Senate and the Audit and Risk Committee will be routinely published on the   University website, in both English and Welsh language digitally accessible versions.

13. Where minutes are published this will be for the current academic year, along with the three preceding academic years. Minutes will be removed from the website once they fall outside of this timeframe.

Process for publication of minutes

Proactive publication of minutes

14. For those Committees whose minutes will be published proactively, as listed in paragraph 12 above, the minute taker will   produce two sets of minutes following the meeting; one a full set of the meeting; and one set which has been redacted as deemed necessary which shall be the Publishable Copy.

15. The Corporate Governance Team/Secretary to the committee will store both the Publishable Copy (i.e. the version with any   necessary redactions made) and the full versions of the minutes.

Applying redactions to create a publishable copy

16. The University’s Information Classification and Handling Policy forms the basis for identifying items which may require   redaction.  See Appendix B for the relevant classifications and examples of how this may apply to committee minutes and papers.

17. Sections of minutes referring to discussions on papers classified as Highly Confidential (C1) should be redacted by default. The decision and title should remain in the Publishable Copy of the minutes, however.

18. Sections of minutes referring to papers classified as Confidential (C2) should be considered and redacted where considered necessary in line with points below.

19. If the minute-taker has queries relating to the necessity to redact an item, these should be directed, in the first instance, to the Secretary of the Committee. If further consideration is required, these should be directed to the Chair. Advice may also be sought   from Corporate Governance Team or the University Secretary.

20. If a minute requires redaction, this section will be removed from the minutes and [REDACTED] or [PART-REDACTED] entered in its place.

21. In the case of routine publication, the draft redacted minutes will be approved as the Publishable Copy by the Secretary, once   the Chair has approved the full minutes and they have been confirmed by the Committee. The Publishable Copy shall be published on the website by the Corporate Governance Team and comply with the Welsh Language Standards and Accessibility   regulations.

Non-routine publication of minutes

22. Where the disclosure of minutes that are not  routinely published has been requested by a person who:

• is neither a member of that committee
• nor holds an office to whom the full minutes would otherwise be routinely distributed
• nor an Internal or External Auditor

the Secretary shall use this policy to determine the need to create a Publishable Copy, and if so, shall apply redactions in accordance with this policy.   In these circumstances approval for disclosure of the Publishable Copy shall be sought from the Chair, and the disclosure shall only be made once the full minutes have been confirmed by the Committee. Advice on redactions in these cases may be sought from the Corporate Governance Team or the University Secretary.

Requests for disclosure of the full minutes

23. In the case of requests for copies of full minutes from a person who:

• is neither a member of that committee
• nor holds an office to whom the full minutes would otherwise be routinely distributed
• nor an Internal or External Auditor

and where the requestor is not satisfied with a Publishable Copy, the request should be dealt with by the Secretary to the Committee in accordance with the Release of Papers on Request set out in paragraphs 33-37 below.

Conflicts of interest

24. There may be occasions when minutes shared with Committee members need to be redacted for individual members due to a   conflict of interest.

25. If a Committee member has a conflict of interest and is unable to see a section of the minutes due to this conflict, the relevant section of the minutes should be removed from the minutes and  [REDACTED] or [PART-REDACTED] entered in its place.

26. These redacted minutes should be shared with the Secretary and/or Chair to confirm the conflict of interest(s) has been   properly managed. The Secretary will ensure that the individual(s) concerned only receives the version of the redacted minutes which specifically account for such conflicts of interest.

27. For Audit and Risk Committee minutes, redaction of minutes should be considered before these are shared with internal and external auditors. It may therefore be necessary to prepare additional and bespoke versions of the minutes specifically for the internal auditors and the external auditors. For example, redactions will be applied in relation to discussions on appointment of external auditors and remuneration for internal auditors.

Publication of meeting papers

28. Papers of committee meetings will not be routinely published on the internet or intranet. Requests for disclosure of papers shall be directed to Committees@cardiff.ac.uk in the first instance.

Paper classification process

29. Paper classifications inform the disclosure process and they follow the categories set out in the Information Classification and Handling Policy:

• Highly Confidential (C1)
• Confidential (C2)
• Non-classified

30. Papers which are classified as Highly Confidential (C1) will have “HC” added after the paper number. Papers which are classified as Confidential (C2) will have “C” added after the paper number.

31. Papers are classified by their authors at point of submission to University Executive Board (the classification is then   confirmed by the UEB sponsor) and/or at the point of submission to the Committee secretary.  If a member of the Corporate Governance team considers that a paper may have been incorrectly classified at the point of submission to the Committee, this will be raised with the paper author in the first instance and resolved with the Secretary and/or Chair as necessary prior to issue of the papers.

32. It is the responsibility of every individual handling papers to apply the appropriate handling rules to each category of information, and to seek clarification or advice from a line manager or ComplianceandRisk@cardiff.ac.uk where they are unsure as to how to classify or handle information. Examples of information falling within the C1 and C2 categories is provided in Appendix B.

Release of papers on request

33. Papers categorised as Non-Classified can be released internally or externally on request, subject to redaction of any personal data in external disclosures.

34. When reviewing the release of Confidential Papers (i.e. those with paper numbers followed by C or HC, papers that are   otherwise marked as ‘confidential’ and unredacted minutes that are not routinely published) to those who are neither committee members nor holding an office to whom the papers are routinely distributed, consideration must be given as to whether any of the conditions that created confidentiality at the time of classification have since changed e.g. the information is now in the public domain.

35. Confidential Papers will only be released on request externally to the University where required by law e.g. due to a Freedom of Information Act 2000 requirement (unless the external requestor is a member of the committee or holds an office to whom the papers are routinely distributed including External Auditors and External Internal Auditors). The request will be managed in accordance with the provisions of the Act and the University’s related procedures, as directed by the Compliance and Risk Team in the University Secretary’s Office.

36. Confidential Papers may be shared on request internally where the requestor:

• is a member of the committee that received the paper
• holds an office to whom the paper would otherwise have been routinely distributed
• is an Internal or External Auditor

37. In all other cases Confidential Papers may be shared on request internally, as agreed by the University Secretary who may   seek the views of:

• the UEB sponsor – or where there is no UEB sponsor, the more senior of the paper author and the paper presenter (where different),
• the Secretary to the Committee and/or the Chair of the Committee
• and shall take into consideration any legal and regulatory obligations relating to the disclosure.