Conflict of Interest & Confidentiality Policy

The Conflict of Interest and Confidentiality Policy applies to members of the Degree Quality Assessment Board and to external experts engaged to conduct an organization review or degree program review at the board’s request. This policy also applies to applicants wishing to declare a conflict of interest with an individual board member or external expert.

Board members must also adhere to the Guidelines for Conduct of Government Appointees to BC Agencies, Boards and Commissions developed by the Board Resourcing Development Office. External experts are also expected to adhere to the spirit of these guidelines.

Board members and external experts must be committed to the principles and practices of quality assurance in post-secondary education and be recognized by their peers for having a broad outlook, open mind and sound judgment. Individuals appointed in these capacities must possess the qualifications to engender the confidence of the minister, applicants, the public, accrediting bodies, other degree-granting institutions and other jurisdictions.

Confidentiality

Board members and external experts must not reveal or divulge confidential information received in the course of their duties. Confidential information must not be used for any purpose outside the board’s mandate.

Except at the direction of the chair, board members and external experts must not make public comments concerning any application.

Conflict of Interest

Board members (as ministerial appointees) and external experts (as board appointees) must avoid any actual or perceived conflict of interest including that which might impair or impugn the independence, integrity or impartiality of the board. There must be no apprehension of bias, based on what a reasonable person might perceive.

Definition of a conflict: A conflict of interest happens when a member of the board or an expert is placed in a situation where their interests, or the interests of someone close to them, conflict with (or appears to conflict with) their responsibilities.

Personal or financial interests of any of the following individuals could cause a conflict:

• The board member or expert
• An immediate family member of a board member or expert
• The interests of a person who is having (or recently had) an intimate relationship with a board member or expert

No board member shall knowingly participate in any decision that appears to directly or preferentially benefit the member or any individual with whom the member has an immediate family, intimate or commercial relationship.

Board members and external experts appointed by the board should not have any connection to the applicant under review within the previous two years, or for a period of up to three months following the completion of their duties in connection with the degree quality assessment process. Some examples of a connection to an applicant organization currently or within the past two years include:

• Preparing an application or providing expert advice used in developing the proposal, beyond information on the board’s criteria, guidelines and procedures
• Making public comment for or against an application or institution that might result in the apprehension of bias
• Working for or previously employed by the institution
• Being a student or a recent graduate of the institution
• Working as a consultant for the institution
• Serving in an advisory capacity or on a board or committee at the institution
• Having financial or other business interests with the institution
• Supervising students or employees of the institution
• Collaborating regularly with the institution
• Teaching at the institution

Some board members are appointed as representatives of private sector membership organizations that broadly represent private sector interests. A public or private institution making application to the board may also hold membership in one of these organizations that a board member represents. In such instances, there would not normally be a conflict of interest unless the member has been actively involved in developing, promoting, or publicly commenting on an application.

Disclosure of Conflict

Where there is an actual or potential conflict of interest, the member must disclose his/her circumstances and consult with the board chair. If unsure if a conflict exists, the member should seek advice from the chair. It is the responsibility of the board chair to determine whether a conflict of interest exists and to inform members of his/her decision. If a member has an actual or potential conflict in regards to an application under consideration by the board, the member must withdraw from any discussion and decision-making process leading to a recommendation on the proposal.

All external experts selected by the board shall make full written disclosure to the board of any potential conflict of interest, within the terms of this policy, as soon as the individual knows the applicant’s identity. Similarly, if an applicant has evidence of a conflict of interest regarding an individual appointed by the board, then the applicant shall make full written disclosure to the board, as soon as the applicant knows the individual’s identity.

Action Required When a Conflict Exists

In accordance with this policy, the board will exercise its discretion in determining if an actual or potential conflict of interest exists and notify the parties accordingly.

If it is determined that a board member has an actual or potential conflict of interest in regards to an application under consideration, the member must withdraw from any discussion and decision-making process leading to a recommendation on the proposal.

An external expert with an actual or potential conflict in regards to an application must decline to serve as an expert.