Dear Imperial College London,
Please could you proved "UPDATE ON UNIVERSITIES SUPERANNUATION SCHEME (PAPER C)" presented at the Council meeting of 7 February 2014, Minute 16
Dear Mr Davies
This is to acknowledge receipt of your request below, made under the Freedom of Information Act. As you may know, the College must respond to your request within twenty working days of receipt of your request, and sooner if possible.
We will contact you again in due course.
Dear Mr Davies
I am writing in response to your recent Freedom of Information request. You asked the College:
"Please could you proved "UPDATE ON UNIVERSITIES SUPERANNUATION SCHEME (PAPER C)" presented at the Council meeting of 7 February 2014, Minute 16"
A copy of the Paper is attached. Please note that some of the information in the paper has been redacted for the reasons set out below.
The paper is concerned with the funding position of the Universities Superannuation Scheme (USS), and the possible changes that may need to be made to the scheme to address its deficit. The College is an employer within the scheme, and as such, any changes to the way in which the scheme operates could have significant implications for College and its staff.
For this reason, information which is considered to be commercially sensitive has been redacted in accordance with Section 43 (2) of the Freedom of Information Act, which states that information is exempt if its disclosure ‘would or would be likely to, prejudice the commercial interests of any person (including the public authority holding it)’.
Further reasons for this exemption are set out below.
The USS is currently involved in discussions with both the employers (including the College) and the Unions (principally the UCU) on possible changes to the scheme. At the end of this discussion period, a finalised proposal will be voted on by USS as well as representatives from the employers and unions. As these discussions on potential changes to the scheme are continuing, the College considers that information about these potential changes and their implications for the College are commercially sensitive and their release before these discussions have been concluded could prejudice the College’s commercial interests.
Disclosure at the present time of the College's specific financial positions and plans while the UCU / USS discussions are still ongoing would potentially be detrimental to the College's ability to participate in discussions and negotiations and thereby to obtain the result that would provide best value for the College and its staff. Furthermore, as the USS is yet to decide on its finalised proposals, the College’s consideration of the financial implications of a range of scenarios are speculative, and it may need to amend its figures in light of any further changes to the USS position. Disclosure of College's specific financial information at this time could affect the College's ability to operate in the competitive environment of Higher Education. The College aims to attract and retain high quality staff in all areas of its work, and competes for those staff with a variety of other organisations across the world, including those in the private sector. The College's participation in pension schemes is an important part of the overall pay and benefits packages offered by the College, and to disclose speculative information about its potential position on those pension schemes may mislead or deter current or potential College staff.
The College does recognise that there is a public interest in how public funds are held and spent by the College. In this instance, however, the College feels that the public interest will be satisfied by the existing processes whereby the USS will publish information to scheme members about the proposed changes to the scheme, once these have been finalised.
For these reasons, the College believes that the information redacted from this paper is exempt from disclosure under Section 43 (2) as described above.
Please note that a few additional redactions have been made under Section 41 of the Freedom of Information Act, as the information has been provided to the College in confidence. The Act states that “information is exempt information if (a) it was obtained by the public authority from any other person (including another public authority), and (b) the disclosure of the information to the public…by the public authority holding it would constitute a breach of confidence actionable by that or any other person.”
Further information about the College's pension schemes, including information on the College's position on pension reform for the USS scheme, is available at: http://www3.imperial.ac.uk/hr/workingati...
I am obliged, under the Freedom of Information Act, to inform you of our complaints procedures in case you are unhappy about the way in which your request has been dealt with. If you wish to complain about this response, you should contact the College Secretary at the address below.
The College Secretary
Imperial College London
Tel: 020 759 47272
E-mail: [email address]
The College Secretary must respond to all complaints within 20 working days.
If you are unhappy about the way in which the College Secretary handles your complaint then you may have recourse to the official regulator for the Freedom of Information Act who is:
The Information Commissioner
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