Response to the 2017 and 2014 UUK USS valuation consultations

The request was partially successful.

Dear Cardiff University,

Please provide a copy of your University’s response to the 2017 and 2014 UUK USS valuation consultations.

Yours faithfully,

Neil Davies

InfoRequest, Cardiff University

Dear Neil

I acknowledge receipt of your email received by this office on 24 October 2017 in which you requested information regarding the University's response to the 2014 and 2017 UUK USS valuation consultations.

Your request will now be dealt with under the Freedom of Information Act 2000 and has been allocated reference FOI17-302 which should be quoted in all correspondence. We will respond to your request within 20 working days starting the next working day after receipt, therefore you can expect to receive a response no later than 21 November 2017.

Where we consider that we will not be able to meet this deadline or if further time is required to consider the public interest test we will contact you as soon as possible and give you a revised date for response.

In some circumstances a fee may be payable and, if that is the case, we will let you know. A fees notice will be issued to you, and you will be required to pay before we will proceed to deal with your request.

Yours sincerely

Gail Thomas
Swyddog Sicrwydd
Adran Cynllunio Strategol a Llywodraethu
Prifysgol Caerdydd
2il Lawr, Friary House
Heol y Brodyr Llwydion
CF10 3AE
Ffôn: +44 (029) 2087 5327
Ebost : [email address]  

Mae'r Brifysgol yn croesawu gohebiaeth yn Gymraeg neu'n Saesneg.
Gail Thomas
Assurance Officer
Strategic Planning and Governance
Cardiff University
2nd Floor, Friary House
Greyfriars Road
CF10 3AE
Tel: +44 (029) 2087 5327
Email: [email address

The University welcomes correspondence in Welsh or English.

InfoRequest, Cardiff University

Dear Neil


Further to our email dated 24th October 2017, unfortunately, we will be
unable to provide you with an outcome by the date which we previously
stated. We estimate that we should be able to respond by 5th December
2017. Please accept our apologies for this delay and for any inconvenience







Alison Preece   Alison Preece
Assurance Adviser   Ymgynghorydd Sicrwydd

Strategic Planning & Governance Adran Gynllunio Strategol a
Tel: 029 208 79919   Ffon: 029 208 79919
E-mail: [1][email address]   E-bost: [2][email address]


We welcome correspondence in Welsh Rydym yn croesawu gohebiaeth trwy’r
or English Gymraeg neu’r Saesneg






show quoted sections

Dear Cardiff University,

Please pass this on to the person who conducts Freedom of Information reviews.

I am writing to request an internal review of Cardiff University's handling of my FOI request 'Response to the 2017 and 2014 UUK USS valuation consultations'.

Thank you for your response. We would like to request an internal review of the FOI request.

Four potential exemptions to our request have been suggested. Below we discuss each in turn. All of these exemptions are subject to a public interest test which we later address.

Section 22 (1) Information intended for future publication
This exemption is for information that will be published at some future date. As part of the review, could you confirm your plans for when and how the response will be published? Please could you confirm whether it is reasonable and fair to USS members, students and tax payers, who ultimately pay for the many of the services of universities, to withhold this response under Section 22?

Section 36 (2) Prejudice to effective conduct of public affairs
This exemption is for information that if released, would inhibit the free and frank exchange of views. The current discussion around the USS valuation and potential changes to the scheme are being widely discussed by many individuals, both in the press and privately in university campuses across the UK. The opinion of employers is an extremely pertinent factor in this discussion. Employees need to know and understand their employer’s position about what is reasonable for employer contributions to the USS and future benefit structure of the scheme.

In addition, Exeter and Lancaster universities have published their responses in full. This suggests that they do not believe that publishing their responses would inhibit a free and frank exchange of views. This suggests that publishing the response is unlikely to severely prejudice your institution’s ability to conduct a free and frank exchange of views.

Section 43 (2) Commercial interests
This exemption is for information that if released, would harm your institution’s commercial interests. Could you clarify how releasing your institution’s response could harm its commercial interests? For example, would it be less likely to: attract students, win research contracts, or recruit and retain staff? None of the information requested relates to competitive contracts. All Russell group universities offer the same pension. Therefore how can publication of the response affect your institution specifically?

Furthermore, Exeter and Lancaster Universities have published their responses. They face the same commercial pressures as your institution, yet have published their responses without harming their commercial interests. This suggests that publishing the response is unlikely to severely harm your institution’s commercial interests.

Public interest test
Transparency and openness
There is a substantial public interest in full transparency and openness around the process of agreeing on the valuation for the USS and potential changes to the scheme. Providing a copy of your university’s response would inform USS members, students, and members of the public about the pressures facing your institutions, its position, and its rationale for the changes it would like to see for the scheme. This would allow ordinary USS members to be involved in this process and aid collaborative decision making.

Scrutiny of spending public money
Furthermore, significant concerns have been raised about the valuation method and the process for agreeing to any changes to the scheme. Publishing your institution’s response would enable the public to better scrutinise how public money is being spent. It would also ensure that the valuation and reform process was fully open and transparent. It would provide clarity about your institution’s position, and ensure that the valuation was handled in a fair, equitable way that maximised value for money.

Suspicion of wrongdoing
Publishing your institution’s response would alleviate any suspicion of wrongdoing. For example that an institution was lobbying the USS to protect its private interests, rather than USS members’ interests. Publishing the response would provide a full picture of the pressures facing your institution and would remove any suspicion of manipulating facts or engaging in ‘spin’.

The fact that some of the responses and many universities’ summaries of their responses are available in the public domain strengthens the case for disclosure.

In the public interest
There is a strong public interest in transparency and accountability. This is particularly important to improve the public and USS members’ understanding about the pressures facing the scheme and their employers. Publishing your institution’s response will help reinforce good decision making with respect to the USS. It will uphold standards of integrity and will ensure justice and fair treatment for all. Finally, publishing the response will help secure the best use of public resources for recruiting and retaining the staff at our universities.

Of public interest
There have been numerous articles in the press about the ongoing discussions around the USS. This issue is undoubtedly of public interest.

In 2015-16 there were nearly 2.28 million students in the UK. These students have a major interest in having a well conducted pensions scheme for their tutors. There are almost 400,000 USS members who have an interest in understanding their employer’s position on the USS. All these individuals, and more, have an interest in universities in the UK maintaining a competitive and well managed pension scheme. The public at large has an interest in ensuring that public money is being well spent. Publishing the response may help achieve this.

In summary, there are unlikely to be major detrimental effects of publishing the response. There are very large potential public benefits from publishing the response. It is vital that the valuation and reform of the USS are conducted in a totally open and transparent way. Withholding the response could lead to an erosion of members’ trust. Many of the 160 signatories below have published a letter in the Financial Times calling for greater transparency over the USS. We very much hope you would be able to help achieve this.

We look forward to your response.

Yours sincerely,

Dr Neil Davies, University of Bristol

On behalf of:

Dr Jeff Round, University of Bristol
Prof Richard Morris, University of Bristol
Dr Eileen Sutton, University of Bristol
Dr Richard Parker, University of Bristol
Dr Theresa Redaniel, University of Bristol
Dr Kyla Thomas, University of Bristol
Miss Emma Cox, University of Bristol
Dr Matthew Suderman, University of Bristol
Dr Kate Northstone, University of Bristol
Dr Joanna Crichton, University of Bristol
Dr Deborah Caldwell, University of Bristol
Mr Hugh Garner, University of Bristol
Dr Emma Anderson, University of Bristol
Dr Gemma Lasseter, University of Bristol
Dr Amy Taylor, University of Bristol
Dr Andrew Wills, University of Bristol
Dr Joanna Thorn, University of Bristol
Dr Hayley Jones, University of Bristol
Dr Jon Heron, University of Bristol
Dr Alison Teyhan, University of Bristol
Dr Diana Santos Ferreira, University of Bristol
Dr Melanie Chalder, University of Bristol
Dr Raquel Granell, University of Bristol
Dr Niamh Redmond, University of Bristol
Dr José López, University of Bristol
Dr Josephine Walker, University of Bristol
Dr Esther Walton, University of Bristol
Miss Rowena Ferguson, University of Bristol
Mr Matthew Quaife, London School of Hygiene and Tropical Medicine
Mr Tim Morris, University of Bristol
Dr Stephen Clark, University of Bath
Dr Sam Marsh, University of Sheffield
Prof Charles Taylor, University of Leeds
Prof Gene Feder, University of Bristol
Dr Andrew Crawford, University of Edinburgh
Dr Helen Cramer, University of Bristol
Ms Catherine Pitt, London School of Hygiene and Tropical Medicine
Dr Becky Mars, University of Bristol
Mr David Troy, University of Bristol
Dr Robyn Wootton, University of Bristol
Dr Ben Cislaghi, London School of Hygiene and Tropical Medicine
Ms Kate Rowley, University of Bristol
Dr Natasha Howard, London School of Hygiene and Tropical Medicine
Mr Michael Crawford, University of Bristol
Dr Sarah Sullivan, University of Bristol
Prof Dennis Leech, University of Warwick
Dr Stephen Burgess, University of Cambridge
Mr Gareth Gough, University of Bristol
Dr Jemima Dooley, University of Bristol
Ms Hannah Schubert, University of Bristol
Dr Alexander Corbishley, University of Edinburgh
Prof James Davenport, University of Bath
Dr Kamie Kitmitto, The University of Manchester
Dr Hynek Pikhart, University College London
Dr Duleeka Knipe, University of Bristol
Prof Saul Jacka, University of Warwick
Dr Luisa Zuccolo, University of Bristol
Prof David Wild, University of Warwick
Prof Wilfrid Kendall, University of Warwick
Dr Laura Howe, University of Bristol
Dr Padraig Dixon, University of Bristol
Dr Ewart Shaw, University of Warwick
Prof David Firth, University of Warwick
Dr Jere Koskela, University of Warwick
Dr Murray Pollock, University of Warwick
Dr Julia Brettschneider, University of Warwick
William Hollingworth, University of Bristol
Prof Yoav Ben-Shlomo, University of Bristol
Leanne Kupers, University of Bristol
Dr Patricia Lucas, University of Bristol
Dr Rachael Hughes, University of Bristol
Prof Bianca De Stavola, University College London
Dr Dario Spano, University of Warwick
Miss Daisy Gaunt, University of Bristol
Dr Suzanne Ingle, University of Bristol
Mrs Anne Rennie, University of Bristol
Dr Maria Clara Restrepo Mendez, University of Bristol
Dr Ana Luiza Soares, University of Bristol
Ms Alison Denny, University of Bristol
Dr Charlotte Davies, University of Bristol
Miss Amy Davies, University of Bristol
Dr Lotte Houtepen, University of Bristol
Mr Michael Holmes, University of Edinburgh
Dr Martin Lopez-Garcia, University of Leeds
Prof Alastair Rucklidge, University of Leeds
Dr Carmen Molina-Paris, University of Leeds
Dr Vladimir Kisil, University of Leeds
Dr Nicola Gambino, University of Leeds
Dr Jan Palczewski, University of Leeds
Prof Steven Tobias, University of Leeds
Dr Michael Dalili, University of Bristol
Dr Robert Aykroyd, University of Leeds
Dr David Carslake, University of Bristol
Dr Alun Coker, University College London
Prof James Speight, University of Leeds
Dr Mike Evans, University of Leeds
Dr Ruth Colson, University of Bristol
Prof Steven Julious, The University of Sheffield
Dr Laura Johnson, University of Bristol
Dr Miranda Armstrong, University of Bristol
Dr Johannes Nordstrom, University of Bath
Dr Tiziano De Angelis, University of Leeds
Dr Derek Harland, University of Leeds
Ms Kerry Humphries, University of Bristol
Dr Suzanne Trill, University of Edinburgh
Dr Clare England, University of Bristol
Dr Shereen Benjamin, University of Edinburgh
Dr Saladin Meckled-Garcia, University College London
Miss Kate Banfield, University of Bristol
Dr James Woodcock, University of Cambridge
Ms Ruth Dar, University College London
Dr Éamonn Murray, Imperial College London
Prof Sian Harding, Imperial College London
Dr David Briggs, Imperial College London
Prof Paul Luckham, Imperial College London
Mrs Michele Foot, Imperial College London
Prof Matthew Jackson, Imperial College London
Dr David Clements, Imperial College London
Dr David Wilson, Imperial College London
Dr Eduardo Coutinho, University of Liverpool and Imperial College London
Dr Huw Williams, Imperial College London
Prof Ben Sauer, Imperial College London
Prof Klaus Hellgardt, Imperial College London
Dr Shahin Tavakoli, University of Warwick
Ms Kay Hancox, Imperial College London
Dr Valerie Good, Imperial College London
Prof Martin Buck, Imperial College London
Dr Andrew Shevchuk, Imperial College London
Dr Robert Zimmerman, Imperial College London
Prof Daniel Elson, Imperial College London
Miss Joanne Chaffin, Imperial College London
Prof Ian Hodkinson, Imperial College London
Dr Bradley Ladewig, Imperial College London
Mr Peter Haycock, Imperial College London
Prof Paul Kelly, Imperial College London
Dr Roberto Rinaldi Sobrinho, Imperial College London
Miss Silvana Zappacosta, Imperial College London
Mr Stephen Condliffe, University of Bristol
Ms Trudy Breuss, Imperial College London
Prof Tim Cole, UCL Great Ormond Street Institute of Child Health
Mr Denis Murphy, Imperial College London
Dr Joao Cabral, Imperial College London
Dr Laura Griffin, Imperial College London
Prof Matthew Foulkes, Imperial College London
Dr Simak Ali, Imperial College London
Mr Andrew Thomas, Imperial College London
Mrs Sibylle Moulin, Imperial College London
Mr Roddy Slorach, Imperial College London
Mr Ronny Pini, Imperial College London
Dr Robert MacCallum, Imperial College London
Prof Yannis Hardalupas, Imperial College London
Dr Peter DiMaggio, Imperial College London
Dr Gemma Taylor, University of Bristol
Mr Martin Eden, Imperial College London
Dr Yann Sweeney, Imperial College London
Dr Ruth Misener, Imperial College London
Prof Ulrik Egede, Imperial College London
Prof Jenny Nelson, Imperial College London
Dr Adam Johansen, University of Warwick

A full history of my FOI request and all correspondence is available on the Internet at this address:

InfoRequest, Cardiff University

1 Attachment

Dear Neil


I am writing in response to your Freedom of Information request dated 24
October 2017 in which you requested information regarding the University's
response to the 2014 and 2017 UUK USS valuation consultations. 


Please find attached the response to the UUK USS valuation consultation
for 2017. With regards to the 2014 UUK USS valuations we no longer hold a
copy of the response, however have requested a copy from UUK which we will
forward once received.


I trust this information satisfies your enquiry.  The University has a
Freedom of Information Complaints Procedure should you feel dissatisfied
with this response or the way in which your request was handled.
Complaints must be made in writing and must set out why you believe the
University has not met its obligations under the Freedom of Information
Act.  You may email your complaint to [1][email address] where
it will be forwarded to the Director of Strategic Planning and Governance
who will be responsible for overseeing the review.


If you remain dissatisfied following the outcome of your complaint, you
have the right to apply directly to the Information Commissioner for
consideration.  The Information Commissioner can be contacted at the
following address: Information Commissioner's Office, Wycliffe House,
Water Lane, Wilmslow, Cheshire, SK9 5AF.


I would like to take this opportunity to thank you for your interest in
Cardiff University. If you require further assistance please feel free to
contact me.


Yours sincerely





Alison Preece   Alison Preece
Assurance Adviser   Ymgynghorydd Sicrwydd

Strategic Planning & Governance   Adran Gynllunio Strategol a
Cardiff University   Prifysgol Caerdydd
2nd Floor, Friary House   Llawr 2, Friary House
Greyfriars Road   Heol y Brodyr Llwydion

Cardiff Caerdydd
CF10 3AE   CF10 3AE
Tel: 029 208 79919   Ffon: 029 208 79919
E-mail: [2][email address]   E-bost: [3][email address]


We welcome correspondence in Welsh Rydym yn croesawu gohebiaeth trwy’r
or English Gymraeg neu’r Saesneg







Visible links
1. mailto:[email address]
2. mailto:[email address]
3. mailto:[email address]

Dear Alison,

Many thanks for sending Cardiff's response. I appreciate Cardiff's commitment to openness and transparency around this important issue.

Yours sincerely,

Neil Davies