Purpose
The purpose of this framework is to:
- Establish a clear process for the development and approval of policies.
- Ensure that policies are being appropriately monitored and policy owners are prompted when a review is due.
- Ensure there is an up-to-date schedule of all University policies and that the Governance Team are able to maintain oversight of this.
- Ensure we have a centralised online space where all University policies can be easily accessed.
Advice and Support
It is strongly advised that before starting work on creating a new policy or reviewing an existing policy that you contact the Governance team.
The Governance team can help staff plan out this work by advising on:
- Whether you need a policy or if another type of document would be more suitable (i.e. guidance or procedure).
- Who should be consulted as part of development of a policy (for example colleagues in ED&I, Sustainability etc.).
- Where to access support on completing your Equality Impact Assessment (This is mandatory for all policies)
- Best practice for what should be included in a policy.
- Where to find a centralised list of all University policies.
- The sign-off and approval route for the policy.
All policies will need to be drafted using the University's policy template. It is also recommended that once a policy is drafted it's submitted to the University's augmented writing platform Textio to ensure the use of inclusive and non-biased language.
Policy owners are ultimately responsible for the content of their policies as the subject matter experts, but Governance can provide valuable support in ensuring the policy is approved and monitored appropriately.
Determining if a policy is needed
The definition of a policy is set out in Table 1.
Before proceeding, policy owners should check their requirements align with the definition of a 'policy'.
Managers of relevant areas are responsible for identifying the need for a particular policy to help the University meet its strategic objectives and/or ensure legal and regulatory compliance. The need for a new or revised policy may result from:
- An external driver such as a change in legislation
- A change in structure, responsibilities, or circumstances
- A need for clarity to broaden the scope of a document
- A review of existing documentation
All staff who have responsibility for developing policy documents should be aware of the Framework and should also review the list of University policies to check for any existing policies with potential overlap.
The University has determined to use the following definitions within its policy framework:
Table 1
| Document | Description |
|---|---|
| University Charter | An official document issued by an authority which formally recognises the institution as a University. The Charter defines the powers, governance and function of the University at the highest level, expanded upon within the Statutes and Ordinances. |
| Statutes | Set out the regulatory framework of the University, including details concerning the role and appointment of officers of the University, the membership and responsibilities of its statutory boards and other matters. |
| Ordinances | Detailed statements which expand upon the broader principles laid out within the Charter and Statutes. |
| Regulations | Sets out the University rule or standards governing an area. Often, but not exclusively, academic rather than administrative. |
| Strategy | Statement or plan of action (usually for a designated period of time) overseen by Council that sets out how the University will manage its resources and meet the aims in the University Strategy. |
| Rules | Created in conjunction with regulations to outline the parameters under which particular academic processes can take place at the University. |
| Policy | A formal statement of the University's principles, intent and values that govern decision making. It establishes standards, rights and responsibilities that would normally be applicable across all functions of the University. Its subject is often administrative, but can be academic. The driver for a Policy is often an external requirement, either legal or good governance practice. Members of the University must comply with University Policies. |
| Procedure/Protocol | Description (involving linked action steps) of how to do something, to ensure consistency of practice, setting out the requirements and restrictions in place. Often supports a Regulation or Policy. Developed with the user/customer in mind. |
| Code of Practice | Advisory document which supports a policy/regulation and can include expectations of behaviour and/or good practice. |
| Guidance | Document giving detailed practical advice on a particular area. |
If a policy has an attached procedure this will need to be submitted for approval at the same time.
Policy Stakeholders
The roles and responsibilities of various stakeholders throughout the policy development process are outlined below. Throughout the Framework we refer to the Policy Owner, however the work may in practice be completed by other individuals.
Policy Owner
The Policy Owner may not always be the Policy Author. They should be an appropriate Senior Manager who has oversight for the area to which the policy refers (For example, the Anti-money Laundering Policy is owned by the Director of Finance). When deciding the Policy Owner, take consideration the risk related to non-compliance with the policy or the policy being out of date - the Policy Owner will have overall responsibility for this and so they should be appropriately placed to respond.
When listing a Policy Owner on the policy, only use their job title. No individuals should be explicitly named within the policy.
The Policy Owner has overall responsibility for all aspects of a policy's development; as such we refer to the Policy Owner throughout the framework, but the tasks may be delegated to other individuals.
University Executive Board (UEB) Sponsor
The UEB Sponsor may be the same person as the Policy Owner but not always. They are an appropriate member of the University Executive Board who will sponsor the policy when it is going through the various approvals routes. For example, for any Human Resources policy the UEB Sponsor will be the Director of Human Resources.
The UEB Sponsor should be aware of all new policies or policy review papers being submitted as they may be required to speak to these papers at various Board and Committee meetings.
They should not be listed in the policy unless they are also the Policy Owner and/or if they have separate responsibilities under the policy.
Policy Author
This is the person who writes the policy. They may be the Policy Owner but not always. Typically, they will be a member of the team whose role looks at policy development and review.
Their names or job titles will not be included in the policy.
As the author they will also have the responsibility for liaising with the Governance Team to discuss the policy approval routes, maintaining the policy's internal version control history and updating the policy's webpages when approved.
Policy Champion
Policy Champions are individuals who are significantly involved in policy work within their team. They have been nominated by the policy area leads as suitable people for this role.
Through this group the Governance Team will discuss various changes to the Policy Framework and where improvements can be made. Additionally there is a Teams channel where best practice for policy writing can be shared and new policies flagged to ensure communication across the University to prevent duplication of work or conflicting information.
If you would like to join this Teams channel, please contact the Governance Team.
Policy Development
Policy owners should refer to the Policy Lifecycle when drafting their policies.
In addition to completing an Equality Impact Assessment, policy owners should consider the following areas when drafting their policy and any potential impact.
| Area for consideration and brief description | Associated Risk |
|---|---|
| Strategic alignment - An assessment of how the policy aligns with the University's strategy and priorities. | The policy inadvertently encourages actions which is contra to the Strategy, Mission and Values of the University. |
| Staffing - An assessment to ensure the policy does not infringe employment law etc. | The policy opens the University to extensive legal claims and damages the reputation of the University. |
| Student - An assessment to ensure policy is appropriately student focussed. | The policy inadvertently takes action which negatively impacts student outcomes or experience. |
| Equality Impact Assessment | Places the University in breach of equality legislation opening the University to financial claims and reputational damage. |
| Climate Impact Assessment | University fails to meet its carbon targets. |
| Legal, Compliance & Data Protection - An assessment to determine whether further legal advice is required and the GDPR impact | Significant legal claims and prison |
| Financial implications - upfront and ongoing resource impacts of the implementation of a policy, and | Unable to achieve financial sustainability |
| Risk - A review to assess what high risks may arise from implementation of the document | Crystallisation of a significant risk. |
| Accessibility | Breach of legislation |
| Wellbeing - Does this policy impact staff and/or student wellbeing? | The policy inadvertently worsens the mental health or wellbeing of students/staff. |
Policy Sign-Off and Approval
Once your policy is fully drafted on the appropriate template and ready for committee approval, you email this along with a cover paper to governance@bath.ac.uk.
When you first send through your policy for approval, please copy in the relevant Senior Manager and University Executive Board Sponsor.
| Classification | Senior Manager | UEB Sponsor |
|---|---|---|
| Admissions | Director of Student Recruitment & Admissions | Pro-Vice-Chancellor (Education) Home Admissions/Pro-Vice Chancellor (Global) International Admissions |
| Academic Standards | Director of Academic Registry | Pro-Vice-Chancellor (Education) |
| Student Experience/Support | University Secretary & Registrar | Pro-Vice-Chancellor (Student Experience) |
| Research | Associate PVC for Research | Pro-Vice-Chancellor (Research) |
| Human Resources | Relevant Deputy Director of HR | Director of HR |
| Equality, Diversity and Inclusion | Deputy Director of HR (Culture & Inclusion) | Deputy Vice-Chancellor |
| Safety, Health and Employee Wellbeing | Deputy Director - Safety & Wellbeing Services | Director of HR |
| Finance | Director of Finance Operations | Director of Finance |
| Fundraising | Director of Advancement | Director of Finance |
| Marketing, Brand and Communications | Director (Marketing & Brand) | Executive Director (External Relations) |
| Fraud | Head of Internal Audit | University Secretary & Registrar |
| Operations | Relevant Director of Operations | Chief Operating Officer |
| Risk Management | Risk and Compliance Manager | University Secretary and Registrar |
| Data Protection | Chief Information Security Officer | Chief Operating Officer |
| IT Security | Chief Information Security Officer | Chief Operating Officer |
If your policy requires submission to several committees, it may need amending or updating in between submissions. You will be responsible for ensuring you send the most up to date draft to the governance account by each committee paper deadline.
The Governance team will use a degree of discretion when determining the appropriate approval route as some policies may not be easily classified. The key dates for committee submission and anticipated implementation date can then be confirmed.
Post Approval
Following approval of the policy the Governance team will:
- Confirm approval with the policy owner and UEB Sponsor.
- Update the University's policy schedule with review dates and confirm this with the policy owner.
- If required, update the University's scheme of delegation to reflect any delegated authority granted within the policy.
The policy owner will then upload the approved policy to the appropriate web page, and a link sent to the Governance Team so this can be added to the central University Policy Centre.
The Governance team will maintain the University's Policy Centre and carry out an annual review of the policy schedule, contacting policy owners annually or when a policy is due for renewal to ensure policies are kept up to date. Audit and Risk Assurance Committee will maintain oversight of the schedule. Policies will be reviewed at least every three years. Continued publication of a policy beyond its document's review date will not invalidate the policy.
It is the responsibility of policy owners to communicate the approval and publications of the policy.
If your policy is business critical you should engage with the Communications Team where a tailored communications plan can be created on a case-by-case basis.
For other policies you can complete this form to have a news item published on the University homepages (staff and/or student) as well as inclusion in the weekly Communications Team's University Update email. For best engagement you should draft a short news item, including a photo for better visibility, which then links to the published policy page. To view an example news item click here.
Making amendments to this procedure
The University Secretary and Registrar can make amendments to this procedure.