Conflict of interest documentation serves two purposes. In the moment, it creates accountability — assessors who know their declarations will be recorded think more carefully about what they're disclosing. After the fact, it's the evidence base for defending your process when a funding decision is challenged.
Most grant programmes document less than they should and store it less carefully than they should. Here's what good practice looks like.
Declaration forms: Retain signed conflict of interest declarations from every assessor, for every round. These are the primary record that your programme asked the right questions and assessors responded formally.
Materiality assessments: When a conflict is declared, document the programme manager's assessment of whether it's material. This should be a brief written record — two or three sentences explaining the nature of the relationship, why you assessed it as material or immaterial, and what action (if any) you took.
Recusal records: When recusal occurs, document who was recused, from which application(s), and what happened with the affected application as a result.
Nil returns: Keep records of declarations where no conflict was identified. A declaration that says "no conflicts" is positive evidence that the process was followed, not just the absence of a record.
Panel composition records: For each round, maintain a record of who sat on the assessment panel, when they joined and left, and any changes during the assessment period.
When a declared conflict requires substantive management, document in more detail:
The relationship: What was declared, in the assessor's own words where possible. Include any follow-up clarification you requested.
Your assessment process: Who reviewed the declaration, when, and what information they used to make the materiality assessment.
The decision: What action was taken, and why. If you decided recusal wasn't required despite a declared relationship, explain your reasoning explicitly.
The outcome: What happened to the affected application. If the assessor was recused, record how the application was assessed in their absence and by whom.
Communication: Any communications with the assessor about the declaration and the management decision.
If a conflict of interest comes to light after the fact — through a complaint, a media inquiry, or internal discovery — your documentation needs are more extensive:
This is your incident record. It should be written contemporaneously — as the situation unfolds — not reconstructed later.
Who should have access: Declaration forms and conflict of interest records should be accessible to the programme manager and relevant governance but not to the assessment panel. Assessors' declarations about each other are confidential.
How to store them: Keep conflict of interest records with your programme records, not in personal email inboxes. If your grants management system has a document management function, use it — records stored there are more findable, more securely controlled, and less likely to be lost when staff change.
Digital vs. paper: Digital records are generally preferable — searchable, backed up, and easier to control access to. If you use paper declarations, scan them and store digitally. Wet signatures are not required; electronic signatures are acceptable for most purposes.
The right retention period depends on what your records might be needed for.
For audit purposes: Most government grant programmes require records to be kept for seven years from the end of the funded period. If your programme is funded by government, this is your minimum.
For legal challenge: Funding decisions can potentially be challenged through complaints processes, judicial review, or civil action. The relevant limitation periods vary by jurisdiction but are typically three to six years from the date of the decision.
For accountability to your own funder: Check your grant agreement or funding contract. Some funders specify record retention requirements.
As a practical default: Seven years from the end of the grant round is a safe retention period for most programmes. This covers most audit windows, most legal limitation periods, and allows for meaningful historical analysis of your programme.
After the retention period, records can be destroyed — but do this systematically, not ad hoc. Document what was destroyed, when, and under what authority.
For a single round, a complete conflict of interest file contains:
This doesn't need to be a large file — for a well-run programme with few conflicts, it might be ten or fifteen pages. The point is that all the relevant records are in one place, findable, and retained for the appropriate period.
When a question is raised about a decision three years after it was made, you want to be able to open a folder and find a complete record — not to be reconstructing events from memory or searching through email inboxes.
This article is part of the complete guide: Conflict of Interest in Grant Assessment: A Practical Guide.