Report of Discussion: 26 May 2026

Tuesday, 26 May 2026

A Discussion was convened by videoconference. Deputy Vice‑Chancellor Professor Johan van de Ven, CTH, was presiding, with the deputy for the Director of Governance and Compliance, the Junior Proctor, the Deputy Proctor and forty other persons present.

The following item was discussed:

Remarks on the Consultation on proposals for changes to senior administrative offices

(Reporter, 6823, 2025–26, p. 447).

Mr G. P. Allen (Wolfson College):

Deputy Vice-Chancellor, the opportunity to comment on these proposals before the Council publish a report to implement them is welcome. The Council described the proposals as an opportunity, ‘to help modernise the university structures and processes’. Such a bland statement surely requires amplification, given for the last few years the University seems to have been engaged in an endless series of so-called transformation programmes. I hope the proposals aren’t intended to signal a significant shift towards a more managerial approach than has been customary in the University’s academically led culture. That would be unfortunate for both the University and the proposed Chief Operating Officer when they discover they have less power than in the corporate world.

Secondly, the Council asserts there is a need to make the workload of the Registrary ‘more manageable’ and propose to do this by shifting a substantial part of that workload, that is the management of most of the Unified Administrative Service with the addition of the University Information Services to a new office of Chief Operating Officer (COO). This transfer risks the creation of another possibly ‘unmanageable set of responsibilities’ and the dilution of the attention the COO could give to the important duties currently discharged by the Chief Financial Officer (CFO). These include oversight of the University’s wider operating assets and investment portfolio, as well as its long-term strategic and financial plan.1 As regards whether the workload is manageable or not, in my 32 years on the staff of the University Offices, I worked closely with three Registraries who successfully discharged the full range of responsibilities through a combination of their personal authority and commitment, effective teamwork and delegation to their senior colleagues. It is also noteworthy that they were all Cambridge Ph.D.s familiar with the workings and values of the University, as well as commanding the respect of the academic community.

Thirdly, turning to structural aspects of the proposals, first and declaring my interest as a former Academic Secretary, the proposed revision of the role of the Registrary, analogous to a company secretary, but designated as the principal academic planning officer of the University, to whom the Academic Secretary would report.

This revision will create confusion and asymmetry between the two roles, given the scale and breadth of the Academic Secretary’s existing responsibilities for the University’s core activities of teaching and research, planning and secretaryship of the General Board, while the Registrary’s residual core responsibilities, focusing on the Council, legal affairs, ceremonial and governance would be similar to those of the former office of Administrative Secretary. Figure 1.1 in the Notice literally puts the Academic Secretary as falling between two stools.

This apparent downgrading of the office of Academic Secretary sends a confusing message to the University community about the importance of education and research. Accordingly, I would encourage the Council to give further consideration to the triumvirate model referred to in paragraph 12 of the Notice, which would better reflect the weight of the three offices of Registrary, Academic Secretary, and COO.

In the Notice seeking applications for the office of Pro‑Vice-Chancellor (Resources and Operations),2 it was stated that the person appointed would provide academic leadership for ‘all estates-related activity’, ‘the University’s ambitious transformation programmes’ and ‘the University’s IT and digital landscape’. The advent of an experienced COO with responsibility for all these areas surely poses a risk of too many chiefs. What are the implications for the PVC role and the proposed COO?

Finally, the proposals place the Division for Health, Safety and Regulated Facilities under the proposed COO. The Division carries heavy legal responsibilities on behalf of the University for inter alia, animal houses, health and safety, radioactivity and ionising radiation – all high-risk areas which in the past have brought unwelcome attention and enforcement action to the University. Successfully negotiating the complex compliance requirements without interrupting valuable research activities requires a firm but nuanced approach by highly qualified staff who have the confidence of the scientists. I suggest that the nature of these duties is not operational in the same way as processing invoices or maintaining buildings. I urge the Council to consider shifting this Division to a more cognate area, either the Academic Division where it would fit alongside other colleagues responsible for research and education, or the Registrary’s team alongside the Legal Services Division.

Mr R. Hey (University Information Services and Wolfson College):

Deputy Vice-Chancellor, I am Deputy Director in the University Information Services (UIS) and a Fellow of Wolfson College. I speak in a personal capacity in support of the proposal to introduce a Chief Operating Officer to oversee enabling functions, including the current University Information Services.

There are however a couple of aspects directly relating to IT and Digital that might benefit from refinement:

Firstly, the Pro-Vice-Chancellor areas of alignment (shown in Figure 1.2) of the proposal set out in the Reporter are, in my opinion, lacking in coverage. As an example, ‘Digital’ (as referenced in the diagram) must be a key enabler for the University and is crucial to both the strategy and operations for both Education and Research. As a minimum, I would suggest that the respective PVC roles for these areas should both also be aligned with Digital.

Secondly, whilst I acknowledge that the suggestion I am about to make would require additional changes to Statutes and Ordinances beyond that currently proposed, formally renaming the current Unified Administrative Service as the Unified Enabling Service would better reflect the actual functionality proposed and its position as an enabler in direct support of Education and Research. In doing so, the term ‘Functions’ would far better describe the constituent parts of this service as opposed to the term ‘Division’. This change would set a clear agenda for unified and coordinated delivery in support of the University’s academic mission. Such a change is far more than branding; it sets a clear remit and focus for activities under the Chief Operating Officer and recognises that supporting Education and Research is central to its purpose.

Finally, taking the opportunity to rename University Information Services to something that better reflects its function as both a Digital partner and IT enabler should also be considered.

Dr J. K. Plummer Braeckman (Cambridge Institute for Sustainability Leadership, Newnham College, and Chair of the Board of Scrutiny):

Deputy Vice-Chancellor, I speak as Chair of the Board of Scrutiny. In its 29th Report1 the Board of Scrutiny wrote: ‘has the administration now grown so large that a substantive post of Chief Operating Officer should be established, with the policy and operations administrative support being separated?’. Following on from this recommendation, we are pleased to see this change gradually taking effect and welcome the current consultative process. Given our usual efforts to keep the Board of Scrutiny report as brief as possible we did not, in the 29th Report, go into any detail as to the organisational structure that would be required to support this change. The current consultation thus seems an appropriate moment for the Board to contribute to the discussion (given that our next report will come too late for this present consultation).

The Board refers back to the report for the Audit Group on North West Cambridge2 in 2016 which said that ‘The Council should give urgent consideration as to the way in which the need for an individual (a Chief Financial Officer) to take overarching financial and strategic responsibility for large commercial undertakings across the University might be most appropriately met and implemented.’. Nothing has changed in the financial oversight of the University in the past ten years since this report – or if it has changed, it has only become more challenging given our current financial position. Thus, we see it as unfortunate that, in the current reorganisation, the need for a strong CFO has been subsumed within the rest of the reorganisation.

We are also concerned that the COO role as suggested in the consultation paper is too broad and will thus suffer from the same overload which the paper notes for the Registrary: ‘the office of Registrary has had a broad and, at times, unmanageable, set of responsibilities requiring a skillset seldom found in one individual’. As envisaged, the COO would have many of the operational responsibilities of the current Registrary together with many of the responsibilities that the Audit Group for North West Cambridge envisaged for the CFO, and more.

The Academic Secretary is the University’s equivalent of a Chief Technical Officer. Subordinating the role which incorporates the very function of the University to the Governance function (the Registrary) or the operations department sends the wrong message to the staff and students in terms of where value is placed in the institution.

Dealing with the need for a high profile to the Academic Secretary role and the need to reduce the unwieldy remit of the COO as suggested in the current proposal, the Board would suggest that there be a triumvirate structure of three key roles, each reporting to the Vice-Chancellor, consisting of:

1.COO – who manages all the routine internal operational functions of the University, including finance, HR, administration, IT and estates.

2.Registrary – who manages governance, compliance and external affairs, including communications, and CUDAR, and provides support to the Council.

3.Academic Secretary (or Secretary General) – who manages all matters of academic operations, planning and policy, and provides support to the General Board.

This triumvirate structure might better map on to the different but complementary skill sets of potential postholders than the proposal, which blurs academic policy oversight with technical compliance support. It would also allow the Pro‑Vice‑Chancellors to take a more clearly policy-based role. A mapping of the University Committees onto these offices would be required, and some joint committees would clearly, in certain circumstances, require the presence of more than one of these officers.

The Board commends consideration of this tripartite arrangement to the Council, and also urges it to keep the matter of a need for a CFO (whether reporting to the COO or otherwise) under review. We would of course be happy to discuss this further if helpful.

Dr S. J. Cowley (Faculty of Mathematics):

Deputy Vice-Chancellor, I am Secretary of the Board of Scrutiny, but I speak in a personal capacity; hence this might be viewed as ‘not the Board of Scrutiny’s response’. Also, since I refer to Secretaries of Schools, I declare an interest in that my wife is a Secretary of a School (but she has no idea of what I am about to say).

The Chair of the Board of Scrutiny has referred to the Board’s question in its 29th Report (which I signed and which I help draft) of whether the administration has ‘now grown so large that a substantive post of Chief Operating Officer (COO) should be established, with the policy and operations administrative support being separated’. I am pleased that this question is being addressed. However, while I am favour of a COO, and I am not yet convinced that the current proposals are, in the round, what is needed.

In my Note of Dissent of 4 June 2018 to the Joint Report of the Council and the General Board on the establishment of an Education Division, Research Division, and Strategic Partnerships Division1, I noted that:

Institutions in the University are either under the supervision of the Council or the General Board; as such University Governance has a bicameral nature. Traditionally the Academic Secretary has been Secretary of the General Board and, more importantly, like the Registrary, has been one of the administrative officers in the University with a broad and comprehensive understanding of the University. This arrangement, with both the Registrary and the Academic Secretary having the right to attend key committees, has worked well. Whilst the arrangement might suggest an element of duplication, when both posts were filled it meant that an officer with a holistic view of the University was present at key meetings (which has not always been the case in recent months).

I stand by those remarks, and as a subsequent Notice observed:

The Council and the General Board note the concerns expressed in the Discussion about the proposal. The Registrary has subsequently explored with a number of academic and administrative colleagues the issues that have been raised. In light of those conversations and the clear disquiet that the proposals have generated and following the Registrary’s further advice, the Council and the General Board have concluded that it would be prudent to maintain the integrity of the Academic Division. … The Council and the General Board have therefore agreed to withdraw the Joint Report.

Notwithstanding that the Joint Report was only indirectly concerned with the role of the Academic Secretary; the Council and the General Board wish to affirm the importance it places on that office. For example, it notes the observation in the Discussion that the Academic Secretary has a central role in providing a ‘broad and comprehensive understanding’ of the University.2

That 2018 Report was an example of muddled thinking, e.g. the elevation to Division level of the Strategic Partnership Office, an Office that has now been disbanded. Unfortunately, there seems to be evidence of muddled thinking in this report.

In a bicameral system, where substantive proposals and decisions are made at both the General Board and the Council, the General Board needs a senior administrator with clout and a broad and comprehensive understanding of the University. As Graham Allen has observed, under the current proposals the Registrary’s residual responsibilities, focussing on the Council, legal affairs, ceremonial and governance, are little more than those of the former Administrative Secretary; this is the role of a ‘Company Secretary’. The responsibilities of the Academic Secretary are far larger and far wider, and as such indicate a more senior post. The Registrary’s boxes of responsibility in Figure 1.1 include ‘Ceremonial Support’ and ‘Regent House Engagement’, while those of the Academic Secretary include ‘Academic Planning’, and both ‘Research Strategy’ and ‘Education Strategy’, while the COO has boxes covering ‘Digital’, ‘Estates’, ‘Finance’ and ‘HR’. The scope of the Registrary’s boxes do not compare. Moreover, surely the qualities that make a good Company Secretary are not necessarily those that make a good Academic administrator (as I think the University may have discovered). I am not advocating that the Registrary should report to the Academic Secretary rather than vice versa, but tails should not wag dogs. Also, I do not think that the University should be precious about the pre-eminence of the post of Registrary in the University’s hierarchy (Cambridge is not Oxford), especially given that the role of ‘Company Secretary’ is in itself an important post.

As the Chair of the Board of Scrutiny has also observed, the need for a Chief Financial Officer (CFO) was identified in the report of the Audit Group on North West (NW) Cambridge. The first phase of NW Cambridge incurred substantial cost overruns. Indeed, a 2020–2022 review demonstrated that the total cost of delivering Phase 1 exceeded the receipts from plot sales, as well as the value of the assets that were created. Further, a modelled repayment trajectory for the bond that funded NW Cambridge and that was meant to be repaid around 2050, predicts repayment around the 2070s with a stronger rental growth scenario, but that date extends much further, out to around 2100 or just beyond, under a lower rental growth scenario. As someone who voted for Phase 1 on the basis that it would wash its face, this is intensely depressing.

According to the Council’s Notice of 16 April 2026 concerning the Delivery of the future development of the North West Cambridge site3 the University is embarking on Phase 2. So, is this the time to subsume the post of CFO into that of the COO given that, as envisaged, the COO would have almost all the operational responsibilities of the current Registrary together many of the responsibilities that the Audit Group for NW Cambridge envisaged for the CFO? Compare the recommendation of the Audit Group for NW Cambridge:

The Council should give urgent consideration as to the way in which the need for an individual (a Chief Financial Officer) to take overarching financial and strategic responsibility for large commercial undertakings across the University might be most appropriately met and implemented.

with the proposal from the current report, that the COO should:

take over from the CFO oversight of Cambridge University Press and Assessment, the non-operational estate and financial investments, the capital plan and investment appraisal (supported by a new small directorate – identified as ‘Planning and Investments’ in the chart in Annex B).

If the current Registrary’s role has a ‘broad and, at times, unmanageable, set of responsibilities requiring a skillset seldom found in one individual’, given the recommendation of the Audit Group for NW Cambridge, should not the Council provide a detailed justification as to why the proposed COO role does not have a ‘broad and, at times, unmanageable, set of responsibilities requiring a skillset seldom found in one individual’?

The above outlines my major concerns with the proposals, but I have many others. For instance:

•The relative roles of the PVCs, the COO, the Academic Secretary, etc., need to be fleshed out.

oFor example, with the appointment of a COO might it be better to revert to a PVC for Planning and Resources (a role that used to work well in the past), rather than a PVC for Resources and Operations?

•In what way will the COO take ‘primary responsibility for the operational planning at Schools and Non-School Institutions (NSIs) through the School Secretaries’; this looks like a potential minefield. It is true that some administrative staff in the Schools already report to Heads of Divisions (e.g. Finance and Human Resources) rather than the School Secretaries, but School Secretaries, for the most part, report to the Academic Secretary. There needs to be clarity of responsibility.

In summary, the University needs an administrative structure that works. If that means a COO, an Academic Secretary, a Company Secretary and a CFO, with clearly defined roles, then so be it, especially if it results in an efficient and effective administration that leads to significant cost savings that outweigh the cost of the extra post(s).

I finish with a further quote from my aforementioned Note of Dissent:

In 2004 there were Reviews of the Personnel and Research Services Divisions, with detailed reports published in the Reporter (https://www.admin.cam.ac.uk/reporter/2003-04/weekly/5972/4.html). By comparison, the case for the changes proposed in this [2018] Report, which are arguably more far-reaching, has not been made.

I understand that there is an urgent need to appoint a person to head the operations of the UAS and UIS, but the changes in this report (small ‘r’) are far-reaching, and a better case needs to be made. The University should beware of acting in haste and then having to repent in leisure … yet again.

Mr A. Odgers (Chief Financial Officer), read by the Junior Proctor:

Deputy Vice-Chancellor, I have been coordinating work in relation to options for the University’s Senior Administrative Officers. Thank you all for taking part in the Discussion today. We very much welcome and appreciate your feedback on the proposals outlined.

Mr B. Watkins (University Information Services and Department of Veterinary Medicine), read by the Junior Proctor:

Deputy Vice-Chancellor, having read the consultation report on the proposed changes to senior administrative offices, including the proposal for UIS to become a new Division within UAS, I am concerned this change may influence how colleagues in research and academia perceive the new Information Services Division. It is worth noting that, over twelve years ago, the academically focused Computing Service and the UAS-focused MISD were brought together to form UIS, in order to provide a more unified service to the University. There is a risk the new Division under the UAS could be seen as primarily focused on delivering UAS administrative services, rather than on developing and providing critical digital services for research and education across collegiate Cambridge.

Additionally, should the change progress as proposed, I wonder whether the new Division might be more appropriately named the ‘Digital Services Division’, as this would better reflect the numerous digital services that Division would provide to the University as a whole.

Dr W. J. Astle (MRC Biostatistics Unit), read by the Deputy Proctor:

Deputy Vice-Chancellor, although I am a member of the Council, these remarks are made in a personal capacity.

Paragraph 12 of the Report explains that the Council ‘gave serious consideration to a tripartite model in which the Registrary, the COO and the Academic Secretary would be peers, all reporting to the Vice-Chancellor as Chair of the Council, with the Academic Division as a third pillar alongside the Divisions under the Registrary and COO’. I hope that a version of this model will receive further thought, since it appears to imply a clearer division of responsibilities between the Registrary and the Academic Secretary than the proposed alternative.

As paragraph 13 of the Report notes, decisions in the University are made by committees, which are ultimately accountable to the Regent House or, through the Councils of the Schools, to the Faculties. It therefore seems sensible for the senior administrative officers to be accountable to their respective senior committees, with day-to-day oversight delegated to the Vice-Chancellor as their Chair. That suggests that the Academic Secretary should be accountable to the General Board, as its senior administrative officer, rather than to the Council through the Registrary (primarily) and the Chief Operating Officer (secondarily). For the Academic Secretary to be both junior to and accountable to the Chief Operating Officer suggests a risk of the subordination of the academic to the operational.

The proposed arrangements would put the senior financial officer in the University, the Director of Finance, a rung below the senior officers with responsibility for the administration. Is that wise, when there is an accepted need to make the University’s operations more efficient, and to place a check on the size of the University’s administration?

Finally, I’m concerned that the proposed amendment to Statute C VI would introduce the concept of ‘post-holder’ to the Statutes. The Board of Scrutiny has repeatedly requested that criteria be drawn up to determine the use of unestablished posts. A review of their use by the HR Committee has been repeatedly postponed, but it is now to be legitimised by statute. An administrator sufficiently senior to perform one of the statutory duties of the Registrary surely ought to be a University office holder, recognised by the Statutes and Ordinances.

Mr R. S. Haynes (University Information Services and Darwin College), read by the Junior Proctor:

Deputy Vice-Chancellor, the proposed changes to senior administrative offices seem both unhelpfully rushed and sparse on key details, as well as a puzzling attempt to include the essentially broad and specialist areas of digital and information technologies in the higher education context. At the very least, that latter area, and the proposed incorporation of the University Information Services (UIS) to be subsumed into the Unified Administrative Service (UAS), need to be extracted from the debate about whether to create a Chief Operations Officer (COO) and taken as a separate item. This latter matter is of course to be taken up as part of the Discussion on a Topic of concern scheduled for next week, so will be further detailed then.

While it is not yet clear how creating a COO, and shifting responsibilities from Registrary and Chief Financial Officer (CFO), along with adding even more responsibilities such as for UIS, will either save money, or improve manageability, or increase overall effectiveness for all impacted, it is clear that there has been insufficient time or engagement with the University community to properly explain and explore these significant issues. The All-staff meeting online for an hour on 11 May was a starting point, however the questions and answers following the slide presentations were extremely brief and truncated before all questions were answered and provided no opportunity for real dialogue.

It also is unclear where a COO position has been successfully adopted in any of our peer universities, and which set of roles are covered there compared to the currently proposed set under discussion here. It also is ambiguous how this would be a move toward ‘modernisation’, given its commonality in some industries, and whether it is an appropriate aspect to adopt for our University. As previously discussed when considering adding a 6th PVC, expanding our suite of senior leadership is not always our best option or a persuasive response to resolve existing challenges, especially without sufficient time to properly deliberate together or available evidence to help discern such an important proposed change.

Given the tens of millions being spent and further committed to the transformation projects for central administrative systems, and the many millions (£2m/year?) previously spent on the ‘Our Cambridge’ project to use Lean methodology to ‘untangle the spaghetti’ and reduce bureaucracy, becoming more top-heavy in our leadership does not seem to be a demonstrably persuasive choice. Perhaps with additional time, engagement and discourse with the University community this could be suitably explored?

Whatever the deliberations about the proposal for a COO, the considerations about the reporting structures for UIS should be disaggregated from the proposed UAS and COO’s structures, as will be further considered in the 2 June Discussion, along with the logical importance of waiting for the guidance to come from the successful co‑creation within the University community of a digital strategy and maturity model for the whole of the University. Our productive digital future relies on not acting on this proposed rapid shift of reporting structures for UIS until the University’s digital hopes and requirements are made clear to all, and the resulting digital strategy and framework for improvement and related maturity are together made unambiguous.

Professor G. R. Evans (Emeritus Professor of Medieval Theology and Intellectual History), read by the Deputy Proctor:

Deputy Vice-Chancellor, this Discussion is prompted by a vacancy in the Office of Registrary and the imminent departure of the present Chief Financial Officer. It is proposed that the opportunity be taken to ‘reorganise the responsibilities of those two offices’, howver the confidence that this will ‘help modernise the University structures and processes’, points to a far bigger objective.

The wording of Figures 1.1 and 1.2 should revive previous concerns about the use of the term ‘senior leadership’ in a University run by the Regent House as a democracy. The expression has never been approved for use by the Regent House. It is time for it to be asked to do so.

In the published ‘charts’, Figure 1.1 covers ‘Senior leadership roles, reporting lines and high-level departmental structure’. Figure 1.2 relates directly to the topic of this Discussion, depicting ‘Pro-Vice-Chancellor areas of alignment with professional services departments/functions’. These are to be divided between the future Chief Operational Officer and the Registrary. Between the two is slotted ‘School partnering’, headed by the Vice‑Chancellor and the Academic Secretary. So ‘leadership’ is taken to include both administrative and academic Officers.

It is implied that the Registrary has too much to do, making it sensible to move some of the responsibilites of that Office to the Schools. That requires change to Statutes A and C, so it will also need royal consent. In practice that has always been given but it may take the Privy Council a little time to process. The University already has a petition before it, seeking ‘amendments to Statute A IX 10’ to ‘update the Commissary’s jurisdiction, replacing an outdated legislative reference to ensure compliance with the Higher Education Act 2004’.1). If the Regent House gives its own approval to the present proposal the Privy Council must receive any new petition proceeding from this Grace within eight weeks (‘exclusive of any University vacation’).

Statute C I lists at 1(a) only ‘those persons’ who ‘hold any of the University offices of Chancellor, Vice‑Chancellor, Pro‑Vice‑Chancellor, High Steward, Deputy High Steward, Commissary, Proctor, Orator, Registrary, Librarian, Director of the Fitzwilliam Museum, Esquire Bedell, University Advocate, and Deputy University Advocate, but adds ‘any other University office established or specified by Statute or Ordinance’. That would include the Chief Financial Officer, holding an Office mentioned several times in the Statutes and Ordinances. Must it also include ‘Directors’ holding a University Office so named though a Director may also hold ‘such other title as may be determined from time to time by the Council’.

It is proposed that under an amended Statute C VI the Registrary and the Chief Operating Officer may be one or two persons, the Council appointing as it chooses. If it ‘determines that there shall be two officers, one designated as the Registrary and the other designated as the Chief Operating Officer’, the Vice-Chancellor is to choose how to allocated duties not specified by Ordinance, with the condition that the Council may not appoint one of its own members. This seems to involve a significant change to the University’s understanding of ‘Officers’.

Changing Ordinances requires only the consent of the Regent House. It is being asked to get ahead of itself. Approval of the proposed Grace will rescind the Ordinance for University Information Services, a category to be found in Chapter I of the Ordinances. This is a matter to be considered in a Discussion scheduled for next week on a Topic of concern on the ‘pause of UIS reorganisation’, called for by 75 members of the Regent House under a longer title: ‘Urgent Pause of Proposed UIS Reorganisation and Relegation under UAS’.

In what way does all this involve the ‘modernisation’ which it is suggested is now needed? Is ‘modernisation’ necessarily desirable? A speaker in debate on the Universities of Oxford and Cambridge Bill in the Commons on 22 June 1923 commented that ‘these ancient universities are daily proving themselves capable of adapting themselves to the necessities of modern demand’ and ‘must reflect the modern state of things’. But the ‘modern’ moves with the times. It may be wise for the University to be cautious about ‘modernisation’ today.

The Office for Students, now the ‘Regulator’ of English providers of higher education and their allocator of Government funding, has its own ‘strategic roadmap’:

Looking to the future, digital technology and artificial intelligence will precipitate potentially transformative shifts in teaching, learning and assessment, accentuated by a demand for lifelong learning and the changing skills needs of the economy.2

So far the OfS has refrained from interfering with Oxford and Cambridge but it may try. But perhaps it will think twice since it had been rapped on the knuckles by the High Court after it fined the University of Sussex.3