Decision

Summary of business appointments applications - Robert Hannigan

Updated 5 December 2018

Robert Hannigan left his position as Director at GCHQ in April 2017.

1. Senior Associate Fellow, Royal United Services Institute

The Committee was asked to consider an application from Robert Hannigan for advice on taking up an appointment as an unpaid Senior Associate Fellow at the Royal United Services Institute (RUSI).

Mr Hannigan spoke at RUSI while in office and was on their advisory board (automatically by virtue of his position as Director, GCHQ).

The Committee noted that there is precedent for former heads of Intelligence Agencies taking up Senior Associate Fellow positions at RUSI. The Committee sees nothing improper in this given RUSI’s role as an independent think-tank in the defence and security sector; and because former officials are prevented from using privileged information and, under the Government’s Business Appointment Rules, from lobbying Government for two years after leaving office. Further, GCHQ has confirmed that there are no conflicts of interest arising from his time in office and the contact that he had with RUSI while he was Director of GCHQ.

The Prime Minister accepted the Committee’s advice that, in accordance with the Government’s Business Appointment Rules, this appointment be subject to the following conditions:

• he should not draw on (disclose or use for the benefit of himself or the organisation to which this advice refers) any privileged information available to him from his time in Crown Service; and
• for two years from his last day in service, he should not become personally involved in lobbying the UK Government on behalf of RUSI.

The letter containing the Committee’s advice was sent in November 2017 and the appointment was announced in January 2018.

2. Trustee, Bletchley Park Trust

The Committee was asked to provide advice in relation to Robert Hannigan accepting an appointment as an unpaid trustee of Bletchley Park Trust, an unfunded independent museum and registered charity.

Mr Hannigan explained in his application that he is personally very committed to Bletchley as a heritage site and as an educational/cyber skills inspiration for the next generation.

GCHQ has confirmed that while it has a close connection to the Trust, there is no financial relationship, nor anything else that could lead to a conflict of interest. Mr Hannigan had dealings with the Trust and visited several times whilst Director, as would be expected.

The Committee noted that whilst there is a close connection between the Trust and GCHQ, there is no reason to think that the Trust would stand to gain an unfair advantage by appointing Mr Hannigan.

The Prime Minister accepted the Committee’s advice that, in accordance with the Government’s Business Appointment Rules, these appointments be subject to the following conditions:

• he should not draw on (disclose or use for the benefit of himself or the organisation to which this advice refers) any privileged information available to him from his time in Crown Service; and
• for two years from his last day in service, he should not become personally involved in lobbying the UK Government on behalf of Bletchley Park Trust.

The letter containing the Committee’s advice was sent in November 2017 and the appointment was announced in January 2018.

3. Independent consultancy and commissions with BlueteamGlobal, Hiscox Insurance Ltd & Immersive Labs Ltd

Robert Hannigan sought advice under the Business Appointment Rules about establishing an independent consultancy providing strategic advice on risk, primarily, but not exclusively, in the context of cyber security.

Mr Hannigan also proposed to accept the following commissions:

1. BlueteamGlobal (a new US cyber security company). He would become Head of the European Advisory Board. He said this is a paid role and noted the company will not sell services to Governments.
2. Immersive Labs Ltd (a new, small UK start-up offering cyber skills assessment and training for organisations). He said he would join the Advisory Board and help to shape their skills offer. This is an unpaid role.
3. Hiscox Insurance Ltd. This will involve ‘thought leadership’ on cyber insurance and is a paid role.

The Cabinet Secretary and the Director General, Capability, at GCHQ have no reservations about Mr Hannigan’s application. Their view is that the proposed consultancy is a reasonable use of Mr Hannigan’s generic experience and insight.

3.1 BlueteamGlobal

The Committee noted that BlueteamGlobal announced the launch of its operations by press release on 3 August 2017. The press release also referred to senior leaders from the private sector and national security agencies that have been recruited to the company, including Mr Hannigan’s appointment as head of the company’s European Advisory Board.

In its letter to GCHQ, the Committee registered its concern that Mr Hannigan’s appointment with BlueteamGlobal was announced before the Committee had the opportunity to consider and make a recommendation on the application. It advised it is unable to offer retrospective advice on appointments that have already been announced.

3.2 Independent Consultancy and commissions with Immersive Labs Ltd and Hiscox Insurance Ltd

The Committee considered the potential risk of public perception that Mr Hannigan could unfairly advantage his clients, by virtue of the information he holds or the contacts he has in Government. It concluded this is low for the following reasons:

• he had no access to commercial information about competitors while in post;
• the Department noted that commercial and cyber policy aims are rapidly evolving and have a limited shelf life;
• he had involvement in cyber security while in post, but not in relation to any particular sector or industry;
• he had no involvement in selling cyber insurance or in the insurance sector;
• GCHQ does not have a regulatory role on cyber;
• he has been clear that he will not represent the interests of his clients to Government; and
• over 4 months have passed since Mr Hannigan left the Civil service.

The Committee had no concerns that the commission could reasonably be perceived as a reward given he had no contact with the company while in post, and GCHQ has confirmed it has no relationship with it either.

The Prime Minister accepted the Committee’s advice that, in accordance with the Government’s Business Appointment Rules, the consultancy and the commissions with Immersive Labs Ltd and Hiscox Insurance Ltd be subject to the following conditions:

• that he should not draw on (disclose or use for the benefit of himself or the organisations to which this advice refers) any privileged information available to him from his time in Crown service;
• for two years from his last day in Crown service, he should not become personally involved in lobbying the UK Government on behalf of any of his clients or those he advises, nor should he make use, directly or indirectly, of his Government and/or Crown service contacts to influence policy or secure business on behalf of his clients;
• for two years from his last day of service he should not undertake any work as a consultant that involves providing advice to any company or organisation on the terms of a bid or contract relating directly to the work of GCHQ; and
• for two years from his last day in Crown service, before accepting any commissions and or/before extending or otherwise changing the nature of any commission, he should seek advice from the Committee. The Committee will decide whether each commission is consistent with the terms of his consultancy and consider any relevant factors under the Business Appointment Rules.

The Committee further noted that while it is not willing to provide advice on the commission with BlueteamGlobal, it would expect Mr Hannigan to comply with the conditions set out above in the exercise of his role.

The letter containing the Committee’s advice was sent in September 2017. The consultancy and commission with Hiscox were announced later that month. The commission with Immersive was announced in October 2017.

4. Subsequent commissions under the independent consultancy

Mr Hannigan has since taken up the following commissions under the terms of his consultancy:

• McKinsey (October 2017)
• Rubica (October 2017)
• Schillings International (October 2017)
• The Centre for Secure Information Technologies (April 2018)
• Bluevoyant (May 2018)