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NHS Digital slavery and human trafficking statement

NHS Digital does not tolerate modern slavery in any of its forms of slavery and servitude, forced or compulsory labour and human trafficking within our activities or our supply chain.

We continue to fully support the government's objective to eradicate modern slavery and human trafficking and we acknowledge our role in both combating it and supporting victims. We are committed to ensuring our supply chains and business activities are free from ethical and labour standards abuse.

About NHS Digital

The Health and Social Care Information Centre (HSCIC), known as NHS Digital, was set up by the Department of Health and Social Care in April 2013 and is an executive non-departmental public body.

Our teams design, develop and operate the national IT and data services that support clinicians at work, help patients get the best care, and use data to improve health and care.

Current policies and initiatives


NHS Digital's Human Resources (HR) policies provide processes and procedures to ensure that our employees and those employed in our supply chain are treated fairly at all times. 

These include:

  • confirming the identities of all new employees and their right to legally work in the United Kingdom
  • all staff are appointed subject to references, immigration checks and identity checks. This ensures that NHS Digital can be confident, before staff commence, that its staff have a legal right to work within NHS Digital
  • NHS Digital has a set of values and behaviours that staff are expected to comply with, and all candidates are expected to demonstrate these attributes as part of the recruitment selection process 
  • adopting the national pay, terms and conditions of service, NHS Digital has the assurance that all staff will be treated fairly and that pay, terms and conditions will comply with the latest legislation. This includes the assurance that staff received, at least, the National Minimum Wage from 1 April 2015
  • NHS Digital has various employment policies and procedures in place designed to provide guidance and advice to staff and managers but also to comply with employment legislation, which are accessible to all staff via NHS Digital’s intranet
  • committing to creating and ensuring a non-discriminatory and respectful working environment for its staff, in line with its corporate social responsibilities
  • NHS Digital’s Equality and Diversity, Grievance, Respect and Dignity at Work, and Whistleblowing policies and procedures additionally give a platform for its employees to raise concerns about poor working practices 
  • developing a new Safe to Challenge reporting service, due to be launched in Autumn 2021, will provide staff with an additional independent, confidential route to raise concerns and seek advice
  • from Autumn 2021, training and enabling a network of ‘Freedom to Speak Up Guardians’, will act as agents of equity and inclusion within the business
  • ensuring appropriate mechanisms to regularly review and track progress on promoting and supporting diversity and inclusion, both as an employer and service provider
  • NHS digital includes publication and monitoring of trends in its Workforce data as well as use of Equality Impact Assessments (EIA) to inform the development of people processes and the services it provides; and
  • All NHS Digital staff are required to undertake mandatory staff training in relation to diversity and inclusion.  

NHS Digital Whistleblowing policy

NHS Digital's Whistleblowing policy gives a platform for employees to raise concerns for further investigation and offers support to individuals that have suffered fiscal or professional detriment as a result of whistleblowing.

Procurement and our supply chain

Over the last year NHS Digital has continued to take steps to identify, prevent and mitigate modern slavery in our procurement and supply chains. We have adopted the Procurement Policy Note 05/19: ‘Tackling Modern Slavery in Government Supply Chains’ through updated policy, process and training.

We have supported the compliance of modern slavery and human rights awareness and prevention standards amongst our staff. We have provided access to relevant training for procurement and commercial staff at all levels, including ethics training accredited by the Chartered Institute of Procurement and Supply (CIPS); 100% of commercial’s permanent team members have completed this training. This training supports staff in understanding how to identify modern slavery and how to tackle it effectively in supply chains, both in existing contracts and new procurement activity. As such, in November 2020 we obtained CIPS Ethics accreditation.

Our standard contracts for the supply of goods, service and works contain terms regarding modern slavery principles and are reviewed during our due diligence and assurance process. We also use Government framework agreements including the Crown Commercial Service frameworks, to procure common ‘commodity’ goods and services, as well as the NHS Terms and Conditions where applicable. These each set out the behaviours that buyers and suppliers can expect of each other throughout procurement and supply chain relationships, including specific provisions on modern slavery and compliance with relevant legislation. Additionally, we have updated our Commercial Policy and supporting processes to provide awareness of the Modern Slavery Helpline.

We look to provide continuous improvement to be more resilient to modern slavery and the focus this in 2021 will be on implementing and incentivising responsible business practices to protect workers in our supply chains. This will be achieved by using the Government guidance as part modern slavery due diligence checks for both new and existing suppliers.

Diversity and Inclusion policy

The purpose of this policy is to ensure that NHS Digital realises its ambition to create an inclusive culture and work environment, where everyone feels that they can be themselves and are valued for the difference that they bring. This furthers the commitment to having a diverse and representative workforce, alongside ensuring that its actions demonstrate a zero-tolerance approach to inappropriate behaviour and unequal treatment, and where it is safe to challenge at all levels.

Code of Business Conduct

The Code of Business Conduct fulfils the dual role of protecting NHS Digital's interests and protecting staff from any possible accusation that they have not acted properly. All employees and all staff are provided with a copy of this document and, where necessary, can refer to the detailed provisions. 

Review of effectiveness

NHS Digital's goals for the next financial year form part of its efforts to continuously improve how it protects workers from exploitation. In line with the commitment to comply with the Government’s commercial policy and standards, there will be put in place appropriate measures to do this effectively.

To achieve this, in 2021/22 NHS Digital will:

  • apply effective and strengthened ongoing contract management and quality assurance through collaborative engagement with suppliers to assess risks during selection and approvals processes and put mitigation plans in place if red flags are raised, including monitoring and audits throughout the commercial life cycle
  • require suppliers to evidence strong social values by including social value evaluation criteria (where relevant and proportionate) to achieve improved social value awareness and compliance across all our activities
  • continue to support its staff to understand what steps should be taken to prevent modern slavery, including increasing awareness of reporting mechanisms for raising concerns and focus ongoing efforts in delivering/making available appropriate annual training to procurement and commercial staff, to build their capability to identify and address modern slavery risks; and
  • strengthen risk identification and due diligence measures by mandating, where appropriate, suppliers to complete the Modern Slavery Assessment Tool                                                       

Adoption of statement

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and applies to NHS Digital. The Board approved this statement at its meeting on 19 May 2021.

Last edited: 20 May 2021 4:02 pm