NHS Digital slavery and human trafficking statement

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.

Our 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 and appointing staff subject to references, immigration checks and identity checks. This ensures that we can be confident, before staff begin employment, that our staff have a legal right to work within the organisation
• having a set of values and behaviours that staff are expected to comply with, with all candidates expected to demonstrate these attributes as part of the recruitment selection process
• adopting the national pay, terms and conditions of service means that we have 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 2022
• implementing employment policies and procedures designed to provide guidance and advice to staff and managers and to comply with employment legislation. These are accessible to all staff via our intranet
• committing to creating and ensuring a non-discriminatory and respectful working environment for our staff, in line with our corporate social responsibilities
• providing a platform for our employees to raise concerns about poor working practices, through the implementation of policies covering equality, diversity and inclusion; grievance; respect and dignity at work; and whistleblowing
• implemented a Safe to Challenge reporting service which provides staff with an additional independent, confidential route to raise concerns and seek advice
• implemented a network of ‘Freedom to Speak Up Guardians with appropriate training, who 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. This includes the publication and monitoring of trends in our Workforce data as well as our use of Equality Impact Assessments (EIA) to inform the development of people processes and the services we provide
• requiring all staff to undertake mandatory training in relation to diversity and inclusion

Our 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.

Over the last year we have 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 had completed this training at the point of the CIPS Kitemark renewal in November 2021. New members of staff, joining since this date, are required to complete the training by November 2022 to ensure compliance to this standard. 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, we hold 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 2022 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.

The purpose of this policy is to ensure that we realise our 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 our commitment to having a diverse and representative workforce, alongside ensuring that our actions demonstrate a zero-tolerance approach to inappropriate behaviour and unequal treatment and where it is safe to challenge at all levels.

The Code of Business Conduct fulfils the dual role of protecting our 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. 

This Code makes clear the duties and obligations of all staff. It outlines the support available in NHS Digital to protect staff from accusations of inappropriate conduct in carrying out their work. It sets the boundaries of acceptable business conduct and behaviour.

Our goals for the next financial year form part of our efforts to continuously improve how we protect workers from exploitation. In line with our commitment to comply with the Government’s commercial policy and standards, we will put in place appropriate measures to do this effectively.

To achieve this, in 2022/23 we 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 our staff to understand what steps they should be taking 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 our procurement and commercial staff, to build their capability to identify and address modern slavery risks; and
• strengthen our risk identification and due diligence measures by mandating, where appropriate, suppliers to complete the Modern Slavery Assessment Tool                                                       

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 8 June 2022.