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Slavery and human trafficking statement 2018/19

We support the government's objective to eradicate modern slavery and human trafficking, and acknowledge our role in both combating it and supporting victims. We’re committed to make sure 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.

It exists to help patients, clinicians, commissioners, analysts and researchers. Its goal is to improve health and social care in England by making better use of technology, data and information.

With an operating budget of around £340 million, and a team of 2,500 staff, it provides national information, data and IT systems for health and social care services.

Current policies and initiatives

NHS Digital recognises the requirement of supporting the Government’s objective to eradicate modern slavery and human trafficking and recognises the significant role NHS Digital has to play in both combatting it and supporting victims.

Specifically, NHS Digital is committed to ensuring that its supply chains and business activities are free from ethical and labour standards abuse.

Steps taken by NHS Digital to date 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, health checks, 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 selection process 
  • adopting the national pay, terms and conditions of service, NHS Digital has the assurance that all staff will be treated fairly and 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.
  • NHS Digital’s Equality and Diversity, Grievance, Respect and Dignity at Work policies and procedures additionally give a platform for our employees to raise concerns about poor working practices 
  • NHS Digital recognises and acknowledges that diversity and inclusion are key corporate social responsibilities and is committed to creating and ensuring a non-discriminatory and respectful working environment for its staff 
  • NHS Digital has incorporated its diversity and inclusion objectives into the annual business plan and reviews them regularly to ensure that NHS Digital policies and practices promote and support diversity and inclusion both as an employer and service provider; and 
  • All NHS Digital staff are required to undertake mandatory staff training in relation to diversity and inclusion.  

Whistleblowing in the NHS

  • NHS Digital subscribes to the independent whistleblowing charity ‘Protect’. NHS Digital was one of the early signatories for their ‘First 100 Campaign” to support their whistleblowing Code of Practice. Governance arrangements are well embedded within NHS Digital. 
  • NHS Digital’s Whistleblowing Staff policy additionally 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

  • NHS Digital Commercial addresses Modern Slavery in its supply chain through the  three P’s; 
  1.  Policies to prevent, detect and eradicate modern slavery within their own operations and the operations of suppliers and business partners
  2. Processes to identify key vulnerabilities and taking a risk management approach to ethical commercial practice.
  3. Planning for situations where corrective action is needed where issues have been identified via audit reports, whistleblowing, media reports etc.
  • NHS Digital standard Terms and Conditions require suppliers to comply with relevant legislation.
  • A large proportion of the goods and services procured are sourced through Government supply frameworks and contracts also require suppliers to comply with relevant legislation.
  • Social value considerations are included in specifications and evaluation criteria where this is appropriate and legal to do so.

Review of effectiveness

NHS Digital intends to take further steps to identify, assess and monitor potential risk areas in terms of modern slavery and human trafficking, particularly within supply chains.

In 2018/19, NHS Digital will also:

  • support its staff to understand and respond to modern slavery and human trafficking, and the impact that each and every individual working at NHS Digital can have in keeping present and potential future victims of modern slavery and human trafficking safe
  • develop staff awareness of the Modern Slavery Act 2015 and reporting mechanisms if a case of modern slavery or human trafficking is suspected i.e. access to training on how to identify those who are victims of modern slavery and human trafficking and inform them of the appropriate action to take if they suspect a case of modern slavery or human trafficking
  • embed social value best practice into commercial processes which will achieve improved social value awareness and compliance across all our commercial activities; and
  • impact assess all new or reviewed policies for diversity and inclusion  compliance.                                                                         


Adoption of policy

Sarah Wilkinson, Chief Executive Officer, NHS Digital, December 2018

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 18th December 2018.

Last edited: 14 February 2019 1:58 pm