This statement is published in line with section 54(1) of the Modern Slavery Act 2015.
Am yr ICO
The Information Commissioners Office is the UK’s independent authority set up to uphold information rights in the public interest, promoting openness by public bodies and data privacy for individuals.
We employ approximately 1000 staff and also have people placed with us on a temporary basis through employment agencies. Through our work we also engage with numerous suppliers of goods and services.
Our commitment to the principles of the Modern Slavery Act 2015
The ICO is committed to the principles of the Modern Slavery Act 2015 and the abolition of modern slavery and human trafficking. We acknowledge the role that we can play to help to bring this about.
We are an equal opportunities employer, fully committed to creating and ensuring an inclusive and respectful working environment for all our staff.
We want all our staff to feel confident that they can report concerns without any risk to themselves.
Our recruitment and people management processes are designed to ensure that all prospective employees are legally entitled to work in the UK and to safeguard employees from any abuse or coercion.
We recognise that, as a purchaser of goods and services, we have the opportunity to influence good practices in the employment of people by other organisations.
We do not enter into business with any organisation, in the UK or abroad, which knowingly supports or is found to be involved in slavery, servitude and forced or compulsory labour.
In addition to publishing our modern slavery statement on our website we will add this to the Home Office modern slavery statement registry.
Here are the steps the ICO has taken and continues to take to understand and minimise the potential risk of modern slavery in its business and supply chains.
Our supply chain
We procure goods and services from the UK and a limited number of overseas suppliers. Where possible we make full use of approved UK Government Procurement Frameworks such as Crown Commercial Services.
We build relationships with our suppliers to ensure they understand our values, and comply with our expectation and commitment to protect human rights and the environment.
As part of our procurement processes, we require all of our suppliers to comply with the requirements of the Modern Slavery Act and include appropriate contractual obligations within our commercial agreements.
We require organisations tendering to work with the ICO to confirm that they have fulfilled their statutory requirement to have produced a Modern Slavery Statement if they meet the criteria to do so.
Our policies which relate to the Modern Slavery Act 2015
The following policies are available to all staff through the ICO intranet:
- Code of conduct
- Dignity at Work
- Whistleblowing
- Recruitment and Selection
- Disciplinary Procedure
- Procurement Policy
These policies set out the standards required of our staff and include details of the mechanisms in place which can be used report issues or concerns about Modern Slavery linked to our organisation taking place.
Due Diligence
- Through undertaking due diligence in our activity, we seek to ensure that we do not inadvertently support Modern Slavery. We make our processes known to potential staff and suppliers as a means of encouraging good practice.
- We ensure that all staff are legally entitled to work in the UK and that the contract is directly with them.
- We also ensure that any recruitment agency we utilise for the placement of temporary staff follows the same requirements to confirm the identity and right to work of individuals placed with us.
- When we undertake a full public procurement process potential suppliers must self-declare if they meet the relevant criteria in the Modern Slavery Act 2015.
- We also reserve the right to challenge any abnormally low-cost tenders to ensure they do not rely upon the potential contractor practising modern slavery.
- We follow guidance provided by the Government Commercial Function and undertake reviews of our current Tier 1 supply base to categorise our contracts by assessing these against key modern slavery risk indicators.
- When we procure we make use of Government Procurement Frameworks as far as possible, which provides an additional level of assurance regarding the practices of suppliers.
- We will further review our supplier onboarding process to embed checks on suppliers to ensure compliance with the requirements of the Modern Slavery Act 2015.
Risk Assessment and Management
The two main areas of risk in relation to modern slavery at the ICO relate to our contractual arrangements and recruitment of staff. The steps that we will take to manage these risks are outlined below.
We will ensure that consideration of the modern slavery risks and prevention are added to ICOs Procurement Policy review process as an employer and procurer of goods and services.
We will ensure when undertaking a further review of relevant people policies they include the consideration and prevention of risks of engagement of people or groups through Modern Slavery.
Training
We will provide mandatory awareness training to all staff on the Modern Slavery Act 2015 and inform them of the appropriate action to take if they suspect a case of modern slavery or human trafficking.
We will ensure that staff involved in buying or procurement, and the recruitment and deployment of workers, receive training on modern slavery and ethical employment practices.
Key Performance Indicators
- 95% of staff will have undertaken mandatory training in relation to modern slavery awareness.
- Policy Review
- The People Services Team conduct a rolling review of People Policies with each policy reviewed every two years. There are seven policies that have not been reviewed in the last two years and these are being worked on as a priority to be completed by January 2025.
- The review considers both policy content and tone of language.
Contact details
If you suspect modern slavery, report it to the Modern Slavery Helpline on 08000 121 700 or the police on 101. In an emergency call 999, your information could save a life.
In addition staff and external contacts can report any concerns in relation to potential modern slavery linked to the ICO’s operations to [email protected].