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.

This statement is published in line with section 54(1) of the Modern Slavery Act 2015.

About the 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 over 800 staff and also have people placed with us on a temporary basis staff 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 a non-discriminatory, inclusive and respectful working environment for all our staff. We want all our staff to feel confident that they can expose wrongdoing 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.

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

Due to the nature of our business, we assess ourselves to have a relatively low risk of modern slavery in our business and supply chains. We procure goods and services from the UK and limited numbers of overseas suppliers. Where possible we make full use of approved UK Government Procurement Frameworks.

Our security company and cleaning company, who provide staff based on our sites, have both published their own statements on tackling modern slavery.

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
  • 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 know 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 that 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 ensure that services where we have outsourced staffing requirements (cleaning and security) are through companies that also have a modern slavery statement, if that is a statutory requirement, and that all such suppliers provide information about their equality policies and practices.
    • 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 Procurement Processes to further embed checks on suppliers to ensure compliance with the requirements of the Modern Slavery Act 2025

We will further to embed the principles through 2021-22 and monitor by:

  • providing awareness training to staff on the Modern Slavery Act 2015 and informing them of the appropriate action to take if they suspect a case of slavery or human trafficking
  • ensuring that staff are appropriately trained to look out for signs of modern slavery when engaging with the stakeholders we regulate.
  • ensuring 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
  • ensure when undertaking review of relevant HR policies they include the consideration and prevention of risks of engagement of people or groups through Modern Slavery.
  • ensuring that staff involved in buying or procurement and the recruitment and deployment of workers receive training on modern slavery and ethical employment practices