As a statutory organisation, the ICB has a number of legal obligations to our patients, members, public and regulators. Please click the relevant section below to find out more about each of these:

Information Governance (IG) is a framework that ensures personal and corporate information is dealt with legally, securely, efficiently and effectively to appropriate ethical and quality standards.

Information is a vital asset, both in terms of the clinical management of individual patients and the efficient organisation of services and resources. Black Country Integrated Care Board (ICB) aims to safeguard patient confidentiality and maintain data security whilst empowering staff within Black Country ICB to perform their role within the parameters of the good information governance.

IG is the way in which the NHS handles all of its information, in particular the personal and sensitive information relating to patients and employees.

Our IG team ensures all of these requirements are met by raising awareness about data protection, confidentiality and information security, and by performing audits to ensure standards are maintained.

It provides a framework to ensure that personal information is dealt with legally, securely, efficiently and effectively, in order to deliver the best possible care. 

It also offers Black Country ICB employees a clear structure to deal consistently with the many different rules about how information is handled, including those set out in the following policies and procedures:

  • Information Governance and Security Handbook
  • Acceptable Use Policy
  • Corporate Records Policy
  • Data Breach Policy and Procedure  
  • Data Protection and Confidentiality Policy  
  • FOI Policy
  • Subject Access Request Policy  
  • Information Governance Policy
  • Information Security Policy

Some of these policies are going through a harmonisation process and will be available in our publications scheme shortly.

Black Country Integrated Care Board Response to the Requirements of the Modern Slavery Act 2015

This statement comprises the slavery and human trafficking statement of Black Country Integrated Care Board (the organisation) in accordance with Section 54, Part 6 of the Modern Slavery Act 2015. The organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking and is absolutely committed to preventing slavery and human trafficking in its corporate activities.

Definition of Offences

Slavery, servitude and forced or compulsory labour.

A person commits an offence if:

  • The person holds another person in slavery or servitude and the circumstances are such that the person knows or ought to know that the other person is held in slavery or servitude, or;

  • The person requires another person to perform forced or compulsory labour and the circumstances are such that the person knows or ought to know that the other person is being required to perform forced or compulsory labour.

Human Trafficking

A person commits an offence if:

  • The person arranges or facilitates the travel of another person (victim) with a view to being exploited;

  • It is irrelevant whether the victim consents to travel and whether or not the victim is an adult or a child.


A person is exploited if one or more of the following issues are identified in relation to the victim:

  • Slavery, servitude, forced or compulsory labour;

  • Sexual exploitation;

  • Removal of organs;

  • Securing services by force, threats and deception;

  • Securing services from children, young people and vulnerable persons.

Organisational Structure

As an authorised statutory body, the ICB is the lead commissioner for health care services (including acute, community, mental health and primary care) across the  Black Country. The Membership, Governing Body, Executive Team and all employees are committed to ensuring that there is no modern slavery or human trafficking in any part of our business activity and in so far as is possible to holding our suppliers to account to do likewise.

Our approach

Our overall approach is governed by compliance with legislative and regulatory requirements and the maintenance and development of best practice in the fields of contracting and employment. The Black Country ICB recognises safeguarding as a high priority for the organisation. In order to achieve this we ensure that we have arrangements in place to provide strong leadership, vision and direction for safeguarding. We make sure we have clear accessible policies and procedures in line with relevant legislation, statutory guidance and best practice.

The organisational structure, business and supply chain

We have a clear line of accountability for safeguarding within the ICB The ICB’s Accountable Officer has ultimate accountability for ensuring that the health contribution to safeguarding and promoting the welfare of children and adults is discharged effectively across the whole health economy through commissioning arrangements. The Chief Nurse is the Governing Body executive lead for safeguarding and has responsibility for providing leadership and gaining assurance in relation to safeguarding issues within the ISB and locality. The ICB employs the expertise of Designated professionals for both children and adults. These roles are an integral part of the ISB’s activity and support the delivery of the safeguarding adult and children’s agenda.


The ICB ensures that organisations commissioned to provide services have appropriate systems that safeguard children in line with section 11 of the Children Act (2004), and adults in line The Mental Capacity Act 2005, The Care Act 2014 and The Modern Slavery Act 2015. With regards specifically to the Modern Slavery Act 2015, there is a specific question in our standard set in the pre-qualification questionnaire so that we can be assured of the approach of potential providers at the outset of procurement. In addition, the ICB’s contractual agreements (Standard NHS Contract) contain an obligation within clause SC1.2.2 for providers of services to ‘perform all of its obligations under the Contract in accordance with’:

  • the terms of this Contract; and

  • the Law; and

  • Good Practice’

Further, under SC32 Safety and Safeguarding there is a requirement upon all of our providers to have in place programmes for safeguarding and to co-operate with the Commissioner in pursuance of these.

The policies in relation to Slavery and Human Trafficking

Across the West Midlands there is a multi-agency policy and procedures for the protection of adults with care and support needs. This policy covers Modern Slavery and Trafficking. Across Wolverhampton. Organisations will report any concerns direct to the police or into adult safeguarding. Any concerns are directed to the police or into adult safeguarding.

The due diligence processes in relation to Slavery and Human Trafficking in its business and supply chains

The ICB is committed to ensuring that there is no Modern Slavery or Human Trafficking in our supply chains or in any part of our business. Safe recruitment principles are adhered to which includes strict requirements in respect of identity checks, work permits and criminal records. The pay structure is derived from national collective agreements and is based on equal pay principles with rates of pay that are nationally determined. Systems are in place to encourage the reporting of concerns and the protection of whistle blowers.

With regards to providers and supply chains, we expect these entities to have suitable anti-slavery and human trafficking policies and processes in place. We will use our routine contract management meetings with major providers to hold them explicitly to account for compliance with the Act and we will implement any relevant clauses contained within the Standard NHS Contract for 2019/20.

The ICBs Safeguarding team have developed a Children and Adults Safeguarding Dashboard and Assurance Reporting Framework that the ICB’s providers are expected to complete to ensure that they can themselves be assured that they have all measures in place but to also provide assurance to the ICB.

The parts of its business and supply chains where there is a risk of Slavery and Human Trafficking taking place, and the steps it has taken to assess and manage that risk

The ICB is committed to social and environmental responsibility and has zero tolerance for Modern Slavery and Human Trafficking. Any identified concerns regarding Modern Slavery and Human Trafficking would be escalated as part of the organisational safeguarding process and in conjunction with partner agencies; such as the Local Authority and Police.

The effectiveness in ensuring that Slavery and Human Trafficking is not taking place in its business or supply chains, measured against such performance indicators as it considers appropriate

The ICB aims to be as effective as possible in ensuring that modern slavery and Human Trafficking is not taking place in any part of our business or supply chains by:

i. Effective interagency working with local authorities, the police and third sector organisations which includes appropriate arrangements for preventing and responding to modern slavery and Human Trafficking;
ii. Signing up to the West Midlands multi-agency policy and procedures for the protection of adults with care and support needs;
iii. Undertaking robust NHS employment checks and payroll systems;
iv. Ensuring good communication through contract management meetings, with our commissioned providers in the supply chain and their understanding of, and compliance with, our expectations in relation to the NHS terms and conditions. These conditions relate to issues including bribery, slavery and other ethical considerations.
v. Requiring the ICB’s providers to complete the Assurance Reporting Framework as stated in IRSG 12 - 100% Compliance with Safeguarding Reporting Framework

Training about Slavery and Human Trafficking

Slavery and Human Trafficking is part of the organisation’s Mandatory Safeguarding Children and Adults training programme.

This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes our organisation’s modern slavery and human trafficking statement for the current financial year.

It is imperative that the ICB ensures complete transparency in our decision-making processes through robust record keeping. Any declaration of interest, and arrangements agreed, in any meeting of the ICB, its committees or sub-committees and Board should be recorded in the in the relevant minutes and can be found in the corporate register by going to: Black Country ICB (

See our Conflicts of Interest Policy. The Conflicts of Interest Guardian for the ICB is Alan Edwards, Non-Executive and Chair of Audit & Governance. The role of the COI Guardian is to:

  • Act as a conduit for members of the public and members of the partnership who have any concerns with regard to conflicts of interest.
  • Be a safe point of contact for employees or workers to raise any concerns in relation to conflicts of interest.
  • Support rigorous application of conflict-of-interest principles and policies.
  • Provide independent advice and judgement where there is any doubt about how to apply conflicts of interest policies and principles in an individual situation.
  • Provide advice on minimising the risks of conflicts of interest.

For any further information or to contact the GOI Guardian please email.

All decisions by the Integrated Care Board (ICB) on the provision or acceptance of gifts and hospitality must be able to withstand both internal and external scrutiny. Casual gifts or offers of hospitality by contractors or others must not be in any way connected with the performance of duties so as to constitute an offence under the Bribery Act 2010 or not comply with the requirements of the NHS England Statutory Guidance on Declarations of Interest.

The ICB has robust processes in place to ensure that individuals do not accept gifts or hospitality or other benefits, which might reasonably be seen to compromise their professional judgement or integrity.  The Conflicts of Interest Policy provides further detail.

The Gifts and Hospitality Register will be published quarterly.  Any questions please email

Organisations need to plan for, and respond to, different types of incidents and emergencies that could affect business functioning. These could be anything from extreme weather conditions to an outbreak of an infectious disease or a major transport accident. The 2022 Health and Care Bill amended the 2004 Civil Contingencies Act (CCA) to designate Integrated Care Boards (ICBs) as Category 1 responders when they are established on 1 July 2022.  The 2004 Act requires NHS organisations, and providers of NHS-funded care, to show that they can deal with such incidents, while maintaining normal services. This is referred to as emergency preparedness, resilience and response (EPRR).

Supporting the local emergency preparedness, resilience and response( EPRR) is a core duty for the Black Country Integrated Care Board to ensure we maintain our ability to deliver essential services during a major incident or emergency situation.

As a Category 1 responder, the ICB must:

  • Ensure we have emergency response plans in place
  • Ensure we have arrangements to make information available to the public and maintain arrangements to warn, inform and advise the public in the event of an emergency.
  • Share information with other local responders to enhance co-ordination
  • Co-operate with other local responders and partner agencies, through the Local Resilience Forum, to enhance co-ordination and efficiency.
  • Have robust business continuity management arrangements in place.

The board have delegated responsibility for approving the ICBs arrangements for business continuity and EPRR to the Chief Operations Officer (COO), Matt Hartland.  As COO, Matt is also the Accountable Emergency Officer (AEO) for EPRR. 

The ICBs EPRR Core Standards assurance rating is submitted to Board on an annual basis.

To ensure that appropriate oversight is in place there is an EPRR Sub-Committee meeting and Business Continuity Management Meeting in place which report into Audit & Governance Committee and then on to Governing Body.

Diagram showing reporting mechanism for EPRR 

The Black Country ICB has an EPRR Policy in place which outlines the responsibilities of the organisation in an emergency and also a Business Continuity Policy which are available to view below:

  • Click here to see the ICBs latest EPRR Policy.
  • Click here to see the ICBs latest Business Continuity Policy.

This Fair Processing/Privacy Notice reminds you of your rights under data protection legislation (this includes the European General Data Protection Legislation 2016 and the UK Data Protection Act 2018) and demonstrates that the ICB is committed to protecting your privacy when you use our services in order to meet our obligations as a ICB.

If you're an employee of the Black Country ICB, you can see the Staff Fair Processing/Privacy Notice here.

It also explains the choices you can make about the way in which your information is used and how you can opt-out of any sharing agreements that may be in place.

The Freedom of Information Act came into force in 2005. The Act applies to all public authorities with the aim to make information available to any person (individual, company or any other body) on request. A request must be made in writing (including email). There are a number of exemptions that maybe applied to withhold information that should not be disclosed. The FOIA is retrospective and therefore includes information that is held by a public authority prior to 2005.

The Environmental Information Regulations (EIR) were also implemented during 2005. Unlike the FOIA, an EIR request can be made verbally or in writing. There are exemptions that can be invoked to withhold the releasing of sensitive data.

Under the Freedom of Information Act any person may make a request for information and must be treated applicant and motive blind. The organisation has up to 20 working days to respond to the request.

The Black Country ICB FOI policy is available in our publications scheme.     

Our disclosure log is also contained in our publications scheme. Here, you can view responses to previous FOIA requests. Before you submit a new request, you may wish to view the disclosure log to see if the information is already available.

Main Features of the Act

A general right of access from the 1 January 2005 (subject to certain conditions and exemptions) to all information held in recorded form

To inform the applicant if the information is held

To adopt a publication scheme

Submitting a request

To submit a Freedom of Information request you can either send it in writing to Black Country Integrated Care Board, Governance Team Civic Centre, St. Peter's Square, Wolverhampton WV1 1SH or email:


Data Protection Legislation; General Data Protection Regulations and Data Protection Act 2018 gives individuals the right, or their authorised representative, the right to apply to access their personal data that an organisation holds about them.

Individuals have the right to access their personal data as well as the right to obtain confirmation that BC-ICB are processing their personal data and other supplementary information. This is commonly referred to as subject access. Individuals are able to make a subject access request verbally or in writing, in which organisations have one calendar month to respond and, in most circumstances, cannot charge a fee.

Access To Health Records Act 1990

The Access to Health Records Act 1990 provides a right for authorised people to apply to access information contained within a deceased person’s health record.

Who Can Make a Request

Subject Access Requests – General Data Protection Regulation

Subject Access Requests can be made by:

  • The individual themselves
  • Those who have parental responsibility (if requesting a child’s record)
  • A representative nominated by the individual to act on their behalf such as solicitors or a relative. In these circumstances, valid consent by the individual granting the authority must accompany the application
  • In certain situations, a person granted an attorney or agent by the Court of Protection on behalf of an adult who is capable of consent
  • The Police 
  • A solicitor acting on behalf of the individual (if the claim is or likely to be against the Trust it should be treated no differently)
  • Via a Court Order

*Note requests made under these circumstances must have the appropriate identification documentation to support the application for access.

In order to be able to comply with a request, you will be asked to provide the following information: 

  • Full name
  • Address
  • Date of birth
  • Scope of information you are looking for, including the time period that the information is from.

Requests made under Access to Health Records Act 1990 for deceased person’s records

Requests made under the Access to Health Records Act 1990 can be requested by:

  • The patient’s personal representative - a personal representative is the executor or administrator of the deceased person’s estate.
  • Any person who may have a claim arising out of the patient’s death.

Where to send a SAR/Access to Health Records request

Requests can be made in writing to or forwarded for processing to:

  • Applications by email:
  • Applications by post: Black Country Integrated Care Board, Civic Centre, St Peters Square, Wolverhampton, WV1 1SH.


If the applicant is dissatisfied with the information provided or the manner the request has been handled by the BC-ICB, they are entitled to complain following the BC ICB complaints procedure.

Complaints should be forwarded to:

If the applicant is still dissatisfied once the complaints process is completed, they are entitled to make a complaint to the Information Commissioners Office (ICO).

The Information Commissioner’s Office
Wycliffe House
Water Lane
Telephone: 0303 123 1113


Privacy by Design

Privacy by design is an approach to projects that promotes privacy and data protection compliance from the start. The UK General Data Protection Regulation (GDPR) confirms that privacy must be designed into the processing of personal data by default.  This ‘privacy by design’ concept is not new and for many years has been recommended by the Information Commissioner’s Office (ICO).

It is important for us to ensure that privacy and data protection is a key consideration in the early stages of a new project, and then throughout is life cycle.  For example when:

  • Commissioning services where data access or sharing is required
  • Developing databases for storing or accessing data
  • Developing policies or strategies that have privacy implications
  • Embarking on a data-sharing initiative; or
  • Using data for new purposes

Using the privacy by design approach is an essential tool in minimising privacy risks and building trust. Designing projects, processes, products or systems with privacy in mind at the outset can lead to benefits which include:

  • Identifying potential problems at an early stage, when addressing them will often be simpler and less costly
  • Increasing awareness of privacy and data protection across the ICB
  • We are more likely to meet the legal obligations and reduce breaches of the Data Protection Act 2018
  • Actions are less likely to be privacy intrusive and have a negative impact on individuals

Data Protection Impact Assessments

A Data Protection Impact Assessment (DPIA) is a process designed to help the organisation identify and minimise the data protection risks of a project and are a legal requirement for processing that is likely to result in a high risk to individuals. It is a key part of our accountability obligations under the UK GDPR, and helps the organisation assess and demonstrate how we comply with all of our data protection obligations.

If you require a copy of a DPIA, these can be requested under the Freedom of Information Act 2000. Please email


NHS Workforce Race Equality Standard

The NHS Workforce Race Equality Standard (WRES) was introduced in 2015 to focus national and local effort in ensuring staff from black and minority ethnic backgrounds have equal access to career opportunities and receive fair treatment in the workplace.

The WRES prompts inquiry and assists participating organisations to develop and implement evidence based responses to the challenges their data reveals.

The WRES requires a self-assessment against nine indicators. Four of the indicators relate specifically to workforce data; four are based on data from the national NHS Staff Survey questions; and one considers BAME (Black, Asian and Minority Ethnic) representation on boards.

We have two roles in relation to the WRES – as commissioners of NHS services and as employers. Since April 2015 the WRES has been included in the NHS standard contract, with trusts producing and publishing their WRES results on an annual basis. In addition to the NHS standard contract, the Improvement and Assessment Framework also requires ICBs to give assurance to NHS England that their providers are implementing and using the WRES.

ICBs are required to commit to the principles of the WRES and apply as much of it as possible to their own workforce. This information will be published in our annual reports.

More information on WRES is available on the NHS England webpages via this link and you can view these videos which explain more about the purpose and value of the work.

The Equality Delivery System (EDS) is an improvement tool to help us review and develop our approach in addressing health inequalities through three domains:

  • Services we provide,
  • Workforce health and wellbeing
  • Inclusive leadership

Domain 1: Services we provide

This assessment includes two reports:

Domain 2: Workforce health and wellbeing

The health of our NHS workforce is critical. This assessment recognises our staff are also our patients. This report is expected in October 2024.

Domain 3: Inclusive leadership

This assessment (expected October 2024) gauges how far the ICB Board members, system, and senior leaders;

  • routinely demonstrate their understanding of, and commitment to, equality and health inequalities
  • identify equality and health inequalities related impacts and risks and how they will be mitigated and managed
  • ensure levers are in place to manage performance and monitor progress with staff and patients.

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