References: Previously undisclosed complaints in reference gave rise to constructive dismissal

Providing an employee's prospective employer with a reference that revealed several complaints made about the employee, of which she had been unaware, constituted a breach by her employer of the implied term of trust and confidence in her contract of employment, holds the EAT in TSB Bank plc v Harris [2000] IRLR 157. The employer had wrongly used the minimum requirements for regulatory purposes as a model for a balanced and fair reference on behalf of an existing employee.