GDPR: Model health and safety documents updated

We have revised our model health and safety documents to comply with the General Data Protection Regulation (GDPR), which is in force from 25 May 2018.

What other model documents have been updated for the GDPR?

We have previously revised our model documents in these areas:

Look out in the coming weeks for more updates to our model policies and documents to make them GDPR-compliant.

The introduction of the GDPR means that employers should review their documentation to ensure that: data protection and privacy considerations are embedded; only the minimum amount of personal data is collected and processed for a specific purpose; there is a legal basis for processing personal data; and individuals whose personal data is being processed are provided with privacy notices.

Health and safety procedures often require employers to gather "health data", which falls within the special categories of personal data under the GDPR. For example, employers could be handling health data when carrying out risk assessments and hazard identifications, accident investigations, equipment checks and other common health-related tasks, such as organising eye and eyesight tests for DSE users.

Health data could also be processed under other health and safety policies, including those related to stress management, violence at work, first aid, safety induction training, infectious diseases and employee wellbeing.

There are some specific issues for employers when they have to put their trust in external organisations to handle data on their employees, for example alcohol and drug testing companies and employee assistance programme (EAP) providers.

We have therefore updated the following model health and safety documents to take account of the GDPR:

Employee health and wellbeing

Risk management

Health and safety induction training

Vulnerable workers

Accidents and incidents

Alcohol and drugs

Infectious diseases

Machinery and equipment

Display screen equipment

First aid

Hazardous substances

Manual handling

Personal protective equipment