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:
- Family-friendly rights
- Right to request flexible working
- Time off work
- Disciplinary procedures
- Grievance procedures
- Underperformance procedures
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
- Employee wellbeing policy
- Stress at work policy and procedure
- Policy setting out an employee assistance programme
- Policy on domestic violence
- Hazard identification and risk assessment policy and procedure
- Lone working policy and procedure
- Young person risk assessment form
- Night work health assessment record
Health and safety induction training
Accidents and incidents
Alcohol and drugs
Machinery and equipment
Display screen equipment
- Display screen equipment policy and procedure
- Eye and eyesight testing policy
- Display screen equipment assessment record
- Form for an employee to request an eye and eyesight test
- Authorisation letter confirming arrangements for an eye and eyesight test
- Control of substances hazardous to health policy and procedure
- Control of substances hazardous to health assessment record
- Control of asbestos policy and procedure