Hi guys,

My boss (H&S group manager) has just published our first set of accident stats and he has left the individuals names on them for the various accidents across all our sites and departments.

Is this normal practice? our should they really be removed as part of data protection etc...

I must admit that in the past i have never published the names only the accident but just needed to clarify as someone has pointed it out to me on managers meeting.

All help and guidance greatly appreciated.

thanks

Paul

I always anonymise all accident reporting that goes to more than a specific individual for a specific purpose.

This includes making the text gender-neutral unless it is substantially impossible to do so without losing facts (for example - when a toilet cubicle door fell off its hinges and struck someone, the report identified which cubicle, which sufficiently strongly implies the sex of the person struck that I left it referring to 'he' etc.)

I don't think there is an issue from a data protection point of view if the details just stay within the company.

I was at the annual BSI awards once and there was a guy doing a talk on the same kind of thing. His view was that we SHOULD keep the names of employees on accident stats/ reports etc.. Otherwise the injured person simple becomes just another number...

Is it not better to include the persons name? Then other employees may sympathise, associate etc with the event on a more personal level. Especially if they know or work with the injured person.

And maybe then this can help improve the general safety culture of the business

Data Protection Act doesn't have any get-outs for merely keeping the data within the company - it applies to whatever a data processor does with the data, not just whether they distribute it externally.

I would think you could advance a case that the injured party did not provide their name in order for it to be circulated widely, and I don't see why it is necessary for it to be circulated widely, so I would argue that principle 2 may be breached. I note that the 'personal data for staff administration' exemption is an exemption only on whether you need to register, not on what you can legally do with the data, so that is not relevant to the question (not that it has been raised yet, but it often is in such discussions).

We certainly do KEEP the names of every individual who has had an injury at work. What the question related to, however, was publishing and circulating those names. We keep the records of the incident and the investigation under lock and key. We anonymise anything circulated to multiple people.

It depends upon the detailed/written procedure you may have ( or not have!) for accident investigations and compilation of reports/statistics for wider distribution/publicising.

The primary purpose of most accident investigations at company level is to prevent a recurence and not to allocate "blame"/"fault".

Although we have names ( not addresses) in our in-house "Event" reporting formats, it is kept confidential to only those involved, i.e. the investigator, line manager, safety rep & HSE Advisor etc.

I publish an anonymised summary regularly for wider distribution.

It is our policy not to name the individual.

Obviously, for most "events", other employees will know about who was actually involved.

My professional view is that for routine investigations and cmpilation of statistics, names shoul not be included as it can have a detrimental effect on the overall reporting culture. Also, just because an individual has an accident does not necessarily mean it was their "fault".