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Anonymous
Is this change a "recommendation" or is it really mandatory? If the latter I have to arrange to change about 200 yellow accident books around the business by December at a cost of £4.75 each plus VAT. Old accident books, which have to be kept for a minimum of three years, can still be referred to - what does the Data Protection Act suggest we do about that?
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Anonymous
The new accident books also means that to collate the information the Health & Safety Manager/Safety Rep has to requesting the Accident Record when completed be sent to him by the employee or the first aider so that the information can be used in the statical information required for any improvement process.
The record must then be sent to HR for placing into the employee personel file. it then must become the responsibility of the HR department to report under the RIDFDOR regs to the HSE.
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Anonymous
It is my understanding that the situation in regard to 'Accident Books' was brought to the Commissioner's attention sometime ago. The standard printed Accident Book was apparently developed before the advent of data protection legislation and therefore the security or disclosure of personal data and the related issues may not have been considered at the time.
I confess to not having seen the new book, but understand that the changes effectively were the addition of perforated pages and suitable advice as to the safe keeping and retention of the personal information by a suitable individual/ department.
The recommendation to change the books used is to prevent continued breach of the DPA - if personal data is currently available for any employee to see, then the organisation may already be in breach. As such, this is not a new rule, simply guidance on how the DPA is likely to be interpreted in this particular scenario. At any time, any issues brought to the Commissioner's attention by individuals adversely affected in some way by current practices will be considered and assessed accordingly by his office.
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