First Aid and GDPR

[RobB]

Hi,

Does anyone let their first aiders know if someone has any significant medical conditions that may be relevant, eg diabetes or epilepsy.

If so how do you do it, especially with GDPR. Obviously any information passed on would only be with the person's permission, but how would we pass the information on etc.

Any suggestions

[EagleBeagle]

Data concerning health is classed as (and has always been) special category data which requires that in order to process it (i.e. provide it to first aiders or for any other processing) you must have explicit consent from the individual data subject. The best way of recording this consent would be in writing to meet the "explicit" requirement.

It sounds like you have a lawful basis (Article 6) of consent for processing of the data, and also can meet the second test of explicit consent for one or more specified purpose (Article 9.2.a). Also if the person publishes or otherwise makes known their condition publicly (i.e. wearing a medical alert bracelet) the second test would not apply (Article 9.2.e).

In practical terms to comply with Article 5, if you wanted to go down this road it would have to be something which was only accessible to first aiders which is not capable of being lost or easily accessed by a third party (i.e. it should be encrypted if electronic format, etc.).

Others might be able to suggest if there's solutions out there, software, apps, etc. that would also allow a level of portability.

[RobB]

It's the more practical side of communicating the info that concerns me most. I am not too worried directly about GDPR as the individuals would have agreed to pass on the info so I doubt there would be any come back.

For example we have an employee with a known heart problem that lots of people are aware of

We are a largish (200 +) employees, so not all the first aiders know everyone, and may not be aware he has a heart problem.
If the recent hot weather in the foundry, he felt faint, the first aider was not aware of his history, so sat him down in the cool. Others were aware of the heart issue so we played it safe and took him to A&E. (It wasn't heart or heat as it happened).

My problems are

If we verbally informed the first aiders, they may forget, or they may not know the name of the person and recognize the patient as being the one with the medical condition.

If we put information in the first aid room, they don't always treat people in there, and may not go in until the event is over, to fill the accident book in.
In a previous company, it was easier, only about 35 people and 2 first aiders. Everyone knew each other, 1 first aid kit, so I asked people to fill a form in with any info they may wish the first aider or emergency services to know in an emergency. Sealed it in an envelope and put them in the first aid kit. There were only about 2 envelopes.

I just cant think of a simple way of ensuring info is passed on reliably.

Rob

[EagleBeagle]

From a first aid point of view, I think that if a SAMPLE history is taken during the incident most of these medical issues would come out either from the patient or from third parties who know them. I suppose that's been my experience both in the workplace and out as a volunteer with St. John Ambulance dealing with complete strangers at events.

The closest I've seen (but I think it's way above your requirements) are encrypted iPad-type tablets used for patient care reporting with a searchable index of previous reports for that patient available, but that doesn't solve the problem where there are no incidents. Perhaps there is something like this available that is secure for business use that can contain notes relevant to the division/floor a person with a condition works in.

My experience would be in smaller workplaces so it always would always have been like your own so I'd have to defer to anyone else here who may have practical experiences of managing this in a larger workplace if it has came up as an issue.