Are dressing books compliant with data protection?

In many companies, the so-called first-aid book can be found near the first-aid box. This contains forms that are filled out as soon as an employee suffers an injury of any kind. The name of the person affected and of the person providing assistance, as well as the nature of the injury and the assistance provided, are entered there. If you scroll back through the first-aid book, you can review all past incidents with all the data mentioned.

It is questionable whether this open availability of personal data is data protection compliant.

Personal data concerned

It is indisputable that the register of associations contains names and similar information. personal data and is therefore subject to the protection of the GDPR. In addition, the listing of injuries and their treatment also affects health data. These are subject to Art. 9 GDPR as personal data special category require special protection. This data must therefore never be stored in a form that is openly accessible.

Documentation obligation for first aid measures

However, the first-aid book also has a purpose: the forms in the book are intended to fulfill the obligation to document first-aid measures. This is prescribed by the German Social Accident Insurance (DGUV) in Section 24 (6) of DGUV Regulation 1. These regulations must be complied with in companies.

Data protection compliant solution

In order to document the incidents without violating data protection law, it is a good idea to keep the first-aid book as a "first-aid pad" so that the written page can be detached and stored safely and only the blank pad is ever kept in the first-aid box. The completed sheets can then be forwarded directly to the employee responsible for safekeeping, or they can be deposited in a locked mailbox that is emptied regularly by the employee responsible.

Such a "dressing block" can be purchased, for example, from the DGUV.

Alternatively, the individual pages can also be printed out on the DGUV website as required in individual cases.