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 complies with data protection requirements.
Personal data concerned
It is undisputed that the dressing book contains personal data through the listing of names and the like and is therefore subject to the protection of the GDPR. In addition, health data are also affected by the listing of injuries and their treatment. These are subject to special protection as personal data of a special category under Article 9 of the GDPR. Therefore, this data may not be kept openly accessible in any case.
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.