How can I ensure the continuity of ongoing counseling when EAP is terminated or a provider is switched?

📌 First answer: The company does not hand over consultation records; instead, it creates 'options to prevent users from disconnecting.'

The continuity that HR must ensure when an EAP contract ends or the operator changes is not simply receiving individual counseling records and handing them over to the new provider. The key is To prevent the abrupt interruption of ongoing consultations, terminate the existing provider, reapply for a new provider, and, if necessary, transfer the minimum scope based on user consent. It is to decide in advance which path to use.

The Framework Act on Workers' Welfare mandates the guarantee of anonymity to prevent the infringement of workers' confidentiality during the operation of EAP, with exceptions made for cases where participating workers have consented to the disclosure of the subjects or content. Therefore, it is advisable to avoid the practice of a company collectively obtaining lists of counselees or counseling content in progress on the grounds of switching providers.

🔄 First, separate the conversion targets and timing.

🧭 The transition method can be designed in 3 ways.

🔐 Consultation details do not automatically transfer just because the provider changes.

Counseling content may include sensitive information such as health and psychological status. The Personal Information Protection Act defines health information as sensitive information and requires separate grounds for processing and safety measures. Furthermore, if the relationship between the company and the EAP provider constitutes a delegation of personal information processing, the delegation contract, management of the trustee, purpose of processing, and protective measures must be verified together.

Therefore, in the conversion process Contractual transfer of operational data and Transfer of individual counseling records It is important not to regard them as the same thing. While the company may hand over contracts, monthly reports, and campaign schedules, you must separately verify the counseling agency's record management standards, the basis for processing personal information, and whether user consent has been obtained regarding individual counseling records.

📋 What HR needs is the conversion status, not the 'individual consultation details'.

📅 Schedules to check starting 30 days before contract ends

1. D-30 — We finalize the transition principles for ongoing consultations, reservations, complaints, and crisis responses with existing companies.
2. D-21 — Tests the new company's application channel, counselor matching, consultation hours, and emergency route.
3. D-14 — Inform the staff of the vendor change date, options for handling existing consultations, and the new application method.
4. D-7 — Check if the paths for canceling/maintaining existing reservations, deferring termination, and reapplying for new vendors have actually opened.
5. Conversion date — We control the timing of the old channel closure and new channel opening so that they do not overlap, and we operate an inquiry window.
6. D+7~14 — Checks for connection failures, duplicate deductions, prolonged waiting times, and missing complaints at the operational data level.

💬 What must be included in employee notices?

What is important in the notice is not the fact that 'the company is changing' What the employee currently consulting can choose This shows the possibility of termination with the existing counselor, rematching with a new counselor, recognition of remaining sessions, new application channels, and contact points.

🧩 Please set separate criteria for remaining sessions.

🚨 Crisis and high-risk cases are not included in the general transition schedule.

Users identified as being in high-urgency situations, such as risks of self-harm or suicide, harm to others, or immediate safety threats, must not be processed through the general 'vendor change queue.' The existing operator's crisis response protocol, the new operator's acquisition timeline, and regional emergency routes must be verified separately.

Even in this case, rather than HR receiving and managing the entire detailed consultation content, ensure that necessary measures for user safety are not omitted Who is the responsible party and whether the transition is complete A structure that checks is good.

🗑️ What happens to the existing vendor's data after the contract ends?

The Personal Information Protection Act stipulates that personal information must be destroyed without delay once the retention period has expired or the purpose of processing has been achieved, and that if preservation is required under other laws, it must be stored and managed separately. Therefore, upon contract termination, rather than handling the matter uniformly as 'immediate deletion of all data' or 'unconditional return to the company,' Basis for retention, retention period, entity responsible for destruction, and return status by information type You must verify this in accordance with the contract and laws.

✅ Vendor Switching Continuity Checklist

❓ FAQ

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📚 Source and Verification Criteria

• Article 83 of the Framework Act on Labor Welfare (Worker Support Program)
• Article 55 of the Enforcement Decree of the Framework Act on Labor Welfare (Guarantee of Anonymity for Confidentiality)
• Article 23 of the Personal Information Protection Act (Restrictions on Processing Sensitive Information)
• Article 26 of the Personal Information Protection Act (Restrictions on the Processing of Personal Information Due to Outsourcing)
• Article 21 of the Personal Information Protection Act (Destruction of Personal Information)

This article is a general practical guide for verifying counseling continuity upon the termination of an EAP contract or a switch of service providers. The feasibility and method of transferring individual counseling records may vary depending on the counseling provider's record management standards, personal information processing structure, contract terms, user consent, and applicable laws. The method by which the company directly collects, stores, and transmits counseling content requires a separate review regarding confidentiality and personal information protection. Date of legal verification: September 22, 2026.