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If the harassment counselor wishes to file anonymously, would it be acceptable to assign only a case number?
Unknown User
2026.09.10 13:46
https://nudgeeap.com/en-US/community/inquiry/135370860
Hello. We operate a workplace harassment counseling service at a company with approximately 500 employees.
Recently, a caller requested that a record of the call be kept so that they could contact us again regarding the same matter, even though they did not wish to reveal their name and affiliation at the moment. Previously, anonymous consultations were recorded only with the date and department, but when multiple similar consultations were received, it was difficult to distinguish whether they were follow-up contacts from the same person.
We are currently reviewing a plan to assign case numbers instead of names and instruct counselors to keep the numbers, while keeping only the filing date, contact channel, key issues, whether immediate protection is required, and the next contact method in internal records. However, we are concerned about whether it is possible to verify the facts necessary to initiate an investigation or take protective measures using only the case number, and how to verify identity if the number is lost.
Is it acceptable to assign only a case number during the anonymous consultation stage? I would like to know the information that needs to be verified when the case is converted to an official report, how to separate consultation and investigation records, and how to determine the access rights and retention standards for case numbers.
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Dain Co., Ltd.Dain Co., Ltd.107 Answers1% Answer adoption rateSpecializes in Health Management, psychological counseling- Unknown User1
- Dain Co., Ltd.Dain Co., Ltd.107 Answers1% Answer adoption rateSpecializes in Health Management, psychological counseling
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- 01CommentsI think it would be a good idea to use the agency's video materials as the basis and show only our on-site photos separately. If we take them ourselves, we have to retake them every time we make corrections.82226.11.04
- 02coach AnswerHello, this is Nudge EAP โบ๏ธ I imagine you must have had a hard time organizing this year's remaining tasks and next year's budget at the end of the year. Organizing remaining tasks becomes much easier if you divide them into three categories: 'Tasks to finish this year / Tasks carrying over to next year / New tasks for next year.' This also helps reduce instances where the same costs are incurred twice or omitted. For training, it is better to rely on the list of actual completions rather than the list of applicants. Separating those who will receive supplementary training this year from those targeted for next year's training will keep your reporting neat and tidy. For improvement items awaiting a quote, first check if they can be executed within the year. If the amount has not yet been determined, you can write 'Quote under review' instead of 0 won. Please prioritize safety measures needed immediately on-site, separate from the budget. In the report form, try listing the category, amount (or status), supporting documents, person in charge, and scheduled date for each item on a single line. For EAP performance data, separate the number of users and counseling sessions, and it is best to omit any information that could identify individuals. **Nudge EAP Performance** There is also a table in the post below that you can use when organizing, so please refer to it as well. https://nudgeeap.com/community/mandatory-training/137579262 https://nudgeeap.com/community/eap/137579952 If you have any questions while preparing, please feel free to leave a comment anytime ๐172226.11.02
- 03CommentsI think it would be easier to compare quotes if you start by deciding whether to support only employees or include their families as well.42226.11.04
- 01coach AnswerHello, this is Nudge EAP โบ๏ธ Rather than excluding all dispatched workers from vaccination support simply because they are dispatched employees, it is better to first check the criteria used to provide support to employees performing similar tasks at the same site. Article 21 of the Dispatched Workers Act prohibits discrimination against dispatched workers compared to employees performing the same or similar duties at the user employer, and discriminatory treatment includes matters regarding welfare benefits (Article 2, Clause 7 of the Dispatched Workers Act; Article 2, Clause 3 of the Fixed-Term Employment Act). However, this does not apply if the user employer employs four or fewer workers on a regular basis, and since judgments may vary depending on the employees being compared and the support conditions, it is difficult to conclude that "the same support must be provided to all dispatched workers unconditionally." - Eligibility: Please first organize the eligibility criteria and reasons for exclusion so that the user employer and the dispatching company can provide guidance based on the same standards. You should review company-mandated welfare support and statutory health checkups separately. - Costs: We were unable to find any criteria regarding the sharing of vaccination costsโsuch as which company must bear the full cost or split the ratioโwithin the scope of this review. After verifying the dispatch contract and welfare standards, ensure that both companies agree on the party responsible for the costs, the settlement method, and the application deadline before vaccination. - Lists and Consent Forms: It is advisable for the company to verify only the minimum information necessary for application and cost settlement, and to negotiate with the vaccination hospital to have them directly collect pre-examination forms, chronic illnesses, and medications. Since health information is sensitive data under Article 23 of the Personal Information Protection Act, requiring separate consent or a legal basis, do not hand over original vaccination-related documents to the dispatch agency. - Post-Vaccination Inquiries: Provide the contact information for the vaccination hospital and medical staff in advance, and designate a joint contact person for both the company and the dispatch agency. It is difficult to prematurely assume that one company bears full responsibility simply because an adverse reaction occurred, and in emergency situations, emergency response services such as 119 take priority. In practice, confusion is reduced if both companies and the hospital first agree on four pointsโeligibility, costs, where information is received, and post-vaccination contact informationโand then provide the same notice to the employees. Reference: https://www.law.go.kr/๋ฒ๋ น/ํ๊ฒฌ๊ณต๋ก์๋ณด๋ฑ์๊ดํ๋ฒ๋ฅ /์ 21์กฐ162226.10.29
- 02coach AnswerHello, this is Nudge EAP โบ๏ธ There is no confirmed law mandating that a health manager must accompany a patient to the emergency room. According to Article 12, Paragraph 6 of the Enforcement Decree of the 119 Rescue and Emergency Medical Services Act, ambulance passengers are only permitted to be requested from guardians or others when necessary, and who rides in the ambulance is determined by the paramedics' instructions at the scene. It is appropriate to revise the wording, as there is currently a gap in service during nighttime shifts. - Accompanying: It is common practice for a colleague or supervisor who witnesses the collapse to go to the scene, while the health manager remains at the scene. What medical staff need is not a job title, but someone who can accurately convey 'when and during what work the patient collapsed, and what was done at the scene.' - Assignment by Shift: Please list the names of those responsible for treatment, calling 119, and accompanying, as well as their substitutes, for each day, night, and weekend shift. It is recommended to specify that the person who discovers the patient should call 119 immediately, without waiting for a report from the health manager (Article 5 of the Emergency Medical Services Act). ** - Contacting Family: HR handles this, and if you establish a procedure where the accompanying staff contacts HR first upon arrival at the hospital, you can reduce confusion where the company and the ambulance crew contact the family separately. - Chronic Conditions/Medications: Health information is considered sensitive information under Article 23 of the Personal Information Protection Act, so we must be cautious about sharing it without the individual's consent simply because the company knows it. If an employee with a chronic condition wishes, we recommend obtaining separate prior consent for "information that may be shared with medical staff in an emergency." - Post-Injury Reporting: The reporting obligation lies with the employer, and the health manager's role is to assist with the investigation of the cause and documentation. For serious accidents, you must submit the Industrial Accident Investigation Report (Article 73 of the Enforcement Rule) without delay (Article 54 of the Act), and if an employee is absent from work for three days or more due to an industrial accident, you must submit it within one month. However, if the illness is a personal condition unrelated to work, it may not be subject to statutory reporting, so you can focus on keeping internal records. Please also provide information on EAP counseling to colleagues who witnessed the collapse. I have summarized the role assignments by shift, companion cards, and an Excel spreadsheet for quickly checking reporting targets and deadlines in the posts below. https://nudgeeap.com/community/serious-accidents-act/137507346 https://nudgeeap.com/community/serious-accidents-act/137510596192226.10.28
- 03coach AnswerHello, this is Nudge EAP โบ๏ธ Yes, the correct approach is to group reports by management type rather than by disease name. Health information is considered sensitive information under Article 23 of the Personal Information Protection Act, and Article 3 of the same Act stipulates that information should be processed anonymously if the purpose can be achieved even without anonymity. Article 132, Paragraph 3 of the Occupational Safety and Health Act also prohibits the use of health examination results for purposes other than the protection and maintenance of workers' health. If "1 person with hypertension" appears in a team of three, the individual can be identified even without a name, which effectively amounts to reporting personal health information. - Monthly Report: It is sufficient to include the number of personnel, consultations, and referrals by management type, such as continuous management, follow-up observation, or referral to external medical institutions. The Ministry of Employment and Labor's "Workplace Health Management Manual" also provides an example of aggregating records from the health management office by reason for visit. - Department Classification: There is no need to eliminate it entirely; you can simply group departments with fewer personnel into larger units like "Factory" or "Headquarters" to display them. There is no legal standard regarding the number of people below which records must be combined, so the company is free to determine this. However, I recommend documenting these standards, such as "combining departments with fewer than 10 people" and marking columns with fewer than 3 cases as '<3'." Since covering just one column allows one to subtract it from the total to determine the number, please cover those columns as well. - Numbers by Disease: If the goal is next year's health promotion plan, a company-wide annual tally is more appropriate than monthly figures by department. Group only items with sufficient case counts into disease groups and provide them separately as data for planning purposes. If you record only the management type in the monthly report, the standards will remain consistent even if the same requests are repeated. - Original Consultation Logs: It is appropriate to keep the original documents containing disease names and blood pressure readings separately from the reports so that only the health office can view them. Since there is no statutory retention period for consultation records themselves, you must establish internal standards. However, health examination results are retained for 5 years (Article 241 of the Enforcement Rules of the Occupational Safety and Health Act), so keeping the two records in different folders will prevent confusion. I have summarized the methods for sharing consultation logs, department head opinions, and management reports, as well as a monthly report Excel file where small cells are automatically hidden when a management type is entered, in the post below. https://nudgeeap.com/community/privacy-pension/137475052 https://nudgeeap.com/community/privacy-pension/137475098223326.10.27
- 01coach AnswerHello, this is Nudge EAP โบ๏ธ Yes, the available time slots for evening and weekend appointments, as well as the time it takes from application to the first consultation, are materials you may request during the proposal stage. If your workplace has nearly half of its employees working shifts, I highly recommend obtaining this information. However, it is better to look at the number of counselors and centers together rather than excluding them. For evening and weekend appointments to open, there must be a sufficient number of counselors available during those times, and employees' ability to choose a counselor or a nearby center ultimately stems from the scale of the counselors and centers. Instead of just receiving the numbers, if you change your approach to asking "how that scale connects to the time, location, and method our employees prefer," comparisons will become much easier. - Time Slot: Number of counselors available during weekday evenings (e.g., after 6 PM) and weekends, operating days and hours - Region/Method: Centers near the logistics center where in-person consultations are available, and whether employees can choose between phone and video consultations - Waiting Period: Time taken from application to the first consultation (including the average and whether most were assigned within a few days), and the percentage of appointments made for the desired time slot - Options: Procedure for requesting a counselor change, and whether employees can select the counselor's gender or area of โโexpertise Since these items can be aggregated if there are records of consultation applications and assignments, it is perfectly fine to request them. It is best to receive data based on operating performance over the past 6 months to 1 year, as this minimizes seasonal variations, making comparisons easier. Since aggregation standards may vary by company, please request the data in a consistent format and verify whether the data is based on all client companies or those of similar size and industry. I recommend requesting that waiting periods and usage status by time slot be included as the same item in the quarterly reports so that they can be checked even after the contract is signed. You should receive the data in an aggregate format that does not allow for individual identification. Please also refer to the previous inquiry post covering counselor assignment criteria, and the post summarizing the deliverables you should receive when outsourcing EAP. https://nudgeeap.com/community/inquiry/135899627 https://nudgeeap.com/community/eap/137430505294526.10.26
- 02coach AnswerHello, this is Nudge EAP โบ๏ธ Yes, the correct approach is to group reports by management type rather than by disease name. Health information is considered sensitive information under Article 23 of the Personal Information Protection Act, and Article 3 of the same Act stipulates that information should be processed anonymously if the purpose can be achieved even without anonymity. Article 132, Paragraph 3 of the Occupational Safety and Health Act also prohibits the use of health examination results for purposes other than the protection and maintenance of workers' health. If "1 person with hypertension" appears in a team of three, the individual can be identified even without a name, which effectively amounts to reporting personal health information. - Monthly Report: It is sufficient to include the number of personnel, consultations, and referrals by management type, such as continuous management, follow-up observation, or referral to external medical institutions. The Ministry of Employment and Labor's "Workplace Health Management Manual" also provides an example of aggregating records from the health management office by reason for visit. - Department Classification: There is no need to eliminate it entirely; you can simply group departments with fewer personnel into larger units like "Factory" or "Headquarters" to display them. There is no legal standard regarding the number of people below which records must be combined, so the company is free to determine this. However, I recommend documenting these standards, such as "combining departments with fewer than 10 people" and marking columns with fewer than 3 cases as '<3'." Since covering just one column allows one to subtract it from the total to determine the number, please cover those columns as well. - Numbers by Disease: If the goal is next year's health promotion plan, a company-wide annual tally is more appropriate than monthly figures by department. Group only items with sufficient case counts into disease groups and provide them separately as data for planning purposes. If you record only the management type in the monthly report, the standards will remain consistent even if the same requests are repeated. - Original Consultation Logs: It is appropriate to keep the original documents containing disease names and blood pressure readings separately from the reports so that only the health office can view them. Since there is no statutory retention period for consultation records themselves, you must establish internal standards. However, health examination results are retained for 5 years (Article 241 of the Enforcement Rules of the Occupational Safety and Health Act), so keeping the two records in different folders will prevent confusion. I have summarized the methods for sharing consultation logs, department head opinions, and management reports, as well as a monthly report Excel file where small cells are automatically hidden when a management type is entered, in the post below. https://nudgeeap.com/community/privacy-pension/137475052 https://nudgeeap.com/community/privacy-pension/137475098223326.10.27
- 03coach AnswerHello, this is Nudge EAP โบ๏ธ Rather than excluding all dispatched workers from vaccination support simply because they are dispatched employees, it is better to first check the criteria used to provide support to employees performing similar tasks at the same site. Article 21 of the Dispatched Workers Act prohibits discrimination against dispatched workers compared to employees performing the same or similar duties at the user employer, and discriminatory treatment includes matters regarding welfare benefits (Article 2, Clause 7 of the Dispatched Workers Act; Article 2, Clause 3 of the Fixed-Term Employment Act). However, this does not apply if the user employer employs four or fewer workers on a regular basis, and since judgments may vary depending on the employees being compared and the support conditions, it is difficult to conclude that "the same support must be provided to all dispatched workers unconditionally." - Eligibility: Please first organize the eligibility criteria and reasons for exclusion so that the user employer and the dispatching company can provide guidance based on the same standards. You should review company-mandated welfare support and statutory health checkups separately. - Costs: We were unable to find any criteria regarding the sharing of vaccination costsโsuch as which company must bear the full cost or split the ratioโwithin the scope of this review. After verifying the dispatch contract and welfare standards, ensure that both companies agree on the party responsible for the costs, the settlement method, and the application deadline before vaccination. - Lists and Consent Forms: It is advisable for the company to verify only the minimum information necessary for application and cost settlement, and to negotiate with the vaccination hospital to have them directly collect pre-examination forms, chronic illnesses, and medications. Since health information is sensitive data under Article 23 of the Personal Information Protection Act, requiring separate consent or a legal basis, do not hand over original vaccination-related documents to the dispatch agency. - Post-Vaccination Inquiries: Provide the contact information for the vaccination hospital and medical staff in advance, and designate a joint contact person for both the company and the dispatch agency. It is difficult to prematurely assume that one company bears full responsibility simply because an adverse reaction occurred, and in emergency situations, emergency response services such as 119 take priority. In practice, confusion is reduced if both companies and the hospital first agree on four pointsโeligibility, costs, where information is received, and post-vaccination contact informationโand then provide the same notice to the employees. Reference: https://www.law.go.kr/๋ฒ๋ น/ํ๊ฒฌ๊ณต๋ก์๋ณด๋ฑ์๊ดํ๋ฒ๋ฅ /์ 21์กฐ162226.10.29
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