Health Manager Health Consultation Records | How Much Medical Information Should Be Used and To Whom Should It Be Reported To?

📥 View Information Item Table · Monthly Report Excel

🩺 Is it okay to write the name of the disease and blood pressure levels in the consultation log?

For example, during a follow-up consultation for a health checkup, the blood pressure was recorded as 158/96, and the employee states that they stopped taking medication three months ago. The health manager records this information and schedules a re-measurement for two weeks later. This record itself is not a problem.

Article 22, Paragraph 1 of the Enforcement Decree of the Occupational Safety and Health Act defines the duties of health managers. Although the term "health counseling" does not appear explicitly, it includes duties stipulated in employment rules, etc. (Clause 1), and health managers who are doctors or nurses. Guidance and management of medical care for patients with diseases discovered through health examinations (Article 7, Subparagraph (d), Recording and maintenance of work performance (No. 13) is included. This means that counseling and recording are within the duties of the health manager.

The problem is 'how' little there is. Information regarding health Article 23 of the Personal Information Protection Act It is sensitive information, and Article 3 of the same Act is necessary for the purpose Minimal information It is decided to collect only [specific information]. There is a response from the Ministry of Employment and Labor stating that since it is a legal obligation for employers to receive result reports from health examination institutions, separate consent is not required (Industrial Health Division-2568, June 11, 2021). On the other hand, medication history, family history, and lifestyle stories heard anew during a consultation are different. It is safer to inform the client before the consultation what will be recorded and to what extent will be shared, and to obtain their consent.

There is a reason for excluding diagnostic estimation. The Ministry of Employment and Labor's "2026 Workplace Health Management Manual" states that while nurse health managers can measure blood pressure and blood sugar, provide guidance on normal, caution, and risk ranges, and advise visiting a medical institution, Acts of determining the presence or absence of disease, predicting the risk of occurrence, or determining treatment methods cannot be performed. This is an announcement (Industrial Health Policy Division-1206, March 11, 2026). For health managers who are not medical professionals, the scope is limited to simple verification of health examination results, collection of data based on individual consent, and guidance on visiting a clinic (Industrial Health Standards Division-228, January 12, 2024). Record sentences should also be written within this scope, focusing on 'measurement values ​​and guidance content'.

🗂️ The reason why the same consultation record is divided into three branches

It is convenient to simply attach a single consultation log to reports for both the department head and management. However, doing so results in the information collected for consultation purposes being used for HR and management purposes. Article 18 of the Personal Information Protection Act It prevents use or provision beyond the original purpose for which it was collected, and limits exceptions to separate consent or special provisions of other laws. The same applies even within the same company.

If the consultation involves health examination results, the Occupational Safety and Health Act follows the same direction. Article 132 Paragraph 2 states that even if the employee representative requests an explanation of the results The results of individual workers' health examinations must not be disclosed without their consent. Paragraph 3 stipulates that health examination results cannot be used for purposes other than the protection and maintenance of workers' health. Dividing this into three parts is the simplest way to comply with these two provisions in daily work.

👔 Scope that can be conveyed to the Department Head | Only work adjustment details

After consulting with the night shift employee, it was determined that they must be excused from night duty for the time being. The department head asks for the reason, stating that the work schedule needs to be redone. What the department head needs is not a diagnosis. What, until when, how It is whether to change it.

Article 132, Paragraph 4 of the Industrial Safety and Health Act stipulates that if necessary based on the results of a health examination, measures such as changing the workplace, transferring duties, reducing working hours, or restricting night work shall be taken, and Article 210 of the Enforcement Rules Paragraph 1 requires that the details of the measure be explained to the workers. Article 669 of the Occupational Safety and Health Regulations It also states that workers should be appropriately assigned to high-stress jobs by referring to health examination results and counseling materials. No provision requires the diagnosis to be reported to the department head. Communication should be done at the level of the action taken.

If the individual wishes to share the situation with a colleague, determine the scope with them and record the agreed-upon details in a single line in the consultation log. There is one more point to keep in mind. The Occupational Safety and Health Act Article 162 The duty of confidentiality enumerates those conducting health examinations, those conducting epidemiological investigations, etc., but health managers are not on this list. To physicians, nurses, and health managers Article 19 of the Medical Act It has not been confirmed by an official interpretation whether the prohibition on information disclosure applies to workplace consultations. Rather than relying on legal provisions Directly specifying the health manager's confidentiality and scope of sharing in the internal regulations. This is a sure method.

📊 Monthly management reports are submitted by management type and aggregate unit.

If a report listing '1 person with high blood pressure' is submitted to a team of three, the team leader immediately knows who it is. Even if a name is not written down, if it can be easily matched with other information, it is considered personal information. Article 2 of the Personal Information Protection Act No. 1). Article 3, Paragraph 7 of the same Act stipulates that processing should be done anonymously if the purpose can be achieved even with anonymous processing, and the Personnel and Labor section of the Personal Information Protection Commission’s “Guide to Personal Information Protection by Sector” (Dec. 2024) If statistics are required, anonymization is the principle. It explains that statistics where the identity of the user is unknown are not personal information.

Therefore, it is more appropriate to change the monthly report from "how many people with what disease" to "how many cases of what management." The actual work performed by health managers also becomes more visible when categorized by management type rather than by disease.

The Ministry of Employment and Labor's operational manual also uses units of cause, such as cough and skin rash, when citing examples of compiling statistics on health management office records by department and reason for visit. This means that grouping by unit rather than by disease name is not an unusual approach.

If an executive says, “We need numbers by disease to formulate next year’s health promotion plan,” do not extract those numbers from the consultation log. Annual summary of health checkup results aggregated at the company-wide level Please provide this separately. What is needed for the plan is not the monthly changes by disease, but the overall flow of the company. Small departments should be combined at the factory or headquarters level, and if the number in a single column is too small, group it and display it as "less than 3 cases." Since there is no set number in the law or official guidelines regarding how many people to group, the company must decide. The Personal Information Protection Commission's statistical compilation guidelines also only advise widening the unit for rare values ​​to include a large number, without specifying a numerical value.

🔐 Setting the retention period and access permissions for original counseling logs

The most confusing aspect regarding retention periods is treating health examination result sheets and counseling logs as the same document. Health examination result sheets and result certificates submitted by the worker are Article 241 of the Enforcement Rules pursuant to Paragraph 2 5 years (For workers handling substances notified by the Minister of Employment and Labor, it is preserved for 30 years.) On the other hand There is no statutory retention period for the health manager consultation records themselves. Neither Article 164 of the Industrial Safety and Health Act nor the Enforcement Rules contain a section for consultation records.

You must not leave it indefinitely just because there is no legal period. Article 21 of the Personal Information Protection Act It is stipulated that personal information that has served its purpose must be destroyed without delay, and that information that must be preserved due to other laws must be kept separate from other information. For example, if an internal standard is established, such as '○ years after retirement,' and health examination results (5 years) and counseling logs (internal standard) are placed in different folders, the times of destruction will not be mixed up.

Please also set the viewing scope. Article 29 of the Personal Information Protection Act It requires safety measures such as internal management plans and the retention of access logs. If consultation log files are located on the HR team's shared drive, access permissions must be restricted to the Health Manager. When the Health Manager changes, the original files must be handed over only to the successor, and the date of handover and a list must be recorded. The problem of the reason for consultation being revealed on screens visible to others, such as consultation appointment schedules, is... Inquiry regarding consultation appointment schedule In this, the scope of sharing for musculoskeletal symptom consultation records is Inquiry regarding musculoskeletal consultation records You can view it together at.

💬 How records are split when connecting to EAP

For example, during a blood pressure consultation, an employee mentions that they have barely been getting any sleep lately and that the team atmosphere makes it difficult to come to work. The health office could continue to listen, but if such stories are recorded at length in the consultation log, there is a high risk that the records will later get mixed up with work coordination or reports.

In such cases, connecting to an external EAP naturally splits the records. Article 83 of the Framework Act on Labor Welfare Paragraph 2 states that in the process of implementing the EAP, the employer and the EAP participant Guaranteeing the anonymity of workers It is stipulated that this be done, with the only exception being when the employee themselves has consented to the subject and content of disclosure. Article 55 of the Enforcement Decree The company receives only aggregates such as the number of users or the distribution of consultation topics, and does not receive the individual consultation details.

In the health manager's consultation log, it is sufficient to record only something like "EAP notified, individual to decide whether to apply." In the monthly report, enter it as a tally, such as "3 EAP notifications." Regarding whether it is permissible to record the fact of notification... Inquiry regarding EAP guidance records after health consultation In this regard, the linkage method of the health manager Can the health manager refer someone for EAP counseling? It was covered in detail in [link].

An Excel spreadsheet that organizes the items included in consultation logs, work coordination opinions, and monthly reports into a single table, and automatically aggregates monthly reports by management type Information item table separating health consultation logs and management reporting materials You can receive it from.

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📚 Source and Verification Criteria

• Article 22 of the Enforcement Decree of the Occupational Safety and Health Act (Duties of Health Managers, etc.)
• Article 132 of the Occupational Safety and Health Act (Employer's Obligations Regarding Health Examinations)
• Article 162 of the Industrial Safety and Health Act (Confidentiality)
• Article 210 of the Enforcement Rule of the Occupational Safety and Health Act (Measures based on health examination results, etc.)
• Article 241 of the Enforcement Rules of the Occupational Safety and Health Act (Preservation of Documents)
• Article 669 of the Rules on Occupational Safety and Health Standards (Preventive Measures for Health Impairment Caused by Job Stress)
• Articles 2, 3, 18, 21, 23, and 29 of the Personal Information Protection Act
• Article 19 of the Medical Service Act (Prohibition of Information Disclosure)
• 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 (Exceptions to the Guarantee of Anonymity)
• Ministry of Employment and Labor, "2026 Workplace Health Management Manual" (June 2026)
• Personal Information Protection Commission, "Guide to Personal Information Protection by Sector" (Dec. 2024), Human Resources/Labor and Statistics Section

Date of verification of laws: October 27, 2026. The Occupational Safety and Health Act is based on the version effective October 27, 2026 (Act No. 22122), and the Personal Information Protection Act is based on the version effective September 11, 2026 (Act No. 21445). The sentence examples, classification of management types, criteria for aggregating small groups, and retention periods for counseling records are examples of internal company standards, not statutory standards. An official interpretation has not been confirmed regarding whether workplace counseling records constitute medical records under the Medical Service Act and whether Article 19 of the Medical Service Act applies. This article is for practical reference purposes only and does not substitute for a legal judgment on individual cases.