Standards for Counseling Records Prior to Official Workplace Harassment Reporting - Scope of Interviews, Protective Measures, and Retention

It is difficult to approach counseling records prior to an official workplace harassment report with the mindset that "it doesn't need to be recorded because it hasn't been reported yet" or that "everything must be recorded in detail just in case." Even at the counseling stage, HR must address this issue. Fact of the interview, main appeal details, need for protection, whether the report was converted to an official one, and the procedures provided. You must leave it within the necessary scope.

However, counseling records are not investigation reports. During the counseling phase, rather than concluding whether workplace harassment occurred, it is advisable to focus on documenting the difficulties the employee reported and the procedures the company guided them through.

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situation

There are instances where an employee approaches an HR representative stating, "I don't want to file an official complaint, just want a consultation." They mention conflicts with their supervisor, public reprimands, exclusion from work, and repetitive pressure, but they do not yet explicitly state that they want an investigation.

In other cases, you may face concerns regarding how much of the employee interview record should be kept, how to mark grievance counseling schedules on a calendar, and how to preserve past counseling and interview records when organizing the accounts of departing employees.

In such situations, HR frequently asks the following questions.

Do I need to record consultations that are not official reports as well?
If the employee does not want to report it, is it okay not to take any action?
May I share the details of the consultation with the department head or an executive?
Is it okay to keep interview records and EAP counseling records together?
Is it okay to continue keeping counseling and interview records even after I leave the company?

This article summarizes the scope of records HR must keep, protective measures, and retention standards during the counseling phase prior to formally filing a workplace harassment report.

conclusion

Even consultation before official reporting It is recommended to keep a record of consultation history to the extent necessary. However, the scope of the recording must be limited.

The consultation record may include the date and time of the consultation, the consultation channel, the main complaint, the need for urgent protection, the intention to switch to an official report, the procedures advised, and the scheduled date for follow-up verification.

Conversely, it is advisable to avoid making definitive statements about unconfirmed facts, identifying the accused as the perpetrator, including unnecessary personal or health information, or leaving excessively detailed descriptions of the counselor's emotions.

division	Recording standards
Content to be left behind	Date and time of consultation, main complaint, need for protection, guided procedures, follow-up schedule
Things to be careful about	Assuming unverified facts, excessive recording of private and health information
Sharing criteria	Limited to necessary personnel, such as HR and research staff.
Conversion criteria	If the content is specific or protective measures are required, review official procedures.
Storage Standards	Define the purpose and necessary period, and restrict access rights.

Even if an employee does not wish to file an official report, if the company is specifically aware of the possibility of workplace harassment, it may need to review the necessity of initial verification or protective measures.

reason

Workplace harassment cases must be managed by distinguishing between the counseling and formal investigation stages. However, if specific behaviors, timing, location, individuals involved, or evidentiary clues are identified during counseling, the situation may escalate beyond simple grievance counseling to a recognized possibility of workplace harassment.

The Labor Standards Act stipulates that anyone may report the occurrence of workplace harassment to an employer, and that upon receiving a report or becoming aware of the occurrence, the employer must conduct an objective investigation to verify the facts without delay.

In addition, secrets learned during the investigation process must not be disclosed against the will of the victimized workers, etc., and the whistleblower and the victimized workers, etc. must not be subjected to unfavorable treatment.

From a personal information perspective, counseling records should be limited to the necessary scope. In particular, it is advisable not to record or to minimize the recording of sensitive or unnecessary information, such as health status, treatment history, family history, and private life.

Therefore, regarding consultation records prior to the official report, the approach is not to “make everything in detail because it could cause problems later,” but, A method of documenting the facts and procedures necessary for follow-up response This is safe.

Practical Checkpoints

1. Distinguish between counseling records and investigation records.

Counseling records prior to an official report are intended to receive the difficulties experienced by the counselor and guide them through the process. It may not be appropriate to immediately write conclusions such as "workplace harassment acknowledged" or "perpetrator identified" at this stage.

It is recommended to include the following in the consultation record.

item	Record example
Consultation Date	2026.08.21 14:00
Consultation Channel	In-person / Phone / Email / Follow-up consultation after anonymous tip-off
Summary of consultation	Appeal regarding repeated public reprimands and exclusion from work by a superior
Related clues	Remarks made during the meeting, messenger content, possibility of being a witness
Need for protection	Departmental Complaints of Burden of Additional Contact
Counselor Doctor	Reviewing whether to switch to official reporting
notification	Information on reporting procedures, possibility of investigation, and confidentiality standards
Follow-up schedule	Scheduled for a follow-up consultation in 3 days.

Rather than transcribing everything the counselor said like a transcript, it is better to summarize only the key points necessary for follow-up action.

2. Check whether to switch to official reporting.

The caller may say, "I would only like to have a consultation right now." In this case, HR should respect the caller's wishes but explain in what instances the company may need to review official procedures.

For example, if a specific perpetrator, repetitive behavior, time, place, evidence, or witnesses are specifically identified, you must review whether to convert the case into a workplace harassment report or an awareness case.

The following information can be included in the consultation record.

Whether there is an intention to file an official report
Do you only want counseling right now?
Whether you would like to decide after additional consultation
Whether protective measures are needed
Whether the company informed that additional verification was needed
Whether the scope and limitations of confidentiality protection were explained

The important thing is not to stop there by simply stating “I do not wish to file an official report.” You must also consider the need for protection, the need for further verification, and the schedule for follow-up counseling.

3. The necessity of protective measures is also confirmed during the counseling stage.

There may be situations where protection is needed even before an official report is filed. These include cases where one must continue to encounter colleagues in the same department, faces repeated public reprimands, fears retaliation, or complains that it is difficult to even come to work.

Protective measures do not necessarily mean a personnel transfer. During the consultation phase, measures to reduce the burden, as described below, can be considered.

Minimize direct contact with the accused
Adjustment of meeting attendance method
Temporary adjustment of work instruction route
Separation of interview schedules
Secure a reconsultation schedule
Information on the availability of paid leave or sick leave
Guide to investigation procedures when switching to an official report

However, even when taking protective measures, care must be taken to ensure that they are not taken against the will of the affected worker. Adjusting work in a way that reveals the fact of counseling may lead to secondary harm.

4. Minimize the scope of sharing.

The scope of sharing regarding consultation details prior to an official report must be managed even more strictly. This is because the information has not yet been fully verified and may contain sensitive information regarding the victimized workers, the accused, or witnesses.

Even when sharing is necessary, you should organize it within the scope required for follow-up measures, rather than simply saying, "I heard someone is having a hard time."

Shared with	Examples of shareable scope
HR Manager	Fact of counseling request, need for protection, and review of official procedures
investigator	Key points of consultation and clues required for case conversion
Department Head	Minimum information required for work coordination
executives	Significant risk, need for investigation transition, need for protective measures
EAP Manager	Level of guidance on counseling referral methods, non-sharing of individual counseling content

You must be especially careful when sharing with department heads or managers. This is because the department head may be involved in the incident, and the counselor could be identified during the sharing process.

5. Schedule and meeting room names are also viewed from the perspective of confidentiality protection.

Caution is also required when scheduling grievance counseling or workplace harassment interviews on the calendar. If you write sensitive details verbatim in the event title, such as “Harassment Counseling” or “OOO Grievance Interview,” they may be exposed to others.

If using an internal calendar or meeting room reservation system, you must verify the event name and the visibility of attendees. If necessary, you may use expressions that do not overly reveal the purpose, such as “HR Meeting,” “Personnel Consultation,” or “Individual Meeting.”

However, internally, the actual purpose of the consultation and details of follow-up actions must be managed in a separate record. It is recommended to minimize visible schedule names while accurately documenting internal HR records to the extent necessary.

6. Set the retention period and access permissions.

If the retention standards for counseling records prior to an official report are unclear, managing them later becomes difficult. It is recommended to categorize grievance counseling records, workplace harassment investigation records, and EAP counseling records according to internal company standards, and to define their storage locations and access permissions.

It is difficult to state a uniform retention period. The company's document management standards, potential for disputes, legal retention obligations, whether the case is converted to an investigation, and the purpose of processing personal information must be considered together.

In practice, the following criteria can be established.

Separate counseling records and official investigation records into separate folders.
Access is restricted to the minimum number of personnel, including HR managers and investigators.
Prohibition of messenger forwarding, saving to personal PCs, and leaving printed materials unattended.
Record modification history management
Display of records transferred to investigation data upon conversion to official reporting
Reconfirm the necessity of retention and destruction standards for records related to departing employees
Application of destruction or separate storage standards after the required period has elapsed

Just as important as keeping a record is limiting who can see it.

Checklist

The checklist below is for internal verification purposes to check counseling record standards prior to formally reporting workplace harassment.

especially Summary of consultation, whether to switch to official reporting, necessity of protective measures, scope of sharing, retention standards is a basic verification item. Among all items If 3 or more are insufficient It is recommended to review the consultation record form and management procedures before filing an official report.

division	Confirmation items	check
Counseling records	The consultation date, channel, counselor, and person in charge were recorded.	☐
Summary of contents	They did not conclude unconfirmed facts and only left the main points of the appeal.	☐
Reporting doctor	Confirmed the intention to switch to an official report and the need for further consultation.	☐
Need for protection	We checked for concerns regarding retaliation, contact burden, and the presence of urgent risks.	☐
Procedure Guide	Information on reporting procedures, the possibility of investigation, and confidentiality standards was provided.	☐
Schedule Management	Sensitive information was prevented from being exposed in the calendar and meeting room names.	☐
Sharing scope	The scope of access was restricted to necessary personnel, such as HR and investigation staff.	☐
personal information	Unnecessary information, such as health details, family history, and private life, was minimized.	☐
Investigation switch	We reviewed whether to switch to official procedures once specific facts were confirmed.	☐
Storage Standards	The storage locations for counseling records, investigation records, and EAP counseling records were distinguished.	☐
Destruction criteria	The criteria for destruction or separate storage after the required period were verified.	☐

Common mistakes

The first mistake is leaving no record of the consultation at all because it is not an official report. If the same problem recurs later or is converted to an official report, it is difficult to verify what was advised during the initial consultation.

The second mistake is recording consultation details in too much detail. While records are necessary, including unverified claims or excessive private information can increase personal information risks.

The third mistake is sharing information directly with the department head without the counselor's consent. The scope of sharing must be examined more strictly, especially if the department head may be involved in the case.

The fourth mistake is exposing the purpose of sensitive consultations directly in calendars or meeting room names. It is advisable to manage schedule names as well, treating them as part of confidentiality protection.

The fifth mistake is mixing EAP counseling records with HR interview records. In principle, EAP counseling content should not be shared with the company or managers, and HR interview records should be limited to the scope necessary for providing guidance on official procedures and reviewing protective measures.

If EAP support is needed

Counseling prior to formal reporting of workplace harassment and record management are not areas that an EAP can replace. The reception of reports, decision to proceed with an investigation, protective measures, record keeping, confidentiality, and disciplinary and personnel actions must be conducted in accordance with the company's official procedures and legal standards.

However, if an employee complains of anxiety, sleep problems, work stress, or relationship stress prior to the official reporting stage, you may refer them to EAP as a supplementary channel. Even in this case, it is advisable to clearly inform them that the content of the EAP counseling will not be shared with the company or their manager.

For example, you can provide guidance as follows.

If anxiety, sleep problems, or relationship stress are significant during the process of reviewing whether to file an official report, you may utilize EAP counseling channels. EAP does not replace the reception of reports, investigations, protective measures, disciplinary or personnel actions, or legal or labor judgments; it is a supplementary channel designed to support the psychological burden of members.

In cases of suggestions of suicide or self-harm, immediate safety risks, or risks of violence, do not respond solely through general counseling or EAP guidance; instead, you must first check emergency channels such as 119, 112, or the suicide prevention hotline 109.

Frequently Asked Questions

Q1. Do I need to record consultations prior to the official report?

It is advisable to keep a record. However, rather than writing in detail like an investigation report, it is better to record the date and time of the consultation, the main complaint, the need for protection, the intention to switch to an official report, and the procedures advised, to the extent necessary.

Q2. If an employee does not want to file an official report, is it okay not to take any action?

It is difficult to make such a definitive conclusion. If the details of the consultation are specific and the possibility of harm or urgent risk is confirmed, the company may need to review the necessity of initial verification or protective measures. However, the wishes of the affected employee and the protection of confidentiality must be considered together.

Q3. May I share the consultation details with the department head?

Even when sharing is necessary, it is advisable to limit the scope to the minimum. In particular, if a department head is involved in the incident or there is a risk of the counselor being identified, it is safer to restrict sharing and have HR or a designated person verify the information.

Q4. How should I mark grievance counseling schedules on the calendar?

It is advisable to avoid writing sensitive details verbatim, such as "Harassment Counseling" or "Grievance Report," in the schedule title. It is safer to minimize external titles to things like "HR Interview" or "Individual Interview," and to manage the actual purpose of the consultation and records restrictively within internal HR documents.

Q5. Is it permissible to retain records of consultations and interviews with former employees?

It is difficult to generalize. You must consider the company's document management standards, the potential for disputes, whether the matter will be escalated to an investigation, and the purpose of processing personal information. It is advisable to apply standards for destruction or separate storage once the necessary period has passed.

Q6. Is it okay to keep EAP counseling records and HR counseling records together?

It is recommended to manage them separately. In principle, EAP counseling content should not be shared with the company or managers, and HR counseling records should be limited to the scope necessary for guiding official procedures and reviewing protective measures.

Next step

When a request for counseling is received prior to filing a formal complaint regarding workplace harassment, it is advisable to organize the counseling record form in advance. You should record the date and time of the consultation, key details, intent to proceed with a formal complaint, need for protection, procedures outlined, and follow-up schedule; however, you should minimize unnecessary personal information and unverified definitive statements.

first of all Scope of consultation records, criteria for verifying protective measures, criteria for converting to official reporting, schedule name management, sharing and storage permissions Try organizing it based on internal standards.

If you wish to overhaul workplace harassment counseling record forms, formal reporting transition procedures, protective measure standards, and EAP counseling linkage systems at the organizational level, review the operational methods suitable for your organization through Nudge EAP implementation counseling.

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Source and Information

This content is intended for general informational purposes. Specific legal matters, labor issues, counseling prior to formally reporting workplace harassment, interview records, protective measures, personal information protection, record keeping, disciplinary and personnel actions, and mental health and psychological counseling matters may vary depending on the workplace situation, the latest laws, and official guidelines; therefore, review by relevant experts or agencies may be necessary. In cases involving suggestions of suicide or self-harm, immediate safety risks, or risks of violence, do not respond solely through general counseling or EAP guidance; instead, prioritize checking emergency channels such as 119, 112, or the Suicide Prevention Hotline 109.

Workplace Harassment