Occupational Health Records: What to Keep and Why
Every pre-employment checkup, audiometry test, injury on the shop floor and fitness-to-work assessment creates information. Kept well, occupational health records help protect workers, show compliance, and reveal patterns that point to hazards. Kept badly, they become a privacy risk and a compliance gap.
This guide covers what to keep, why it matters, and how to handle it responsibly. It is general information; confirm your specific obligations with counsel.
Why occupational health records matter
- Worker health: baseline and periodic results show changes over time, such as declining hearing or lung function, which can prompt early action
- Compliance: factory and labour rules require certain examinations and registers for specific hazards and industries
- Hazard control: clusters of symptoms or injuries in one area can point to a process or equipment problem
- Claims and disputes: accurate records help in compensation claims, insurance and legal matters
- Continuity of care: doctors can see history when a worker returns for follow-up
What occupational health records typically include
| Record type | Examples |
|---|---|
| Pre-employment examinations | Fitness assessment, baseline tests such as vision, hearing or lung function |
| Periodic examinations | Results of regular checks for exposed workers |
| Exposure monitoring | Noise surveys, dust and chemical monitoring, linked to roles |
| Injury and illness logs | First-aid treatments, workplace injuries, occupational illnesses |
| Fitness-to-work decisions | Return-to-work assessments, restrictions, clearances |
| Food handler fitness | Annual medical certificates where applicable |
| Vaccination records | Where vaccinations are linked to the role |
| Onsite clinic visits | Consultations, treatments and referrals |
Your occupational health centre or clinic will usually hold clinical details, while HR may keep outcomes such as fit, fit with restrictions or temporarily unfit.
What the regulations say, in broad terms
Indian factory rules framed under the Factories Act have long required health registers and medical examination records for workers in hazardous processes, often in prescribed forms. The OSH Code 2020 carries these obligations into a new framework, with central and state rules being notified in stages. FSSAI conditions call for records of food handler medical examinations. Retention periods differ by rule and can be long for some exposures, since occupational diseases may appear years later. Because details vary by state, industry and process, check current requirements with your safety adviser and legal counsel rather than relying on a general period.
Privacy and the DPDP Act
Health information is among the most sensitive personal data an employer holds. The Digital Personal Data Protection Act, 2023, with its rules being phased in, sets obligations for how personal data is collected, used, stored and shared. Read more in our glossary entry on the DPDP Act. Key principles to apply:
- Purpose: collect only what you need for a clear, lawful purpose
- Notice and consent: tell employees what is collected and why, and obtain consent where required
- Minimisation: do not collect or share more than necessary
- Security: protect data with reasonable safeguards
- Access: limit who can see detailed health data
- Retention: keep data only as long as required by law or the purpose, then delete it securely
- Rights: enable employees to access and correct their information and to raise grievances
Who should see what
A simple access model helps:
| Role | Typical access |
|---|---|
| Occupational health doctor and nurse | Full clinical records |
| HR | Fitness outcomes and restrictions, not diagnoses |
| Manager | Only the adjustments needed to do the job safely |
| Safety team | Anonymised or aggregated trends linked to hazards |
| Employee | Their own records |
Avoid emailing reports around or storing them in shared drives.
Good practices for record keeping
- Use a consistent format for each type of examination so results can be compared over time
- Link exposure to roles, so you know which workers were exposed to which hazards and when
- Record the examiner, date and method for each test
- Store securely, using systems with role-based access, encryption and audit logs
- Plan for transitions, so records stay accessible if a clinic provider changes or a site closes
- Review trends, at least yearly, in aggregated form to spot patterns
- Dispose securely at the end of the retention period
When you change providers or close a site
Occupational health records often outlive the contracts and sites that created them. If you switch clinic providers, agree in the contract how records will be transferred, in what format, and within what time. If a site closes, decide who will hold its records and how former employees can request them. Planning this upfront avoids lost histories that may matter for a worker's health years later.
Common gaps
- Records kept by an external provider with no agreed handover arrangement
- Paper registers stored in unlocked cupboards
- Results filed but never reviewed for trends
- HR teams holding full medical reports they do not need
- No clear retention or deletion schedule
How MeWeSalus Care can help
MeWeSalus Care helps employers run checkups and onsite clinics with organised, secure records and aggregated health insights for HR, following the approach described on our security and compliance page. To discuss how your occupational health records are managed, contact us.
Frequently Asked Questions
Can HR see employees' medical test results?
Generally, HR should see only what is needed for employment decisions, such as a fit, fit with restrictions or unfit outcome. Detailed results should be held by the medical or occupational health team, with access limited and based on consent and purpose.
Can employees get copies of their own health records?
Employees should be able to access their own health information. Under the DPDP Act, individuals have rights to information about how their personal data is processed. Put a simple process in place for requests.
Is it safe to store health records in spreadsheets?
Spreadsheets are hard to secure and easy to share by mistake. A system with role-based access, audit logs and encryption is a safer choice for sensitive health information.
This article is for general information only and is not medical, legal or financial advice. Please consult a qualified professional about your specific situation.