Managing sickness absence records

Sickness absence records should support pay, contact and fair management without turning every manager's note into a detailed medical file. Health information receives additional protection under data protection law. ^[2]

Separate attendance facts from clinical information

Record absence dates, notification, certification and the relevant pay treatment. Keep diagnostic information and occupational health reports in a more restricted record, available only where needed. A shared rota usually needs availability information, not a diagnosis.

Use consistent absence categories, but do not let an automated trigger make the employment decision. Acas guidance explains that absence management requires consideration of the circumstances, including disability-related issues. ^[1]

Record the decision behind an intervention

If a review meeting is arranged, explain why, what information is considered and what support is discussed. Keep contact arrangements and adjustment reviews visible so a new manager does not restart the process without context.

Check records before relying on them in capability, redundancy or disciplinary decisions. Employer adjustment duties may affect how an absence is treated; subject access requests can involve the employee's personal data in these records. Apply a justified retention schedule and preserve relevant material where a dispute requires it.

Design separate records for separate purposes Identify what payroll, the line manager and HR each need to know. Payroll may need dates and the applicable pay category, while the manager needs availability and agreed contact arrangements. Detailed medical information may belong in a more restricted file. Do not attach the same health report to every system simply because all three teams have an interest in absence. The ICO treats workers' health information as particularly sensitive. [2] Record the purpose and appropriate access for each category of information before choosing where it will be stored.

Use clear definitions for absence dates, partial days, return dates and certification periods. An absence spanning a weekend may need different treatment for certification and scheduled work records. Avoid making one field serve several incompatible purposes. Keep the source of corrections, such as an employee's clarification or a revised fit note, and update the relevant systems consistently. A reliable attendance record should distinguish what occurred from the payroll calculation applied to it, allowing a mistake in one area to be corrected without rewriting the underlying facts.

Limit collection to information needed for the decision Ask for functional information relevant to work and appropriate certification, rather than an unrestricted medical history as a routine condition of absence. Where occupational health advice is sought, define the questions and explain the process. Assess the lawful basis and special-category condition for handling health data with appropriate data protection support; employee consent should not be treated as the universal solution. Keep the current ICO guidance under review where legal changes affect it, and document the organisation's actual purpose and safeguards rather than relying on a generic privacy paragraph.

Control informal records as well as the official personnel file. Managers' notebooks, email chains and shared spreadsheets may contain health information and personal assessments. Give managers instructions on factual recording, secure storage and escalation. A team rota ordinarily needs to show that someone is unavailable, not their diagnosis. If a manager changes, transfer the operational arrangements and authorised information deliberately. Do not leave a sensitive report in a former manager's mailbox as the only record of a support decision that the new manager must implement.

Use attendance triggers to prompt review, not decide outcomes Check the accuracy and context of data before relying on a trigger score. Identify disability-related absence, pregnancy-related circumstances or another reason requiring specific treatment. The purpose of a review should be clear, with the employee able to explain relevant facts and support needs. Acas describes absence management as requiring attention to individual circumstances. [1] A system alert may identify a pattern, but it does not establish misconduct, capability or the appropriate sanction without a fair assessment of the actual position.

Record the reasoning behind management action. State the evidence considered, employee explanation, support explored and the decision made. Keep an adjustment review connected to the attendance process so agreed measures are not overlooked when a score is generated. If a record is used for redundancy or performance assessment, verify that the data and treatment are suitable for that purpose. Reusing an absence total without examining its components can transfer an original recording problem into a more consequential employment decision.

Coordinate records with current pay and return arrangements Ensure payroll instructions reflect current statutory sick pay rules and the contractual scheme. The April 2026 reforms changed the waiting period and earnings threshold, so historic settings should not be assumed correct for a current absence. [3] Keep the dates and calculation basis needed to explain payment. For a phased return, record hours, duties, pay and review arrangements distinctly from the original absence. This helps payroll avoid applying a full-return assumption while a temporary plan remains in place.

Apply a justified retention schedule with a clear process for preserving records relevant to a complaint or claim. Do not delete disputed material automatically because an employee leaves, and do not keep every health detail indefinitely because it might conceivably be useful. Restrict access, review permissions and respond appropriately to correction or access requests. The completed absence record should support accurate pay and fair management while making it possible to explain why sensitive information was collected, who used it and how long the particular record remains necessary.