Harassment policy requires ‘sufficient’ designated staff – Hoey

The HSE National Director of Human Resources (HR) has informed senior managers to ensure a sufficient number of staff are designated responsibility for functions in the revised bullying and harassment policy. 

The HSE has updated its Dignity at Work Policy for the Public Health Service, which contains further guidance on what constitutes bullying, harassment, and sexual harassment. It includes a new section on preventative measures designed to avoid incidents or complaints arising. 

The policy applies across the HSE and section 38 organisations and aims to protect health service employees from bullying, harassment, and sexual harassment by fellow employees and other persons they may encounter during the course of their work. 

According to a circular sent by National HR Director Ms Anne Marie Hoey on 29 August, the changes to the policy have been informed by the findings of staff surveys on bullying and harassment in the workplace and resulting reports and recommendations. 

It is also based on recent new codes of practice jointly developed by the Health and Safety Authority and Workplace Relations Commission; and another by the Irish Human Rights and Equality Commission. 

The revised policy introduces a new “secondary informal procedure” stage as part of the complaint management procedure, after the initial information stage and preliminary screening and before the formal procedure of investigation. 

“Under this stage, an employee assigned to act as a ‘nominated person’ will have responsibility for managing the complaint on behalf of the employer,” according to the circular. 

“The nominated person will engage with the parties to a complaint to try and resolve issues informally and restore positive working relations”. 

The policy has a continued emphasis on the importance of early intervention when incidents or complaints arise and ensuring that “all reasonable efforts” are made by health service managers to deal with complaints promptly, at local level, using an informal approach. 

“The support contact person, whose role is to provide information and support at any early stage to any employee, remains a key element in the revised policy. Mediation as a voluntary process for parties is strongly encouraged and can take place at any stage.” 

There is also an emphasis on informing employees of the health and wellbeing supports that are available within their organisation and how these can be accessed. 

Ms Hoey pointed out that as the revised policy takes effect, a range of actions are essential to support effective implementation. 

“Senior managers should ensure that there are sufficient numbers of suitable staff to discharge these keys roles in the policy,” according to the circular. 

“Training programmes for these roles are currently being delivered by HSE National HR, Capability, and Culture. Employees and managers who are seeking to contact a support contact person or a nominated person should contact their local HR department who will hold details of local personnel. Heads of HR should ensure that local HR/employee relations offices have up to date lists of the contact details of employees who are fulfilling the roles of support contact persons and nominated persons within the organisation/ relevant HSE region as appropriate.” 

Ms Hoey stated that managers at all levels have a key role in the communications roll-out through providing a copy of the policy to staff and ensuring that they understand its contents. 

“The revised policy should be discussed at team meetings and included as a key topic in other HR processes, such as induction, probation management, and performance management, so that all employees and managers understand their roles and responsibilities under the policy,” stated the circular. 

Senior managers should identify and communicate a monitoring system to enable monitoring of the policy and incidents of bullying, harassment or sexual harassment. 

A monitoring system is outlined in the policy and a sample complaint monitoring form template is included in an appendix. 

This provides for anonymised collation of information on complaint management procedures and their effectiveness under the policy. 

“Such monitoring will enable employers to take corrective action or achieve continuous improvement in the operation of the policy at local level.”