Freely accessible association books violate data protection

A responsibly managed laboratory naturally includes a first-aid kit and first-aid book, as injuries and first aid treatments must be documented and retained for five years in accordance with Section 24 Paragraph 6 of DGUV Regulation 1. However, have you reviewed the first-aid book and the format of the documentation in the past five years? If not, this is initially a good sign, as there have probably been no accidents or injuries in your work area. However, in this case, action may be required. The documentation of injuries and accidents constitutes personal health data within the meaning of Art. 9 GDPR, which is subject to the Federal Data Protection Act (BDatSch). Accordingly, the documents must be treated confidentially and protected from unauthorized access. In the recent past, however, it was common practice for the first-aid book to be freely accessible to everyone in the first-aid kit to allow those involved direct access and documentation. This, however, contradicts data protection requirements. For data protection-compliant documentation, DGUV Information 204-021 – Documentation of First Aid Services (Reporting Pad) was published in January 2023, replacing the former DGUV Information 204-020 – First Aid Book. This is a perforated reporting pad with individually detachable pages. The reporting pad should be kept near the first aid kit and completed by those involved in the event of injuries or accidents. The completed form is then handed over to the person responsible for recording. The records should be systematically filed and must be retained for 5 years before being disposed of in accordance with data protection regulations. Professional data destruction or a document shredder are suitable for this purpose. The reporting pad is available for free download or can be ordered from German Social Accident Insurance (DGUV)

Tip: In laboratory facilities that are used jointly by many different working groups (e.g. laboratories for student internships at universities), a standard, lockable mailbox is ideal for collecting the registration forms.