The Audiometric Testing Report
The hearing testing report you will receive consists of two documents, the first of which has four sub-sections, and will be submitted electronically around a week to ten days after the testing.
Document 1: The hearing test report itself
This PDF document has four main sections:
A statistical analysis of the set of hearing tests. This is completely anonymous so may be extracted from the report and circulated within the company as needed.
A list of every attendee in that session, listed by name and category of result, using the HSE's categorisation scheme.
A further paragraph of information relating to any attendee found to have a hearing health issue which may be relevant to their work, including stating clearly what the employer needs to do, or need not do, to follow up on it.
This is then followed by a copy of all results for all attendees - the actual audiograms (the graph and table of their result).
Sections 2 and 3 should only be seen by the person within the company responsible for arranging and overseeing the audiometry process and should not be circulated.
Section 3 is an area we are particularly proud to offer as it means the audiometry technician looking at and considering each and every result rather than merely following a machine-like routine, and it is this section which is of most benefit to the employer in clearly stating what need or need not be done.
Following this in Section 4 will be all the audiograms - this is all the actual test data for each person. These will be within the main single PDF document, presented alphabetically, and include a graphical result and tabular data for every attendee, the category of their result and any pertinent comments the employer should be aware of.
By default the report does not include the health questionnaires which are normally handed back to the attendee, with notes made on the audiogram of any pertinent information the questionnaire contained. This is to minimise the unnecessary retention of data as most of this information is of no further use. If, in advance, the employer has requested the questionnaires as well, then these will also be provided within the PDF document(s). This can be varied if the client lets us know in advance.
Document 2: Audiometry Retest List
Clients will also receive a separate spreadsheet of all attendees and their recommended date for their next hearing test which can be used by the client for future audiometry scheduling. This can help in predicting future costs and help with annual budget planning.
This is emailed to the client with the report and can then be maintained by the client to account for new starters and leavers. In any future audiometry sessions the client can let us have it back and we can update it with that subsequent audiometry session's results to provide an ongoing list of tests and re-tests.
Unfortunately we are unable to update these lists to account for new starters and leavers as the year progresses on our end. This is simply due to time - when we did this before we had over 600 audiometry clients and keeping a track of new starters and leavers, or people who were moved around and no longer in high-noise jobs, for all 600 clients was impossible to do, at least without increasing office staff availability and therefore the prices which had to be charged to cover it. By using this route with the employee list sent to each client post-test, each client can then update it so it is always current and can then easily let me have it back (if they wish) to use and update in future audiometry sessions.
For large audiometry clients, (500+ employees) a service is offered whereby this list is updated if the client sends me details on who has started or left the company in the last quarter. A small fee is added to each audiometry session to cover this.
Notes on audiometric test reports, GPDR and data handling
Your employees - your data
The law says the employer is responsible for the audiometric screening programme, and they are your employees. You are paying for someone to conduct the tests for you as a specialist gathering and analysing the data for you. The data belongs to both you and your employees, not to us. We highlight this not to off-load any work but to stress that our approach is that you should see a lot more than just confirmation the testing took place and some statistical anonymous data.
Minimising unnecessary data - the questionnaires
2018 GDPR also plays an important part in the retaining of any medical data arising from the screening process, a lot of which comes from the pre-test hearing health questionnaire. A fundamental part of GDPR is that companies can only hold data on individuals which they absolutely need to hold for provision of a future service. They cannot hold onto it 'just in case' or just because they have had access to it, and this very much applies to the hearing health questionnaires - they should not be held 'just in case'.
Aside from their previous audiogram which is needed for future comparison, along with pertinent notes on the tiny number of personnel who are identified as at-risk, we have no need to keep hold of masses of data and medical information on the vast majority of attendees - for example, for 98% of the attendees the health data obtained from the questionnaire will never be used or referred to again, so give it back to them and avoid holding unnecessary data.
Third parties holding your employees' data
I am also positive that as the GDPR becomes established over time, employers should not want, and will not want, data on their employees spread to other third party companies, or masses of health data held by these third parties on their employees.
If the data has been collected at the employer's instigation, which it has in the case of workplace audiometry, then the employer has a responsibility to ensure that data is properly safeguarded. That is already an onerous requirement where the employer is storing it themselves, but the employer has no say over where a contracting screening service keeps the data, nor over the people the screening company employ to do the tests, nor over their IT systems used to keep it or transmit it, etc. The employer has in effect lost control of data which they instigated the collection of for their own legal obligations.
The ideal goal is to minimise the spread of data and keep it where it belongs - close to the employer who gathered it and to the employee to whom it relates. Over time, occupational health screening companies should be dramatically reducing the amount of audiometry data they hold, not building more and more repositories of data they will never look at again. This only increases data storage non-compliance increases risks for clients and I would recommend clients keep more data in-house where they can control it rather than letting third parties say it is too secret for them to see.
We go into this in more detail on this page of advice on confidentiality of results and employer access to it.
What about confidentiality, can the audiometry report include everyone?
Yes, it can. The Regs are a good example of regulation by committee and not only do they contradict themselves, they also contain some proper nonsense about employers only seeing statistical data. Unless there are thousands of employees then this grouped audiometric test data is statistically useless. There is also little point in comparing one year against another as the analysis as the type of people being tested changes each year - in some years you are mainly testing people with a problem, while in others you are focused mainly on the Category 1 people. In addition, in health and safety we are supposed to protect individuals, not groups, which means individual audiometry data is needed and not just anonymous statistical rubbish. More information employer access to data is given here.
As well as this, the employer needs to know when people are due retests so the work can be scheduled, and importantly, so it can be budgeted for. From the frequency of re-testing, anyone with half a brain can easily work out what an individual's result was - if they are getting retested every three years then it was clearly a Category 1, if it's every two years then it was a Category 2, while if it's every year it must be a Category 3 or 4. This makes the anonymous statistical approach even more of a nonsense and your Noise Chap is too old and grumpy to be faffing about with that charade and insists on doing the job properly.
What about GDPR and employee consent for data gathering?
GDPR doesn't say consent is needed for all data gathering and is explicit in saying consent is not needed when data is being used to comply with another legal requirements, so in this case the hearing test elements of the Noise Regs.
Distribution of audiometry data to GPs
Another issue to consider is the passing of audiometry data to third parties such as GPs as even though they are medical professionals, they are still outside the enclosure of the employer-employee relationship. We avoid this issue completely by taking the route of instructing audiometry screening attendees identified as having undiagnosed hearing problems to go and see their GP themselves, and give them a letter and copy of the audiogram to take with them. This way neither The Noise Chap nor the employer are passing data on to a 3rd party and it is the employee themselves giving it to the GP.