How to write a workplace COVID testing policy (and reassure employees)
Similar to a Health and Safety policy, a COVID testing policy should detail all the key information about how you’re going to test your employees for coronavirus. It should be simple, straight-forward and accessible for all.
Here’s how to write a COVID testing policy for your workplace.
COVID testing policy: answering the key questions
There’s no one way to write a COVID testing policy. That said, they should all set out to answer the same need-to-know questions, such as:
What tests will be administered?
Read our guide on COVID test procedures to find out which COVID test will suit your business needs.
How will the testing process work?
To answer that question, your policy should address:
How the COVID tests will be carried out
Will you ask your employees to self-administer their own tests, at home or on premises?
Will you work with a provider that sends out trained healthcare professionals to do the testing for them?
When (and how often) the tests will be administered
The government advises that each employee should take two lateral flow tests per week — your policy should reference this, and prepare your staff for weekly testing.
It should also be clear about when additional tests might be required.
If your employees have to travel abroad, for example, your policy should explain how you are going to control the risks of this by offering non-regular PCR tests and/or ‘Test to Release’ tests, for example.
Where the tests will be carried out
Will the tests be administered in the workplace? In a mobile testing van? Or off-site, at a test centre or in the employees’ homes? Make this bold and clear in your COVID testing policy.
What will happen if an employee tests positive?
Your COVID testing policy should outline more than the testing process — it should address what comes after, too. If an employee tests positive for COVID, for example, what does that mean and how will it be handled?
Your policy should answer that in as much detail as possible, by covering:
- How long staff will need to self-isolate for
- How their absence will be recorded
- How much paid and unpaid sick leave they can take
- The steps involved for returning to work
Will visitors and guests need to be tested?
If your testing policy extends to visitors and guests:
- Do they need to be tested on-site, on the day of their visit?
- Or do they just need proof of a recent test result?
- What if they are multi-day guests (attending a two-day meeting, for example)?
Whatever your requirements, get it in writing within your policy.
And if you’re unsure as to whether or not you should test visitors and guests, carry out a Data Protection Impact Assessment to identify if processing personal data (test results) is proportionate to the risk.
More on data protection for your employees in just a moment.
Will you also check for symptoms of COVID-19?
Many businesses require employees and guests to have their temperature taken before entering the premises.
If your business is doing the same, you should outline it in your testing policy. That way, everyone will be on the same page and know what’s required.
Again, you should only do this if you have identified a reasonable need for doing so.
What are the responsibilities of the employer?
When it comes to COVID testing in the workplace, employers have a wide range of responsibilities. These include:
Following data protection law
Medical data, including COVID test results and temperature readings, are classed as special category data. This means they must be processed in accordance with the General Data Protection Regulation — including Article 9.
As such, your COVID testing policy should highlight how you will follow these laws to both reassure your employees and be transparent about your data processing.
Check out the ICOs guidance on COVID testing for more information about how to lawfully process special category data.
Making tests accessible
If you — the employer — want to COVID test your employees, it’s your responsibility to make that process as straightforward as possible. How will you ensure there’s enough tests for everyone?
Supporting employees who test positive
Employers are also responsible for supporting staff who test positive. If someone returns a positive test, you’ll want them to leave work immediately to self-isolate, but what impact will that have on their working week?
You should invest in ways for staff to continue working from home, wherever possible. And if someone becomes ill with the virus and can’t keep working, you need to offer sick pay to cover their losses. Businesses can claim back up to two weeks of sick pay via the Government’s Statutory Sick Pay Rebate Scheme.
Make sure your COVID testing policy is clear about the financial support you’ll offer your employees. It’s the best way to optimise your testing roll-out.
What are the responsibilities of the employee?
Employees also have their part to play in making your COVID testing scheme a success. Your policy should outline what these are, such as:
Being truthful about symptoms
As soon as an employee starts to experience COVID symptoms, it’s their responsibility to tell their employer about it and to self-isolate immediately. Staff can order at-home testing kits to confirm the diagnosis.
Following the COVID testing policy
When employees sidestep or ignore a workplace COVID testing policy, the policy fails to do its job. Within your documentation, directly ask staff for their commitment — and invite any questions or concerns.
Obtaining a coronavirus isolation note
If an employee needs to self-isolate and can’t work from home, they should obtain a coronavirus isolation note from the NHS to inform their employer that they are unable to work.
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