Custom reporting system for undesirable behaviour
Employers must have a policy to prevent or limit psychosocial workload, which includes bullying, (sexual) harassment, discrimination and aggression. If you take that policy seriously, you want to know what is being reported, who picks it up and what happens next. Appfront builds a registration system for reports of unwanted behaviour: confidential, with permissions per role, and with overviews that help your organisation refine its policy.
What is a registration system for unwanted behaviour?
A registration system for unwanted behaviour records what employees report about bullying, (sexual) harassment, discrimination or aggression, who handles the report and how it is resolved. The Working Conditions Act (Arbeidsomstandighedenwet) counts these forms of behaviour as psychosocial workload, alongside work pressure, and in Article 3 requires the employer to have a policy aimed at preventing that workload or, where that is not possible, limiting it. Article 2.15 of the Working Conditions Decree (Arbobesluit) elaborates on this: the risks belong in the risk inventory and evaluation, the measures in the plan of action, and employees must be informed about the risks and the measures. According to the Arboportaal, this also covers behaviour by third parties, such as customers, clients and patients.
The law does not require you to keep reports in a register. However, the employer must regularly review its health and safety policy against experience of how it works, and for that you need data. A register shows how many reports there are, what kind of behaviour they concern, in which departments or locations, and how long handling takes. This allows a confidential adviser and HR to report to management in anonymised form, without it being traceable who reported what. A confidential adviser is currently not a legal requirement. The private member's bill that aims to introduce one was passed by the House of Representatives on 23 May 2023 and is in written preparation in the Senate.
We build this as a custom system because the route a report takes differs per organisation. At one employer a report goes to an internal confidential adviser, at another to an external agency, a manager or HR, and a report of aggression by a customer requires different follow-up than a report of bullying within a team. Which data is recorded, who may see what and when something remains anonymous, we define together with you and your confidential adviser. The system follows your reporting procedure, not the other way around.
Confidentiality
Visible only to those who may see it.
Followed up
Every report has a status.
Insight
Overviews for your policy.
How we build your registration system for unwanted behaviour
We start with your reporting procedure: who receives reports, which forms of unwanted behaviour you distinguish, what happens after a report and which reports management or the works council receive. Then, together with the confidential adviser, we define which data is recorded, which fields are visible only to the person handling the report and when data is deleted. We first build the recording and follow-up of reports and have the confidential adviser and HR review it using fictional cases. Overviews and integrations, for example with your HR system, follow once that works well.
Reporters, handlers, routes.
What, who and for how long.
Tested with fictional cases.
Go-live, monitoring, and maintenance when things change.
What a registration system for unwanted behaviour actually does
The components below appear in almost every registration system for unwanted behaviour. Which ones you need depends on your reporting procedure and the size of your organisation.
Notify
Confidential, even without a name.
Registration
Type of behaviour and context.
Follow-up
Status and follow-up agreements.
Permissions
Restricted per role.
Statements
Anonymised for policy purposes.
Log
Who did what.
Who we build a registration system for unwanted behaviour for
The system is intended for organisations that currently track reports of unacceptable behaviour in emails, loose documents or memory, and have no good overview of them. The more employees, locations or public contact you have, the more it delivers.
Employers
Overview for your PSA policy.
Confidential advisers
Own, shielded file.
HR departments
Follow-up with the right permissions.
Public-facing roles
Aggression by third parties recorded.
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This page is about reports of unacceptable behaviour between people at work. If you are looking at reporting wrongdoing and whistleblowers, see our page on whistleblowing software; for emergencies and incidents there is the emergency and incident reporting system. Customer complaints belong with complaints management, and for the broader personnel file there is HR case management. You can read about our approach at building custom software.
Why Appfront for your unacceptable behaviour registration system?
A report left sitting in a mailbox, a confidential adviser keeping notes at home, or a board that only discovers after an incident that there had been warning signs for years: all of these damage employees' trust. That is what we build against: a fixed place for every report, protection that fits the role, and overviews that show where your policy needs attention.
Careful
Confidentiality by design.
Traceable
Every step recorded.
Usable
Insight without traceability.
Security and privacy in an unacceptable behaviour registration system
Reports of unacceptable behaviour contain sensitive personal data about reporters, those involved and witnesses, sometimes including data about health or origin, and the strictest GDPR rules apply to this. The system records only what is needed for follow-up, shields each file from everyone except the person handling it, and deletes data after the retention period you set. Overviews for management are anonymised and do not show small numbers that could be traced back to an individual.
The system runs in a European data centre, with encrypted connections and storage. Every action in a file is recorded with the time and user. We agree with you in advance who may view reports, whether an external confidential adviser gets their own environment, and whether the works council receives overviews. We can prepare a data protection impact assessment together with your data protection officer.
Frequently asked questions about an unacceptable behaviour registration system
Questions that employers, HR advisers and confidential advisers ask before getting started.
Behaviour at work that is experienced as unwelcome, such as bullying, (sexual) harassment, discrimination and aggression or violence. The Working Conditions Act classes this as psychosocial workload. It can involve the behaviour of colleagues and managers, but also of customers, clients or patients.
There is no legal obligation to keep a register of reports. You are, however, obliged to have a policy to prevent or limit psychosocial workload and to review that policy regularly against employees' experiences. A register gives you the data to do that.
That the risks of psychosocial workload are assessed in the risk inventory and evaluation, that measures to prevent or limit that workload are set and carried out in the action plan, and that employees receive information about the risks and the measures.
Not yet. The private member's bill to make a confidential adviser for unwanted behaviour mandatory was passed by the House of Representatives on 23 May 2023. It is now with the Senate, which is still in the written preparation stage. Until the Senate passes it, it is not law.
They can if you allow it in your reporting procedure. The system can record a report without a name and still give the reporter a way to follow up on it. Whether anonymous reporting is desirable in your organisation is something we discuss with you and the confidential adviser beforehand.
A whistleblowing procedure deals with wrongdoing in the organisation, such as fraud or breaches of rules, and is part of whistleblower protection. A registration system for unwanted behaviour is about how people treat each other at work. The routes, the people who handle reports and the access restrictions differ.
Organisations with multiple locations, a lot of public contact, an external confidential adviser, or a works council that regularly wants overviews. If you rarely receive a report, a carefully maintained file kept by the confidential adviser is often enough.
Want to record reports of unwanted behaviour with care?
Tell us how reports currently come in and who follows them up. We will show you how a registration system makes this confidential and easy to oversee.