In the corporate health service, you produce two completely different types of documentation during the same day. It’s easy to mix them up – and the consequences of doing so lie in a completely different place than in the clinic.

In the morning, you are on a survey in the production hall. You measure, you observe, you talk to the safety representative. What you write afterwards will be included in the company’s systematic HSE work, and the employer will read it.

In the afternoon, one of the same employees sits in your office and talks about sleep problems and a GP she doesn’t have time to see. What you write after that conversation should not be seen by any employer.

Documentation in the corporate health service run along two tracks that look identical from the outside and are fundamentally different from the inside. Keeping them apart is not a formality – it is the very foundation of the system functioning.

The role the law gives to the occupational health service

Workplace Safety Act § 3-3 The regulation states that employers are required to link their operations to a corporate health service approved by the Labour Inspectorate when the risk factors so dictate, and that the assessment must be carried out as part of the systematic OHS work. The regulation further states that the corporate health service must assist employers, employees, the occupational health and safety committee, and safety representatives in creating a safe working environment that promotes good health at work.

And then comes the phrase that explains the entire structure: the corporate health service must have a free and independent position on working environment issues.

It is an unusual position in Norwegian working life. The employer pays, the employer orders – and the service is still supposed to be professionally independent of both parties. Your documentation is one of the few things that makes that independence visible and verifiable.

The track that belongs to the business

Regulations on organization, management and participation Chapter 13 Describes what the employer must ensure BHT does. § 13-2 lists eight tasks: ongoing assessment of the working environment, proposals for preventive measures, assistance with physical and organizational changes, guidelines for chemicals and equipment, monitoring of employees’ health taking into account the work situation, individual accommodations, information and training – and assistance with requests from employees, safety representatives and the working environment committee.

Section 13-3 is more explicit in the documentation. The employer must, in collaboration with the occupational health service, prepare plans and annual reports for the BHT’s assistance, periodic reports and results of surveys, risk assessments and measurements describing hazardous working conditions, with proposals for measures – and routines for follow-up plans and facilitation measures. All of this must be included in the company’s systematic OH&S work.

This is documentation at the group level. It describes the workplace, not individuals. It belongs to the company, and it is intended to be read by management, safety representatives, and – in the case of supervision – the Occupational Safety and Health Authority.

The track that belongs to the patient

As soon as you provide health care to an individual employee, the health care legislation applies in full. Health Personnel Act § 39 obligates the person providing healthcare to keep a record, and the responsibility follows the person who makes the observation or treatment.

The Directorate of Health also points to a distinction that is worth noting: Initially, only persons receiving health care are subject to the health care legislation.. People who are subject to a survey but do not receive healthcare do not have a patient record with you. However, they may be entitled to access documented information under Article 15 of the General Data Protection Regulation and to public access under the rules of the Public Administration Act.

Two different access regimes, that is, for two different documents. That is one of the reasons why it is worth being precise about which track a note belongs in even before it is written.

The Patient Journal Regulations Section 8 also mentions two things that are common in occupational medicine: information about sick leave notifications and certificates prepared in connection with healthcare, and information about expert statements. The fact that they must be included in the medical record does not mean that the content of an expert assessment is shared with the employer – but that it must be traceable.

We have previously written about How sick leave management places its own requirements on record-keeping. Many of the same considerations apply here, with an additional layer: you have a client who is not the patient.

The Medivox fits in

Medivox transcribes speech into text and structures it according to templates you build yourself. For the corporate health service, that part is relevant in a slightly different way than in the clinic: you don’t need one template, you need several that are clearly different.

A workplace mapping template doesn't look like an individual consultation template. By building them separately, with different fields and different logic, the track you're on becomes visible as soon as you start drafting. It's a simple form of prevention: the distinction is enforced by the structure, not by your memory at the end of a long day.

Dictation is the core function, and it works best right after the work is done – in the car after a business visit, or between two consultations.

All data is pseudonymized before it is processed further, and all data processing takes place in Norwegian data centers. We have describes how pseudonymization works in practice For those who want to see the mechanics. You own the record and make the final assessment – Medivox documents it, and does no clinical or occupational medical assessments for you.

The independence must be documented

What makes the corporate health service valuable for both parties is that neither of them need to wonder where the loyalty lies. The employer should be able to trust that the assessment is professional. The employee should be able to trust that what she says in the consultation will be kept confidential.

That trust rests on something quite practical: that the two types of documentation are actually separate, that it is easy to see which is which, and that neither of them leaks into the other because it was busy on a Thursday afternoon.

If someone asked you to show the distinction in your documentation today – how clearly would that be?

Frequently Asked Questions

When must a company have a corporate health service? Section 3-3 of the Working Environment Act states that the duty arises when the risk conditions so dictate, and the assessment must be made as part of the systematic HSE work. The regulation on organization, management, and participation § 13-1 also lists business groups that must always be affiliated with an approved occupational health service.

Does the company doctor have a duty of confidentiality towards the employer? Healthcare personnel in the corporate health service are subject to health care legislation in the usual way. Individual health information from a consultation is not shared with the employer without a basis for it.

Is workplace mapping a journal duty? Group-level mapping is not a patient record. It belongs in the organization’s systematic HSE work in accordance with section 13-3 of the regulations. The journal duty is triggered when you provide healthcare to an individual.

Does an employee have the right to access the information the BHT has written about the workplace? Individuals without a patient record with you may be entitled to access to documented information under Article 15 of the Privacy Regulation and to access to the records of the parties under the Administrative Law Act. This is a different set of rules than the patient record access.

Does speech-to-text work for occupational health care? Yes. You create your own templates, and for the corporate health service it is convenient to have separate templates for mapping and for individual consultations, so that the two documentation tracks are kept separate.

Use Medivox for free – Get started completely free

Are you working in the occupational health service and would like to see how separate templates for assessment and consultation can be set up? Contact us – we go through it with you, without a commitment period.

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