How to keep a dated record of what you do to prevent sexual harassment

Last checked 17 Oct 2026. Great Britain only. Dates can change.

Keep one dated log with a line for each thing you do to prevent sexual harassment: what you did, when, who was involved and when you will look at it again. The commencement regulations (SI 2026/1065) bring the "all reasonable steps" duty into force on 30 October 2026. The specific steps are not yet set out in regulations, so a clear record of what you actually do is the most useful thing you can have.

What is and is not settled

• Section 20 changes the duty from "reasonable steps" to "all reasonable steps". Section 21 deals with harassment by third parties. Section 22 gives ministers a power to specify steps later.
• We have not found regulations that list those steps. Acas does not give a fixed list either. It says the right steps depend on your size, sector and type of work.
• A record does not prove that your steps were enough. It shows what you did and when. See the sexual harassment duty.

How long this takes

Set up the log in an hour. After that, expect 15 minutes a month to keep it up to date and a half day each year for a fuller review.

Steps

1. Create the log. One document or spreadsheet, kept by one named person, with columns for date, area, what was done, who was involved, evidence and next review date.
2. Record what you already do. Write down your existing policy, training, induction content and reporting routes, with the dates they were introduced or last changed. Be honest about gaps.
3. Assess your risks and write the result down. Acas lists higher risk situations such as meeting clients or service users alone, alcohol, work social events, power imbalances and overnight travel. Note which apply to you.
4. List who your people deal with. Customers, clients, visitors, contractors and suppliers. Acas says your assessment should cover these people and that how often staff meet them affects which steps are reasonable.
5. Add actions with owners and dates. For example, update the policy, brief managers, agree what to do when a customer behaves badly, or review a supplier contract.
6. Log each action when it happens. Add the date, who attended or received it, and where the evidence is kept.
7. Set review dates (see below) and diary them.

Areas to cover

• Policy. Acas says a sexual harassment policy can be standalone or part of a wider policy. It should say what harassment is, give several people to report to, explain informal and formal routes, deal with third parties and describe support.
• Training and communication. Induction message, staff awareness, manager training and who is trained to advise someone considering a complaint.
• Reporting routes. More than one route, so nobody has to go through the person they are worried about, with an anonymous option if you can offer one.
• Third parties. Signs or messages to customers, what staff should do, support for the affected employee, security measures and contract wording where it fits.
• Handling concerns. A confidential record of each concern, what was done and the outcome. Acas says a record of complaints helps spot patterns.
• Review. Whether policies, procedures and training are working.

Where third parties fit

Section 21 treats an employer as permitting third party harassment if the harassment happens in the course of the employee's job and the employer failed to take all reasonable steps to prevent it. Acas says third parties include clients, customers, members of the public and people at events. Acas says to consider third parties, and how often staff deal with them, when deciding which steps are reasonable. The third party rule is not limited to sexual harassment: it covers harassment related to any protected characteristic, so include that in your risk notes. In your log, keep a short list of who your staff meet, the risks and what you have done about each.

Review rhythm

• Monthly: 15 minutes to add anything new and check actions are on track.
• After any concern or incident: a short review of what happened and whether anything should change.
• Every year: a full review of the risk assessment, policy, training and reporting routes.
• When regulations on specific steps appear: compare them with your log and note what you changed.

What to record

• Date, area, action and who did it
• Who was told, trained or consulted
• Where the evidence is kept, such as the policy version or a training attendance list
• Concerns raised and how they were handled, kept separately and confidentially
• The next review date

Common mistakes

• Writing a policy but never recording that anyone read it.
• Ignoring customers and suppliers.
• Keeping complaint details in the general log. Keep them in a restricted file and keep them only as long as needed.
• Treating the record as a one off.
• Recording only good news.

This guide is general information to help you prepare, not legal advice. The specific steps are not yet set out in regulations, and nothing here guarantees that any step is enough.

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