Three data contexts
Website enquiry data, employer health records and confidential medical records have different purposes, access controls and retention requirements. They must not be treated as one dataset.
Employer health records
Employers keep the health record required by the relevant surveillance scheme. HSE says it should contain work, hazard and fitness information, not confidential medical information without written consent.
Medical records
Detailed clinical notes and test results are kept in medical confidence by the occupational-health professional. The final operating model must verify hosting, access controls, processors, retention and provider-transfer arrangements.