Read receipts for documents issued to staff: what the law expects and how you prove it

Not everything you publish needs a read receipt, and confusing the two is the fastest way to get people pressing the button without reading. These are the usual cases.

• The itemised pay statement, the payslip.
• Information about the risks of the job and the protective measures in place, and the issue of personal protective equipment.
• Safety procedures and method statements, particularly when they change.
• Internal policies the company wants to be able to evidence: code of conduct, use of digital equipment, the anti-harassment policy, the whistleblowing policy.
• The working-time calendar and the rotas, where your collective agreement gives them contractual force.
• Individual letters with an effect attached: changes of role, of site or of hours.

Everything else, the company news, the photo from the shutdown, the notice that the canteen is opening at a different time, needs no receipt. And it should not have one: a channel where everything asks for confirmation ends up with people clicking without reading, which is the exact opposite of what you set out to do.

Here they are as they stand, without interpretation. What your company specifically has to do, given your agreement and your activity, is for your employment solicitor to say.

A useful receipt identifies four things unambiguously. If one is missing, the evidence is arguable.

1. 01

   Who

   The individual person, not the role and not the shift. 'The afternoon shift received the procedure' evidences nothing about the person who was off sick that week.

2. 02

   What, and which version of it

   The exact document. If the procedure was revised in March, a January receipt evidences the January version. Without version control, a file with the same name may have changed three times.

3. 03

   When

   Date and time, and not changeable afterwards. A date written by hand on a sheet of paper is precisely what the other side is going to dispute.

4. 04

   That it was a deliberate act

   That the person did something: pressed a confirm button, signed. Opening a file is not confirming receipt, and logging opens as though they were is building weak evidence and intrusive monitoring at the same time.

The signing sheet works right up until somebody needs it. The day it is needed, the usual problems turn up.

• The people who were off sick, on leave or at another site that day are missing, and nobody did a second pass.
• The night shift signed a different sheet, which is in a different drawer, or signed nothing at all.
• There are illegible signatures and blank rows nobody can explain.
• The sheet evidences that something was signed, but not which version of the document was on the table.
• It is in a folder on site, and the person asking for it is at head office.

The underlying failure is that paper cannot tell you who is missing. And that is exactly what the person managing this needs: not the list of who signed, but the short list of who has not yet.

In a tool with read receipts, the loop is simple: you upload the document, mark which group of people it goes to, and require confirmation. Each person opens it on their phone and presses the button. What is left behind is a record with name, document, version, date and time.

What to ask before you take this as done, with us or with anybody else:

• Can you see the list of who is missing, filtered by site and by role? That is ninety per cent of the value.
• What happens when the document is replaced with a new version? Do the receipts reset, or do they stay pointing at the old version?
• Can a receipt be deleted? And is there a record of who deleted it?
• How long is the record kept, and what happens when the person leaves the company?
• Can the record be taken out of the tool the day you have to show it to somebody outside the company?

It is worth being clear about this internally before somebody else points it out. A receipt evidences that the document was made available to a person and that the person confirmed it. It does not evidence that they read it, that they understood it, or that they are trained.

Which is why, in health and safety, the receipt sits alongside the training rather than replacing it. And why there is no sense in asking for confirmation of forty documents at once: what you get is a run of automatic confirmations that weakens the ones that mattered.

There is a data question too: the receipt log is named, with date and time, and the employee representatives should know it exists, what it is used for and how long it is kept. Showing them beforehand is worth far more than justifying it afterwards.

1. 01

   A short list of documents that carry a receipt

   Write down which document types require confirmation. Five or six, not twenty. Everything else gets published without one.

2. 02

   A deadline, stated in the document itself

   'Confirm by Friday the 12th'. Without a deadline, the outstanding list never drops below twenty per cent.

3. 03

   A second pass, with names on it

   After three days, each site supervisor looks at who is missing on their site and sorts it at handover. Not the company-wide list: their own, short and actionable.

4. 04

   Close it out at the safety committee

   Outstanding receipts get reviewed where the rest of health and safety gets reviewed, not in a stray email. That is how it stops being the comms department's problem.