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Eyeballing staff

A new portable eye scanner just on the market will allow employers to test workers for drink and drugs more easily and cheaply. But will this contravene their human rights? Paul Griffin, senior associate at Norton Rose, talks to Mary Luckham�

About 5% of employers currently test workers for drink and drugs but this number is increasing. Testing can be costly and invasive but a new portable eye scanner, the �Eye Check Pupilometer�, which has just come on to the market can tell instantly if an employee�s reaction is impaired due to drink, drugs or fatigue.

Will Big Brother soon be watching us all? Not, according to Paul Griffin senior associate at Norton Rose: "The first point to make here is that employees can�t be forced to do anything. Such a test can only be carried out with an employee�s consent; there would be no question of pinning down employees and forcing them to undergo such a test!".

Problems could arise, he thinks, where an employee refuses to take a test. The employer will then have to consider whether it is able to discipline or dismiss the employee.

Firstly, he says: "The question is whether the employer will be in breach of the Human Rights Act in doing anything to the employee for refusing to take the test. That would be the first issue which needed to be addressed. Secondly, whether the employer was in breach of the implied term in a contract of employment of mutual trust and confidence."

He continues: "I think it would be important to establish whether the employer has a policy. That it has made it quite clear in the policy and communicated it to the employees that, firstly they don�t accept drink and drugs in the workplace and what they would require the employee to do in order for the employer to test to see whether they had been taking anything. It would not be enough for an employer to put this in a policy and stick it on the shelf � it would need to be constantly communicated to employees - for example put on noticeboards and intranet."

His view is that random testing of employees would, in most circumstances, contravene the human rights of employees in that he points out: "One of the factors in deciding if a human right has been breached would be the proportion of the response of the employer. For example, if somebody comes back from lunch, reeling then it would be a proportionate response to ask them to take a test but if everybody was just walking back from lunch and had to take a test randomly then that is unlikely to be viewed as a proportionate response. This could contravene the Human Rights Act."

He acknowledges that there would be exceptions to this in circumstances where the drunkenness of an employee could put others in danger such as workers on oil rigs or, perhaps bus drivers and pilots and comments: "Perhaps in situations like that it would be possible to justify random testing."

Another important issue here is, he thinks: "Where the employee agrees to the eye test, the results would become subject to the data protection legislation. It would amount to sensitive personal data because it is potentially related to the employee�s health. That data can only be processed with the employee�s explicit consent. To publish such data without this explicit consent could lead to criminal sanctions."

(02/10/03)

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