MENTAL HEALTH AND WELLBEING POLICY
Important legal-advice, jurisdiction and formality warning
This fictional policy is a worked example for an employer in England and Wales. It is not legal advice, is not a clinical protocol, does not diagnose a condition and does not create a contractual entitlement to a particular treatment or outcome. It must be checked against the Equality Act 2010, health and safety duties, working-time rules, employment contracts, sickness and capability procedures, UK GDPR and Data Protection Act 2018, safeguarding obligations, professional boundaries and current NHS and emergency guidance. It must not replace urgent medical or emergency assistance, occupational-health assessment or an individual reasonable-adjustments assessment. The employer must not make assumptions about a person's capacity, disability, reliability or safety because of a disclosure. Confidential health information must be restricted, recorded accurately and shared lawfully. Every name, date, address and example below is fictional.
Owner, purpose and status
This policy is issued by Hawthorn Quay Housing Association Limited, company number 12764018, 6 Lantern Quay, Bristol BS1 5RN. It applies from 5 September 2026 to employees, workers, apprentices, agency workers where appropriate, and managers working for or on behalf of Hawthorn Quay. The owner is Miriam Celeste Rowe, Director of People and Culture, at wellbeing@hawthornquay.example.test. The policy was approved on 28 August 2026 by Jonas Peter Whitfield, Chief Executive, and is scheduled for review on 5 September 2027. It is a non-contractual policy. It does not replace a contract, a sickness absence procedure, a disciplinary or capability process, a grievance route, an emergency service or professional medical care.
The policy uses “mental health” to include emotional wellbeing and mental health conditions without assuming that a diagnosis is present. “Wellbeing conversation” means a voluntary, work-focused discussion about support, workload and adjustments. “Manager” means the person's line manager. “Occupational health” means an independent clinical advisory service instructed to advise on functional impact, support and return to work, not to provide ordinary treatment.
1. Commitments and boundaries
Hawthorn Quay aims to provide a safe, respectful and inclusive workplace in which people can talk about wellbeing without being mocked, excluded or automatically treated as incapable. Bullying, harassment, victimisation and retaliation for raising a health or safety concern are not accepted. The organisation will consider mental health in risk assessments and service planning, consult affected staff, and take reasonable steps to remove or reduce disadvantage. It will monitor whether policies have an unequal effect and will use employee feedback without identifying individuals unnecessarily.
Wellbeing is a shared responsibility, but it is not an obligation to disclose a diagnosis. An employee may ask for a conversation without giving medical detail. Managers must not promise absolute secrecy: information may need to be shared with People, occupational health, safeguarding leads or emergency services where lawful and necessary to protect someone or comply with a legal duty. The person will be told what will be shared and why unless doing so would create a serious and immediate risk.
This policy does not make an employee responsible for counselling colleagues, assessing suicide risk, providing therapy or acting as a mental-health professional. A manager who is worried about immediate safety must follow the urgent response in section 7 rather than attempting a clinical assessment.
2. Prevention and healthy work design
Managers must plan realistic workloads, clarify priorities, provide appropriate resources, allow rest breaks, monitor excessive hours, make leave possible and address conflict promptly. Team meetings will include a workload check once each month. Managers will not reward routine out-of-hours messaging, and employees are expected to respect agreed working hours except for a genuine emergency or an agreed on-call duty. Work allocation will consider disability, pregnancy, religion or belief, caring responsibilities and other relevant circumstances without making stereotypes.
Hawthorn Quay will provide a quiet room at its Bristol office, confidential employee-assistance counselling through Lumen Support Services, and access to a wellbeing intranet page containing NHS 111 mental-health guidance and local crisis information checked by People each quarter. A staff member may contact the service directly at 0800 555 2470 or through the provider portal. The provider receives only information necessary to deliver its service and does not routinely tell Hawthorn Quay what an individual discussed.
The organisation will offer manager training each year on listening, boundaries, referral, adjustments, absence, confidentiality, suicide-alertness and avoiding discriminatory assumptions. Training is not certification in clinical care. Saira Louise Bennett, Learning Manager, will maintain attendance records and will offer an alternative format or reasonable adjustment. A manager who is not comfortable holding a conversation should say so respectfully and seek People support rather than avoiding the employee.
3. Raising a concern and support options
An employee may speak to their Manager, Miriam Rowe, the People team at wellbeing@hawthornquay.example.test, a trained wellbeing contact or their trade union representative. They may also use the grievance or health-and-safety procedure. The first conversation should focus on what the employee wants to share, the work impact, immediate safety, possible adjustments and the next review date. The employee may bring a workplace companion where the meeting concerns a formal process; an informal wellbeing conversation is not a disciplinary meeting.
Support can include a temporary reduction or reprioritisation of workload, a different work pattern, additional check-ins, a quiet workspace, written instructions, altered communication methods, phased return, time for appointments, an agreed emergency contact, a change of supervisor, leave, occupational-health advice or a referral to external support. The option chosen must be proportionate and reviewed. The employer cannot guarantee that every requested adjustment is reasonable or possible, and it will explain the reason if it cannot provide one and discuss alternatives.
The employee does not need to prove a diagnosis before asking for support. If medical or occupational-health evidence is needed, Hawthorn Quay will explain the purpose, seek consent where required, use the least intrusive information and pay any requested report cost. A refusal to consent will not automatically be misconduct, although the employer may have to decide based on the information available. A disabled employee's request will be considered under the employer's Equality Act duties, separately from a general wellbeing initiative.
4. Confidentiality and records
Managers must record only relevant factual information, such as the support requested, agreed action, review date and work restrictions. They must not write a diagnosis, speculation or personal account that is not needed. Health information is special-category personal data. People will store it separately from ordinary management notes with access restricted to staff who need it for employment, safety or legal reasons. Occupational-health reports will be handled according to their terms and will focus on functional advice.
The normal record of an informal conversation is the agreed action and date rather than a verbatim transcript. The manager will invite the employee to correct a factual error. Information may be shared with a manager, People adviser, occupational-health provider, payroll administrator or safeguarding lead only where necessary, lawful and proportionate. It may be shared with emergency responders where needed to protect life or comply with law. Managers must not discuss a colleague's condition in team chats or ask other staff to provide informal surveillance.
People will retain support and adjustment records for six years after employment ends, unless a shorter period is required or a longer period is necessary for a legal hold, claim or statutory reason. Occupational-health records will be kept according to the provider's retention terms, normally six years after employment ends. Access, correction and other data rights will be explained in the employee privacy notice, subject to lawful limits. A person can complain to the Information Commissioner's Office about data handling, but this does not replace an internal grievance or change an employment limitation period.
5. Absence, return and formal procedures
Mental-health-related absence is sickness absence and will be handled under the Sickness Absence Procedure with dignity and consistency. The employee should notify Daniel Marcus Cole, their People Adviser, by telephone at 0117 555 0186 before 9:00 a.m. on the first day, unless they cannot reasonably do so. The organisation will accept another reasonable method where communication itself is a barrier. A fit note, self-certification and review will be managed in accordance with current requirements, and no employee will be required to disclose more clinical information than is necessary.
Return-to-work meetings are supportive and will cover wellbeing, work capacity, adjustments, attendance expectations and any referral. A phased return is a temporary plan, not a promise of permanent reduced duties. The plan for Kieran Oliver Miles, Housing Officer, is illustrative of the level of detail required: after absence ending 14 October 2026, he will work four-hour mornings from 15 to 21 October, six hours on 22 to 28 October, and his normal 8:30 a.m. to 5:00 p.m. hours from 29 October, with a review on 21 October. The plan was agreed on the functional advice available and will be changed if evidence or experience shows it is unsafe or ineffective.
Capability, attendance, disciplinary or restructuring action must not be started merely because a person has disclosed a mental-health condition. If a formal process may be necessary, the manager must seek People advice, consider disability-related absence, reasonable adjustments, medical evidence, alternatives and the ACAS Code where relevant. An employee will receive the allegation or concern, evidence, reasonable time to respond, a decision and any appeal route. Mental health does not automatically excuse misconduct, but relevant circumstances must be considered fairly.
6. Bullying, trauma and workplace incidents
Employees can report bullying, harassment, violence, traumatic incidents, excessive workload or unsafe working through the grievance, dignity-at-work or incident-reporting route. A manager must not tell a person to resolve a serious concern informally if that would be unsafe or inappropriate. Hawthorn Quay will consider separating people, changing reporting lines, arranging a companion, preserving evidence and preventing retaliation. An employee may contact a union or another representative.
After a distressing housing, safeguarding, customer or workplace incident, the Incident Lead will offer a private debrief focused on immediate safety and practical support. The debrief is not a demand for a detailed trauma account or an investigation interview. Any investigation will be separate, fair and proportionate. Records about a customer or resident remain subject to confidentiality and data-protection rules.
Where work involves lone visits, risk assessments will consider communication, travel, violence, fatigue and access to urgent help. No employee must enter a dangerous situation to provide a service. The Manager may stop or redesign work while advice is obtained. Health and safety reports will not be treated as evidence of poor attitude.
7. Immediate risk or emergency
If someone is in immediate danger, has suffered a serious injury, is unable to keep themselves or another person safe, or says they intend to act imminently, call 999 or take the person to the nearest emergency department if it is safe. Do not leave the person alone if doing so would increase risk and do not promise secrecy. If there is no immediate danger but urgent advice is needed, contact NHS 111 and select the mental-health option where available, or use the current local urgent service. The employee-assistance service is not an emergency service.
A manager should move to a private safe place, listen without judgement, ask plainly whether there is an immediate safety concern, contact the emergency service where necessary, notify People as soon as practicable and make a factual record. The manager must not promise a particular clinical outcome, search personal belongings without lawful authority, or attempt to restrain someone except in accordance with law and immediate safety necessity. The organisation will consider the person's wishes and privacy while meeting safeguarding and life-protection duties.
If a colleague reports a concern about another person, the colleague should share only relevant facts with the Manager or People. Hawthorn Quay will not require staff to diagnose or investigate one another. After an emergency, People will arrange a welfare contact, consider leave and adjustments, protect confidentiality and review the incident for safety learning.
8. Managers, review and accountability
Managers must complete the agreed action, schedule a review, check workload and avoid intrusive questioning. Priya Nandita Shah, Regional Housing Manager, is the escalation manager for a concern involving a line manager. If the concern involves Priya, it goes to Miriam Rowe. A manager must contact People before making a decision about absence, performance, dismissal or a major change to duties where mental health may be relevant.
People will review anonymised uptake, absence patterns, adjustment delivery, training and staff survey results twice a year. Reporting will not identify a person in a small team. The policy will be reviewed with the recognised employee forum, Hawthorn Quay Staff Council, at its meeting on 21 August each year. Employees can suggest changes at wellbeing@hawthornquay.example.test. This policy does not prevent a person using a statutory, contractual or collective route.
Approval and acknowledgement
For Hawthorn Quay Housing Association Limited:
Jonas Peter Whitfield, Chief Executive Signature: ____________________ Date: 28 August 2026
Policy owner: Miriam Celeste Rowe, Director of People and Culture Signature: ____________________ Date: 28 August 2026
Employee acknowledgement: Kieran Oliver Miles, Housing Officer Signature: ____________________ Date: 5 September 2026
Acknowledgement records that the policy was provided and explained. It does not require a disclosure, waive a legal right, or turn this non-contractual policy into a term of employment.