DSE record keeping: what to keep, for how long, and why

The regulations do not prescribe a retention period or a record format. That is not the same as saying records do not matter. When a DSE issue turns into a dispute, the record is the entire case.

What a defensible record contains

The assessment itself

The answers given, dated, attributable to a named person. Not a summary.

The findings

What the assessment identified, ideally with a severity or priority against each.

What you did

The action taken against each significant finding, with a date. This is the part that matters most.

Equipment issued

What was provided and when, which also doubles as your asset record.

Training and information

Evidence people were told about the risks, their eye test entitlement and break arrangements.

The review date

When it will next be looked at, so the record does not silently age out.

How long to keep it

Six years is the common practice, and the reasoning is sound. The limitation period for a personal injury claim is generally three years from the date of knowledge, and date of knowledge can fall well after the exposure. Six years gives sensible headroom and aligns with other business record retention.

Data protection, because it is health data

DSE assessments routinely capture information about aches, pains, conditions, disabilities and pregnancy. That is special category data under Article 9 of the UK GDPR, and it needs handling accordingly.

• Limit access to the people who need it to act, normally the line manager and whoever handles health and safety.
• Be clear with employees, before they start, that their completed assessment will be visible to administrators.
• Do not copy health details into general HR systems or email threads.
• Set a retention period and actually apply it, rather than keeping everything forever by default.
• Record your lawful basis. For most employers this is the employment law obligation under Article 9(2)(b).

What happens when you cannot produce one

Two scenarios, both realistic for a small business.

An HSE inspection. The inspector asks how you assess DSE workstations. Without records the conversation moves quickly from a discussion to an improvement notice.

A claim. An employee alleges their working conditions caused a musculoskeletal injury. Your defence rests on showing you assessed the risk and acted on it. Without a record, you are asking a court to accept that you did something you cannot evidence.

Keeping it manageable

For a small business, a folder per person containing the assessment PDF and a one-line action log is enough. What matters is that it is complete, dated and retrievable, not that it is sophisticated.