Harassment duty from 30 October: a report form and a steps log for trades firms

Who it’s for

UK trades businesses with at least one employee or apprentice, or a labour-only subcontractor who has to do the work personally (plumbers, electricians, builders, roofers, cleaners, decorators), whose staff work in customers' homes or on shared sites

Time to set up

About 90 minutes once, then 15 minutes a quarter

Difficulty

Beginner

Monthly cost

£0

You help a small UK trades business prepare for the employer duties that start on 30 October 2026: taking all reasonable steps to prevent sexual harassment of staff, and not permitting staff to be harassed by third parties such as customers, other trades on site and members of the public. Use ONLY what I tell you about the business: never invent staff, incidents, policies or dates. Do not give legal advice and do not say the business is or will be compliant. PART 1, RISKS: list where my staff could be harassed, highest risk first, each with one line on why (for example working alone in customers' homes, young workers or apprentices, shared sites, alcohol at work events, power imbalances, messaging groups). PART 2, STEPS LOG: a table with columns Step, Who, By when, Reasonable for us? (Yes or No), Reason. Include steps such as a short written policy, more than one way to report, a named second contact if the owner is the problem, customer wording, induction and refresher talks, lone-working check-ins, and reviewing the log each quarter. If a step is probably not reasonable for a firm our size, say No and give a one-line reason. Use dates from today's date, which I give you. PART 3, CUSTOMER WORDING: one sentence for quotes and terms, and one for booking confirmations, saying we will not tolerate harassment of our staff and what we will do (for example stop work and leave). PART 4, TOOLBOX TALK: a five-minute script for the owner to read out, in plain words, covering what harassment is, that it includes customers, how to report (the form and the named people), and that nobody will be punished for reporting. RULES: British English, plain and direct. If I haven't told you something, or you're unsure of it, add a short note in brackets saying in plain words what to check, for example (check this date against your terms). Never ask for or include details of any real incident. Today's date: [paste]. About the business: [paste]

From Friday 30 October 2026, the law changes for every trades business with staff, and in equality law an “employee” can include a labour-only subcontractor who has to do the work personally (legislation.gov.uk). Employers will have to take “all reasonable steps” to prevent sexual harassment of their employees, and must not permit their employees to be harassed by third parties, which includes customers (GOV.UK). The commencement regulations, made on 1 October, bring both changes into force on 30 October (legislation.gov.uk).

Think about where your team actually works. An apprentice alone in a stranger’s kitchen. An electrician on a new-build site with 30 people from other firms. Your office manager taking a call from a customer who’s furious about the bill. The householder, the other firms’ workers and the customer don’t work for you, and from Friday, failing to take all reasonable steps to stop them harassing your staff is your problem in law. This guide gets you the cheap, sensible basics in an afternoon: a report form, an alert, a dated log of what you’ve done, and customer wording. It’s free, and no report ever goes near the AI.

What does this automation do?

1. ChatGPT turns a few lines about your business into a risk list, a dated steps log (with reasons for anything you decide not to do), customer wording and a five-minute toolbox talk.
2. A Google Form gives staff a way to report harassment from their phone, with or without their name.
3. Each report lands in a locked Google Sheet and emails the two people who need to know.
4. The steps log lives in the same sheet, so every quarter you can see what you’ve done and when.

What do you need before you start?

• A free Google account for the firm (ideally a business one, not a personal Gmail you share with family).
• A free ChatGPT, Claude or Gemini account.
• Your quote template, terms and booking confirmation, so you can add a line to each.
• 90 minutes, and ideally your office manager or a senior member of staff alongside you.

How do I set it up?

Step 1: Work out where your staff are at risk

Acas, the government-funded workplace advice service, says you should assess the risks in your own organisation and “must not assume that it will not happen” (Acas). Its list of higher-risk factors reads like a description of trades work:

• “meeting clients or service users alone”
• “an environment where people are drinking alcohol” and “work-related social events”
• “power imbalances between workers”
• “travelling for work, including overnight stays”

It adds that some people may be at higher risk, including “younger workers, including apprentices and interns”.

Then list who your staff meet. Acas says a third party “could be anyone a worker is in contact with through work” and names customers, clients, “self-employed consultants, contractors or tradespeople” and “other members of the public” (Acas). The Act’s own definition is simpler: anyone who isn’t you or another of your employees (legislation.gov.uk). For most trades that’s householders, landlords and tenants, the other trades on a shared site, site managers from the main contractor, and anyone who rings or messages the office.

Write five or six lines about your firm: how many people, what they do, where they work, who they meet, any work socials, any messaging groups. That’s what you’ll paste into the prompt.

Step 2: Draft your risk list and steps with ChatGPT

Paste your description and today’s date into the prompt below. You get four parts back:

• Risks, highest first, each with a reason.
• A steps log with columns Step, Who, By when, Reasonable for us? and Reason.
• Customer wording for quotes and booking confirmations.
• A toolbox talk you can read out in five minutes.

The steps log matters most. Acas says that “all reasonable steps” means “taking all of the steps that are reasonable for your organisation rather than just some of the steps”, and “focusing on preventing sexual harassment rather than only reacting to incidents” (Acas). It also says “Some steps will not be possible for every organisation” and that it’s “a good idea to record why you have not taken steps you’ve decided are not reasonable” (Acas). That’s why the log has a Reason column for every No.

Notice what goes in: a description of your business, nothing about any real person or incident. ChatGPT drafts; you decide every Yes and No.

Step 3: Tell customers, in your quotes and booking messages

Among the steps Acas suggests for third-party harassment are “reviewing client, customer and supplier contracts or terms of conditions to make sure they include relevant parts of the policy” and “telling customers the consequences of harassing workers, for example on posters or in emails” (Acas).

For a trades firm, that’s two sentences:

• In your quote and terms: that you won’t tolerate harassment or abuse of your staff, and what you’ll do (for example stop work and leave). If you link that to your cancellation terms, check the wording against your own terms first, or ask whoever wrote them.
• In your booking confirmation: a friendly line asking customers to treat your team with respect.

Most customers will never notice. The one who does has been told before your apprentice knocks on the door.

Step 4: Build the report form

In Google Forms, create a form called “Report a problem at work”. Keep it short enough to fill in on a phone in a van:

1. When did it happen? (date)
2. Where? (job reference or site, not the customer’s full address)
3. Who was involved? (choice: a customer or someone at the property, another trade or site worker, someone from our firm, someone else)
4. What happened? (paragraph, in your own words)
5. Do you feel unsafe now? (Yes or No, with a line underneath: “If you’re in danger, call 999. If you feel unsafe at a job, leave and ring the office.”)
6. What would help? (paragraph, optional)
7. Your name (optional), and how should we contact you? (optional)

In the form’s Settings, open Responses and make sure “Collect email addresses” isn’t set to Verified or Responder input, so the name question really is optional. Acas suggests “encouraging workers to report situations where they felt at risk, even if nothing happened” (Acas), so say that at the top of the form too.

Step 5: Lock down the responses and set the alert

Link the form to a new Google Sheet: in Forms, Responses › Summary, then More › Select destination for responses (Google). One line in Google’s help is the one to watch: “When you create a new response spreadsheet, form collaborators automatically get access to it.” So before you create the sheet, check who’s a collaborator on the form, and keep it to the two people who’ll handle reports.

Then turn on the alert: Responses › More › Get email notifications for new responses (Google). Both named people should do this, so a report reaches someone even if one of you is on holiday. And think about the case nobody likes: if the report is about the owner, the second person must be able to see it and act. In one of Acas’s examples, a co-owner makes the comments and the supervisor tells the worker they’ll need to “toughen up” (Acas).

Why the fuss about access? A report can include details about someone’s sex life or sexual orientation, which UK GDPR treats as special category data (ICO). The ICO says you must have “appropriate security” in place so personal data isn’t “accidentally or deliberately compromised” (ICO). A sheet that only two people can open, on an account with two-step verification, is a sensible start for a small firm. (The ICO notes that this security guidance is under review after the Data (Use and Access) Act.)

Step 6: Keep the steps log, with the reasons

Add a second tab to the same sheet called “Steps log” and paste in the table from Step 2, after you’ve edited it. Add two columns: Done on and Notes. Every time you do something (the toolbox talk, the new wording, a check-in rule), put the date in.

This is the record you’ll want if you’re ever asked what you did. The law already lets an employment tribunal add up to 25% to a sexual harassment award if the employer breached the prevention duty (legislation.gov.uk), and the EHRC’s guidance gives a worked example where a £40,000 award becomes £50,000 (EHRC). The EHRC guidance was last updated on 26 September 2024, so it explains the duty as it stood then (“reasonable steps”) and not Friday’s changes. The EHRC says it is “currently working to update this guidance”.

One more thing that changes on paper on Friday. legislation.gov.uk’s current text of section 40A still says employers “must take reasonable steps”, because the Employment Rights Act’s section 20, which inserts “all” before “reasonable steps”, isn’t in force yet (legislation.gov.uk). Don’t be thrown if you look it up this week.

Step 7: Tell the team, then repeat every quarter

Read the toolbox talk out to everyone, at the same time, before Friday if you can. Then:

• Put the form link in the WhatsApp group description and on the van key ring tag or job sheet, wherever your team will actually see it.
• Give it to every new starter on day one. Acas’s example of an employer doing it right covers the policy, training and how to report at induction (Acas).
• Every quarter, open the log, check what’s done, look at any reports for patterns (the same customer, the same site) and update the steps.

Acas suggests “having someone at senior level to make sure the organisation is taking steps”, which in a firm of six is you (Acas). There’s also a power in the Act for ministers to set out specific steps employers must take, by regulations “at a later date” (GOV.UK). We’ll update this guide if they do.

Step 8: When a report comes in

This is where automation stops. Don’t paste a report into ChatGPT, and don’t forward it around. Read Acas’s guide to handling a complaint before you need it (Acas). The short version:

• “take any complaint of sexual harassment seriously”, handle it “fairly and sensitively” and look into it “as quickly as possible”.
• Talk to the person privately and don’t rush them. Don’t suggest it’s not that serious, or ask if they’re sure they want to go ahead.
• Don’t move the person who complained “unless they ask to be moved”. Moving them can look like a punishment.
• If a customer is involved, you decide what’s reasonable: send someone else, send a pair, or stop working for them. Record what you did in the log.

Acas also points out that since 6 April 2026, sexual harassment is a “qualifying disclosure” under whistleblowing law, so you “must not use a non-disclosure agreement (NDA)” to stop someone whistleblowing about it or reporting a crime to the police. If it’s serious, or you’re unsure, ring the Acas helpline or get legal advice. And note the change from 1 October 2026: for most employment tribunal claims about something that happened on or after that date, someone now has 6 months minus 1 day, up from 3 months minus 1 day. If it happened before 1 October, the old 3-month limit still applies. Acas notes that “a few claims”, such as equal pay and statutory redundancy pay claims, already had 6 months minus 1 day before 1 October. Before they can claim, they must notify Acas, and the clock pauses during early conciliation. That pause “only applies if you notify Acas within your employment tribunal time limit” (Acas).

The copy-paste prompt

You help a small UK trades business prepare for the employer duties that
start on 30 October 2026: taking all reasonable steps to prevent sexual
harassment of staff, and not permitting staff to be harassed by third parties
such as customers, other trades on site and members of the public. Use ONLY
what I tell you about the business: never invent staff, incidents, policies or
dates. Do not give legal advice and do not say the business is or will be
compliant. PART 1, RISKS: list where my staff could be harassed, highest risk
first, each with one line on why (for example working alone in customers'
homes, young workers or apprentices, shared sites, alcohol at work events,
power imbalances, messaging groups). PART 2, STEPS LOG: a table with columns
Step, Who, By when, Reasonable for us? (Yes or No), Reason. Include steps such
as a short written policy, more than one way to report, a named second contact
if the owner is the problem, customer wording, induction and refresher talks,
lone-working check-ins, and reviewing the log each quarter. If a step is
probably not reasonable for a firm our size, say No and give a one-line
reason. Use dates from today's date, which I give you. PART 3, CUSTOMER
WORDING: one sentence for quotes and terms, and one for booking confirmations,
saying we will not tolerate harassment of our staff and what we will do (for
example stop work and leave). PART 4, TOOLBOX TALK: a five-minute script for
the owner to read out, in plain words, covering what harassment is, that it
includes customers, how to report (the form and the named people), and that
nobody will be punished for reporting. RULES: British English, plain and
direct. If I haven't told you something, or you're unsure of it, add a short
note in brackets saying in plain words what to check, for example (check this
date against your terms). Never ask for or include details of any real
incident. Today's date: [paste]. About the business: [paste]

What can go wrong?

• A form nobody knows about. A link buried in a handbook isn’t a way to report. Put it where the team looks every day, and say it out loud.
• One route that runs through the person being complained about. If every report goes only to the owner, a report about the owner goes nowhere. Two named people, both with alerts.
• A response sheet half the office can open. Check the form’s collaborators before you link the sheet. When someone leaves, remove them from both the form and the sheet: Google doesn’t copy later permission changes across.
• “It’s part of the job.” That’s the line Acas uses in its example of an employer who very likely didn’t take all reasonable steps against third-party harassment. Walking off an abusive customer’s job has to be something your staff know they’re allowed to do.
• A log that stops in November. A steps log with one date in it shows you did something once. The quarterly review is what keeps it honest.
• Treating this guide as legal advice. It’s a practical starting point built on Acas and the legislation. For anything serious, take advice.
• Outside Great Britain. The Equality Act 2010 covers England, Wales and Scotland. Northern Ireland has its own equality law, so this guide doesn’t cover it.

Your staff’s time on the phone is easier to manage with the missed-call text-back, and the customer wording from Step 3 drops straight into the template in the voice note to quote guide. If you work under CIS, the CIS invoices and monthly statements guide keeps the paperwork straight. One practical automation like this, with the £ and the hours it saves, lands in your inbox every Friday if you join our free email.

Frequently asked questions

Sources

1. GOV.UK (DBT): Plan to Make Work Pay and Employment Rights Act timeline update (updated 22 October 2026)
2. legislation.gov.uk: The Employment Rights Act 2025 (Commencement No. 6 and Transitional and Saving Provisions) Regulations 2026, regulation 3 (SI 2026/1065)
3. legislation.gov.uk: Employment Rights Act 2025, section 20 (all reasonable steps)
4. legislation.gov.uk: Employment Rights Act 2025, section 21 (harassment by third parties)
5. legislation.gov.uk: Equality Act 2010, section 40A (employer duty to prevent sexual harassment)
6. legislation.gov.uk: Equality Act 2010, section 124A (compensation uplift)
7. Acas: Third party harassment (harassment law changes)
8. Acas: Sexual harassment (harassment law changes)
9. Acas: Preventing sexual harassment
10. Acas: Handling a sexual harassment complaint
11. Acas: Employment tribunal time limits (last updated 1 October 2026)
12. legislation.gov.uk: SI 2026/954, regulation 4 (time limits: transitional provisions)
13. legislation.gov.uk: Equality Act 2010, section 83 (who counts as employed)
14. Acas: What sexual harassment is
15. EHRC: Sexual harassment and harassment at work, technical guidance (last updated 26 September 2024)
16. ICO: What is special category data?
17. ICO: A guide to data security
18. Google Docs Editors Help: Choose where to save form responses
19. Google Docs Editors Help: View & manage form responses

This guide is general information, not legal, tax or financial advice. Tool prices and screens change; we re-check every guide regularly. Spotted something out of date? Tell us and we’ll fix it.