My new company has sent me the insurer forms to fill in for the private health insurance they offer as part of the employee benefits. All costs are covered by the company.
The insurance is entirely optional, I am not obliged to subscribe.
In these insurer forms, the disclosure of my full medical records is required, since I have never been registered with a UK GP before.

I asked the HR person if it would be possible to forward the form and my medical records directly to the insurance company, but they said no. I should send the forms and attachments back to them, and they would forward it to the insurer.

Is it normal practice to disclose your full medical records to your employer in the UK, for private insurance purposes?
Some UK companies do let you send the information directly to the private insurer?

  • 6
    Check with a lawyer - this is very UK and medical record specific...
    – Solar Mike
    Commented Apr 4, 2020 at 16:01
  • 2
    @SolarMike While I think a lawyer might help with the legality of the disclosure, I don't think my two questions are about legality.
    – Adam Smith
    Commented Apr 4, 2020 at 16:07
  • 9
    While I don't know the answer, as an EU citizen, this looks like a serious breach of privacy. Medical records are sensitive personal data. (Most of the time, occupational health checks should only include a fit / unfit decision, only revealing the reasons to the employee.)
    – andyz
    Commented Apr 4, 2020 at 16:21
  • 2
    I suggest contacting the health insurance company directly. They may tell you a different story.
    – TonyK
    Commented Apr 4, 2020 at 16:37
  • 2
    @O.Jones It is an addition to the NHS coverage. I would not say it is uncommon for engineers, I have seen it in most of the job offers I got. Since I am relocating from another country to the UK, I do not know how things work there. That is why I am asking.
    – Adam Smith
    Commented Apr 4, 2020 at 17:25

4 Answers 4


In the UK the use and processing is governed by the Data Protection Act.. This is a law that requires companies to use and store your data only for relevant specific purposes and under strict regulations. If the company has a relevant reason for having your complete medical history (a real reason, not just in their opinion) they can make you give it. If not they cannot. I am not a lawyer but in my view the company has no legitimate reason to ask for your medical records, and I have never encountered a company in the UK or elsewhere that asked for them, even when private insurance is offered. Sending your records direct to the insurance company (who are forbidden from passing them on without your consent) is normal, and most don't even need that. There is huge potential for abuse if your employer had unrestricted access to your medical records.

In your place I woul research the Data Protection Act a little. Then I would write to the company and ask specifically what use they will be putting the data to and what restrictions they have on its use under the DPA, including who they might be provided to. Make it clear you are aware of the DPA restrictions. Say you are happy to provide your medical records to medical practitioners.

If I were you, unless the company provides a compelling reason to have the records (and I can't think of a valid one) I would decline. However be aware that this is a high risk strategy as the company may rescind their job offer, and while my amateur opinion is that would be illegal, even if it were true proving it would be very hard.

You might consider consulting a UK lawyer. If a lawyer were to tell you that making your employment conditional on medical records was illegal, passing that on to the company might convince them to drop the request. However a company prepared to ask for illegal information is probably shady in other ways.


According to comments the employer is asking only that you send them the records so that they can be forwarded to the insurer. In that case they have some legitimacy. However I would still be cautious. My preference would be to tell the employer that you will forward the records directly to the insurer. I would also contact the insurer to verify that they absolutely require the records rather than just would like them (again in my experience most insurers don't need them). If they do then check the form for a statement saying that they will not forward the records to anyone without your consent (this is normal practice) and mail the records directly to them. Thank the employer for their kind offer to do the forwarding, but say you prefer to deal with the insurer directly. At the very least you should put the records and the form in a sealed envelope addressed to the insurance company and marked "confidential" and send it to your employer for forwarding.

  • 1
    Thanks for the great answer! I think there is a slight misunderstanding though. They sent me the form from the insurer. The insurer asks for my full medical records in the form. I asked them if I should mail the form and the required medical records to the insurer, but they said I should send everything back to them and they would do the forwarding to the insurer. The work contract is already signed. The private health insurance benefit is optional, but since it is the company that pays, I was willing to get it as well.
    – Adam Smith
    Commented Apr 4, 2020 at 18:29
  • 3
    Please can you edit this information into the question. Commented Apr 4, 2020 at 21:08
  • Only one of many employers demand my medical record: a summer camp where I would be far away from docs and hospitals for many days at a time. They would have cared for me if I fell ill (Wilderness First Responders, what fun!) It was perfectly justified.
    – O. Jones
    Commented Apr 5, 2020 at 0:32
  • 1
    That's not completely unreasonable. Please edit the question to include this information. You can use the edit button below the question. Commented Apr 5, 2020 at 13:45
  • 1
    @AdamSmith, If you need a reason to say "no". Just say that your own medical doctor refuses to forward your medical records to your new employer and refuses to give them to you, but that he will gladly forward them to the new insurance company. Of course, you may want to speak to your current medical doctor first. Commented Apr 6, 2020 at 20:31

Ah, in a comment you said you are relocating from another jurisdiction. That gives you an opening to ask the company's benefits person (HR) to explain more fully, and you should do that.

"I'm not from here, so could you please help me understand this private insurance benefit? Why does the employer and not the insurer need to see my records? Where I come from that's not the usual way."

If you ask for information instead of challenging their "right" to this info, you'll almost surely get the answer you're trying to get from us.

  • Thanks for the answer. I think you advice is applicable for my case. I would just like to clarify that the forms are from the insurer. I asked the company if I should send the filled in forms directly to the insurer, but they said to send everything back to them, and they would forward it to the insurer.
    – Adam Smith
    Commented Apr 4, 2020 at 18:37

I'm not sure how your medical records are compiled. But if they are a collection of individual pieces of paper, put together, then there is nothing your employer can do if you give a subset to them and arrange for full disclosure to the insurer. Just make sure you are not dealing with an idiot at the insurance company. Your employer doesn't need to know about the time you had a dildo surgically removed from your butthole


Is it normal practice to disclose your full medical records to your employer in the UK, for private insurance purposes?

Yes this is normal. I take it you're not originally from the UK, but yes this is normal. They are trying to work out what it will cost and what you will be covered for which they need to assess you medical history. Most of the private health insurance in the UK specifically did not cover pre-existing conditions even if you don't even know about them. So if you get a problem the day after you are covered and it turns out the problem happened years ago they won't cover that. They often don't cover major things that will cost a lot of money like cancer. You also have to watch your taxation details here.

Some UK companies do let you send the information directly to the private insurer?

I've never heard of that but you can phone the insurance company in question if you have questions.

  • Surely the company is not equipped to perform a medical assessment. This sounds like something that the insurance company should do. Basically they generate a dollar figure and the company can decide to go ahead or not. Commented Apr 6, 2020 at 11:14

You must log in to answer this question.

Not the answer you're looking for? Browse other questions tagged .