October 2026

Sexual harassment risk assessment

This is practical commentary for people, HR, and compliance leaders — not legal advice. Confirm commencement dates, wording, and what the 2027 regulations require with qualified UK employment counsel before you rely on any of it in a policy or a board paper.

Sexual harassment risk assessment

A sexual harassment risk assessment is how the preventative duty becomes local. The EHRC puts it at step 3 for a reason: training that ignores the assessment is decoration. Most templates stop at environments — the Christmas party, lone working, the warehouse at night. Those matter. They are not the whole risk.

The conversation is also a risk. Which roles have to handle a complaint, confront a colleague, or manage an abusive customer — and has anyone checked they can? That is the part almost every downloaded template misses, and it is the part all reasonable steps will test.

Copy the template, print it, put it in the file you would hand to counsel. Then look at the rows you scored “high” on conversation and ask whether your only control is a video.

Why most templates are only half an assessment

Environment assessments ask: where could this happen? Alcohol. Hierarchy. Customers. Uniforms. Messaging apps. Off-sites. Good. Do that.

They do not ask: when it happens, whose mouth has to work? A night manager who has never practised shutting a guest down is a different risk from a night manager who has. A line manager who will receive the first disclosure is a risk even in a well-lit open-plan office with no Christmas party.

The status quo treats skill as implied by job title. If you are a manager, you can take a disclosure. If you are an agent, you can handle an abusive caller. The preventative duty does not work like that. Gehlen is about training that was too thin to count. An assessment that never names the unrehearsed conversation is how you end up with thin training: you never saw the gap, so you never bought the step.

How to do a sexual harassment risk assessment

Keep it ugly and specific. A polished PDF with another company’s floorplan is not your assessment.

  1. Do it with people who work the risk, not only the people team. Night team. Contact-centre coaches. The PA who books the client dinners.
  2. Split environments from conversations. Same workshop, two lists. They interact — a client dinner is an environment; the bystander sentence is a conversation.
  3. Name roles, not “staff.” “Managers” is not a control owner. “Shift supervisors on store 14” is.
  4. Record whether competence has been checked. Trained (module) is not the same as practised (spoken, scored, dated).
  5. Date it and say when it will be wrong. After a restructure, a new channel (chat, social), a serious incident, or twelve months — whichever comes first.
  6. Feed it into the syllabus. High conversation risk without practice is the manager training and third-party work, not another all-staff click.

This is not legal advice. Counsel should see the finished document. The template below is the shape we see missing.

Template: environments

Sexual harassment risk assessment — environments

Use one row per location, channel, or event type. Add rows. Delete what you do not have. Do not leave “N/A” on customer-facing lines because the head office is quiet.

Environment / situationWho is presentPower / alcohol / isolationExisting controlsResidual risk (L/M/H)Further stepsOwnerReview date
Open-plan office / hot-desking       
1-1s behind closed doors       
Night / lone working       
Uniform / appearance-focused roles       
Customer-facing floor (retail, hospitality, care)       
Contact centre / phone / chat       
Client sites, travel, overnight       
Work events with alcohol       
Messaging, email, social adjacent to work       
Third-party contractors on site       
Performance / bonus / tips culture       
(Add your actual sites)       

Prompts the generic template never asks

  • Where do customers or clients have unsupervised access to workers?
  • Where is the worker’s pay or tips in the other person’s gift?
  • Where would a junior person have to challenge someone more senior in public?
  • Which channels are recorded (calls) and which are not (WhatsApp, car parks, smoking areas)?

Template: conversations

This is the half most risk assessment templates omit. It is also the half that tells you whether the duty can actually be discharged.

Sexual harassment risk assessment — conversations

For each conversation, name the role that has to do it, whether they have practised it (not only watched a module), and what you will do about people who have not.

ConversationRoles who must handle itHow often it could arisePractised? (Y/N, date)If unrehearsed, what happensFurther stepsOwner
Colleague discloses harassment and asks you to keep it quietLine managers, shift leads     
Private follow-up after inappropriate banter (no formal complaint yet)Line managers     
Bystander intervention in a meeting or on the floorManagers and peers     
Shutting down a customer / client who crosses a lineAgents, hosts, reception, security     
Live escalation of a third-party incidentSupervisors on shift     
First conversation with a complainantHR, designated officers, investigators     
Interview with the accusedInvestigators     
Naming retaliation / cold-shoulder after a complaintLine managers, HR     
Telling a high performer their joke is now conductSenior managers     
(Add the conversation your last incident actually was)      

How to fill “Practised?”

  • Yes means a dated spoken attempt against a scenario that matches this row, with a score or observed pass. Classroom discussion does not count.
  • No means the control is hope. Under all reasonable steps, hope is not a step.

Map “No” rows to the evidence checklist. The disclosure conversation is Please don’t tell anyone. The banter follow-up is this practised conversation. Third-party shut-down sits with customer-facing teams. Once it is a complaint, the skill is different: investigation and first conversation.

What to do with the scores

An assessment that does not change the syllabus is a risk register for the drawer.

  • High environment, low conversation skill — do not only add CCTV or a poster. Add the practised response. For phones, that is a customer service cohort, not a respect module.
  • High conversation, untrained role — those people are in scope for manager or investigator practice before the next rota. If they cannot be practised in time, they should not be the designated route.
  • Everything “medium” — you have not looked. Force a ranking. The duty is about your risks, not a smooth heatmap.
  • Review after the thing you were afraid of — if a real incident happens, the assessment was either right (and the control failed) or wrong (and you missed the row). Write down which.
realtalkstudio.com
A workplace scene representing the evidence question
The assessment should make the evidence question answerable: who was in scope, what they practised, when.

Real Talk Studio does not replace the assessment. It is what you attach to the conversation rows: a dated, scored attempt for the people whose mouths the duty actually runs through. See conduct-risk practice and how we evidence competence.

FAQ

Frequently asked questions

01What is a sexual harassment risk assessment?

A documented look at how sexual harassment could happen in this workplace — environments, third parties, power, and the conversations that have to work — plus the steps you will take. The EHRC lists it as a core preventative action.

02Is there a statutory risk assessment template?

No single government form. The EHRC expects you to assess and reduce risk. Use a template that matches your operations. The one on this page is ungated; have counsel review what you actually file.

03Should the assessment include customers and callers?

Yes, if your people face them. From 30 October 2026, third-party harassment is standalone liability. An assessment that only covers colleagues is incomplete for a contact centre or a shop.

04How often should we repeat it?

When the workplace changes, after a serious incident, and on a planned cycle — annually is a common minimum, not a legal magic number. Stale assessments have the same problem as stale training.

05How does this connect to training?

Training should follow the assessment. If managers taking disclosures are a high row, manager e-learning is not the matching control. Practised conversations are.