Can the company see who uses it? The answer you need to have ready
The question employees and unions ask most. What HR sees in the report, what it doesn't, and how to say it in three sentences.
When you announce psychological support at an all-staff meeting, one question always comes up, and it's always the same one. Sometimes the union rep asks it, sometimes someone in the back row. “So will the company know who's using it?” Whether anyone signs up depends on the answer. Have it ready: short, and true.
The short answer
No. The employer can't see who uses it, who they talk to or what about. That answer has to be just as true for the CEO, the HR director and the line manager. If anyone in the company can see a list of accounts, the answer is different, and people will sense it.
Here's how it works. Employees register themselves, on their own device, with their own password. They can use a personal email address, or a company code if they don't have a work inbox. They book sessions directly with a specialist. The date, the topic, the specialist's notes, the number of sessions, the results of any self-assessments they took: all of it stays between them and the specialist. None of it reaches the employer, with a name or without one. The same goes for registration details: the company doesn't get a list of the email addresses or phone numbers people gave when they signed up.
What the company gets is an aggregate report. It shows how many people have created an account, how many sessions took place, which topics came up most often and how the anonymous surveys turned out. The report only covers a group once it passes a set minimum size. Below that threshold the company sees nothing, not even a number. This stops the situation where, in a small team, “someone's using it” and it's easy to guess who. At Mindgram we call this the aggregation threshold.
What HR can and can't see
HR can see:
- the number of registered users across the company and in groups above the threshold,
- the number of sessions and workshops held,
- the most common topics: stress, sleep, relationships, money, family,
- aggregate results from anonymous wellbeing surveys,
- trends over time, for example whether conversations about burnout went up this quarter.
HR can't see:
- who has created an account,
- who talked to whom, or how many times,
- what was said in sessions, the specialist's notes, or any diagnosis,
- individual test or survey results,
- any data from groups below the threshold, including a team where one particular person works.
You can print this list and put it on the intranet next to the sign-up link.
If a provider offers a report broken down by department or location, ask what group size the data starts at. A group below the threshold should disappear from the report entirely, registration numbers included. Even “not enough data” next to the name of a small team gives something away.
How to explain it
Three sentences you can say at a meeting and paste onto the intranet:
- “You sign up yourself. Nobody in the company gets a list of accounts.”
- “What you talk about with the specialist stays between the two of you. The company has no access to it.”
- “The company only gets overall numbers, and only once a group is above a set size. You can't tell from them who's using it.”
Don't say “your data is completely secure” or “we guarantee anonymity”. That's terms-and-conditions language and it reassures nobody. What works is describing the mechanism: who signs up, what the company gets, from what point. People trust a mechanism, not adjectives.
Put it in your own words. If you have unions, tell them the same thing separately, before the staff meeting. A union that heard the answer first will pass it on to its members. A union that heard it at the same time as everyone else will set out to check it.
On the intranet, these three sentences should sit directly above the sign-up link, not in the terms on a separate page. People read them at the moment they're deciding whether to click.
Someone won't believe you. They'll say: “Go on then, show us the report.” Show them. Print the latest aggregate report and put it on the table. You don't need to black anything out, because there's nothing to black out. People will see a table of numbers and topics, with no names and no departments below the threshold. A sheet of paper they can pick up settles it better than half an hour of reassurance. If you're only just launching and there's no report yet, show them the provider's sample report.
Managers are a separate matter. Some will quietly ask HR: “Can I check whether anyone on my team is using it?” The answer is the same: no. Ideally they hear it before they ask, for example at a managers' briefing before the announcement.
GDPR in one paragraph
The data controller for session data is the support provider, not the employer. The employer buys the service and makes it available to staff, but doesn't decide how the data is processed and can't see it. Employees give their data for one purpose: to use the support. The legal basis is the service agreement they enter into with the provider when they register, and for health data, their explicit consent. Health data is a special category with stricter rules, so the provider can't pass it to the employer even if the employer asks. The employer only receives statistical data that can't be used to identify anyone. The contract between the company and the provider should say this explicitly, and you can show that part of the contract to the unions.
Before you announce the support, save the three sentences from this article in a note on your phone. The question will come up at the first meeting and you won't have time to look for them.



