Third-Party Harassment Toolkit
Harassment doesn't just come from colleagues. Customers, clients, patients, contractors and members of the public can create an unsafe or hostile environment for your staff - and from October 2026, employers will be directly liable for it. This playbook gives you a clear, practical guide to understanding the risk and putting the right protections in place before the law changes. Download it to get:
A breakdown of the legal changes and what they mean for your organisation
The risk areas to look out for, from customer-facing roles to lone working and events
Practical guidance on prevention, reporting, and response
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More about our Third-Party Harassment Toolkit
Third-party harassment is a bigger risk than most employers realise. NHS staff alone reported almost 24,000 incidents of sexual assault and harassment by patients and the public between 2022 and 2025. McDonald's had to enter into a formal agreement with the EHRC after concerns about how it handled harassment complaints across its UK restaurants. These aren't edge cases - they're a preview of the scrutiny every employer is about to face.
Since October 2024, the Worker Protection Act has required employers to take reasonable steps to prevent sexual harassment - including harassment from third parties. But the Employment Rights Act goes much further. From October 2026:
- Employers become directly liable for harassment by third parties against their workers
- Protection extends beyond sexual harassment to cover all protected characteristics
- Employers must show they took all reasonable steps, not just some
- Liability can apply from the first incident - there's no need for a pattern to build up first
For employers, this is a shift from reacting to incidents to actively preventing them. That means risk assessments, visible policies, trained managers, accessible reporting, and a track record of taking concerns seriously - even when the person responsible is a customer, client, or senior stakeholder.
This toolkit walks you through exactly what's required, what the risks look like across different sectors, and the practical steps you can take now to get ahead of the legislation - rather than scrambling to catch up when it lands.
Download your copy
FAQs
Questions? We've got answers.
Third-party harassment is harassment by someone who isn't employed by your organisation - customers, clients, patients, students, contractors, suppliers, consultants, event delegates, or members of the public. It can relate to any protected characteristic, not just sex.
Yes. Since October 2024, the Worker Protection Act has required employers to take reasonable steps to prevent sexual harassment, including third-party harassment. The EHRC has confirmed this duty covers third-party conduct, not just colleague-to-colleague behaviour.
Under the Employment Rights Act, employers will be directly liable for third-party harassment, protection will extend to all protected characteristics (not just sex), the bar rises from reasonable steps to "all reasonable steps," and liability can apply from the very first incident - no pattern of behaviour needs to build up first.
Still have questions?
The ever-changing regulatory landscape can be tricky to navigate - we're here to guide you through what your organisation needs to do to stay compliant and protect your people.
Your partner in preventing workplace misconduct
Misconduct rarely starts as a headline issue - it starts with something small that goes unaddressed. Culture Shift helps organisations surface concerns early, respond consistently, and embed long-term cultural change through our Report + Support™ platform, trauma-informed training programmes, and community-led best practice.
