From reactive to proactive: what the new sexual harassment duty really demands
From October 2026, UK employers face a tougher legal bar. Instead of taking "reasonable steps" to prevent sexual harassment, they'll need to show they've taken "all reasonable steps," a standard that will factor into tribunal compensation decisions and vary depending on an organisation's size, sector, and resources.
In a new article for HR Magazine, our Co-founder & CEO Gemma McCall sets out why the shift changes what good practice looks like in practice, and why data has to be part of the answer.
One line captures the risk of waiting too long:
"If a concern only arises once it's already become serious, it's already too late."
This is the core problem with treating a reporting channel as a box-ticking exercise. Many organisations have a way for employees to raise concerns, but few are reviewing what comes through it for patterns. A single report might look like an isolated incident. Ten reports pointing to the same manager, team, or time of year tell a very different story, one that gives HR a chance to intervene before a situation escalates into something serious. Under the new duty, that kind of pattern-spotting is not a nice-to-have. It's part of what "all reasonable steps" is likely to mean in practice.
What Gemma says here gets to the heart of the mindset shift required:
"Handling cases that have already happened isn't the same as preventing them."
This distinction matters because it's easy to conflate the two. Responding well to a report, investigating it fairly, and resolving it properly, is good case management. But it's still reactive. Prevention means looking at reporting data over time, spotting hotspots, testing whether interventions are actually working, and adjusting where they're not. Only 43% of senior HR professionals currently say they use reporting insights this way, which suggests most organisations still have work to do before the October deadline.
Neither of these ideas requires organisations to build something from scratch. They require using what's already being collected, more deliberately.
Read the full article on HR Magazine.
.png)
What we're reading
Latest insights from the front lines of workplace culture.
What the FCA's Q2 2026 whistleblowing data tells regulated firms about culture risk
The FCA published its whistleblowing data for Q2 2026. Containing 886 allegations, 339 of which are related to misconduct and poor reporting systems.
The 29% Blind Spot: What HR Leaders Don't Know About Their Own Workplace
In the Culture Shifters Annual Report 26/27, we asked UK HR professionals a direct question: are you confident that all levels of workplace misconduct are reported and visible within your organisation? Just 71% said yes. That leaves 29%, almost three in ten HR leaders, openly acknowledging that they do not have full visibility of what is happening across their own workforce.
%20(1).png)
Speak Up Culture & Evidencing Compliance for Your Ofsted Inspection
Join Stefan Jordan, Colchester Institute's Director of Inclusion and Wellbeing, with Culture Shift Co-Founder, Gemma McCall, as they break down what Ofsted's new further education and skills inspection toolkit actually expects from you on speaking up, follow-through, and staff protection.
Feeling inspired?
Take the first step toward preventative misconduct management with a demo of our Report + Support™ platform. We can show you how to breakdown reporting barriers with anonymous 2-way messaging, and how to act before things escalate with name-matching and pattern-spotting across our analytics dashboard.
