Employee Health Data Confidentiality in Egypt: An HR Guide Under Labour Law 14 of 2025
Quick answer
Employee medical examinations are common in Egyptian companies, but what happens to the results matters as much as the test. A practical HR guide to confidentiality, consent, access control and working with an external medical provider.
Under Egypt's Labour Law No. 14 of 2025, employers must keep medical examinations of employees confidential and must not disclose an employee's health status. In practice this means HR should collect only the health information it needs, restrict who sees results, share with managers only a simple work-fitness outcome rather than diagnoses, and choose a medical provider that holds clinical records itself. This guide explains how, using only what the law's published summaries state and general data-protection good practice. It is not legal advice.
- The law was published in the Official Gazette on 3 May 2025 and took effect on 1 September 2025, according to a law-firm summary by Arinite.
- Summaries of the law state that employers may request medical examinations for drug use or infectious disease, must keep examinations confidential, must not disclose an employee's health status, and employees may appeal the results (sources: Arinite; Sadany & Partners via Legal 500).
- Employers must also comply with decisions of the competent medical authorities on sick leave or health-related work prohibitions (Sadany & Partners via Legal 500).
- The published summaries do not say which examinations are mandatory, who pays, or what penalties apply to health-data breaches. Confirm these points in the official text of Law 14 of 2025, its executive regulations and with your legal counsel.
- Best practice: separate clinical results (held by the medical provider) from the work-fitness decision (shared with HR).
Why confidentiality matters for HR
An employee's examination result can reveal a diagnosis, a medication, a pregnancy or an infection. If that information circulates among colleagues or managers, it can lead to stigma, unfair treatment and loss of trust, and it can expose the company to legal risk. Egypt also has a Personal Data Protection Law, Law No. 151 of 2020, which regulates the handling of personal data; ask your counsel how it applies to the health information your company holds, because we have not verified its detailed provisions for this article.
What Labour Law 14 of 2025 says about medical examinations
The summaries we reviewed agree on a short list of points. Employers may request medical examinations to detect drug use or infectious disease. Those examinations must be conducted confidentially, and employers must not disclose an employee's health status. Employees have a right to privacy regarding these examinations and a right to appeal the results. Employers must also comply with the decisions of the competent medical authorities on sick leave or health-related work prohibitions. Employees in hazardous or unhealthy jobs receive an additional seven days of annual leave. The law came into force on 1 September 2025.
A practical confidentiality framework for HR
1. Collect the minimum
Define in writing which examinations each role needs and why. A desk-based role and a role involving food handling, driving or work at height do not need the same tests. Do not ask for diagnoses, medications or family history unless a clinician needs them for the specific assessment.
2. Let the medical provider hold the clinical file
Clinical records such as lab results, imaging and doctor notes should stay with the medical provider or the company's own clinician under their professional confidentiality duties, not in the HR folder. HR receives a short outcome.
3. Share a work-fitness outcome, not a diagnosis
A simple outcome format works well: fit for the role, fit with defined adjustments, temporarily not fit and review date, or not fit. The line manager sees only what they need to apply an adjustment, never the reason.
4. Control access and keep an audit trail
Name the two or three people who may see outcomes. Store records in a restricted system rather than shared drives or WhatsApp groups. Log who opened what.
5. Obtain informed consent and explain the process
Tell employees before the examination what will be tested, who will see the outcome, how long it is kept and how to ask questions or appeal. Offer the notice in Arabic and English.
6. Set retention and deletion rules
Decide how long outcome records are kept and who deletes them, with your legal counsel, and apply the same rule to every employee.
7. Give a route to appeal
Because the law gives employees the right to appeal results, define who receives an appeal, how a second opinion is arranged and how the employee's position is protected meanwhile.
What HR sees vs what the medical provider holds
| Information | Held by | Shared with HR? |
|---|---|---|
| Lab results, imaging, doctor notes | Medical provider or company clinician | No |
| Diagnosis, medication, history | Medical provider | No |
| Work-fitness outcome (fit / adjustments / not fit) | Medical provider, then HR | Yes, the outcome only |
| Required adjustment (for example no night shifts for a period) | HR and line manager | Yes, without the reason |
| Appeal or second-opinion request | Employee, provider and HR | Process details only |
Choosing a medical provider that protects confidentiality
Ask a prospective provider where clinical files are stored, who can access them, whether results are given to employees directly, how outcomes are reported to HR, and how long records are kept. Prefer a provider that keeps clinical data separate from the commercial relationship with your company, and put these rules in the service agreement. Our guide on choosing a corporate healthcare provider in Egypt lists further questions.
How Hospitalia can help
Hospitalia is an Egypt-based integrated home healthcare and corporate medical services platform. For employers it offers on-site employee health programs, pre-employment and annual employee medical assessments, doctor consultations and telemedicine. We can scope an examination process that reports only work-fitness outcomes to HR. Confidentiality arrangements are agreed in the service scope with each company.
Call 01063151838 or request a corporate proposal and we will scope examinations and reporting that suit your workforce.
Request a corporate proposalFrequently asked questions
Is it legal for an employer to ask employees for a medical examination in Egypt?
Summaries of Labour Law 14 of 2025 state that employers may request medical examinations to detect drug use or infectious disease, and that these must be confidential. Other examinations, such as pre-employment or periodic checks, may be governed by sector rules or other decisions, so confirm with your legal counsel.
Can HR see an employee's diagnosis?
Best practice is no. The medical provider keeps the clinical file and gives HR a work-fitness outcome. The law summaries say employers must not disclose an employee's health status.
Can an employee appeal an examination result?
The published summaries state that employees have a right to appeal the results. Define an internal route and a second-opinion process in your policy.
When did Labour Law 14 of 2025 take effect?
It was published in the Official Gazette on 3 May 2025 and took effect on 1 September 2025, according to a law-firm summary.
Who should hold employee medical records?
The medical provider or the company clinician, under professional confidentiality duties, in a restricted system. HR should hold only the outcome and any required adjustment.
Does the law say who pays for employee medical examinations?
The summaries we reviewed do not say. Check the official text, executive regulations and your contracts.
