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Internal communication: inviting employees without pressure
Whether a program with genetic analyses is truly voluntary is decided in how you communicate it. The invitation should not come from the direct manager, should state clearly that nobody will ask, and should explain who sees the result: only the person tested. Incentives must never be tied to results; rewards for mere participation call for caution, because saying no must not lead to any disadvantage. The works council or employee representatives belong on board early – in Germany under the BetrVG, in Austria under the ArbVG, in Switzerland under the Participation Act. Whether a formal co-determination right applies depends on how the program is designed.
An open door, not a turnstile
A sentence like “We are counting on your participation” sounds friendly. To many employees, it is an instruction. In a health program with genetic analyses, communication decides whether participation is truly voluntary – and that is far more than a matter of style.
Think of the difference between an open door and a turnstile. Anyone who wants to can walk through an open door. Nobody counts, nobody checks who stays outside. A turnstile, by contrast, registers every person who passes. Your invitation should be an open door.
The law draws clear lines here. In Germany, the employer may not demand genetic examinations and may neither receive nor use results (Section 19 GenDG); anyone who refuses an examination must not be disadvantaged for it (Section 21(1) GenDG). In Austria, employers, including their agents and staff, are prohibited from, among other things, demanding body substances for genetic analysis (Section 67(1) GTG). In Switzerland, employers may not require non-medical genetic tests (Art. 37 GUMG).
Then there is the psychology of employment. The European Data Protection Board considers it unlikely that employees can respond freely to a request for consent from their employer without feeling pressure (Guidelines 05/2020, para. 21). Your communication has to take that pressure out actively. The full legal framework is explained in Law: what employers may and may not do.
Who invites shapes the answer
Whoever sends the invitation sends a second message along with it. If it comes from the direct manager, even the friendliest wording sounds like an expectation. Senders at a distance from performance reviews work better.
| Sender | Best used for | Watch out for |
|---|---|---|
| HR or workplace-health team | the official announcement to everyone | no response lists, no follow-up questions |
| External partner or expert | information session, questions about the analysis and data protection | making clear that nothing flows back to the company |
| Management | a brief signal that the offer is wanted | no appeals, no target rate |
| Works council, where one exists | co-sender that builds trust | agreeing on a joint message in advance |
| Direct manager | a one-time mention to the whole team | never approaching individuals, never asking |
A contact for questions outside the company, at the lab or partner, removes a quiet worry for many people: that even asking a question might give something away.
The invitation: sentences that open doors instead of pushing
Good invitations are short, specific and honest. They answer four questions: What is the offer? What does it show – and what not? Who sees the result? What happens if I do not take part? The table shows typical stumbling sentences and better alternatives.
| Instead of … | Better … |
|---|---|
| “We expect everyone to sign up.” | “The offer is voluntary. If you do not take part, there is no disadvantage – and nobody will ask.” |
| “Find out how prone you are to stress.” | “Learn how your body handles nutrition, exercise and stress.” |
| “The program will cut our sick leave.” | “A personal offer for you – with no promises attached.” |
| “Your results will help us improve the program.” | “Only you see your result. We evaluate the program through anonymous feedback.” |
| “The sign-up list is in the HR office.” | “You register yourself, directly with the lab.” |
| “The test tells you which diseases you are headed for.” | “The analysis shows innate predispositions. It is not a diagnosis.” |
Also state what the company receives: the invoice, not the results. Describe the saliva sample’s route – straight to the lab, never through the company. And avoid labels such as stress types or risk groups. At work, they quickly read like a rating of the person.
For international workforces, it helps that reports are available in up to 18 languages. The invitation itself should cover your workforce’s languages too. The rules for advertising genetic analyses are explained in the nutrigenetics guide under Advertising genetic tests.
Incentives: what works – and what never does
May a company reward participation? One boundary is fixed; the second calls for a delicate touch.
- Never tied to results: no bonus, no discount, no benefit that depends on the result. The company does not even know the results – and in Germany it may neither receive nor use them (Section 19 no. 2 GenDG). In Austria, Section 67(1) GTG bans any use, and in Switzerland, too, employers may not make use of such data (Art. 37 GUMG).
- Tied to participation – only with caution: according to the European Data Protection Board, the GDPR does not preclude all incentives. But whoever offers them must be able to show that consent was still freely given (Guidelines 05/2020, para. 48). Anyone who says no must not suffer any detriment (paras. 46–47). The bigger the incentive, the more likely it turns into pressure.
A participation bonus has another catch: to pay it out, the company would need to know who took part. That is exactly what it should know as little about as possible.
The simplest solution: the offer is the incentive. The company pays for the analysis, and the follow-up support is open to everyone – nothing more is needed. Skip rankings, team contests over sign-up numbers and participation rates per department. In small teams, such figures reveal who took part and who did not.
Bring the works council and employee representatives on board early
Where there is a works council or employee representation, it belongs in the process from the start. It is the best ally for a message that depends on trust. Whether a formal co-determination or consent right applies depends on how the program is designed – have this reviewed case by case. These provisions are the points of reference:
| Germany (BetrVG) | Austria (ArbVG) | Switzerland (Participation Act) | |
|---|---|---|---|
| Information | inform in good time and comprehensively (Section 80(2)) | information on all matters affecting employees’ health interests (Section 91(1)) | timely and comprehensive information (Art. 9) |
| Possible co-determination | technical devices designed to monitor behavior or performance (Section 87(1) no. 6); health protection within the framework of statutory rules (no. 7) | personnel questionnaires going beyond general details (Section 96(1)(2)); systems for automated processing of employee data (Section 96a(1)(1)) | special participation rights on occupational safety and worker protection (Art. 10(a)) |
| Voluntary agreement | works agreement on additional measures to prevent damage to health (Section 88 no. 1) | works agreement on measures to protect employees’ health (Section 97(1)(8)) | – |
| Protecting the person | protect and promote the free development of employees’ personality (Section 75(2)) | access to individual employees’ data generally only with their consent (Section 91(2)) | confidentiality in personal matters of individual employees (Art. 14(2)(b)) |
Switzerland has a special feature: employees in companies with at least 50 staff can elect a representation (Art. 3). Where there is none, the information and consultation rights under Art. 9 and 10 belong directly to the employees (Art. 4). In that case, inform the workforce itself.
The less data ends up with the company, the less there is to regulate. A concept with no genetic data, no lists of names and no health questionnaires of the employer’s own makes these talks easier. A written agreement that records the ground rules – voluntary, no results, no lists, no pressure – sends a strong signal even where none is required.
Managers: tailwind without follow-up questions
Managers are the most delicate point in your communication, because they help decide on tasks, reviews and development. Give them a short briefing in advance:
- Mention the offer once in the team, the same way for everyone – and then leave it.
- Never ask who has signed up or how a result turned out.
- Never comment on participation or non-participation, and never let it enter conversations about performance or development.
- Pass questions about the analysis on to the external contact.
- Take part yourself if you wish – as a private matter, without promoting it.
And if someone wants to share their result unprompted? Then the manager steers the conversation elsewhere in a friendly way, takes in no details, writes nothing down and uses nothing. In Germany, the employer may not even receive the results of genetic examinations (Section 19 no. 2 GenDG). In Austria, the ban on accepting results expressly covers the employer’s agents and staff as well (Section 67(1) GTG). A good line for this: “Thanks for trusting me – that stays with you. The counseling service is there for questions about your report.”
During and after the program: keep going without pressure
- Reminders: one neutral reminder to everyone, never targeted at those who have not signed up yet. Ideally, the company does not even know who they are.
- Questions: one fixed external contact for questions about the analysis, the report and data protection.
- Workshops: on exercise, sleep and nutrition, open to everyone – with or without an analysis. That way, nobody who stays out is at a disadvantage.
- Feedback: anonymous and brief. Was the offer easy to understand? Did it feel voluntary? Was it helpful?
- Wrap-up: an honest summary of what the program offered and how the anonymous feedback turned out – never with genetic figures. How to evaluate the benefits is covered in Measuring benefits and impact.
Also say what the program does not promise: no health outcomes and no cost savings. This very honesty is what makes an offer credible.
Communication checklist
- The invitation says clearly: voluntary, no disadvantage, nobody will ask.
- It explains what the analysis shows and what it does not – without diagnoses, labels or promises.
- It states who sees the result: only the person tested. The company receives the invoice.
- Registration and consent go directly to the lab or partner.
- The invitation does not come from the direct manager; an external contact answers questions.
- No incentive depends on results; there are no rankings and no rates per department.
- The works council or employee representatives were informed early, and co-determination questions have been reviewed.
- Managers have a short briefing and do not ask.
- Reminders go neutrally to everyone.
- Workshops are open to everyone.
How the stages run from kick-off to report is covered in Rollout: from kick-off to results.
Frequently asked questions
May we pay employees a bonus for taking part?
Does the works council have to agree?
May a manager ask who has signed up?
What if an employee wants to show their manager their result?
How often may we remind people of the offer?
Related: Rollout: from kick-off to results · Law: what employers may and may not do · Data protection and confidentiality of results
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Request a project →Corporate health in the longevity guideNote: This guide is general information for businesses and professionals and does not replace medical or legal advice. The genetic traits determined in a genetic analysis are well documented (each gene included is backed by at least three independent studies); recommendations derived from them are logical conclusions, not scientifically proven. Regulations can change; errors and changes excepted.