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PDPA guide

Workplace Fairness Act: Getting HR Records and Processes Ready

Singapore's Workplace Fairness Act 2025 makes discrimination on 11 protected characteristics unlawful in hiring, promotion, training and dismissal, and requires employers with 25 or more staff to run a written grievance process. It was not yet in force on 21 October 2026, but TAFEP says it is slated to take effect in end-2027. When a claim arrives, an employer's best defence is a clear record of why each decision was made. This guide explains what the Act requires on grievances and records, which hiring and HR decisions to document, how long to keep the records, and how to do it without breaching the PDPA. It is general information, not legal advice.

By IT Sorted teamReviewed 8 min readHow we write guides
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Key takeaways

  • The Act was passed on 8 January 2025; TAFEP says the WFA is slated to take effect in end-2027.
  • It lists 11 protected characteristics, from age and nationality to caregiving, disability and mental health.
  • Section 27 requires a written grievance process, including keeping written records for a stated period.
  • Employers with fewer than 25 employees are outside most of the Act, unless the Minister changes the number.
  • Records of grievances and hiring decisions are personal data, so the PDPA's protection and retention rules apply.
In this guide · 7 sections
  1. 01Where the Workplace Fairness Act stands in October 2026
  2. 02What section 27 requires for grievance handling
  3. 03HR records worth keeping for each employment decision
  4. 04How long to keep the records, and the PDPA
  5. 05A simple grievance system for a 25 to 200 person company
  6. 06Do it yourself or get help?
  7. 07Frequently asked questions

Short answer

Employers with 25 or more employees must set up a written grievance process that commits to inquiring, reviewing, informing the employee of the outcome, keeping written records for a stated period and confidentiality. Also record the job-related reasons for hiring, promotion and dismissal.

Where the Workplace Fairness Act stands in October 2026

Parliament passed the Workplace Fairness Act 2025 on 8 January 2025, and the Workplace Fairness (Dispute Resolution) Bill on 4 November 2025. Section 1 says the Act comes into operation on a date the Minister appoints by notification in the Gazette. On 21 October 2026, Singapore Statutes Online still listed it under uncommenced legislation.

TAFEP's Workplace Fairness page says the Act is 'slated to take effect in end-2027', and MOM's factsheet on the dispute resolution bill said it intended both bills to be implemented in 2027. Check SSO and MOM for the actual commencement notice before relying on a date.

ItemWhat the official sources say
Who is coveredEmployers with 25 or more employees (section 4), a number the Minister can change
Decisions coveredHiring (including inviting to interview), appraisal, promotion, training, demotion, dismissal, retrenchment and termination
Protected characteristicsAge, nationality, sex, marital status, pregnancy, caregiving responsibilities, race, religion, language ability, disability, mental health condition
Grievance processRequired under section 27; employees told about it in writing
RetaliationProhibited for raising a grievance or bringing a claim (section 28)
ClaimsInternal grievance first, then mediation; Employment Claims Tribunal up to S$250,000, High Court above
From the Act's text on SSO and MOM's October 2025 factsheet. Not legal advice.

What section 27 requires for grievance handling

Section 27 is the part that turns into an HR system. The employer must develop a process under which it commits in writing to:

  • inquiring, in a stated manner, into each grievance raised by an employee;
  • reviewing each grievance in a stated manner;
  • informing the employee who raised it of the outcome, in a stated manner;
  • keeping, for a stated period, a written record of every inquiry and every review; and
  • not disclosing the identity of the employee or information about the inquiry or review, unless reasonably necessary.

The employer must also inform all employees of the process in writing. The Act leaves the 'stated manner' and 'stated period' to you, so your written policy has to fill them in. MOM's factsheet says an individual should first raise discrimination internally through the grievance process before mediation and a claim.

HR records worth keeping for each employment decision

The Act covers far more than recruitment. For each covered decision, the question in a dispute will be what the decision was based on. Short, contemporaneous notes beat long reconstructions written after a complaint arrives.

DecisionRecord to keep
Job advert and shortlistingThe advert, selection criteria, who shortlisted, and why each applicant was or wasn't progressed
Interviews and testsPanel members, questions asked, scores against criteria, final reasons
AppraisalsGoals set, evidence of performance, rating and who reviewed it
Promotion and trainingWho was considered, the criteria, and why the chosen person met them
Demotion, dismissal, retrenchmentPerformance or business reasons, warnings given, selection criteria for retrenchment
GrievancesComplaint, inquiry steps, review, outcome communicated, date closed
Suggested record set. Focus on job-related criteria, not personal characteristics.

Our guides to careers page and job advert rules and fair AI-written job descriptions cover the recruitment end in more detail.

How long to keep the records, and the PDPA

Section 27 asks you to state a retention period for grievance records. The PDPA's Retention Limitation Obligation says not to keep personal data longer than a legal or business purpose needs, without setting a fixed period. MOM's factsheet says claims are subject to prescribed time bars for mediation requests; set your retention period to cover those time bars once the subsidiary legislation confirms them, plus a margin, and write it into your policy.

Records and PDPA checklist

Our guides to employee personal data under the PDPA and the PDPA checklist for small businesses cover access requests, protection and retention.

A simple grievance system for a 25 to 200 person company

You don't need specialised HR software. What matters is that every grievance is logged, handled by people without a conflict, closed with an outcome, and kept confidential.

  1. Publish the process in writing

    Who to contact, alternatives if the complaint is about that person, timelines, confidentiality and protection from retaliation. Share it with every employee.

  2. Give one intake channel

    A confidential form or mailbox that creates a case record with a reference number and date received.

  3. Assign an independent reviewer

    Someone not involved in the matter. Record who was assigned and when.

  4. Record the inquiry and review

    Interviews, documents reviewed, findings and reasons, in the stated manner.

  5. Inform the employee of the outcome

    In writing, and record that this was done.

  6. Close and retain

    Mark the case closed, set its deletion date per the stated period, and limit access.

Do it yourself or get help?

Writing the policy and deciding retention periods is HR and legal work; TAFEP runs resources and clinics on grievance handling, and complex cases deserve a lawyer. Building the intake form, case log and reminders is a small technical job.

Our Workflow Automation (S$390 per workflow) can build a confidential grievance intake form that creates a case record, notifies the right reviewer and sets a deletion reminder, in your own Microsoft 365, Google or Make account. The PDPA Compliance Pack (S$690) covers the data inventory, staff data protection policy and breach plan. IT Sorted is a Singapore-based team of developers with over 10 years of experience; you pay upfront, send the brief in writing and follow progress on your order page. We are not lawyers; this guide is not legal advice.

Frequently asked questions

The Act comes into operation on a date the Minister appoints by Gazette notification. As of 21 October 2026 it was still listed as uncommenced on Singapore Statutes Online. TAFEP says it is slated to take effect in end-2027, and MOM said both bills were intended to be implemented in 2027.

Section 4 says most of the Act does not apply to employers with fewer than the prescribed number of employees, which is 25 unless the Minister changes it by notification. Smaller employers should still follow the Tripartite Guidelines on Fair Employment Practices, which TAFEP promotes for all employers.

Section 27 requires a written commitment to inquire into and review each grievance in a stated manner, inform the employee of the outcome, keep written records of every inquiry and review for a stated period, and keep the employee's identity and information confidential unless disclosure is reasonably necessary. All employees must be told about it in writing.

The Act asks you to state the retention period in your process; it does not fix one. Choose a period that covers the claim time bars set under the dispute resolution rules, plus a margin, then delete. The PDPA requires you not to keep personal data longer than a legal or business purpose needs.

Section 8 lists 11: age, nationality, sex, marital status, pregnancy, caregiving responsibilities, race, religion, language ability, disability and mental health condition. Employment decisions such as hiring, appraisal, promotion, training and dismissal must not be made on these grounds, subject to the Act's exceptions.

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