From 30 October 2026, your legal responsibility for your staff changed. You must now take all reasonable steps to prevent sexual harassment of your employees. You're also responsible for preventing harassment of your staff by clients and other members of the public. If a client harasses a stylist and you haven't taken the necessary steps to prevent it, the salon can be held liable.

What changed on 30 October

The Employment Rights Act 2025 changes how you must protect your staff. Since 2024, you've had a duty to take reasonable steps to prevent sexual harassment, but the standard is now higher. You must now take all reasonable steps. This includes preventing harassment by third parties, such as customers or delivery drivers. If someone who doesn't work for you harasses an employee during their shift, and you failed to take those preventative steps, the law treats you as having permitted the harassment.

These duties apply in England, Wales, and Scotland. Northern Ireland maintains its own separate equality legislation. You must take all reasonable steps to prevent anyone who isn't your employee, from regular clients to the people delivering your retail stock, from harassing your staff while they work.

Defining harassment by a client

Sexual harassment is defined by the Equality Act 2010 as unwanted conduct of a sexual nature. This conduct is harassment if it violates a person's dignity or creates an environment that's intimidating, hostile, degrading, humiliating, or offensive.

In a salon, this can look like a client making comments about a stylist's appearance or body. It includes inappropriate touching at the backwash or making suggestive remarks to a stylist while the client is in the chair. The third-party duty also extends to harassment related to age, disability, gender reassignment, race, religion or belief, sex, and sexual orientation. If a client makes a racist remark or mocks a staff member's disability, you have the same legal obligation to have taken steps to prevent that harassment.

Salon environments and risk

Hairdressing is inherently close physical work. Your team spends hours close to members of the public, often in one-on-one situations. This creates specific risks that a typical office or shop doesn't face. You need to look at when and where your staff are most vulnerable.

Late-night shifts are a common risk point, especially if only one or two people are on the floor. Apprentices and junior staff are often the youngest people on the floor and can find it harder to stop a client's comments. Basins and private treatment rooms are also high-risk areas because the physical proximity is greater and there are fewer witnesses. You should regularly review these situations to see where the environment can be made safer for your employees during their working day.

Reasonable steps for your business

What counts as a reasonable step depends on the size of your business and the risks your staff face. Acas suggests several practical actions that fit the salon environment.

  • Risk assessment. Review your salon layout and shift patterns to identify where staff are at risk from clients.
  • Written policy. Create a clear document that explains what harassment is and how your team should report harassment.
  • Client communication. Tell your customers that harassment won't be tolerated, using signs in the salon or notes in your booking emails.
  • Staff training. Give your team the tools to handle difficult clients and ensure they know you'll support them if they speak up.

You should also look at your staffing levels to ensure nobody is left alone with a client who has a history of making the team feel uncomfortable. Acas also suggests reviewing your customer terms, for example adding a line that says you'll refuse service to anyone who harasses your staff. This sets clear boundaries before the appointment even begins.

Handling an incident on the floor

When an incident occurs, you must act quickly. Your first priority is the safety and wellbeing of your staff member. Listen to their account without judgement and offer immediate support. Step in and finish the service yourself or ask the client to leave the premises immediately.

The action you take against the client will depend on the severity of the behaviour. This could range from a formal warning about their conduct to a permanent ban from the salon. You have the right to refuse to book a client again if they've made your team feel unsafe. If the team sees that you prioritise their safety over revenue, it helps in building a team that stays.

Recording details in your system

You need a reliable way to track client behaviour so the whole team is aware of potential issues. Luminate allows you to add summary notes to a client's profile. A General note can be pinned so it stays at the top of the client's profile. The full incident report should sit with your staff records, and the client's profile carries only a short factual note or badge so the team knows before the client arrives.

You can also use customer badges to flag specific requirements, such as a Senior staff only label. Store the full details of what happened and who saw it in your staff records, and keep the note on the client's profile short and factual. Remember that under GDPR, a client has the right to see their personal data.

The cost of getting it wrong

If an employment tribunal finds that an employee was sexually harassed and that the employer breached the duty to prevent sexual harassment, it can increase the compensation by up to 25%.

The time limit for staff to bring a claim has also increased. For incidents happening on or after 1 October 2026, employees now have six months to start the process rather than three.

Official guidance and resources

This article is for information only and isn't legal advice. For detailed guidance, visit the Acas website or the Equality and Human Rights Commission. Acas has guidance on preventing sexual harassment and on third-party harassment, while the EHRC provides technical guidance, an action plan checklist, and an 8-step prevention guide. Check these official sources to ensure your salon's policies follow the law.