It rarely begins with a conversation. It begins with someone on your team being different for weeks: quieter in meetings, short on the phone, three absences in quick succession, tasks slipping that used to run by themselves. You notice. And then you face the question most managers stay stuck on for far too long: do I say something – and if so, what?
Supporting employee mental health puts managers in a role they were never trained for. The two most common reactions are both unhelpful: saying nothing for months so as not to intrude – or going too far and starting to look for causes in someone’s private life. This article maps the ground in between: what you may raise, how such a conversation is built, what you must not record, and where you can refer people in Austria.
Your role: manager, not clinician
The most useful clarification comes first, because it makes everything else easier. It is not your job to work out what someone has. It is not your job to fix it either. Three other things are your job – and they are demanding enough:
- the working conditions you actually control: workload, availability expectations, deadlines, role clarity, conflict within the team
- being approachable – so that nobody has to guess whether they are allowed to raise something
- pointing the way to help, rather than trying to provide it yourself
That this role can be learned is well evidenced. The WHO guidelines on mental health at work (2022) issue a strong recommendation for manager training, with moderate certainty of evidence. What is notable is where the effects show: on managers’ knowledge, attitudes and behaviour, and on reducing stigmatising attitudes – not on managers becoming a source of care. That is exactly the right expectation to hold.
What Austrian law requires – and what it does not
The Austrian Occupational Health and Safety Act (ASchG) is clearer here than many assume. Under § 2 (7), work-related psychological strain explicitly counts among the hazards that can lead to harmful stress; § 2 (7a) states that health, in the sense of the Act, means physical and mental health. Sections 4, 5 and 7 govern the assessment process, and § 4 (4) requires hazards to be tackled at source where possible.
What matters, though, is what this duty applies to – and this is where the most common misconception arises. The workplace assessment of psychological strain targets objectifiable working conditions acting on employees. It is not a screening of individuals and says nothing about how a particular person is doing. Treating the assessment as a tool for identifying struggling employees misreads it – and puts you on thin ice under data protection law.
The wider legal frame – duty of care, the assessment obligation, what employers actually owe – is covered in a separate article: Duty of care and mental health at work.
The conversation: observation, not interpretation
One sentence carries the whole conversation: talk about what you see, not what you suspect. Observations can be checked and leave the other person in charge of interpreting their own experience. Assumptions – however well meant – push them into defending themselves.
Setting the frame
- Schedule it. A concern raised in passing lands as a concern worth a passing moment.
- Two people, no minutes taken, no third party „just sitting in“.
- Say at the outset what this is and what it is not: not a performance review, not the groundwork for consequences.
- Plan the ending: one concrete agreement and a follow-up date. Without that, even a good conversation evaporates.
What you can say
Three factual, work-related observations are enough: „I’ve noticed you’ve barely spoken in our team meetings these past few weeks. And the analysis that used to be routine for you has slipped twice. That’s on my mind – how are you finding the work at the moment?“
The sentence that opens the most doors is the one that removes the pressure: „I don’t need to know what’s going on. I’d like to know what would make the work easier for you right now.“ It makes unmistakably clear that this is not an interrogation – and it keeps you inside your remit.
What not to say
- No suspected diagnosis. „Are you burnt out?“ is not a question but an attribution – and not yours to make.
- No digging into private life. If someone volunteers it, listen. Do not ask.
- No promises you cannot keep – above all, no unconditional confidentiality.
- No instant fix. „Why don’t you take a week off“ usually ends the conversation rather than the problem.
What you must not record
Health data falls under the special categories of personal data in Article 9 GDPR. Processing is prohibited in principle, and the exceptions are narrow. In plain terms: assumptions about someone’s mental state, the health-related content of a conversation, a diagnosis someone confided in you – none of it belongs in a personnel file, an HR system, a notes app or an email to the division head.
What you may and should record are the work arrangements: that a task was temporarily reassigned, that a follow-up is scheduled. The distinction is not a formality – it decides whether your conversation builds trust or destroys it. Why confidentiality works differently again in external counselling, and what an employer does and does not get to see, is explained in how confidentiality from the employer actually works.
Where to refer people in Austria
Referring on is not offloading; it is the most professional part of your role. Four routes that genuinely exist in Austria:
- fit2work – established by the federal government, free of charge for employees and companies, voluntary and confidential. The lowest-threshold entry point when health problems put a job at risk.
- The occupational health services in your own organisation: occupational medicine and occupational psychology. Present in most larger employers and routinely underused.
- External, confidential counselling – independent of the company, with nothing reported back to the employer. For many people this is the only route they will actually take: external employee counselling in Vienna.
- If things escalate: the social psychiatric emergency service of the Psychosocial Services in Vienna or the emergency help for psychological crises of the Vienna Health Association.
A note on how you offer them: name several routes and leave the choice. A single route pressed with conviction quickly reads as an instruction – and voluntariness is the precondition for counselling to work at all.
When it becomes acute
Rare, but possible: there are signs of immediate danger. A different rule applies then – safety takes priority over confidentiality. Do not leave the person alone, make no promises of secrecy, and bring in professional help (the emergency service; in an emergency, 144). You do not have to be able to assess the situation yourself. You only have to know whom to call – which is why it is worth knowing the numbers before, not during, an emergency.
What organisations can do structurally
Finally, the uncomfortable part, because it moves the subject from the individual back to the organisation. A widely discussed study by William Fleming (Industrial Relations Journal, 2024) analysed survey data from 46,336 employees across 233 British organisations and found no evidence of benefit for eleven common individual-level wellbeing offerings – mindfulness, resilience training, stress management courses, wellbeing apps; some were even associated with slightly worse outcomes. An important caveat: the data are cross-sectional, so this is not causal proof. As a warning signal it still holds.
The WHO guidelines point the same way. Alongside manager training, their second strong recommendation is to provide reasonable work accommodations for employees with mental health conditions – that is, to work on conditions, not only on people. The practical reading: conditions first, offerings second. A counselling service is no substitute for addressing causes. It is, however, the only lever that changes anything for a particular person today – which makes it not a contradiction but the second half. Which models exist and how they differ is compared in EAP, external employee counselling or wellbeing programmes.
Frequently asked questions
May I raise mental health with an employee at all?
You may raise your work-related observations – not a suspected condition. There is no obligation to answer: the other person may say they would rather not discuss it. The conversation still matters, because it signals that the door is open.
What if the person shuts the conversation down?
Accept it and do not push. Make an open offer, name the external services and agree a later follow-up. Separately, review what is in your hands: workload, deadlines, role clarity, conflict in the team.
May I document the conversation?
Not its health-related content – that falls under Article 9 GDPR. You can document the work arrangements: what was temporarily reassigned, until when it applies, and when you will speak again.
Do I have to inform HR?
Only as far as work organisation requires it – cover arrangements, reassignments, deadlines. Health details are not part of that, not even in abbreviated form.
Conclusion
When an employee is struggling, the management task is smaller and at the same time harder than it feels: not to understand what is going on, but to stay approachable, work on the conditions and keep the route to help open. Managers who draw the boundary around their own role clearly tend to fill it well – and to do less damage than those who mean too well.
This article is not legal advice. For the assessment of an individual case under employment law, consult a legal representative, the Austrian Economic Chamber or the Chamber of Labour.
Sources
- Labour Inspectorate: workplace assessment of psychological strain
- WKO: assessment of psychological strain at work
- Chamber of Labour Vienna: psychological strain
- WHO: Guidelines on mental health at work (2022)
- Fleming, W. (2024): Employee well-being outcomes from individual-level mental health interventions, Industrial Relations Journal
- fit2work – support for health problems affecting work
- PSD Vienna: social psychiatric emergency service
