Mr G Leedham v Royal Mail Group Limited — 2024

The claimant, an Operative Post Grade at Royal Mail, said he had not been given itemised pay statements since June 2023 when the respondent moved from paper payslips to digital access through the People App and related online routes. He accepted that his objection was one of principle and said the respondent was only telling workers where to access the information rather than giving it to them.

The tribunal considered the meaning of "given" in section 8 of the Employment Rights Act 1996. It treated Anakaa v Firstsource Solutions Ltd as persuasive authority that online provision of wage information by password access could comply with equivalent statutory wording, while recognising a caveat that an alternative method may be required where the employer knows an employee has difficulty accessing payslips in that way.

The claimant accepted that he had a phone which could access the information online and that a local library offered computer access and printing facilities. The tribunal found that giving access to wage information in readable electronic form complied with section 8 in the circumstances and that the respondent had discharged its duty. The privacy concerns raised by the claimant were not determined because they had not been pleaded, the respondent had no notice of them, and expert evidence would have been required.