In Japan, the Ministry of Health, Labour and Welfare issued corporate guidance that employers should recommend their employees to have tests for hepatitis B virus and hepatitis C virus (HV) at least once in their lifetime. However, employers should treat this information as confidential, even though the testing is carried out along with the health examination designated by the Industrial Safety and Health Law. Therefore, the records of HV tests should not be kept by employers, even though records of medical examinations designated by the law must be. This study aimed to clarify the present method for keeping records of HV infection and the rationale in Japanese workplaces. Questionnaires about viral hepatitis were sent to 118 occupational health physicians, and 81 physicians from 100 workplaces responded. The HV test for employees was conducted in 58 workplaces (75.8% of large, 60.4% of bigger medium-sized and 16.7% of smaller medium-sized enterprises). These workplaces were the types of industries where the risk of infecting other persons was low. Subjects of the HV tests were workers who were suspected to have hepatitis virus, and workers who were applicants. Occupational health physicians from most workplaces answered that records of medical examinations designated by law and records of HV tests were not kept separately and shouldn't be. The opinion that the two types of records should not be kept separately appeared to be more from the workplaces where employers or health insurance covered the cost of the HV test. In these cases, the purpose of conducting HV tests at the workplaces was thought to be both promoting welfare of employees and occupational considerations for workers. Occupational health physicians from about 60% of workplaces had misgivings about employees who had hepatitis virus being discriminated against at the workplace if the HV test was included with the required medical examination. Among occupational health physicians from workplaces where occupational health professionals were in charge of the records, there was no standardized rationale for keeping records. However, most workplaces took into consideration the workers' privacy by getting employees' consent before divulging information to their employers. This relied not only on the occupational health professional's or health/safety officer's ethics, but also the necessity of reviewing the purpose and methods of keeping records of HV testing of employees, based on official notices or the Act on the Protection of Personal Information.