One possibility in cases of very severe harassment could be a civil claim for compensation under the Protection from Harassment Act 1997 (PHA 97). The 2007 case of Majrowski v Guy’s & St Thomas’ NHS Trust established that the PHA 97 can be used in an employment setting, making an employer vicariously liable for acts of bullying and harassment, as long as there is a sufficiently close connection with employment, and provided the worker can establish a “course of conduct”, directed at him or her and intended to cause alarm or distress.